Koodankulam: Memorandum submitted in 2006 Public Hearing

To

K A Mathew  

Chairperson, Tamil Nadu Pollution Control Board
& G. Prakash
Collector, Tiruneveli

Sirs

This is to draw your attention to the hasty and under-publicised public hearing on the four new nuclear power reactors to be installed in Koodankulam, Tiruneveli district. I came to know of the public hearing conducted by TNPCB at the Tiruneveli collectorate on 6 October 2006 through activists and journalists.

Environmentalists had raised serious concerns over the secretive EIA for the first two reactors to be established in Koodankulam following the 1988 Indo-Russian agreement. As a human rights activist then, I was one among those who had expressed concern over the establishment of a nuclear plant close to Kanyakumari. You may be aware that there was no public hearing for the first two reactors whose construction was okayed in 1998 and began in 2002. The EIA for the same has still not been made public.

In this context I am raising the following issues which should be discussed by everybody in Tamil Nadu including all political parties and members of civil society:

1. Currently, 6 more reactors are proposed to be added to the existing two at the same site. According to international norms, no reactor should be built 30 km from the vicinity of a town. According to a recent article by S.K. Agrawal, Project Director, KKNPP, “the nearest town is Nagercoil, which is about 35 km west of KudanKulam village.” The fact is Kanyakumari is a major town and tourist center 25 km northwest of Koodankulam. This has been ignored by the EIA and Mr Agrawal.
   
   
2. The EIA was conducted by NEERI before the December 2005 tsunami. The tsunami had ravaged coastal TN including Kanykumari. The EIA on which this public hearing is based shockingly makes no mention of the tsunami. NPCIL, while admitting that a possible tsunami was not factored in during the construction of the first two reactors in 1998, continues to reason that the 2005 tsunami did not affect the plant and therefore tsunamis needs not be factored in. This is a very dangerous move that can endanger the lives of people in three districts and even Sri Lanka. No VVER reactor has ever been established in a coastal area before. And now this is a tsunami-prone coast.
   
   
3. Moreover, earth tremors of a high magnitude have been recorded 64 times in South India since 1688.  Tremors have been experienced 36 times in between 1900 to 2000 including eight in 1960s, six in 1970s and four in the 1980s. Geologists have noted strange Rock Melt Extrusions in Kanyakumrai district. Dr. Jaykumar, ex-Vice Chancellor of Periyar University had pointed out that India is the fastest moving land mass in the world. It has moved from original to present position by several hundred km. The land mass of India is moving northwards and the Indian Ocean is still spreading.
   
   
4. The fuel to be used in all reactors is 4% enriched Uranium-di-Oxide. Though Russia has agreed to provide fuel for 40 years, the spent fuel will not be sent back to Russia. This is an important part of the agreement. Spent fuel is highly radioactive and the DAE has not decided how to deal with it. This poses a grace environmental risk.
   
   
5. Water is a major and immediate issue as far the locals are concerned. In March 2002, when the first pour-concrete ceremony was held for the first 2 reactors, the locals in Radhapuram taluq had protested. Enraged locals, led by local political leaders had asked: “Where is the water they promised us?” NPCIL had promised drinking water but failed to deliver. Radhapuram Union councillor and Congress leader E. Sureshkumar had noted in a report in The Hindu: “We have appealed to all in the hierarchy, from the Mumbai office of the Nuclear Power Corporation to the local director.” They say there have been only more promises and assurances. But no water. The situation has not changed today. In Vidyapathi panchayat, a fishing village of 17,000 people a kilometre from the plant site, people had said in 2002. “They have given us a borewell and a motor.”
   
   
6. Today the water situation is more serious with four of the six more plants coming up. The proposed VVER Light Water Reactors requires fresh water as a coolant for the reactors every day. Water is crucial life-line issue for the 2 districts—Kanyakumari and Tirunelveli. According to the EIA: “Fresh water from Pechiparai dam, which is about 65 Kms north west of the project site is proposed to be used for meeting various water demands.” If the demand is projected for all the six reactors based on the EIA estimate, the total quantity of water required would be: 30,891 m3/day.
   
   
7. Pechiparai dam was completed across Kodayar River in 1906 by the erstwhile Travancore State. The reservoir has never had full capacity in since 1963. On an average  it received 16 percent less than full capacity (currently 139.473 Million M3). The data gathered by independent environmentalists indicate that the annual rainfall is deficient almost in half the number of years during time duration of 88 years spanning 1901 to 1989. Drought Data for Kanyakumari District proves that the district has witnessed droughts for 11 years in the 88 year period from 1901 to 1989. The district had witnessed 41 years of drought-like situation during the above said period. Out of the 88 years 52 years were prone to some extent of drought in this district. Studies prove that the Kodayar river basin is already under severe stress.
   
   
8. In such a context, KKNPP is demanding a major share in the total fresh water available in a River Basin. The extent of  KKNPP’s demand (even with the highly unrealistic, conservative value of 8 to 9% on the Total Capacity of Pechiparai Capacity) on the Kodaiyar Basin’s surface water potential is something like this:
   
   a) KNNPP seems to demand 2.783% of the entire storage capacity of the Kodaiyar Basin; it seems to demand 1.22% of the Total estimated Surface Water Potential of the entire Kodayar Basin.

b) KNNPP water demand is 38.475% of the drinking water demand in 1999; 35.987% in 2004; 32.609% in 2019; 19.686% in 2004.

c) KNNPP demands 1.548% of the Total Agriculture Fresh Water Demand of the basin.

d) KNNPP’s water demand is 3.32 times the fresh water demand by the entire life stocks of the basin.

e) KNNPP demands 5.87 times the water used by the basin’s industries in 1999; 4.88 times in 2004; 3.24 times in 2019; 2.07 times in 2044.

9. Under any circumstance, drought or no drought, KKNPP cannot afford to forgo its fresh water demand from the basin, as without this freshwater its Reactor Cooling Systems simply cannot function. Freshwater is an ABSOLUTELY ESSENTIAL ITEM for these reactors. During these times of immense water crisis, KKNPP might draw 50% or say even the entire capacity of the very little water that would remain in the reservoir. KKNPP would naturally get the first priority for this water.
   
   
10. Any water shortage will affect Small Farmers and Landless laborers first and worst. The EIA shockingly and Mr Agrawal’s article cited earlier do not consider these scenarios at all. Since the EIA is deeply flawed on several counts listed above, as a Member of the Tamil Nadu Legislative Assembly, I urge the district administration to look into these issue and I urge the TNPCB to discharge its duty and order a fresh EIA and put the project on hold till then. Tsunami and earthquake threats, safe disposal of radioactive waste and spent fuel, and most crucially the withdrawal of water from the Pechiparai dam should be factored in by the EIA.
    
    

Sincerely,

D Ravikumar

MLA, Viduthalai Chiruththaigal Katchi