(since official expert committees dealt with only reactor safety and not public safety aspects, activists must demand for non-technical public safety reports and not for technical reactor safety reports)
Director, Center for Environmental Studies,
GITAM University, Visakhapatnam-530045
Presently there is a controversy about the supply of Kudankulam nuclear safety reports to the anti-nuclear activists under the Right to Information Act the Nuclear Power Corporation refuses to obey the orders of Chief Information Commissioner to supply to the public the site evaluation report and nuclear plant safety report to the public under the pretext that it belongs to a third party namely, the Russian nuclear plant suppliers. The activists are worried because there are several repsorts on the working of many Soviet reactors in a very unsafe manner. Consequently the doubts about the safety of Kudankulam are genuine. Hence the activists must provided with the public safety aspects of the Kudankulam reactors by providing the people with the reactor explosion scenario source terms, atmospheric dispersion of radioactivity and demarcation of the exclusion zone, sterilized zone, emergency zone and the off-site disaster management zone along with concentrations of radioactivity expected at the ground level in these zones. First of all the people are evacuated due to a reactor accident upto a radius of 30km in Japan and some European countries and Americans are evacuated in Japan due to Fukushima explosion upto 80km from the accident site but Indian Standards are very vague as they may evacuate people due to an accident upto maximum of 5kms from the reactor as per the AERB guidelines while International guidelines by IAEA stipulate evacuation of people upto 25km and treat emergency zone upto 300kms. It means that the Tamilnadu Chief Minister and the Prime Minister of India are treating the people living in the off-site disaster management zone as people who can be sacrificed by poisoning and slowly killing them as practiced by Hitler during the second world war by using the gas chambers which represent the present day Kudankulam nuclear reactors. Hence people must study these problems of life and death and take necessary timely action by remembering that even God canot help those who refuse to help themselves Even though Article 51A(g) of the constitution demands people to discharge their duties under the constitution.
1) WHO ARE THE PEOPLE TO DECIDE ON THE SAFETY OF NUCLEAR PLANTS:
The British Atomic Energy Agency experts on safety J.G.Tyror and A.R.Garlic safety goals for nuclear plants have to ensure that they are safe enough to the operation of the plant and the public in its neighbourhood in practice one must get a comprehensive idea of the whole question of what constitutes adequate safety for a hazardous nuclear reactor in modern society. It is not a purely technical matter and much less simple calculations of risk and comparing the results with a numerical target as compared with road accidents, aircraft crashes, industrial accidents and fires. The purpose of safety goals for a nuclear industry are to consider them as a decision making aid. If so one must know who makes such decisions on the safety of a rector. Infact many people are involved in decision making on the safety goal of a reactor including the designer the control operator, plant manager, the operating organization, the regulator, the public enquiry inspectorate, the responsible minister, members of Parliament and state legislature and the concerned public. The legal responsibility for safety rests mainly with the reactor operator organization while all the other are part of a chain of accountability who can make decisions effecting in someway or the other the safety of the reactor. Under these circumstances the nature of the safety goals and the information required to assess whether these safety goals have been met do vary depending on who is making the decision and whose interests are represented in the decision making. Safety goals are considered both primarily at the technical level and also at the non-technical level involving public safety goals. The decisions on safety goals might vary depending on whether a decision maker is prone to protect his personal interests, those of his his local community people, those of his contracting company, those of the nation or indeed the international interests. It is always not clear in decision making what or who is being protected and if the interests of the society are safeguarded. Since most decisions on nuclear plants are made nationally. International interest are not of much concerned but this is not true because the foreign reactors suppliers exert pressure through their heads of states to strike business deals with heads of poor countries by paying them huge kickbacks as had been reported in the case of defence deals such as Bofor deals in India.
2) SAFETY GOALS OF A NUCLEAR PLANT:
In dealing with safety goals we are concerned with the damaging impacts of the routine radioactive emissions and emissions from reactor explosions. The International Atomic Energy Agency (IAEA) provides guidelines on how safety goals should be formulated to deal with measures to safeguard public safety goals. In the case of nuclear accidents like Chernobyl it was not only the public concern about the incidence of cancers and deaths but it was also about the forced evacuation of tens and thousands of people from the radioactive contaminated zones, the necessity to forbid the use of habitations and agriculture lands and the consumption food stuffs, enormous financial costs entiled by the counter measures, costs of decontamination and replacement of lost electrical output etc., The Atomic Energy Agency in United Kingdom for their Sizewell nuclear power plant conducted a public enquiry and found that the opinion of the public should underlie the evacuation of the risk due to nuclear reactor. A public symposium was conducted where it is said that pubic is not interested in the technical details of safety nor by the seemingly irrelevant risk comparisons. Instead the public are concerned about the competence and motives of the institutions including the reactor suppliers, operators, technical experts, legislators and regulators whose job it is to ensure safety.
3) Goals of Emergency Preparedness (Based on report of Nuclear Reactor disaster, NDMA, New Delhi)
The probability of a major accident at nuclear reactor leading to release of enormous radioactivity into the air, water and soil environment is generally small due to control measures. Even during an explosion radioactivity release into the environment is minimized by taking counter measures which reduce radiological dose and health effects to the public.
The practical objectives of emergency preparedness are:
i) To reduce radiation-induced health effects by minimizing the radiation dose to the workers and the public.
ii) To limit the radiation exposure to the public in the emergency planning zone by sheltering them and evacuating them helps in reducing public health damage.
4)Preparedness for Nuclear/ Radiological Emergencies
The handling of nuclear emergency preparedness and management must be coordinated between different service groups of the nuclear plant. In the event of large scale releases of radioactivity due to an explosion into the public domain all the authorities at the district, state and central, levels must play an effective and coordinated role.
5)Emergency Preparedness for Nuclear Power Plants
There must be a comprehensive emergency preparedness plan prepared and debated by the public before the nuclear reactor goes into operation. The Atomic Energy Regulatory Board must ensure that the nuclear plant is provided with the Emergency Response Manuals for the three main types of emergencies, namely, the plant, on-site and off-site, and that the plans are in place to handle these types of emergencies. The assessment of the type and quantum of release of radioactivity under various accident conditions and the extent to which it can spread into the environment must be prepared in advance.
The response actions for the nuclear facility are the responsibility of the plant operator. But the implementation of the emergency response plan in the public domain (beyond the site boundary)as off-site emergency response is the responsibility of the concerned district Collectors and the state Government. In the event an off-site emergency having the potential for trans-boundary effects, necessary action is taken by DAE in accordance with the international obligations. Indian nuclear plant authorities have the emergency response plan in place and they are tested during periodic exercises as per international practice.
6)Handling Off-Site Emergencies
If a major nuclear explosion is expected to occur and the radioactivity is going to be released into the environment effecting the people the concerned district authorities are directed to take up necessary measures to implement emergency response systems.
The following additional measures must be taken for handling a reactor emergency that impacts the public
i) Pre-identification of plant conditions which can lead to an emergency in the public domain.
ii) An assessment of the radiological status at the site boundary and in the public domain.
An Off-site Emergency Response Plan is expected to be prepared by the local state government and the District Collectors in consultation with the reactor operators. This plan identifies the role of each response agency in a clear and unambiguous manner. After obtaining concurrence from the AERB, detailed emergency response plans and procedures for handling offsite emergencies are approved by the Chairman, State Executive Committee (SEC) of the concerned state where the nuclear plant is located. Finally, procedures are also in place to carry out drills/exercises to rehearse these disaster response and management plans which are periodically reviewed and revised based on the lessons learnt from past exercises.
For handling an off-site emergency response system in a nuclear plant , there is an off-site emergency committee headed by the district Collector and magistrate of the concerned district and supported by the district subcommittee, which include chiefs of all public service departments relevant to emergency management in the district and also the Head of the Site Emergency Committee of the nuclear facility for technical advice. This committee takes decisions pertaining to the handling of a nuclear emergency outside the site boundary and ensures implementation of countermeasures such as sheltering, prophylaxis and evacuation and resettlement, including maintenance of law and order and civil amenities. All the activities pertaining to the handling of an off-site emergency are guided and coordinated from a pre-designated emergency response centre located outside the boundary of the nuclear plant. The information and broadcasting department of the district, in association with an authorised information officer, ensures the smooth flow of information to the media to avoid panic and spreading of rumours.
7)Training of Stakeholders, Periodic Exercises and Mock Drills
Training plays an important role in the proper implementation of various emergency response activities. It focuses on roles and responsibilities, resource identification, use of equipment, understanding the effects of radiation on human beings, animals and the environment. The required emergency preparedness is maintained by organizing various training courses for onsite and off-site personnel at regular intervals.
Appropriate training is imparted to employees of the facility at all levels at regular intervals to familiarize them with the required actions during an emergency. Similar training courses are organized round the year for various public authorities and state government officials in view of the routine turnovers.
The adequacy of emergency response arrangements at a nuclear facility is evaluated through the audit and review of plans, procedures and infrastructure. The ability to carry out the required emergency actions is assessed, in general, through audit and reviews of past performance. However, a primary evaluation of the same is based on the feedback of designated observers for the periodic mock exercises. The preparation, conduct and evaluation of these exercises shall involve the coordination of all functionaries within the facility, the district authorities and the CMG of DAE. These drills for plant, on-site, and off-site emergencies will preferably be conducted quarterly, annually and once in two years, respectively; however, the frequency of the actual exercise will depend on the type of nuclear facility.
If the disaster preparedness and management exercises in the off-site area are not found feasible the nuclear plant is not allowed to function to that detriment of public safety and environmental resources conservation and alternative methods of producing power as anticipated from this nuclear plant must be made available by the state and central governments by taking the consultation from experts all over the world by inviting international tenders and thereby the electricity requirements of region can be easily met on the same lines as Germany and other European countries are following in the wake of the closure of all the existing nuclear plants consequent to the Fukushima nuclear plant explosions. These procedures must be followed even for Kudankulam nuclear power plant and the environmental activists and social workers must demand for these public safety evaluation reports consequent to the upcoming Kudankulam nuclear plants. The relevant risk analysis reports, emergency response systems and disaster management plans are furnished in the following websites for the use of the concerned social activists.