20 March 2012

Reply to Indian Prime Minister's interview published in "Science"

Mr. Bruce Alberts
1200 New York Avenue NW
Washington, DC 20005
United States of America
Phone: 001 202-326-6550
Fax: 001 202-289-7562, 001 202-371-9227

Dear Sir,

This is with reference to India's Prime Minister Dr. Manmohan Singh's interview published in the journal Science[1]We are writing this letter to set the record of history straight and also bring to light the serious safety related issues of Kudankulam Nuclear Power Project (KKNPP) which Dr. Singh has sought to brush aside in his interview.  Two weeks prior to Dr. Singh's interview in your journal, the Russian Ambassador in India Alexander A. Kadakin, made the following statement during a press conference:  "Considering that Haripur was geologically much worse than Kudankulam and the ground situation due to fishermen's movement and state government's stand, India had agreed to suggest new site for the nuclear plant.  'We are ready to build. Where it will be convenient, it is India's choice not Russian choice,' he said."[2]  Kudankulam faces a series of problems relating to the site and availability of fresh water which are summarized below:

Past Volcanism
According to a recent paper "the area in and around Kudankulam, where India's largest nuclear power complex is being built, has a unique geology. The terrain is transected by mafic bodies cutting into the granulite grade of metamorphic rocks. The mafic bodies intrude into the country rock as plugs, ...while they acquire the form of dyke swarm towards the east. Despite the noted occurrence and structural characteristics, their importance in understanding the upper continental characteristics in and around Kudankulam and the Gulf of Mannar (GoM-a deep water body in the Bay of Bengal located towards the east) has not yet received detailed attention."[3] Several papers featuring these anomalies have been published since 1987.[4],[5]A 2010 paper reports mantle upwelling and crustal thinning south of the Achankovil shear zone.  Ground Magnetic Survey conducted at Kudankulam also reveals extreme mantle upwelling to the extent of 200 meters.[6]  The same phenomenon has been observed in the Gulf of Mannar as well.[7]  Bhoominathan who studied KKNPP site observes:  "confirmatory geological and geotechnical investigations carried out after excavation of strata to the founding level at various sites for nuclear facilities show the presence of weaker zones which have not (been) identified in the original investigation.  Therefore geological and geotechnical investigations shall be well planned and executed by reputed agencies at the beginning stage of the investigation."[8]

Indications of tectonism under reactivation (Small Volume Volcanic Eruptions (SVVE))

Since 1998, there have been four rock-melt extrusion (RME) events within a radius of 60 km from the reactor site, all near electric poles.  After conducting microscopic, spectrographic and chemical analysis of the samples, three groups of scholars reported that these were of volcanic origin.[9], [10], [11]
(Similar events near electric poles in Assam (India)[12]and Tor Zawar (Pakistan)[13] have also been named as SVVE.)  NPCIL investigated these intrusions only after we expressed serious concern about them.[14]  More than a decade after the events, "a team of officers visited the RME sites.  Interaction with locals and physical inspection of the features indicated that they resulted due to the lightning and/or shorting of the high voltage current into the ground through the concrete pole."[15]

Victor Rajamanickam, a senior geologist who studied the RME events testifies: "when such is the tectonic structure of this area, the rock melt injections... are confirming the activities of neo-tectonic movements. Over and above the seismic tremors, tectonics in this region is also bringing a question of stability for the area. Large scale studies have already brought forward for Achankovil shear zone’s role in destabilising this block. Under such circumstances, before going for any major structure in Kudankulam, one has to ensure the tectonics of this block. It is lying on a lineament plane. So, it is a must to take up microlevel studies for confirming the tectonic stability of this landmass in the region before launching a major plant in Kudankulam."[16]

In short, the site and the region have experienced volcanism, there are indications that these are being activated.  According to the International Atomic Energy Agency (IAEA) "volcanic activity or igneous intrusions, such as dykes, may change groundwater flow patterns and cause fluctuations in the depth of the water table. Unexpected discharges of water and mud from the interior of volcano edifices …generate lahars that are attributed to the disturbance of the hydrothermal or groundwater system by volcanic intrusions. Magma intrusions also can trigger explosions in the hydrothermal system. Changes in the groundwater system may cause subsidence in karst terrains."[17]

Near Field Tsunami
The NPCIL insists that there is no possibility of a near zone tsunami for any of the coastal reactors in India.  Since 1975, several researchers have found undersea volcanoes and volcano vents in the Gulf of Mannar at about 100 kilometers from the Kudankulam site. Hedervari places this site as one that belongs to the "Indo-Australian seismic belt, the longest, seismically active zone in the world-ocean."[18]  Vestal and Lowrie found evidences of past landslides in the 90 km long East Comorin Slump and the 35 km-long Colombo Slump[19]  while Sastriet al[20] and Murtyet al[21] reported volcanic vents beneath them.  Petrographic studies in this area of GoM have revealed the presence of large scale clay stones, which make the occurrence of submarine landslides easier.[22] Earthquakes have occurred near these slumps in 1938 (5.8R) and in 1991 (5.2R).  An earthquake on the Indrani fault that extends into the GoM can cause a slope failure in these slumps.  According to Wijetunge, "massive slope failures of these slumps have the potential to cause destructive tsunamis."[23]

Unstable shoreline and sea water recession
Studies by Brucknur, Altrin Armstrong Sam and others show that this shore had remained unstable in the geological past.[24] During 1948-49, the southern part of erstwhile Dhanushkodi town (a patch of land of about half a km wide and seven km long in the Rameswaram island) facing GoM, had sunk by 5 meters and submerged in sea due to vertical tectonic movement.[25]

After the December 2004 tsunami, many events characterized by sea water recession occurred in the GoM coast. Though these events have been extensively reported in the media, no scientific study has been done so far.  During such episodes, the sea water intake for the reactors will be disrupted, leading to dry intake and damage to the reactor.  Each reactor at Kudankulam requires 83,000 liters of seawater every second for condenser cooling.  The United States Nuclear Regulatory Commission[26] mandates studies of paleo-tsunamis, the possible tsunamigenic factors in the near and far fields, issue of dry intake that may occur during tsunami or sea water recession and gives detailed guidelines for such studies near coastal reactors.
Not enough freshwater

Fresh water supply is the Achilles' heel of the Kudankulam project. According to the detailed project report of 1989, fresh water for industrial and domestic purposes was to be drawn from the Pechiparai reservoir, 65 km south-west of the site.  There was also a provision for storing 60,000 m3 of water at the campus.  In its sanction letter, the Atomic Energy Regulatory Board (AERB) wanted a backup pipeline from another reservoir.  The NPCIL did neither conduct any study on the assured availability of water in the reservoir, nor did they inform the people who have been using the water from the 120 year-old dam. According to a study, "the district had faced 52 years of drought and drought like situations during 1901-89. The run-off in the dam during 1963-90 was 15% to 37%t less than the expected average."[27]  Considering these and the agitation by farmers, NPCIL changed its plan and went for desalination plants for meeting the industrial and domestic needs. Even though India is considered to be a leader in seawater desalination, the plants based on multi-vapor compression technology were imported from Israel.  There are four desalination plants of which three will be online and one on reserve and the daily water production will be 7,600 m3 and the site's daily requirement is 6,936 m3. As reserves, there are twelve tanks with combined capacity of 11,445 m3.  Out of this, fire water reserve is 2,000 m3.  The site has a reserve for running two reactors for less than two days as against seven days of reserve promised in the project proposal.  According to AERB, "if the minimum water supply required for long term heat removal from the core cannot be ensured under all circumstances, then the site shall be deemed unsuitable. Availability of adequate quantity of water to maintain the reactor under safe shutdown state for at least thirty days needs to be ensured under all circumstances."[28]

In response to the criticism regarding the inadequacy of the reserve water, the NPCIL responded that "in the case of grid failure, the desalination plants and the reactors will be shut down." They have not factored the possibility of breakdown of the plants due to mechanical or zoological (jelly fish intrusion) reasons.

Limestone mining within the exclusion zone

A third of the 700 hectares of land acquired by the NPCIL for the nuclear project at Kudankulam was used for mining limestone by a cement industry during 1999-2005. This was allowed because of "the superior technology of the machine, (sic)" with which "collection of lime stone was done by surface scrapping only" and "they (the cement company) also carried out tree plantation in the areas."[29]  While the safety related structures at the Kudankulam project are just 2.5 meters above the anticipated flood level (5 meters MSL), several other buildings are at a lower elevation.  Intensive mining for seven years at a coastal nuclear site, with a thinned out crust (of 200 meters) is intriguing.

To sum up, the Kudankulam project has been built at a site without conducting the necessary geological, oceanographic and hydrological studies, ignoring the warnings from professional geologists.  The plant is illegal and violates the conditions and safety guidelines laid down by the national regulator and IAEA.  Attacking non-governmental organizations, the church or the Russian Ambassador is not a creative solution to a mega-misery and a trillion rupee disaster in the making. 

It is time the Prime Minister and his government woke up to the warning issued by the IAEA three years ago:  "Nuclear power generation does not occur in a vacuum. Exposure to the outside world can bring dangers such as hurricanes, earthquakes, fires, tsunamis and volcanoes.  With safety the first priority for nuclear plants, it is incumbent upon nuclear installation designers and builders to prepare for the worst that nature can bring to bear."[30]

Thanking you for giving us an opportunity to write to you,

Sincerely yours
R Ramesh, V Pugazhendi,  VT Padmanabhan

[1] Haripur in the state of West Bengal was proposed as a site for setting up 10 GW(e) nuclear power plants from Russia.  The proposal has been frozen due to opposition from the local communities and the State Government.

[1]  India's Scholar-Prime Minister Aims for Inclusive Development, Science, Volume 335 (6071), 24 February 2012, 907-908, http://www.sciencemag.org/content/335/6071/907.full
[2]  Anon., 2011, N-energy, military ties focus of Indian PM's Moscow visit,  Indo-Asian News Service,7 December, accessed from the website of Russian Embassy in Delhi, India, http://www.rusembassy.in/index.php?
[3]  Biju Longhinos, S. P. Anand and Mita Rajaram, 2010, Physical Geology of Subvolcanic Systems: Laccolith, Sills and Dykes, LASI 4 Conference, Moab and Mount Hillers, Utah, USA, 22-26 September 2010
[4] R. Ramaswamy, 1991, Occurrence of Soda-trachyte near Kudangulam village, Tamilnadu, Current Science, Vol. 61, 401- 402
[5] M.Ramasamy, 1993, The evidence of late Cenozoic volcano tectonic deformations in Kudangulam, near Cape Comarin, Tamilnadu, International Geological Correlation Programme
[6]  Biju Longhinos, S. P. Anand and Mita Rajaram, 2010, Physical Geology of Subvolcanic Systems: Laccolith, Sills and Dykes, LASI 4 Conference, Moab and Mount Hillers, Utah, USA, 22-26 September 2010
[7]  G.R.K. Murty, Y. Satyanarayana and T, Pradeep Kumar, 1994 Magnetic Profile across Gulf of Mannar,Journal Geological Society of India, Vol. 44 , 443-449
[8]  A. Boominathan, 2004, Seismic site characterization for nuclear structures and power plants, Current Science, Vol. 87, No. 10, 1388-97
[9]  R.Ramasamy, 2000, Molten Rock Extrusions, Journal of Geological Society of India, Vol.55,
[10]  G.Manimaran, P.Sivasubramaniyan and M.Senthiyappan, 2001, Rock Melt Extrusion at Abhishekappatti, Tirunelvelli district, Tamil Nadu-A Report, Journal of Geological Society of India, Vol.57,
[11]  G. Victor Rajamanickam and N.Chandrasekhar, 2000, Extrusion of Rockmelt in the vicinity of high tension electric line, Journal of Geological Society of India, Vol.55,
[12]  B J Saikia, G Parthasarathy, N C Sarmah and G D Baruah, 2008, Fourier–transform infrared spectroscopic characterization of naturally occurring glassy fulgurites,Bulletin of Material Sciences, Vol. 31(2), 155-158
[13] A. C. Kerr, M. Khan and I. McDonald, 2010, Eruption of basaltic magma at Tor Zawar, Balochistan, Pakistan on 27 January 2010: geochemical and petrological constraints on petrogenesis, Mineralogical Magazine, Vol. 74(6), 1027-1036
[14] Expert Group on Kudankulam Nuclear Power Project constituted by the Government of India, Supplementary Report on Safety of Kudankulam Nuclear Power Project  and Impact of Its Operations on Surroundings Report dated - 31 January 2012
[15] A Muthunayagam, et al, 2012, Expert Group on Kudankulam Nuclear Power Project constituted by the Government of India, Supplementary Report on Safety of Kudankulam Nuclear Power Project  and Impact of Its Operations on Surroundings, 31 January 2012

[16]  G.Victor Rajamanickam, Personal Communication to Prof.N.Markandan, 15 May, 2002

[17] International Atomic Energy Agency, 2011 Volcanic Hazards in Site Evaluation for Nuclear Installations, DS405 Draft Specific Safety Guide
[18]  P. Hedervari, 1978, Volcanism and Seismicity in the Indo-Australian Seismic Belt: Manifestations of Intraplate Tectonics, March 1978
[19]  William Vestal and Allen Lowrie, 1982, Large Scale Slumps Off Southern India and Sri Lanka, Geo-Marine Letters, Vol. 2, pp. 171-177
[20] V. V.Sastri, B. S. Venkatachala, B.S. and V. Narayanan, 1981, The evolution of East Coast India, Palaeogeography, Palaeoclimatology, Palaeoecology, Vol. 36 (1-2), pp 23-54
[21] G. R. K Murty, Y Satyanarayana and T Pradeep Kumar, 1994, Magnetic Profile Across Gulf of Mannar,Journal of Geological Society of India, Vol.44, 443-449
[22] N. A.Eremenko and A. Gagelganz, 1966. New data on the tectonic framework of the New Indian Peninsula, Bulletin of the Oil and Natural Gas Commission, Vol. 3(2), 1-3 
[23] Janaka Wijetunge, 2010, Assessment of Potential tsunamigenic seismic hazard to Sri Lanka, International Journal of Disaster Resilience in the Built Environment, Vol 1(2), 207-220
[24] H. Bruckner, 1989, Late Quaternary shorelines in India; In: Late Quaternary sea-level correlation and application; (eds) D. B. Scott, P. A. Pirazzoli and C. A. Honig, Dordrecht, 169–194
[25] G.G. Vaz, M. Hariprasad, B.R. Rao, V. SubbaRao, 2007, Subsidence of southern part of erstwhile Dhanushkodi township, Tamil Nadu - Evidences from bathymetry, side scan and underwater videography, Current Science, Vol. 92(5), 671-672
[26] Rajiv Prasad, 2009, Tsunami Hazard Assessment at Nuclear Power Plant Sites in the United States of America -  Final Report, United States Nuclear Regularty Commission
[27] R Ramesh,  2006, KKNPP and the Pechiparai Reservoir of Kanyakumari District”, Paper submitted to the Ministry of Environment and Forest, Government of India
[28]  AERB, 2005, Code of Practice on Safety in Nuclear Power Plant Siting, http://www.aerb.gov.in/T/documents/regprocess.pdf

[29]  A Muthunayagam et al, 2012, Expert Group on Kudankulam Nuclear Power Project constituted by the Government of India, Supplementary Report on Safety of Kudankulam Nuclear Power Project  and Impact of Its Operations on Surroundings, 31 January
[30]  International Atomic Energy Agency, 2011, Volcanic Hazards in Site Evaluation for Nuclear Installations, DS405 Draft Specific Safety Guide,  54, 74, 75

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