Friday, April 16, 2010

NUCLEAR PLANT RISKS, SRIKAKULAM DISTRICT (AP STATE, INDIA)

Prof.T.Shivaji Rao
Director, Center for Environmental Studies, GITAM University, Visakhapatnam
(This article is both in English and also in Telugu (as published in Eenadu on 14-1-1993 and the same is presented as scanned picture below this article)

http://www.nirs.org/reactorwatch/licensedtokill/LiscencedtoKill.pdf 
(Killing fishes and marine life due to reactor effluents, 
cheating by nuclear industry pages 101 and 104)  
http://georgewashington2.blogspot.com/2011/04/ap-risk-of-nuclear-catastrophe-could.html 

http://www.nrc.gov/about-nrc/emerg-preparedness/about-emerg-preparedness/planning-zones.html 
DO VISAKHAPATNAM PEOPLE KNOW THAT THEY ARE WITHIN ZONE OF INFLUENCE OF EMERGENCY  ACTION PLAN DUE TO KOVVADA NUCLEAR ACCIDENT ?
http://desastres.unanleon.edu.ni/pdf/2002/noviembre/pdf/ENG/DOC13731/doc13731-contenido.pdf 
Nuclear Accident influence Zone is upto 100 km.in Finland for Emergency Response Actions ,WHY not such protective actions be taken by authorities in INDIA to save the people...??
http://www.bellona.org/articles/articles_2011/rosatom_report[Russaian safety report]
http://www.nytimes.com/2011/06/02/world/europe/02germany.html?pagewanted=all 

http://www.osti.gov/bridge/servlets/purl/102183-vTsUij/webviewable/  [Accident modelling]
http://www.remm.nlm.gov/nuclearaccident.htm#figure1  [Reactor accident modelling]
http://tshivajirao.blogspot.com/2011/08/diaster-consequences-of-kovvada-nuclear.html [Excellent]
[It presents actual villages and towns and cities that will be ruined due to a Reactor Accident ]
http://www.ccohs.ca/oshanswers/phys_agents/ionizing.html 
[ Conversion of radiation Exposure in Air to radiation Dose absorbed by body]
http://projectpangaia.wordpress.com/2011/05/21/nuclear-catastrophe-vs-alternative-energy/ 
[Excellent Eye-opener Videos on Chernobyl accident and Global impacts+Fukushima scenarios]
http://allthingsnuclear.org/tagged/Japan_nuclear {Fukushima Video] 
http://www.oecd-nea.org/press/2011/BWR-basics_Fukushima.pdf [Fukushima Reactor]
http://www.greenpeace.org/eu-unit/en/News/2011/companies-back-100-percent-renewables-25-01-11/  Alternate Energy Sources for Nuclear plants]
http://www.japantoday.com/category/national/view/yoko-ono-says-japan-should-look-to-geothermal-energy  [Japan has Geo-thermal Sources as Alternatives to Nuclear plants]
http://www.thehindu.com/opinion/op-ed/article1770465.ece [Natural Gas as alternative in India]
http://2sustain.com/2011/01/greenpeace-report-shows-europe-could-convert-to-almost-entirely-renewable-energy-resources-by-2050.html

http://www.ansn-jp.org/jneslibrary/PWR_Safety_Design.pdf  [Reactor safety Design,Japan]
http://www.frontlineonnet.com/fl1713/17131020.htm   [Safety violated by Government of India]
http://www.greenpeace.org/india/en/What-We-Do/Nuclear-Unsafe/Safety/Nuclear-accidents/Nuclear-accidents-in-India/Accidents-at-nuclear-power-plants/  [Indian Reactor Accidents]
http://bhujangam.blogspot.com/2011/08/unsafe-nuclear-reactors-in-india.html 
 http://www.indiastudychannel.com/resources/139114-Nuclear-accidents-India.aspx
http://www.indiastudychannel.com/resources/138996-Nuclear-accidents-reasons-safety-measures.aspx
http://en.wikipedia.org/wiki/Nuclear_power_in_India#Accidents 
http://ec.europa.eu/research/energy/pdf/off-site_nuclear_emergency_mangement_en.pdf  [European Nuclear plants accidents scenario-Chernobyl calculations]
http://www.iaea.org/Publications/Booklets/Chernobyl/chernobyl.pdf 
http://bhujangam.blogspot.com/2011/08/probable-nuclear-reactor-1100-mw.html
(Sizewell Reactor accident scenario for rehabilitation and resettlement of people) 
http://isid.org.in/pdf/DN1111.pdf  [NUCLEAR SAFETY 0LANS TO BE STRENGTHENED]
Supreme Court judges Douglas and Black described Nuclear power as “a most deadly, a most dangerous process that man has ever conceived”. In fact the radioactive pollutants are a million to billion times more toxic than many chemical poisons. Many experts emphasize that nuclear power proliferation is a serious threat to mankind meriting comparison with nuclear war. But some people believe that it holds the key to national energy and defence problems and is clean, safe and cheap. However, the former head f U.S. Nuclear establishment David Lilienthal belatedly admitted in 1981 that “nuclear technology is not really so advanced; it is not dependable enough; it is not safe enough”. Even the Russian expert Legasov posed the questions: “Is not the development of nuclear energy on an industrial scale premature? Will it not be fatal to our civilization, to the eco-system of our planet? We must work for the creation of anti-accident centers and centers devoting themselves to compensating for the losses to the environment. The upgrading of the industrial level of safety and the solution of the problem of the relations between man and machine would be a lot more natural thing to do than concentrating the efforts on only one element of the energy structure in the world. This would benefit the whole of humanity”. The Chernobyl disaster and Fukushima Disasters actually proved that even highly disciplined developed nations like Russia  and Japan could destroy their own human and natural resources and those of other neighbouring nations without a war just by accidental mismanagement of the so called peaceful uses of the atom.
WHY NUCLEAR REACTORS  AT KOVVADA ARE BOUND TO EXPLODE AND FAIL ?
The modern passive safe reactors proposed in places like Kovvada and other places in India are claimed to be safe even incase of failure of pumping and electrical power as they depend upon laws of nature as also on design and materials behavior on the assumptions the passive cooling systems work on gravity, draining, natural circulation and low thermo-syphoning.  The diesel generator sets are proposed at eleven meters elevation at Kovvada for cooling the reactors after they are shut down.
 But international nuclear experts state that safety risks may be the greatest when nuclear systems are the latest brands and operators have less operational and research experience with them.  Nuclear expert David Lochbanm argues that almost all serious accidents occurred with the latest versions of reactors at all time because firstly accident scenarios occur that are impossible to plan for in the simulation exercises and secondly workers often make mistakes because to err is human.  Safety culture in nuclear industry is the personal dedication and accountability of all workers and supervisors engaged in the fabrication, construction, operation and maintenance of reactors.  There is some evidence that operators almost never follow instructions and written procedures exactly and the violation of rules appears to be rational because operators often work under high stressed conditions.
  A reactor may be designed to be safe for a given magnitude of air, earthquake and a Tsunami wave to withstand to withstand both.  But if a third risky event like a terrorist attack that devastated the world trade center in NewYork , Bomb attacks that destroyed Dams in Germany during the second world War on a missile attack is experienced by a nuclear plant nobody can guarantee the safety of the reactors.  Hence Nuclear Safety is a myth particularly under Indian nuclear industrial work culture and hence India must follow the Japanese Prime Minister in abandoning nuclear reactors and promote alternate sources of energy.  Nuclear reactor proliferation is the greatest threat to human life amounting to an undeclared nuclear war against mankind posing a threat to our civilization. 
http://www.climateandfuel.com/pages/generationfour.htm 
Advanced  passive safety Reactors
 Questioning the safety of nuclear reactors Dr.Hannes Alfven, a noble laureate said “although the nuclear experts devote more effort to safety problems than other, the real question is whether their blue-prints will work as expected by them in the real world and not only in their technological paradise”  The growing number of nuclear incidents show that it is impossible to ensure complete safety even the most modern reactors.  Decay heat  needs pumped cooling water for an year to prevent over heating nuclear plants are some of the most sophisticated and complex energy systems and no matter how will they are designed and engineered, they cannot be deemed fail-proof .
 Reactors are highly complex machines with an incalculable things including inter connected linkages that could go wrong.  In the Three Mile Island Reactor accident one malfunction led to another malfunction and then to a series of others until the core itself began to melt and even the best experts did not know how to respond .  A combination of electrical, mechanical and human failures can disable the reactor itself.
http://www.parliament.uk/documents/post/postpn222.pdf 
Terrorist Attacks on Nuclear Plants-Report to U.K.Government
http://en.wikipedia.org/wiki/Nuclear_safety
http://www.deccanchronicle.com/channels/cities/hyderabad/kovvada-n-plant-be-safe-469
(Kovvada Nuclear Plant  claimed to be safe due to improvements)  
http://bravenewclimate.com/2011/03/13/fukushima-simple-explanation/
HOW TO PLAN IN ADVANCE TO MEET A NUCLEAR REACTOR DISASTER TO SAVE PEOPLE
SEE WEB SITES: http://www.fema.gov/hazard/nuclear/index.shtm
https://feww.wordpress.com/2011/04/18/probability-of-a-nuclear-disaster-by-country/ 
 http://www.nukefreetexas.org/crac_2_study.html   [Texas Disaster case study plus Detailed Report for USA on the Linked Web site]
http://www.scribd.com/doc/54129523/L-AM-II-01  [Disaster Coping and Management]
http://bhujangam.blogspot.com/2011/07/disaster-scenario-for-spent-fuel.html
(Fuel Storage tank accidental scenario for Disaster Management)

http://www.nucleartourist.com/events/NUREG-1465.pdf [Source Terms as estimated by USA]
http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/29/013/29013389.pdf  [Chernobyl estimates]
http://irpa11.irpa.net/pdfs/KL-7a.pdf
http://en.wikipedia.org/wiki/Sizewell_nuclear_power_stations#Decommissioning   [Decommissioning costs]
http://www.sustainablenuclear.org/PADs/pad0305dubberly.pdf
Nuclear plant Decommissioning  and Final Disposal plans
 In the light of the harrowing experiences from Chernobyl disaster most of the countries have decided against nuclear power and some have chosen to close down the existing reactors in a phased programme. At this juncture, the Government of India has launched a major expansion programme in nuclear power. Karnataka, Andhra and Tamil Nadu will be affected by this projectThey are planning major Reactors in Maharashtra and Gujarath also inspite of serious public agitatations against them.ForFalse claims on safety of Nuclear reactors by DAE and other indian experts employed by Nuclear Power promoting Government agencies,see web site:
NUCLEAR SAFETY IS A 100% MYTH and NUCLEAR POWER ECONOMICS IS A 100% FRAUD.:
http://en.wikipedia.org/wiki/Nuclear_safety
http://www.nirs.org/alternatives/battleofthegrids.pdf
http://www.nirs.org/factsheets/routineradioactivereleases.pdf
http://archive.greenpeace.org/comms/nukes/chernob/rep02.html
http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0216/r2/br0216r2.pdf

http://www.world-nuclear.org/info/inf06.html
http://www.world-nuclear.org/info/inf06app.html
http://books.google.co.in/books?id=jAsAAAAAMBAJ&pg=PA17&lpg=PA17&dq=permissible+levels+of+air+pollution+from+nuclear+reactor+in+USA&source=bl&ots=X5RFIxmjRk&sig=SICGSs0VkJ9hbvTlnT0DxTcxHWk&hl=en&ei=BEbzTYGLF4borQeP_5jGBg&sa=X&oi=book_result&ct=result&resnum=1&ved=0CCwQ6AEwAA#v=onepage&q&f=false
(Nuclear Air Pollution + Heat output from coal plants + health costs of nuclear radiation)
http://whqlibdoc.who.int/monograph/WHO_MONO_46_%28p38129%29.pdf http://whqlibdoc.who.int/monograph/WHO_MONO_46_%28p381%29.pdf
(WHO publication by French expert on air pollution due to radioactivity)
http://theamericano.com/2010/10/25/russia-venezuela-cuba-threat-nuclear-power-plant/
[Risks of VVER-440 Reactors planned in Kudamkulam,Cuba etc.,15 times riskier than US plants]
SAFETY DOSES: OF RADIATION EXPOSURE FOR PUBLIC as fixed by States
http://www.aerb.gov.in/t/news/CNS2010.pdf  [pages-103-104,India 1mSv per year]
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1650/r3/sr1650r3.pdf [pp131-0.25mSv/year]
Extract on Nuclear safety aspects from the web site:http://www.world-nuclear.org/info/inf06.html
 http://www.aerb.gov.in/T/PUBLICATIONS/CODESGUIDES/SG-EP-02.PDF  [Disaster Management]
www.iaea.org/inis/collection/NCLCollectionStore/_Public/.../24074640.pdf   [Copy this on Google search]
http://sanhati.com/excerpted/3324/
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0492/sr0492.pdf   (Fault Tree Handbook)
https://netfiles.uiuc.edu/mragheb/www/NPRE457%20CSE%20462%20Safety%20Analysis%20of%20Nuclear%20Reactor%20Systems/Loss%20of%20Coolant%20Accident%20LOCA.pdf   (Reactor Core Temperature Locations)
http://bhujangam.blogspot.com/2011/07/failures-of-nuclear-reactors-during.html  (Maintenance Failures)
http://bhujangam.blogspot.com/2011/07/passive-safe-reactors.html

Nuclear plant operators are to begin work on a document for each power plant site. This analysis of 'extreme scenarios' will follow what ENSREG called a progressive approach "in which protective measures are sequentially assumed to be defeated" from starting conditions which "represent the most unfavourable operational states." The operators have to explain their means to maintain "the three fundamental safety functions (control of reactivity, fuel cooling confinement of radioactivity)" and support functions for these, "taking into account the probable damage done by the initiating event."

The documents have to cover provisions in the plant design basis for these events and the strength of the plant beyond its design basis. This means the "design margins, diversity, redundancy, structural protection and physical separation of the safety relevant systems, structures and components and the effectiveness of the defence-in-depth concept." This has to put focus on 'cliff-edge' effects, e.g. when back-up batteries are exhausted and station blackout is inevitable. For severe accident management scenarios they must identify the time before fuel damage is unavoidable and the time before water begins boiling in used fuel ponds and before fuel damage occurs. Measures to prevent hydrogen explosions and fires are to be part of this.

Since the licensee has the prime responsibility for safety, it is up to the licensees to perform the reassessments, and the regulatory bodies will independently review them.



Operators should send a progress report on their work to their regulators by 15 August 2011 and a final version by 31 October. Regulators are to report progress to the European Commission on 15 September and in full by 31 December. Information is to be shared among regulators throughout this process before the final reports go to peer-review by teams appointed by ENSREG and the European Commission. The final documents will be published in line with national law and international obligations, provided this does not jeopardise security - an area where each country may behave differently.  The process is to be finished in April 2012
The IAEA Convention on Nuclear Safety  (CNS) was drawn up during a series of expert level meetings from 1992 to 1994 and was the result of considerable work by Governments, national nuclear safety authorities and the IAEA Secretariat. Its aim is to legally commit participating States operating land-based nuclear power plants to maintain a high level of safety by setting international benchmarks to which States would subscribe.
The obligations of the Parties are based to a large extent on the principles contained in the IAEA Safety Fundamentals document The Safety of Nuclear Installations. These obligations cover for instance, siting, design, construction, operation, the availability of adequate financial and human resources, the assessment and verification of safety, quality assurance and emergency preparedness.
The Convention is an incentive instrument. It is not designed to ensure fulfillment of obligations by Parties through control and sanction, but is based on their common interest to achieve higher levels of safety. These levels are defined by international benchmarks developed and promoted through regular meetings of the Parties. http://www.world-nuclear.org/info/inf06.html

1. REACTORS AT KOVVAD: As a part of this venture it is proposed to establish a nuclear plant (PHWR) at Kovvada in Srikakulam Dist., with an initial capacity of 2 x 500 MW and an ultimate capacity of 2000 MW. In the proposed pressurized heavy water reactors the core is located in a steel vessel known as Calandria that is filled with heavy water and kept at atmospheric pressure. Low pressure heavy water is used as a moderator while high pressure heavy water is used as a coolant, permitting natural uranium as fuel. The fuel rods, separated laterally by spacers consist of natural uranium dioxide pellets clad with Biracloy. Without reactor shut-down one machine inserts fuel bundle into pressure tube at one end while spent fuel bundle is discharged at the other end.
As in a pressurized water reactor, the primary circuit of PHWR consists of several loops. For each loop a number of pipes emanating from individual pressure tubes feed into an outlet header that is connected to a steam generator main coolant pumps and inlet header that again feeds individual pressure tubes. The coolant temperature and void coefficients are positive. Primary shut-down is provided by vertical absorber rods immersed between the pressure tubes with secondary shut down, if necessary, by injection of chemicals under pressure into the moderator.
II. REACTOR SAFETY PROBLEMS: Although pressure tube design has positive and negative points from a safety point, the possibility of uncontained fuel melting accidents is not eliminated in this design. Even if pressure tube design precludes the chances of massive pressure vessel failure, the long length, surface area and complexity of the primary system piping results in greater possibilities for loss of coolant accidents. Online refueling provides additional means by which loss of coolant accidents can be initiated. As the pressure tubes are exposed to the full neutron flux, they experience the consequential weakening effects. Due to deuterium-zirconium interaction, delayed hydride cracking occurs in the piping system. Moreover the natural uranium heavy water void coefficient of reactivity is positive and any loss of coolant accident lads to a power excursion. A loss of coolant accident coupled with scram failure leads to rapid melting of fuel and possible common mode breach of the containment. While heavy water results in large and hazardous tritium inventories, extensive use of zirconium in the core provides for a large zirconium – system reaction potential. The multi-unit station design may ultimately result in common mode failures which have not been studied in depth in safety analysis in the Indian environment with considerable degree of emphasis on indigenization on various parts of reactors. Since the containments are not usually designed to withstand some of the worst case accidents involving large scale zirconium-steam reactions, hydrogen and vapour explosions, common mode rupture of primary and secondary coolant systems inside the containment, human failures, sabotage, missile hits terrorism, bombing, massive aeroplane crashes etc., it is highly improper to emphasize that nuclear power is absolutely safe.
Safety cannot be engineered in. According to Dr.Hannes Alfven, a noble laureate, “although the nuclear experts devote more effort to safety problems than others, the real question is whether their blue-prints will work as expected by them in the real world and not only in their technological paradise”. A number of incidents show that it is impossible to ensure complete safety. A cyclonic storm that hit one of reactors destroyed five separate emergency power lines, a mathematical impossibility. A research reactor experienced a series of twenty-one sequential failures at the rate of seven failures and three identical channel-systems and surprisingly it was saved by one other system that was not being used because of unreliability. A series of six fatal mistakes made by the Russian experts at their Chernobyl plant proved that even with the best safety systems in the world, no reactor can be considered to be fool proof for all time and that safety ultimately lies in the constant supervision of the safety officers and the undiminished competence of the operators of the Nuclear plant.
In fact the Tarapur plant is said to have fuel failure as high as 20% to 35%. Among the prominent failures at Tarapur are the recirculation pumps, control rod drives, electronic monitoring and control systems, instrumentation, cracks in system piping, feed water pumps, leaks in condenser tubes, control valves, steam generator tubes control valves, water lines and extensive corrosion. Because of the effects in design, operation and maintenance, about 350unsuual occurrences are reported to have occurred by 1980 at the Tarapur plant.
III.RADIATION HAZARDS: With the splitting (fission of the atoms) of the fuel I its core, a nuclear reactor produces abundant heat and many fission products of higher elements most of which area radioactive. In an additional reaction, atoms heavier than Uranium such as Plutonium, Amricium, Curium and other Trans-Uranic elements that are also radioactive are produced. The radioactive substances from a Nuclear Plant can be broadly divided into alpha and beta particles, gamma rays and neutrons. Alpha particles travel for one or two inches in the air. If they get into the human body, they ionize the cells in organs like nose, eyes and tongue and harm the normal growth of cells. Even the beta particles destroy the cells in various organs of man. When the cells in the blood are thus destroyed, cancer will occur. The radioactive substances may directly get into man by being inhaled along with the air. The radioactive dust in the air may settle over the land from where it can reach man through the vegetables and fruits. When the grass over such contaminated pastures is eaten by the cattle the pollutants get concentrated in man through the consumption of milk and meat from such animals. Similarly the radioactive substances that get into the prawns and fishes from the contaminated tanks, rivers and lakes get into man. Thus the radioactive substances gradually build up in man through the consumption of contaminated air, water and food and cause slow but serious damage to different organs in the body even at very low doses.
III. MYTHS OF SAFE DOSE: People are exposed to a background Natural radiation of 130 millirems per year. Man made pollution adds 5 millirems. Exposures due to luminous watches and television screens are each equal to 2 to 3 percent of the background radiation. Some atomic energy officials feel that exposure of workers to ionizing radiation of 5 rems per year will not cause any harm. In the USA while the Environmental protection agency reduced the annual limit of exposure from 500 millirems to 25 millirems for residential zones around the Nuclear plants, the Energy Research Agency recommended a limit of only 5 millirems for the general public. Environmental scientists hold that as any minute level of radiation produces cancer and irreversible genetic deformities, no does of radiation is so low that the risk of cancer becomes zero. Unfortunately while the above limits to what is locally released from the plant into the environment are carefully regulated the cumulative impact of radioactive pollutants from all nuclear activities and their grave consequences of their biological magnification and slow poisoning effects on plants, animal and human populations even in the remote areas are not studied on scientific lines. Some people may become impotent. The nuclides penetrate the embryo of pregnant women who consequently may deliver deformed babies. Because of their continuous disintegration, the radioactive substances will undergo many changes and ultimately become stable substances. The time taken by such a substance to decay by 50% of its original weight is known as its “Half Life”. The half-lives of some of the pollutants are 5 days for renon-133; 8 days for Iodine-131; 10 days for Krypton-85; 28 years for strontium-90 and 30 years for cesium-137; 25,000 years for plutonium and crores of years for Uranium-238. Being chemically similar to calcium, strontium gets into the bones. Similarly cesium like potassium gets into the muscular cells. Unlike the common food substances like sugars, the radioactive substances are not amenable for digestion and hence accumulate in critical organs like gonads, breasts, bone-marrow, lungs and thyroid glands. Administration of 1 to 5 milli-curies of Iodine-131 corresponding to thyroid doses of 1000 to 10,000 rods causes serious damage. The hazards at lower exposure are enhanced by synergy with other common or unusual co-factors.
SOME OF THE ISOTOPES PRESENT IN SPENT-FUEL
ELEMENT
HALF-LIFE
IMPLICATION
Tritium 3H
12 years
Emits beta rays-absorbed internally
Krypton85Kr
44 Hours
Radiates beta rays-inert gas
Strontium 90Sr
28 Years
Emits bet rays-bones lungs absorb
Iodine 131I
8 Days
Emits beta rays – Thyroid absorbs
Xenon 133Xe
5 Days
An inert radio-active gas
Cesium 137Ce
30 Years
Irradiates body- absorbed internally
Plutonium 239Pu
24,300 Years
Hazard to health-body organs absorbs
(Source : Peat , David, the Nuclear Book: what happened at Harrisburg? And can it happen here? (1979) P.47.
IV. POLLUTION: The radioactive pollutants like iodine and caesium from the Chernobyl disaster of April 26, have created a terror not only in the East European countries but also in other distant places. The dust reached Japan and India as well as contaminated the soil, water, air and food. While the children were kept indoors in Australia, the sale of milk was stopped in Poland. Sweden has prohibited the import of foods from European countries. In some countries they are Planning to destroy the cattle and crops exposed to the radiation. People in the productive age group are adopting birth control methods. Some women in their youth are prepared to sacrifice both normal family life and motherhood. The educated youth are agitating that their elders who have kept silent at the time of establishing these nuclear plants have force closed their options and their rights for better quality of life to the present population and their progeny. Annual production of liquid wastes from a 1000 MW plant is estimated at 4000m3 with low radioactive of 1 curie/m3. Similarly, the annual discharge of radioactive materials into the atmosphere for a similar reactor are estimated at 12 curies for Tritium and 6 curies for Carbon14, discharges from the reactors into the atmosphere may include Argo-41 (from irradiation of air) Krypton-35(fission product) Xenon-133 and isotopes of Iodine-131 and Carbon-14 from irradiation of reactor materials. From a public health view pint, in addition to the above isotopes, tellurium, Ruthenium and Caesium are also harmful. Exposure of man is due to fission products discharged into the atmosphere. Smaller amounts of radioactive materials (from induced activity in corrosion products etc.) may be discharged with liquid effluents. Pressurized water reactors release mainly Xenon-133, the exposure within 80KM being estimated at 0.01 millirems per MW per year. In the USSR the emissions of radioactive substances from the Chimney stacks of Nuclear power plants per day are limited to 1 million-curie for strontium-90 and strontium-80, 100 millicuries for Iodine-131; 500 millicuries for the sum of Beta and Gamma aerosols besides the strontium and Iodine and 3500 curies for the sum of the radioactive inert gaseous isotopes of krypton, Xenon and Argon. All these substances get into man either through the air he breathes, the water he drinks or the food he eats. Often they get into the food chains and food webs in natureget biologically magnified many thousand fold and cause slow poisoning effects in man 20 to 30 years subsequent to his first exposure. In the water of Columbia river Zn-65 was found at a concentration of only 25 thousandths of pico-curie (p CI) per gram. Yet local inhabitants contained 4000 p CI in their bodies through bio-magnification.
The hot effluents from the condenser of reactor are bound to have adverse impact on all biological activity, varying from feeding habits and reproductive rates of fish to the changes in the nutrient levels, photo-synthesis, Eutrophication, 02-transfer, metabolism and degradation of organic material. Since the summer temperatures of water will be high this additional thermal input from the condensers may be very harmful to fisheries when the quantities of natural water get diminished during lean periods. The oxygen content will get reduced and the aquatic life will be under great stress. Sometimes the fish, their larva and eggs will be damaged while passing through pumps and condensers. The chemicals used intermittently for defouling the condensers will adversely affect the fish and the fish-food organisms. The higher temperature enhance the solution of chemicals and the rate of bio-chemical reactions and this may prove fatal to different forms of life in the presence of detergents, algaecides, corrosion-inhibiters and low-level radioactive wastes discharged along with the condenser coolant.
The condenser cooling waters will be discharged into the fishing areas of the sea coast. The most treacherous aspect of radio-active pollution is that it can not be detected by physical senses of man such as sight, smell, taste, touch or hearing that is why any increase in radio-activity beyond the natural back-ground levels is considered harmful to man and international organizations insist on As Low As Reasonably Achievable (ALARA) does to man such low dose of radioactivity is possible only if the reactors are of the second generation such as Modular High Temperature Gas Cooled reactors which are inherently safe and are now planned to be set up in USA and USSR.
V. SOCIO-ECONOMIC COSTS OF ACCIENTS: According to US and British experts nuclear accidents will continue to follow the general sequence of wind-scale, Three-Mile-island and Chernobyl, the frequency of accidents being once in every 4 or 5 years. Even a partial release of the gaseous and volatile fraction of the core inventory according to a study conducted by the Brookhaven national laboratory in 1956 would produce 3400 deaths, 43,000 injuries and property damage of $7000 million (at 1956 prices) and contamination of land area the size of Maryland. It is said that people will die upto 15 miles and injured upto 45 miles away from the reactor. When this report was revised in 1965, the worst imaginable accident was reported to cause 45,000 deaths, 100,000 injuries and property damage of $17,000 million (at 1965 prices) According to a British study of 1973, the costs of damage due to an accident was estimate at 600 million pounds (at 1973 prices) After the Three-Mile-Island accident, the US Nuclear Regulatory Commission got a study made by the Sandia National Laboratories on the possible accident sequences for each of the 80 sites with different procedures. For the worst accident the damage cost was estimated at $314,000 million. The emergency evacuation must be implemented for 10 miles around the rector and may be extended upto about 50 miles in the sectors down-wind depending upon weather conditions. In the light of the high economic costs for accidents the US Government recently revised the compensation under the Price Anderson Act to be paid to victims of nuclear accidents to $7000 million from the earlier figure of $560 million. If the lives of Indians are considered to be as important as those of the Americans, the Union Government must enact a law similar to the Price –Anderson Act, with financial provision of Rs.10,000 crores to defray the costs of damage due to inevitable accidents in nuclear plants.
VI. RISK AND DISASTER MANAGEMENT DUE TO AN ACCIDENT: Since the State Governments have to save the lives of people and their properties and provide for emergency evacuation, rehabilitation and health care during accidents, they must be prepared to earmark at least Rs.5000 crores to be kept in deposit with the State Bank for emergency use. The State Government should not think that since it gets only ten percent power from the reactors in addition to its normal quota, they cannot undertake the burden of protecting the people and their properties due to accidents in reactors.
According to a recent British study on the socio-economic consequences of a 1100 MW plant accident at size-well, people will have to be evacuated upto 140 to 170 KM from the plant under the worst conditions. The costs of damage are estimated at Rs.6000 crores. If this scenario is extrapolated to the propose plant in Kovvada people upto 140 KM must be evacuated within a short-time to distant places. Places to be evacuated during an emergency due to an anticipated maximum credible accident in a Nuclear plant proposed at Kovvada in Srikakulam district,.
Since the first generation of reactors proposed in the Northern most part of AP state at Kovvada are inherently unsafe, they are bound to fail sometime or the other resulting in a catastrophe as had happened at Chernobyl in USSR. As per the standard practice followed in England to identify the impact of risks in case of the anticipated failure of the Size-Well B reactor on the assumption of a wind speed of 5 meters per second, a rainfall of one milli meter per hour and neutral stability conditions, the emergency evacuation of people should be completed within 6 hours for 2 to 5 km downwind from the plant, 12 hours for 5 to 25km; 24 hours for 25 to 75km and 48 hours beyond 75km distance from the proposed reactor plant (See figure)
Since the radio-active pollutants seriously pollute the lands, buildings and equipment, the people duly evacuated and rehabilitated in safer places, can return along with their cattle to their original homes in their native places only after one year upto 140km, after 5 years upto 115km, after 10years upto 98km and 20 years upto 77km distance from the nuclear plant under consideration. Depending upon the vagaries of the weather, some places may be more polluted than others.
Distance from Kovvada
Places that will be affected
30km
Srikakulam, Ponduru, Cheepurupalli, Bejjipuram, Bhogapuram, Kondada, Sriramnagar, Kumuli, Rellivalasa, Kongavanipalem, Nellimarla
40km
Bheemunipatnam, Vizianagaram, Garbham, Rajam, Amudalavalasa, Sreekakulam, Chittivalasa
50km
Uppada, Pandrangi, Jami, Gajapatinagaram, Palakonda, Narasannapeta,Kalingapatnam, Sankili, Padmanabham, Alamanda, Devepalli, Mandapalli, Terlam, Koduru
77km
Visakhapatnam, Gajuwaka, Sabbavaram, Andra, Pachipenta, Makkuva, Narsipuram, Kurupam, Tekkali, Hiramandalam, Pathapatnam, Parlakimidi, Jiyyanavalasa, Parvathipuram, Veeraghattam, Bobbili, Saluru, S.Kota,Anantagiri
115km
Mandasa, Gunupur, Anakapalli, Elamanchili, Kasimkota
140km
Nakkapalli, Machkund, Baruva, Sompeta,Rayagada, Koraput, Madugula, Narsipatnam, Chodavaram
170km
Tuni, Jeypore, Berhampur, Icchapuram
SITING CRITERIA:
i) According to Indian Siting criteria for Nuclear plants, villages and towns with more than 10,000 population shall not be present within 16km and 40km distance respectively from the proposed Nuclear plant site.
ii) According to American safety standards for selection of sites for Nuclear plants, population growth centers with more than 25,000 people shall not be present within 32km for a 600MW Nuclear Reactor and 51km for a 1300MW Nuclear plant.
WHY FRESH THINKING ON SITING THE REACTOR AT KOVVADA:
Dr.Alvin Weinberg, a long time supporter of Nuclear power has recently admitted that Rasmassens’ famours risk assessment did not take into account the social costs of Nuclear accidents. The Chernobyl accident proved that accidents are inevitable; nuclear hazard is somehow different from traffic accidents and the like; the notion of interdicting land with an unseen agent is now viewed by the public as particularly threatening. Dr.Weinberg admitted that it would be claiming too much to insist on the impossibility of an accident that breaches the containment vessel. “The chance of a meltdown in a US reactor by 2000 is estimated at one in 12. can reactors be designed for which probability of a serious accident is zero (i.e) a reactor whose safety depends not on the active intervention of safety systems but on the physical principles of its inability to fail? The Uranium fuel is automatically cooled in the inherently safe reactors known as “Modular High Temperature Gas Reactor” (MHTGR) and Process Inherent Ultimately Safe Reactor” (PIUS). Instead of planning for the conventional reactors, all the experts must concentrate their efforts on setting up these reactors as early as possible.
They can be processed only through public support. It must be justly stated that current conditional assurances on reactor safety exclude the possibility of human failure, sabotage, terrorist and enemy attacks. Hence Nuclear Safety has become a matter of faith. Since the claims of the proponents of Nuclear power failed to ensure absolute safety at many plants there is an urgent need for new strategies that provide additional and that too design independent margins of safety. Buffer zones provide one of the alternatives. They not only minimize the residual health risks from accidents but also eliminate the danger that a future change in public perception might demand for closure of the reactors on grounds of safety. In selecting even the reactors that are inherently safe if people are not taken into confidence the authorities will be simply gambling with public funds and lives of the people yet to be borne.
PUBLIC DEBATE NEEDED: In USA for instance, the decisions on safety aspects of reactor siting are made not on the basis of the enormous costs involved but only from the stand point of protection of public health and environment. In fact, the sponsors of the nuclear plants, incountries like USA and Japan hold public hearings before finalizing the most appropriate site among the different alternates for which environmental impact statements are prepared and circulated among people one month in advance of such a public debate. Unfortunately the atomic energy commission in India plays an apparently self contradictory dual role not only as the promoter of Atomic Energy but also as its regulator and thereby yields to expediency. Hence its views must be taken with a pinch of salt.
In a participatory democracy the people for whose benefit the energy is intended must have a say to determine which alternate sources of energy or which alternate locations for a reactor would be in the best interests of the nation. Intellectuals all over the world argue that what degree of nuclear risk can be tolerated by a society in relation to the alternate sources of energy and alternate locations for reactors is a political, socio-economic and a moral decision and such risk assessment is not just a technical matter to be decided by the nuclear scientists alone. Some environmental experts believe that while the application of ecologically sound principles ensures proper siting of the reactor as an asset to society, the wrong siting or choice of the reactor based upon purely economic considerations can often make the reactor a neutron bomb, at least in its damaging consequences during incredible accidents.
Under these circumstances, it is incumbent on the people of North Coastal Andhra to exercise their right to information and decision-making on the siting of nuclear power plants so that development takes place without destruction of human and natural resources. In the wake of Chernobyl disaster the Prime Minister has demanded for a public debate on the safety problems of Nuclear plants. Hence it is necessary that experts and general public discuss about the siting of the proposed Nuclear reactor in Andhra.
CONCLUSION: Under articles 48(A) and 51(A) of the constitution on environment both the citizens and the Government have duty to protect the environment of man. On a complaint from the citizens the Union Ministry of Environment can prohibit the siting of hazardous industries in the ecologically sensitive areas. The site selection committee for Nuclear plants might have not prepared the environmental impact analysis reports for making a comparative study of the costs and benefits for different sites. In countries like Japan and USA such reports are placed before the public for their constructive suggestions before a final decision is taken in the matter by the Government. Unfortunately neither the people nor the concerned environmental experts from the Universities are taken into confidence in India. In the present case, the request of the Government for a Nuclear power plant in Andhra and their demand for locating the same at Kovvada is not only suicidal but also violates the constitution. In the absence of statesmen like Tenneti Viswanadham people must work as the ears and eyes of democratic Government so that leaders would not unknowingly pledge the health and welfare of the present and future generations of people of coastal Andhra in a Faustian bargain and that too without holding a public debate on the advantages and disadvantages of Nuclear plants and their siting in different places. Since the accident scenario presents serious consequences to people of Srikakulam District in particular and to Indian Navy and industries at Visakhapatnam, a public debate must be held on this crucial project.
Extracted from the Web Site

Out of this discussion some general principles have arisen. These are summarized here:
Principle of No Absolutes. Nothing is absolutely ethical, only more or less ethical
Principle of No Acceptable Risk. There is no single “acceptable risk”: acceptability represents a judgement that the risk of a proposed activity is low enough in view of the expected net benefits.
Principle of No Free Lunch. Making one activity much safer than the others results in limited resources being unavailable to make less safe activities safer, thus reducing overall safety.
Principle of Alternatives and Consequences. To decide on the ethics of some proposal, one must compare it with available alternatives, examining the consequences of each.
Principle of Risk Optimization. Risks should be optimized for the public benefit, considering technical, economic and social factors,, but with an absolute limit to the allowable risk for any individual however great the benefit to society at large.
Principle that Good Intentions are not Good Enough. There is an ethical obligation to examine the issue thoroughly before reaching a conclusion.
Principle that Facts Matter. Sound judgements have to be based on properly established facts.
Principle of Quantification where Possible. An informed comparison of the alternatives requires quantification of the factors involved, where possible.
Principle of Anti-Semanticism. Energy sources should be chosen on their merits, not as a matter of semantic dogma.


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Tuesday, April 6, 2010

RISKS OF CHLORINE IN DCM PLANT, NEW DELHI



RISKS OF CHLORINE IN DCM PLANT, NEW DELHI

Prof.T.Shivaji Rao,
Director, Centre for Environmental Studies,
GITAM University,
Visakhapatnam-530045
CIVIL ORIGINAL JURISDICTION
CIVIL WRIT PETITION NO. 12739 OF 1985
M.C.Mehta … Petitioner
Versus
Union of India & Ors … Respondents.
AFFIDAVIT
I, M.C.Mehta, S/o Shri.Tirth Ram Mehta, R.o 3, Ring Road, Laj at Nagar-IV, New Delhi, do hereby affirm and declare as under:-
  1. That I am petitioner-in-person in above said case.
  2. That as per the direction of this Hon’ble Court, I am enclosing herewith a report of three experts (Annexure-I) who visited Chlorine Unit of M/s Shriram Foods and Fertilizers Ltd., Najafgarh, New Delhi on 9th December, 1985......................
Report On The Chlorine Unit Of M/S.Shriram Food And Fertilizers Industries Ltd., New Delhi
PREFACE
Annexure-I
As per the orders of the Supreme Court, and a request made by Shri.M.C.Mehta, the petitioner in Writ Petition No.12739 of 1985, we, the following members, namely,
1.Prof.T..Shivaji Rao
2. Dr.G.D.Agarwal
3. Mr.Prabir Purkaystha
Accompanied by Shri.M.C.Mehta have visited M/s Shriram Food and Fertilisers Industries Ltd. (Chlorine Unit), on Monday, the 9th December, 1985. The report of our visit including our analysis of the hazards to the people is presented here.
http://www.indiankanoon.org/doc/1599374/  [see pages 320 and 321]
I. INTRODUCTION
Thousands of tonnes of hazardous chemical substances are daily produced, transported, stored and used by industries in many countries. Some of these chemicals are highly toxic to human beings and their environment and the accidental release of even small amounts of such toxic substances into the atmosphere of a highly densely populated residential area or the working environment of industrial labour is bound to cause extremely serious consequences to public health and welfare. It would have been very ideal both for human environment and industrial economy, if such hazardous chemical accidents did not happen at all.
Unfortunately most of the accidents arise because something unforeseen occurs for which existing safety devices and procedures have not been designed. Apart from the uncertainty, one has to deal, therefore, with the management of surprise which are definition unpredictable. People may be exposed to toxic chemicals by an accidental release through an explosion in a factory for reasons like fire accidents, equipment failure or sabotage. Accidents are going to happen regardless of our efforts to prevent them.
Even when the most ideal emergency-response system is devised and alarm sirens given to alert the public of an impending chemical accidents, and instant evacuation of people is contemplated, the wind-speeds and directions may change so suddenly during the period that the disastrous consequences may be fall population at the most unexpected sports in the neighbourhood of the industry.
Having realized the inherent inadequacies in running the industries without spillover of toxic chemicals into residential areas, the USSR Government have shifted many industries from Moscow and they have made laws to provide protective health zones of 1km. distance around hazardous industries. Moreover they have provided green-belts of about 10km width in between industrial belts and residential areas in cities like Stalingrad and Perth (Australia).
A good look at the worst of all possible events could make a lot of differed between a disaster and our ability to anticipate such potential hazards and take timely preventive action by taking lessons from past experiences in industrial accidents relating to toxic chemicals as this comparatively new threat of gas leaks is growing day-by-day. Moreover, the toxic chemicals may affect not only the industrial workers, but also the general public by any one or more combination of routes, such as the air we breathe, the food we eat, the water we drink and the whole range of influences and materials in our living environment, producing a range of known or suspected health problems including carcinogenic, mutagenic and teratogenic effects on the present and future generations.
No two chemical accidents need be exactly the same because, by definition, an accident is an unplanned event. In particular, the environmental impact of an accident involving the sudden release of a toxic chemical due to an exploded tank or a ruptured pipeline is different from that of a normal emergency resulting from a traffic accident, fire or train derailment. Even though the vulnerable points are identified, adequate preventive and safety measures adopted and emergency-response plans are chalked-out and practiced, there remains the distinct possibility that an accident may occur at a place originally considered safe and it will trigger off a chain reaction whose potential impact including its multiplier effects on the production, distribution and storage of hazardous chemicals in the factory cannot be imagined and hence, our industrial managements must make continuous evaluation of their plants not only for replacement of inefficient and obsolete plant and machinery, but also for relocation of their most hazardous components in the light of their expansion programmes and potentially harmful effects on the growth of population in the industrial neighbourhoods.
II. OBSERVATIONS
Having gone through Manmohan Singh Committee Report (hereinafter called the Singh Report), the report of Dr.Slater and other documents and also after a visit to chlorine plant of M/s. Shriram Food Fertiliser Industry (SFFI), Najafgarh, the committee makes the following observations.
Comments on the chlorine plant:
The SFFI stores chlorine in three process tanks of 20MT each and one tank of 25MT. It has been stated that the use of two tanks of 100MT capacity has been discontinued as per the recommendations of the Singh Committee. It has also been stated that the danger to the public has been “minimized” after the discontinuance of the 100MT tanks. The danger which still exists to the population of North, West and Central Delhi will be discussed in quantitative terms below.
  1. Concentration of chlorine in the air above 25 parts per million (PPM) is defined by occupational safety and Health Authorities (OSHA), USA as Immediately Dangerous to Life and Health (IDLH). The IDLH level for Methyl Isocyanate (MIC) is 20 PPM as per OSHA. It may also be noted that chlorine was extensively used in the First World War as a poison gas.
  2. The impact of accidental release of chlorine from the industries on the adjoining area and population based on Standard Texts on Atmospheric Dispersion is presented as follows:
Table: Possible Short-term Peak Concentrations of chlorine (PPM) at different points under different wind speeds for a release of 5kg Chlorine/Sec (18 MT in one hour)
istance from source km
Natural Wind Stability
Extremely Stable Atmosphere
V=0.5
V=1.0
V=2.0
V=0.5
V=1.0
V=2.0
0.5
1636
818
409
5920
2960
1480
1.0
472
236
118
2226
1113
556
3.0
86
43
22
432
216
108
5.0
38
19
10
262
131
66
8.0
20
10
5
110
55
28
Note: i) Hazardous Level of Chlorine: 25 PPM (Immediately dangerous to life and health
i i) Instant Death Level of Chlorine: 1000PPM
As per the chlorine dispersion data of Singh Committee, if at any time the chlorine leakage takes place from the storage tanks, the effect on the surrounding community will be disastrous as the lethal dose is 1000 PPM and ‘FEW INHALATIONS CAN PROVE FATA’ (Page 47 of Singh Committee Report) It may be noted that the dispersion shown above is for the failure of the 20/25 MT tanks which have been allowed to be continued by the Singh Committee report or from pipe/valve rupture.
  1. Storage tank failure could occur in the following way:
a) Rupturing of the tank due to corrosion or stress induced failure.
b) Rupturing of valves and piping connected to the tank.
c) Fire in the area.
d) Enemy action, sabotage etc.
Any one of the above causes could lead to accidental release of 20 to 25 MT. The instantaneous release of chlorine vapour on the tank and vapourisation of the liquid chlorine, as chlorine has boiling point -34oC. The rate of chlorine release can be higher than that shown in the calculations of 20/25 MT release per hour.
  1. SFFI uses a method of spraying water and foam, on to liquid chlorine to neutralie spillage. They also have a dyke to contain the liquid chlorine. While this may have same effect if chlorine spillage is small, it will result in even more rapid vapourisation of chlorine in view of the exotheric reaction of chlorine and water. To quote from the Slater Report “the principle behind the design of the water deluge needs to be re-examined and some modeling performed to establish under what conditions, if any, it can help and the critical leak size above which it would exacerbate the consequences to the public by increasing the ‘boil-off rate’ (Slater Report P.3)
  2. Three of the 20 MT tanks are of 1949 vintage- they are 37 years old. The other 25 MT tank is also 21 years old. Without radiography and thickness survey of the above tanks, the safety margins of the tanks are not known. In view of the general level of maintenance SFFI as exemplified by the Oleum tank collapse, legitimate doubts exist regarding the safety in this facility.
  3. The danger to the population is directly proportional to the amount of chlorine stored in the container tanks. If 20 tonnes are stored in ½ tonne container, then the risk is less, as the failure of any container will release only half a tonne. If one 20/25 MT capacity tank is used, its failure releases 20/25 MT and thereby raises the concentration level of chlorine above the danger point for large sections of the people. The danger in SFFI lies in the size of the storage. Further, at any point, a number of cylinders are in the filling area, and this could be hazard in case of fire etc.
  4. The Manmohan Singh Committee had recommended that these 100MT tanks should not be used for storage (P.53). However, we understand that these tanks were used for storage till recently. There is no guarantee that even if designed as surge tanks, these may still not be used to store chlorine.
  5. The SFFI has a scrubbing system of MAXIMUM CAPACITY OF ONLY 4 MT /HR. While the maximum storage capacity was as large as 285 MT even the reduced storage of 60 to 85 MT allowed by the Singh Committee is far above the neutralizing capacity. Indeed the Singh Report states that, the scrubber system has ‘so far been used for neutralization upto 1.5 tonnes/hr’ only (P.8) In case an emergency like failure of tank, fire etc. takes place, the neutralsiation system cannot be used effectively to control the situation.
  6. A number of deficiencies exist with the scrubbing system. As the Singh Report makes clear (PP.37-38), the scrubber neutralizing system is designed for normal venting only and not for emergency discharges which would involve much larger gas flows. This is similar to the situation which obtained at Bhopal where due to fundamental inadequacy of the neutralizing system designed for normal discharges only, massive quantities of toxic gases escaped into the atmosphere. The result of such design practice is clear now to everybody. It is surprising that even after a disaster of such magnitude at Bhopal, this plant should be allowed to operate with such a small capacity of neutralizing system.
  7. A number of studies have shown that scrubbers designed for small leakages are not able to handle high discharges for the following reasons:
a) Two phase flow i.e. mixture of liquid and gas in case of major accidents. The scrubber designed for small leaks gets overwhelmed in such conditions.
b) Pressure of discharge is much higher than the pump head leading to non-flow of the scrubbing solution.
  1. Though the Singh Committee had suggested the modification f the scrubbing system, the committee observed that only inadequate marginal modifications have been made. The MAJOR TECHNICAL PARAMETERS OF THE SCRUBBER REMAIN THE SAME, NAMELY LOW NEUTRALISATION CAPACITY.
  2. Apart from the scrubber, there does not seem to be any major safety system in the plant. There are no provisions for water curtains or other arrangements to knock down the gas cloud or vapour.
  3. If any leakage develops in the chlorine storage tanks, the contents of the tank can only be transferred by siphoning action and not by pumping. Rapid evacuation of a leaking tank is not possible under such conditions (pp 24-25 of Singh Report)
  4. Continuous measurement of moisture in the tanks is a must in view of the danger of wet chlorine corroding the tanks. Currently intermittent sampling is used to keep track of the moisture content.
  5. The filling system of the 20/25 MT tanks is manual with a temperature switch as an indication of the prescribed level being crossed. No direct indications exist for overfilling which could lead to a hazard.
  6. Long piping systems with a number of joints pose an environmental hazard as undetected leaks can continue for long periods. Even during the plant visit on 9-12-1985 chlorine leakage was noticed from a flanged joint.
  7. SFFI has not so far implemented the recommendations of Singh Committee in respect of
a) constructing a shed over cylinder store area,
b) installing load cells and carrying out radiography of chlorine storage tanks,
c) modifications to control room
d) maintaining adequate pressure in fire-fighting systems and
e) provision of under-ground pit etc. etc.
As can be seen from the above, the plant is totally unsafe on the following counts:-
a) STORAGE OF LARGE VOLUMES OF CHLORINE UNDER PRESSURE.
b) UNDERSIZED NEUTRALISATIONSYSTEMS
c) PROXIMITY TO POPULATION CENTRES OF HIGH DENSITY
d) UNSAFE WORKING CONDITIONS AND PREVIOUS ACCIDENTS IN SFFI AS SEEN BY THE MASSIVE OLEUM LEAKAGE ON DECEMBER FOURTH.
III. DISCUSSIONS
Under the circumstances, it is pertinent to review the question of protection of public health and safety in the context of the crucial location of the industry and its potential for chemical accidents.
Question: Can a facility such as the chlorine-section of SFFI (providing around 120tpdof dry chlorine gas, liquefying it, supplying some 70 tpd to HIL converting a part of it into Hcl and another part into bleaching powder and filling 20-30 tpd in standard one tonne cylinders for sale to sundry customers) ever be made entirely safe for the community living around it (such as that living around SFFI)?
Answer: No, the reasoning being as follows:
a) Toxicity: The extremely high toxicity of chlorine needs no elaboration. It was invented as a war gas.
b) Storage: The greatest hazard is posed from large storage since they are under high pressure and often at low temperatures and any failure or significant leak results in release of large quantities within a short period. SFFI has 2 bullets of 100 MT capacity each and 5 of 20/25 MT capacity each on location, one stated to have been abandoned for some years. The stress of Manmohan Singh Report and of other recent arguments has been to avoid (or discontinue, as they say) the use of the tanks for storage and use them only “dump” or surge” tanks. We consider this infructuous and impractical since (i) In an industrial system like this production and consumption or utilization cannot be balanced most of the time and some balancing storage shall always be necessary. Thus, what if HIL operates only one shift a day or wants their total requirement of the day within a few hours? What if HIL stops functioning or there is a problem in pipe-line? Or there is a problem in pipe-line? Or there is a problem in Hcl unit or bleaching powder unit? Or if filled one-tonnersre not lifted due to bundh, a curfew or a transporter’s strike? There will always be a 101 reasons for imbalance and the surplus chlorine shallhave to be stored or “dumped” whatever one may call it.
ii) The very presence of these costly tanks is a proof of their need and once they are there, they will be full sometimes if not all the time. Experience indicates that in India all “Guard-ponds”, ‘buffer-tanks” etc. remain full all the time and generally, act as flow through units. Miss Bali’s impression that often all chlorine tanks at SFFI were full may not be far from truth and to us not far from expectation.
iii) Discontinuing the use of these tanks (2 Nos. 100MT capacity and 1 No.;20/25 MT cpacity) but retaining them as emergency “dump” tanks, as suggested in Manmohan Singh Committee Report shall lead to poor maintenance and loss of reliability of various systems on these tanks when an emergency really arises.
iv) With the operational requirements of one tank receiving chlorine, one tank delivering chlorine, and the third under evacuation, an average of 20 MT and a frequent peak of 35-40 MT shall be in storage at any time in the 3 Nos. 20/25MT bullets if the Singh Committee recommendations were fully implemented. To this may be added the 40-60 MT in one tonne in the filling yard. Even 20 MT is enough to cause a disaster in the location of SFFI.. And as discussed, storage annot be reduced even to this level,leave apart lower levels.
c) Pipe-lines, flanged-joints valves, pump-gaskets etc. The hazards due to a failure in these appears to have been under-estimated and under-stressed. Maintaiing such long, complex and jumbled systems in a leak-proof condition is IMPOSSIBLE. Some significant leaks are known to have taken placed and many more may have gave unnoticed. Unfavourable meteorological conditions combined with a significant leakmay any day result in the death of some unsuspecting passers-by on a cold winter-night, or children walking to school at dawn.
d) Safety devices and provisions: Most of thee are designed to protect healthy, knowledgeable and alert plant-workers against routine leaks and failures and shall rarely be effective in case of a significant failure or accident. Provision of oxygen masks or medical facilities can be of little help to persons falling victims outside the premises.
e) Meteorology : Often notions like chlorine gas is heavier than air and so can be contained by a few meters of AC/GC sheet curtain probably do mere damage than good. The density of chlorine is not much different than that of MIC, SO3 or SO2. The formation f clouds with fine droplets of the liquid entrained in the gas evaporating from release of liquids stored under pressure (as at Bhopal or recently at Delhi)and being swept by winds horizontally with almost no vertical dispersion could have (or would have) happened, with chlorine too. The occurrence of low-level inversions (as low as 30-40 m above GL)in Northern India and its’ affects on transport has neither been properly studied nor is understood. And one an never be too sure.
f) The only safe solution:: Whether one takes the Dr.Slater Report or the Manmohan Singh Committee Report, the ultimate gist is, and so is going to be the consensus of all people having even a rudimentary knowledge of the subject that a facility, like SFFI cannot be made SAFE at its present location. The only alternatives to being really SAFE are either relocate the factory with a minimum 10km green belt/buffer zone or to relocate the neighbouring communities to create such a green belt/buffer zone.
Question: At this stage one is likely to ask –Given a Unit like SFFI can never be made entirely SAFE for its present location in densely populated surroundings, can it be made atleast reasonably SAFE? Will a complete compliance of Singh Committee Report be not adequate for this?
Answer: No. The reasoning being as follows :-
i) Reasonably safe for what conditions? For normal steady-state operation conditions- Yes. SFFI (Whether on itself or under Government and public pressure) has already rigged up a system for such normal steady-state conditions. Singh Committee recommendations further help on it. If need be opinion of more experts (people with real experience in handling toxic and hazardous chemicals) can be sought to improve the system further. Even these improved facilities may not work under emergencies and upset conditions which are none too rare in India due to (i) frequent power tripplings (ii) extreme climate variations (iii) presence of all types and hues of extremists and anti-social elements all-around and most of all (iv) extremely poor equipment maintenance and credibility/reliability of operating personnel to act correctly on the spur of the moment. The last factor may be due to (a) stress and nervousness leading to confusion at moments of crisis, (b) poor training (c ) lack of commitment, dedication and involvement (do poor working conditions or (d) any other factors. But the fact is, that it is there and has been proved time and again by Bhopal, Delhi and Bombay gas leaks and even the frequent rail and road accidents. In facilities like SFFI poor maintenance of equipment and operations performance accentuated by (i) extremely poor and ineffective inspection and enforcement by Government agencies like Inspector of Factories, Labour Inspector, Pollution Control Board etc. (ii) a plethora of non-specific and often confusing rules and regulations and (iii) extremely poor industrial relations.
IV. CONCLUSION
Under so many uncertain factors, a chlorine manufacturing unit cannot be even reasonably safe when located in proximity to a densely populated area. Under the circumstances, the only practical solution is to re-locate the chlorine plant of SFFI so as to be at last 10km away from the urban limits of densely populated areas, with adequate safety measures.
Sd/- Sd/- Sd-
Dr. G.D.Agarwal Prof.T.Shivaji Rao P.Purkaystha.

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Born in 1932 at Mudinepalli, near Gudivada, Krishna Dist. Andhra Pradesh, received Bachelors degree in Civil Engg., from Viswesaraiah Engineering College, Banglore (1956) and Masters Degree in Environmental Engineering from Rice university, Houston, Texas, (USA) (1962), Ph.D (Hony). Former Head of the Department of Civil Engineering and principal of College of Engineering, Andhra university.Formerly Hony.Professor in Andhra University,Manonmanian Sundarnar University,JNT University. Fellow of the Institution of Engineers,India Recipient of the University Grants Commissions National Award "Swami Pranavananda Award on Ecology and Environmental Sciences" for the year 1991. Recipient of Sivananda Eminent Citizen Award for 2002 by Sanathana Dharma Charitable Trust, Andhra Pradesh state. Presently Working as Director, centre for Environmental Studies, GITAM University, http://www.geocities.com/prof_shivajirao/resume.html http://www.eoearth.org/contributor/Shivaji.rao