Nuclear threat to Karachi? – II

PNRA’s gazette guidelines provide for special considerations for large cities. Let me reproduce, part of para 6: A population center distance of at least one and one-third times the distance from the installation to the outer boundary of the low population zone. For this purpose, the boundary of the population center shall be determined upon consideration of population distribution. Political boundaries are not controlling in the application of this requirement. Where very large cities are involved, a greater distance may be necessary because of total integrated population dose consideration.

There is no evidence that special consideration and assessments have been made as per legal requirements. If such is the case, it should be made public. Fukushima lessons: The most important lesson from Fukushima is that things do not always work as assumed and planned for. Formula and assumptions fail. An earthquake of 9 Richter could not be thought of. There are various comments on Fukushima and the lessons learnt. Let me quote from a respectable institution:

An earthquake of 9.6 on Richter scale followed by Tsunami of not expected and designed for magnitude followed. Spread of radioactivity necessitated evacuation of public in the nearby areas extending up to 20-30 kms to prevent exposure of the public. The event was initially rated as Level 5 on the International Nuclear Event Scale. The rating was subsequently revised to Level 7. However, the total radioactivity released during this incident was about 10% of that released during the Chernobyl accident in 1986.

Fukushima officials revealed that areas extending more than 60km (36 miles) to the north-west of the plant and about 40km to the south-south-west have seen radiation levels exceed annual limits. There was a 20km mandatory evacuation zone and 20-30km voluntary zone. Tens of thousands were evacuated. Five communities beyond the existing evacuation zone have also been evacuated. As Greenpeace reveals on Fukushima that had the wind blowing in the other direction whole of Tokyo and other communities’ up to 250 kms away may have to be evacuated.

KARACHI’S UNCERTAIN SEISMICITY We are enclosing excerpts from a research paper on seismicity of Karachi due to lack of data and inadequate research. As can be seen from the paper, Karachi used to be included in High Seismic Hazard zones (highest hazard rating of 4) of the world equal to Los Angeles California. It was later changed to zone 2 with moderate hazard rating. There are several active and inactive faults. However, no earth quake has occurred for the last two centuries. Requisite Research and data collection on the area is not up to the international standards. Whatever data collection and map-making has been done is under global initiatives of hazard map making. There is controversy whether, Karachi falls under zone 4 (High Hazard) or Zone 2 (moderate Hazard). For normal construction activity, such controversies and confusions could be taken lightly. However, for siting of multiple nuclear power reactors of 1000 MW, the risks and consequence of not applying the right code of construction is very high.

It may be useful to make a global comparison of the seismicity of regions. Iran is perhaps the riskiest country with almost all of the country falling in zone 4 of highest hazard. Except for the west coast, the whole of US falls under low seismicity rating. The whole of Africa and Saudi Arabia falls under no seismic green zone. Except for Himalayan region which falls under zone 4, most of India is largely in low seismic green zone. Pakistan, however, falls under moderate to high seismic risk zone. All of us remember the recent earthquake in Kashmir which devastated parts of KPK and all of our part of Kashmir. While northern parts of Pakistan are in zone 4, controversy notwithstanding, Karachi falls under moderate seismic risk and rating, under the most optimistic assumption. However, it is reassuring that the proposed GIII reactor (K2 and K3) designs take a very high seismic factor (0.3 g) in their designs.

WORST-POSSIBLE SCENARIO – REACTOR FUEL MELTDOWN Keeping in view the seismic factor and the terrorism, both in adjoining Balochistan and the wider menace of extremism, lack of exposure and expertise in operating such high (1000 MW) capacity power plants and week transmission grid ,worst possible scenario becomes a relatively significant possibility. Project design cannot take care of all of these issues. Locating away from the populous areas is the only option. The proposed location, close to one of the densest parts of the country and even of the world, appears to be the riskiest option warranting a detailed review.

OTHER LOCATION POSSIBILITIES BUT NIMBY NOT IN MY BACKYARD? Going further into Balochistan coast merits some consideration, although one cannot go very far, due to power demand issues and increasing seismic risks as one approaches midway towards Iranian border. One approaches Gadani, if one moves 50 kms from Paradise point, where already a 5-6000 MW imported coal power project is being implemented. Why not around Gadani, as massive power transmission projects are being planned. One would also wonder, whether Gadani is real vis-à-vis competing Thar? One can go farther but then Ormara seems to be the limit. Some people point out the separatist threat and the long-term consequences for continued access to facilities located in Balochistan. That, however, is a defeatist argument. Are we mentally withdrawing and conceding step by step? There are possibilities between Gharo and Keti Bandar. Closeness to India and Run of Kutch seismicity may be the constraints. Pakistan lacks geographical depth. Such considerations vis-à-vis India would not let us do many things. In any case, it is highly unlikely that India would attack a nuclear reactor.

VAGARIES OF NATURE Nature has its own ways to be innovatively destructives some times. What happened at Chernobyl was not repeated in Fukushima and what may happen here may be completely different set of circumstances. You may always discover that you did not do something that should have been done or that your data and assumptions were lacking. As we have discussed elsewhere, Karachi’s seismic data is controversial and uncertain. It is based on a two-hundred years of history only while in most cases 1000 years of earthquake history has been made use of in developing seismic ratings and codes.

On the other hand, we accept that, generally speaking, nuclear power is safer than other technologies and that more deaths and disease are caused annually by conventional technologies such as of coal power. However, the consequence of highly unlikely event, if it occurs, can be extremely devastating. Why to risk our biggest city, even if the probability is extremely low. Impact and evacuation area of 16-kms much touted by PAEC and PNRA is a general planning figure. It may be highly inadequate in case of very large cities like ours, where environmental data is lacking in quality and quantity. Fukushima was designed on high quality data, yet earthquake and Tsunami of unexpected magnitude occurred which was not designed for. PNRA guidelines require special considerations for very large cities. What PAEC is arguing for may be generally correct. However, their judgement, in case of the highly populated, chaotic and strife-stricken city, appears to be lacking sensitivity and even responsibility. And on top of it all, secretive approaches and bypassing due processes is even more painful for us, the residents of Karachi. PAEC and PNRA bureaucracy lives in and around Islamabad. It is but natural that they may have taken it differently, had they been living here. All is well but not NIMBY.

THE MEANINGLESS SECRECY Our nuclear establishment should examine and re-evaluate their workings and policies and adapt themselves to the newer times and a new Pakistan where multi-pronged and counter-acting sources of power have emerged; an informed public, strong media and independent judiciary. No longer, can one hide behind the so-called national security argument endlessly and unduly. At this moment the debate is in rather knowledgeable circles. Eventually, it will trickle down. Electronic media has not yet become alive to this. PAEC has to make its case, if there is one, and put forth the facts and make use of common sense. The argument and data has to be compelling. Up to now, it has not been convincing. And it is doubtful if they can convince people that under a worst-possible scenario of a nuclear accident within or beyond design (and quite likely terrorism threats), there would be no threat to Karachiites’ safety, life and property.

After all what is so secret about nuclear power and nuclear reactors. There is an imported design, originally from the US and replicated and indigenized in China. And for environmental evaluations, one need not reveal a lot of reactor details. One has to develop a dispersion models and examine the contamination paths of air and water under various scenarios including worst possible and most likely cases. The kind of data that we have presented indicates that the proposed site is risky and does not match with the generally prevalent practices and norms. Still, one would like to hear the case.

Additionally, in a country where three major military installations have been attacked with the kind of ease that everybody has noticed, it would be impossible to make a reasonably strong or acceptable case about impenetrable defense. It is impossible to predict and prevent such attacks, although one has the option of doing this dangerous business elsewhere, where the impact of such happenings may be much limited. If I were them, I would have started looking for other options. It would be in every one’s interest including the ambitious ones wanting fast track rewards and careers.

CONCLUSION We are not taking an extremist view here of opposing nuclear power altogether. All we are asking is a little more careful attitude. The nuclear siting policies and data that we have provided strongly suggest the need for changing the proposed site to another location. PAEC is using the evacuation zone of 16 kms as a basis for locating nuclear power plants in a rather routine and callous way irrespective of population at risk. Contamination zone extends to 50 Miles as defined by NRC and the nuclear industry in the US. And there have been talks of extending this zone. Indian Code requires a minimum of 30 kms distance from a population centre of more than 100,000. And even the most dangerously sited Indian Point reactor is at 25 miles 40 kms) from the city limits. That was done in 1970s. It would be unthinkable now. Common sense suggests that the safe distance in case of Karachi nuclear plant L2 would be 50 Miles (75 kms). In fact this should also be a general yardstick for nuclear site planning in Pakistan.

ADDENDUM I maintain and emphasise that Keamari, Orangi, Lyari, Baldia, SITE and others would be at risks of various intensities and types. This population totals 2.0 million. Even if we accept the argument of low population in K2’s neighbourhood, it is highly likely that the surrounding population would grow and PAEC would not be able to control land use and the population spillover from the adjoining densely populated areas. One should not forget Bhopal tragedy of Union Carbide Plant in which 16,000 poor people perished and 558,125 were injured. Initially, population around that plant was small and increased later (Union Carbide maintained that it was a result of sabotage and did not result from any laxity on the company’s part. We should not ignore these possibilities as well, in view of the ideological confusion we are passing through). Can the K2 project afford to buy off the whole Keamari Town to be able to control population and land use in its neighbourhood. Not only that a large population would be at risk, but the population itself would pose risks to the reactor, having a potential to harbor terrorists in its fold. Everybody knows how successful we are in controlling this later menace?

One would have accepted the arguments of PAEC in other normal circumstances. But in this case, a city like Karachi is involved, a lifeline for Pakistan. If this city goes down, Pakistan goes down. In this case, one has to take even very small risks very seriously. Whatever I have read and developed an understanding of the issues leads me to conclude that it is all probabilistic, approximations and assumptions. There are complex systems and redundancies, yet there may be unknown ways and sequences in which mistakes and accidents can occur. Then Nature has its own creativity on being different every time it strikes. What happened in Fukushima could not be predicted; the Tsunami and Earthquake of the intensity that came was unthinkable and unpredicted. With rudimentary climatological data and its limitations, it would be too simple-minded to pose very confident about things and make determination of safety, something which in its very nature is highly probabilistic. Again I would repeat, one would readily accept the arguments of additional safety features of Gen-III technology and other supporting arguments. But, here too much is at stake?

3. Instead of point-scoring, PAEC is expected to adopt and display a more scientific and robust policy and present scientific evidence. PAEC should demonstrate under a scientific and neutral study that under a nuclear accident at the scale of INES-7, the radioactive releases would not pose any risk to the health and well-being of the populations of Kemari, Lyari, Baldia and Orangi including I.I. Chundrigar Road and the harbour and that there would be no contamination of food and water in the larger Karachi area. And that PAEC would be able to handle, a little disturbance that may be created. It would be foolhardy to expect mass management and co-ordination by an organisation which does not make its telephone numbers available to the public.

For our part, we are able to demonstrate that there is considerable risk in the K-2 proposition as we are able to cite data from three studies done in three countries on similar G-III reactors, namely Sanmen in China, Fennovoima in Finland and a NPP in Lithuania. Ironically, even China has made the results public and a paper has been published in a journal containing risk assessment of Sanmen reactor, which indicates that some 284000 persons would be facing the risk of cancer(We cannot say, how many would face equivalent risk min Karachi, however, similarities are there). Similarly, Fennovoima and Lithuania, where full-scope EIAs have been conducted and results made public. If we extrapolate their results, we reach a conclusion indicating substantial risk to a very large section of Karachi population.

I have come across a very relevant evidence and am reproducing extracts from, a journal paper evaluating the impact of NPP Sanmen China, an AP 1000 reactor, similar of which is being sited at Paradise Point Karachi. The paper models impact of accident, probably INES-6 or 7.The results are disturbing, especially wrt the population density in Karachi, as one would readily see perusing the paper and its abstract:

“In November 2013, an AP1000 nuclear power plant (NPP) will be put into commercial operation. An atmospheric dispersion of radio nuclides during a severe hypothetical accident in Sanmen NPP, Zhejiang province,… The accident assumes that a station blackout (SBO) accident to have occurred on August 25, 2011, 55% core was damaged and 49 radio nuclides were released into the atmosphere. Our simulation indicates that, during this dispersion, the radioactive plume will cover the mainland China, Taiwan, Japan, North Korea, South Korea and Russia. The radiation dose levels in Japan, North Korea and Russia are the lightest, usually less than 1mSv. The influenced areas in these countries are 9901 km2,31,736 km2 and 2,97,524 km2, respectively; dose levels in Taiwan and South Korea are moderate, no more than 20mSv. Information about reducing dose should be given to the public. Total influenced areas in these two countries are 3621 km2 and 42,370 km2 which take up 100% of the land in Taiwan and 35% of the land in South Korea; the worst situation happens in mainland China. The total influenced area is 3 x 106km2 and 1,40,000km2 in this area has a dose level higher than 20 mSv. Measurement must be taken to reduce the dose. More than 284 thousand residents will face the risk of developing cancer. Furthermore, 96% of this population is mainly concentrated in Zhejiang province, where Sanmen NPP locates. “Simulation and dose analysis of a hypothetical accident in Sanmen …www.researchgate.net/…Sanmen…/72e7e52a45e4f1d924.pdf? by Z Yangmo – ?2014

It is not necessary that the radiological dispersion from Karachi nuclear reactor (although with a similar technology) in case of a nuclear accident would reach the same distances with identical density. The absolute volume of radiological debris would probably be comparable and it would reach larger areas or smaller areas depending on the environmental conditions. However, one would suspect that there may not be huge environmental differences so as to make the conclusions of the Sanmen paper irrelevant for Karachi. Surely, one could make a useful inference from this to understand the implications in our case. On the other hand, PAEC has been propagating a very low radiation doze of 0.01 mS (I suppose related to normal operations).Either accident conditions have not been studied or only convenient data is being released.

PNRA has issued a NPP siting guide under a SRO in which it lays out the criteria and methodology to evaluate suitability of sites for nuclear power reactors. Para 5.2.i of SRO 911(I) PNRA, concerned with Nuclear Siting, requires impact evaluation under accident condition, although it does not specify the severity on INES scale, a flaw that one would like to be rectified in the light of similar rules in other countries. “For each proposed site, the potential radiological impacts in operational states and in accident conditions on people in the region, including impacts that could lead to emergency measures, shall be evaluated with due consideration of the relevant factors, including population distribution, dietary habits, use of land and water, and the radiological impacts of any other releases of radioactive material in the region.”

And From the China paper, we find that in case of a nuclear accident, there would be fallout with doses in the range of 20-100 mS, while in most countries 1 mS is the maximum dose limit. In case of Sanmen China, 284,000 persons have been predicted to have cancer risk. In Karachi, with such high population and high population density and poverty, such risk could be even higher. This is an added reason to re-evaluate and revise the nuclear power plant siting decision in Karachi or proves through an open and credible process that this would not be the case. The onus of proof lies with the project proponent. It is hoped that PNRA would examine this evidence and grow some teeth to make a decisive and correct determination in this respect.

Our nuclear bureaucracy seems to be out of tune with times. It is living in 1960s, when they could quietly build KANUPP (only one-tenth of the size and risk) without public consultation or acceptance. A habit has been developed of masking things under the garb of national security. I am prepared to organise a credible risk assessment study based on generic third party data without asking for any data from our nuclear establishment so that the notional national security is not jeopardised.

As to the PNRA, it is a toothless body like any other regulatory body in this country be it Civil Aviation Authority, EPAs, SECP etc. Despite proclamations of independence, it is a subservient body. PNRA’s professionals are rotated between the two organisations. They cannot possibly speak their mind objectively and without fearing of losing their jobs and perks. There are capacity problems as well. PNRA’s rules are mostly qualitative and descriptive. For example, requires considering nuclear accidents in nuclear siting proposals but fails to specify anything like INES scales radioactive release timings etc. It does not specify even the safe dose limit which in most countries has been standardised at 1 mS. One can predict the response to this. They would argue that they use international standards and in the same breath would argue that every country has its own standards to win another argument.

We are all sincere and patriotic Pakistanis irrespective of the opinions that we have. We should coolly examine the evidence that comes to our knowledge and be ready to make amendments in our views, opinion and judgements. It is the responsibility of PAEC to make the evidence available. It is very difficult and costly to bulldoze projects without adequately taking the people into confidence with objective data and evidence .It would be in the very interest of the project. In India, KudanKulam NPP project was delayed for a decade due to lack of consensus. Nearby villagers blocked roads which carried personnel and material of the project and thus slowed down its construction. The opposition to KudanKulam has still not subsided even when it is near commissioning. Facing an excruciating energy crisis, we cannot afford such delays. Hence, the proponents should have options ready in case they are not able to make a cogent case. They seem to be losing already, as they are hiding facts and data. Only objectivity, truth and openness will work. Assembling non-specialist populist crowds in hotels would not be very helpful in building confidence.