People's Democracy

(Weekly Organ of the Communist Party of India (Marxist)


No. 25

June 20, 2010



Need for Bonafide Scientific

Cost Benefit Assessment

Vivek Monteiro


THE proposed 10,000 MW nuclear power park at Madban, situated near the port of Jaitapur in the southern part of Ratnagiri district of Maharashtra would, if constructed, be the largest single location nuclear power project in the world. The project is based on the import of 6 nuclear power plants each of 1650 MW capacity from AREVA, a French company. In the first phase, two plants are to be built between 2012 and 2017. The plant when constructed would be operated by the Nuclear Power Corporation of India Ltd. (NPCIL), an undertaking of the Department of Atomic Energy (DAE).


A necessary precondition for a nuclear project of this magnitude, would be a detailed scientific study of potential risks and hazards and a rigorous cost benefit analysis based on these scientific studies. The first question that arises in regard to the Jaitapur Nuclear Power Project (JNPP) therefore is,  “Has a rigorous and scientific  environment impact assessment and cost benefit analysis been performed for this project”?


The task of performing the Environmental Impact Assessment for the JNPP was assigned to the National Environmental Engineering Research Institute (NEERI). NEERI has submitted a 1200 page EIA Report, filled with tables, charts and diagrams. This voluminous collection might at first sight impress an uninformed or an uncritical observer. But if one goes beyond first impressions to actually examine the contents, a different picture emerges.


A scientific study does not mean a mass of technical reports filled with technical jargon. Mere technical detail can also obfuscate, especially if technical jargon is used to avoid addressing the important issues.  A typical example of unscientific techno-obfuscation is on record in the manner in which the Enron project received sanction.  The debacle that resulted was the direct consequence of  a corporate-political nexus succeeding in preventing a scientific techno-economic scrutiny of the project. The Enron debacle  resulted in losses to the nation of tens of thousands of crores of rupees (which are hidden in the NPAs of Indian banks, and government subsidies, which are still being given.) In the case of the JNPP, the consequences of avoiding a scientific scrutiny would be immeasurably more severe and serious.



As soon as the EIA became available, about a month prior to the public hearing on May 16, 2010, the Indian School of Social Sciences, Mumbai set up a study group consisting of Dr Vivek Monteiro, Professor S  Ranade, Adwait Pednekar, Mangesh Chavan, Tejal Kanitkar, Dr Sudhir Paranjpe, Dr T Jayaraman, Dr M C Arunan, Professor P K Dasgupta, to analyse the 1200 page document. A 100 page written submission was prepared  by this team and submitted to the Maharashtra Pollution Control Board (MPCB) prior to the public hearing on behalf of three organisations: Indian School of Social Sciences, Lok Vignyan Sangathana and the Mumbai Shramik Sangh (CITU).


The main conclusion of this study was communicated to the MPCB without mincing any words:


“Prima facie the NEERI EIA study is a disgraceful unscientific exercise in the name of science. Unfortunately since NEERI is a CSIR institution, the EIA becomes a blot on the face of Indian science…. Throughout the voluminous report it is hard to find a single observation of negative impact of the project on any parameter.  The NEERI study is supposed to be a scientific study of the  environmental and safety issues and a scientific assessment of the risks and potential hazards of the JNPP. Reading the report and its summary conclusions, one feels ashamed and appalled to see what is going on in the name of science in India. The report reads  as if it were written by the Public Relations department of NPCIL or Areva. This is necessary and sufficient reason to reject the entire report.”


The Indian School's written submission began by identifying what ought to have been the main concern of the EIA-


“The accident at Chernobyl released into the atmosphere an amount of radioactivity equivalent to 400 bombs of the Hiroshima variety. The Nuclear Power Project of Jaitapur is about 10 times the size of the Chernobyl Power Plant. The huge radioactive accumulations at the plant site are the principal causes of concern which must be addressed.”


On this principal concern, it is soon obvious that NEERI does not have the competence to assess the project. On all matters relating to radioactivity, the NEERI repeatedly only asserts that the project meets AERB (Atomic Energy Regulatory Board) norms and standards without conducting an independent assessment. It is clear that on nuclear matters, the NEERI is relying completely on the AERB. The AERB reports however,  if they exist, are not part of the EIA.


Despite the professed incompetence of NEERI to assess radioactive risk, it does not hesitate to certify the safety of the plant in the following manner:


“Through individual event sequence analysis for different initiating events, it is estimated that the plant is provided adequate safety features and measures to mitigate or minimise any unsafe consequences”.



But elsewhere in the document a startling admission is made which shows that the above certification is premature and unjustified. Discussing the probabilistic safety assessment studies for the plant, the EIA states:


“All the above scenarios explained, namely Design Basis Accidents (DBAs) and Beyond Design Basis Accidents (BDBAs) are thoroughly studied and detailed reports are generated as Preliminary Safety Analysis Reports (PSAR) and these reports will be submitted to Atomic Energy Regulatory Board (AERB) for review and approval for construction of Nuclear Power project at Jaitapur.” (Emphasis added - Ed)


The plain meaning of the above statement (which is made twice in the EIA) is that the safety approval by the AERB is yet to be obtained. Instead of pointing this out as a lacuna, as would have been expected in a critical scientific study, the NEERI does not hesitate to certify the adequacy of the safety of the plant against “any unsafe consequences”.




Because of the size of the project, after a few years of operation the radioactive equivalent of several thousand Hiroshima bombs would have accumulated at Madban. If an ‘initiating event’ occurred which resulted in the release of even part of this accumulation of radioactivity, the consequences would be correspondingly more severe than those of the Chernobyl accident. The Chernobyl accident resulted in an exclusion zone of minimum radius of 30 km (more than double this in certain directions) where agriculture has been destroyed for the foreseeable future. The total area of agricultural land permanently destroyed in Ukraine and Belarus as a result of the Chernobyl is estimated at more than 100,000 square kilometers. For the Madban JNPP, an initiating event which leads to release from spent fuel accumulation, could result in an exclusion zone of more than 100 kilometres radius. This would result in radioactive contamination and irreversible long term destruction of agriculture in the districts of  Western Maharashtra, particularly Kohlapur, Sangli, Satara, Sindhudurg, Ratnagiri, and parts of Pune district, Karnataka and Goa.

The Indian School written submission submitted documents pertaining to an essentially identical  plant being constructed by AREVA in the UK in which it is specifically admitted that the EPR plant design does not include protection against certain kinds of ‘initiating events’, namely “initiating events due to intentional maloperation or sabotage, or  malicious events like intentional aircraft crash”.




The written submission included documents which established that after the 9/11 terrorist attack in the USA, the risk arising out of ‘malicious events’ is estimated as much higher than the risk of accidents. In fact the threat of terrorist attack on nuclear power plants is considered by US authorities as  both credible and substantial. The complete text of a recent (2009) report presented to the US Congress: on “Nuclear Power Plant Security and Vulnerabilities” was included as an annexure.


That the threat of terrorist attack on nuclear plants in India is also considered credible is clear from the specific exclusion in clause 5 (ii) in the proposed Civil Liability for Nuclear Damage Bill (2010) which has been tabled in parliament:


“An operator shall not be liable for any nuclear damage where such damage is caused by a nuclear incident directly due to – an act of armed conflict, hostility, civil war, insurrection or terrorism”


The NEERI EIA is completely in the dark as regards the crucial issue of risk arising out of malicious intent which is considered so substantial in the USA that amendments have been made in US law to require nuclear plant design to address this risk. (In the Civil Nuclear Liability Bill, the risk is addressed in exactly the opposite direction). The same studies cited above also point out that the radioactive release arising out of malicious events is likely to be much higher than that due to nuclear accidents.


A chapter in the Indian School submission deals with the issue of high level nuclear waste, which will accumulate on the site. It is pointed out that NEERI’s satisfaction with the NPCIL claim of safe storage for 100 years is completely misplaced, as 100 years is less than one per cent of the  lethality lifetime of the spent fuel. What will happen to the waste after 100 years is an unaddressed question, as India does not have a geological repository for nuclear waste and there are no sites in India suitable for building one.


Another huge lacuna in the EIA is the absence of a specific plan for decommissioning, without which no new plant can be built in Europe or the USA.


The above issues arising out of spent fuel accumulation and decommissioning will be dealt with in more detail in a subsequent article.




On the issue of cost of power from the JNPP, the Indian School study squarely challenges the claim of the NPCIL, uncritically accepted by the  NEERI EIA,  that the power would be ‘competitive’ as compared to coal based power. Pointing out that the cost of the Areva plant has not been disclosed by the NPCIL despite specific queries, the Indian School study argued from available information that the JNPP plant capital cost appeared to be in the vicinity of Rs 18.5 crore per MW, which was comparable to Areva plant costs in Finland. Based on this capital cost the levelised tariff for the first ten years of JNPP would be in excess of Rs 9 per unit, to which would have to be added costs of managing radioactive waste and decommissioning. It was pointed out that at such a high cost, several alternatives are available which would be safer and have smaller carbon footprint than the JNPP. It was also pointed out that this power was even more expensive than Enron power, and that what Enron had showed was that high cost power is not viable as baseload power.




At the public hearing at Madban on the May 16, 2010, the NPCIL, NEERI, MPCB and state government authorities had to face determined resistance. Slogan shouting local farmers and fisherfolk protested the high handed and undemocratic actions of the state government. Women turned out in large numbers. The local MLA, Rajan Salvi, publicly announced the opposition of his constituency to the project. Dr Bhikaji  Waghdare challenged the procedure of the public hearing. Dr Vivek Bhide emphasised the need for a cumulative environmental impact assessment including additional 21,000 MW of  thermal power projects coming up on the Konkan coast. Dr Vivek Monteiro raised the issues relating to nuclear waste and costs. Arun Velaskar of Konkan Bachao Samiti raised the issue of the Civil Nuclear Liability Bill. The cocky tone of the NPCIL spokesman at the beginning of the public hearing had vanished by the end of the hearing.


At the meeting of the Maharashtra state committee of the CPI(M) held on the June 8, 2010 at Pune, a note on the JNPP was discussed. It was decided to conduct a mass education campaign involving Kisan Sabha, trade union, student and other mass organisations for which literature would be produced. The mass campaign would also try to reach the large number of Mumbai residents who hail from the Konkan.


On June 9, a delegation from Maharashtra met the minister of environment and forests, Jairam Ramesh. The minister assured the delegation that the Expert Appraisal Committee of the MoEF would give a hearing to organisations in the presence of the NEERI and NPCIL. He also agreed to the demand for conducting a cumulative environmental impact assessment for projects in the Sindhudurg and Ratnagiri district. The delegation also met CPI(M) Polit Bureau member M K Pandhe and Dr Bhalchandra Mungekar, MP,  on the same day to discuss the issues.


The issues arising out of the proposed Jaitapur Nuclear Power Project are extremely serious and grave. It is clear that the NEERI EIA is untenable, which means that as of now an independent scientific assessment of the project has not been performed. It would be extremely foolhardy and irresponsible to proceed with the project in the absence of a bona fide scientific cost benefit analysis. The task before democratic and patriotic people in India is to ensure that such a scientific assessment is performed without delay and that the project is put on hold till the major issues are brought upfront on the agenda and satisfactorily addressed.