The Honorable Vice President of India
6, Maulana Azad Road,
New Delhi – 110 011
Dated 21st May, 2019
Greetings from Sagar, Western Ghats, Karnataka.
This has reference to a statement attributed to you while addressing the scientists and staff of the Atomic Minerals Directorate for Exploration and Research (AMD) recently (May 2019) at Hyderabad on the occasion of 70 years of exploration and research by the organisation, wherein you were reported to have underlined the importance of nuclear energy in the context of climate change, which was one of the foremost environmental concerns.
Nuclear power can reduce greenhouse gases
In this context, may I draw your kind attention to some of the harsh realities w.r.t nuclear power in the context of Climate Change? There have been a number of credible studies from different parts of the world to analyse whether nuclear power can be a suitable technology in order to minimize carbon di-oxide (CO2) emissions. The nuclear power has also come to be known as the costliest and riskiest of all the sources of electricity in recent decades, especially after two major nuclear reactor disasters at Chernobyl and Fukushima. It is most certainly so in the case of India, which is facing multiple crises due to the vast population base, which is still growing, and due to fast dwindling natural resources.
Kindly permit me to elaborate further on this crucial issue as in few paragraphs below, because of the larger ramifications.
1. Although the nuclear power plants are generally not associated with any carbon di-oxide (CO2) emissions during their normal operation, the life cycle CO2 emissions (which are linked to the numerous stages from nuclear ore mining till the spent nuclear fuels/wastes are safely disposed of after thousands of years) are recognized as considerable.
2. The energy related costs of keeping the spent nuclear fuel safe for hundreds of years, if not for thousands of years, also cannot be inconsiderable and can be seen as unjust burden on the future generations, because all the associated benefits of nuclear power, however meager they may be, would have come to the present generation alone. Taking all these direct and indirect costs and CO2 emissions into objective account the nuclear power technology has been ranked by credible analysis as one of the least beneficial and the costliest among various sources of electricity.
Economics of the processes
3. Nuclear power is considered as probably the most expensive ways to reduce the CO2 emissions. Also, in terms of cost-effectiveness in reducing CO2 emissions, nuclear power fairs very poorly. It is reported that in 1995, after a year-long, exhaustive review of the case for nuclear power, the UK Government concluded that nuclear power is one of the least cost-effective ways in which to cut CO2 emissions. In the US, improving electricity efficiency is considered to be nearly seven times more cost effective than nuclear power for obtaining emissions reductions.
4. In a press release on May 8, 2005, the NGO, Friends of the Earth, had issued few interesting facts. It referred to a study of the CO2 abatement options, in order of cost-effectiveness, in which the nuclear power technology was ranked as 16th out of 17 options studied. The nuclear wastes are piling up in huge quantities, as there are no proven strategies exist for the permanent safe storage of nuclear waste. Producing long-lived radioactive wastes, with no solution for their disposal, leaving a deadly legacy for many future generations to come is contrary to the principle of sustainability, and will be sheer injustice to the future generations, who have to bear all the future costs/risks. Since nuclear power is also known to be uneconomic, unsustainable and unsafe, the very concept of viewing it as a green source of energy should be viewed as irrational.
5. An ELSEVIER paper on energy policy under the title “Valuing the greenhouse gas emissions from nuclear power: A critical survey” by Benjamin K. Sovacool, June 2008, has screened 103 lifecycle studies of greenhouse gas-equivalent emissions for nuclear power plants, and on the basis of which he concludes: “The first conclusion is that the mean value of emissions over the course of the lifetime of a nuclear reactor (reported from qualified studies) is 66 grams of CO2 equivalent per kWh of electricity produced, due to reliance on existing fossil-fuel infrastructure for plant construction, decommissioning, and fuel processing along with the energy intensity of uranium mining and enrichment. Thus, nuclear energy is in no way ‘‘carbon free’’ or ‘‘emissions free,’’ even though it is much better (from purely a carbon-equivalent emissions standpoint) than coal, oil, and natural gas electricity generators, but worse than renewable and small scale distributed generators.”
6. The logistical/physical impossibility of constructing adequate number of nuclear power plants to be able to make any substantial impact on global GHG emissions level can be observed through few revealing facts.
7. One global estimate indicates that in order to have any discernible benefit from the Climate Change perspective, nuclear power capacity needs to be about 33% of the total installed power capacity at the global level. This estimate also indicates that in order to achieve such a capacity about 2,500 nuclear reactors of average capacity of 1,000 MW would be required, and nearly four new reactors would have to begin construction each month until 2075. If nuclear power were to play more than a marginal role in combating global warming then some nuclear-power reactors would have to be operated even in those countries, where there is no nuclear power as of now. Looking at the past experience of the increasing public opposition, the safety issues, and the threat of nuclear terrorism etc. such a huge addition of installed capacity is impossible. Since India’s nuclear power capacity is unlikely to reach even 2 % of the total power capacity in the foreseeable future, the rationality of even considering the Climate Change perspective of nuclear power should come under diligent scrutiny.
8. As per a less known Department of Atomic Energy (DAE) document of 2008 “A Strategy for the Growth of Electricity in India”, the plan was to increase the nuclear power capacity in the country to about 275,000 MW by 2050. Even if we were to consider this highly unrealistic plan, it will require about 390 nuclear reactors of average capacity of 700 MW. The enormity of the task of constructing 368 additional reactors (excluding the no. of reactors we already have) in the next 31 years should become evident when we compare the fact that only 22 nuclear reactors, which are in operation, were constructed in duration of about 50 years. Keeping in view the enormous quantities of water required for these reactors it is most likely that the future reactors will have to be located very close to the sea coast to make use of sea water. Even assuming that 4 reactors of 700 MW of capacity each will form a single nuclear project, the country’s 6,000 kM coastline on the mainland will have to be dotted with a nuclear power project at every 60 kM. Though this stupendously ambitious plan (may mean adding on an average 8,000 MW of nuclear power capacity every year during the next 3 decades) sound hilarious to say the least, looking at what has been achieved in the last 50 years, it should be a matter of grave concern to our society because it indicates the determination of DAE to seek huge budgetary support to try and expand nuclear power capacity exponentially, and the potential for the denial of adequate financial resources to develop renewable energy sources which are the sustainable sources.
9. Allowing for an average of 1.5 sq. kM area around each reactor as safety zone, 390 reactors may require a minimum of about 585 sq. KM area as a whole in addition to the vast stretches of land for dedicated transmission lines, and the associated mining/milling operations. The affordability of diverting such a vast land area for nuclear power sector in a densely populated country should be another matter of concern requiring diligent approach. The integrated energy policy of the erstwhile Planning Commission had clearly mentioned that the Uranium reserve in the country can support only about 10,000 MW of nuclear power, which goes to indicate that the country ahs to rely on imported technology and fuel for the kind of targets DAE has. The implications of energy security and foreign exchange outflow associated with such imports cannot be ignored. In this context, the very policy of DAE to plan for additional nuclear reactors must be satisfactorily explained to the public.
Conundrum of Energy Return on Energy Investment
10. In most scenarios, the total amount of energy consumed in setting up a nuclear reactor, and then in the safe disposal of nuclear wastes can be more than the total amount of energy that reactor can generate during its life cycle. For low-grade ores (less than about 0.01-0.02% U3O8, i.e. 10-20 times less concentrated than the high-grade ores), it is estimated that the fossil energy consumption in mining, milling and enrichment becomes so large that nuclear power emits more CO2 than an equivalent gas-fired power station. Furthermore, the quantity of known uranium reserves with ore grades richer than this critical level is very limited. These high-grade reserves are projected to last only about 19 years. This is hardly sufficient for a sustainable substitute for coal or any other energy source.
11. An article published in Australasian Science, July 2005, under the title “Can nuclear energy reduce CO2 emissions?” by Mark Diesendorf has highlighted many of these associated concerns. It says: “Nuclear power stations themselves do not emit CO2. But most of the energy inputs to the full life cycle of nuclear fuel come from fossil fuels and so are responsible for CO2 emissions. The nuclear fuel cycle is a complex process with the following steps, some of which are large energy users:” The article has listed many steps including: mining and milling to produce an oxide of uranium known as ‘yellow-cake’, U3O8; enrichment to increase the concentration of the isotope U-235; fuel fabrication; power station construction; operation and maintenance of power station; interim storage of spent fuel; long-term waste management (which only exists in theory); and power station decommissioning (which has never been done for a large nuclear power station).
12. The serious lacuna in the unsubstantiated argument of nuclear power advocates can be noticed in the Environmental Impact Assessment (EIA) study prepared for DAE in the case of a project proposal for the expansion of Kaiga nuclear project capacity, in Karnataka. Whereas this EIA has made a poor attempt to say that the additional power from the project will help in our efforts in the Climate Change efforts, it has conveniently ignored the considerable CO2 emissions associated with various processes of nuclear ore mining, milling, fuel rods, construction, transportation, spent fuel disposal after thousands of years etc. In the case of Kaiga NPP, the destruction of more than 54 Hectares of thick tropical forest land will result in not only the perpetual loss of a highly effective carbon sink but also will lead to CO2emissions when the forests are destroyed to set up the reactors. Hence, the total CO2 emission to the atmosphere in such a scenario will be many times more due to the destruction of natural carbon sink.
13. The negative impact on CO2 relevance from a nuclear power plant can be similarly judged from the potential destruction of hundreds of hectares of thick tropical forest and other types of vegetation in the proposal to set up the world’s largest nuclear power plant at Jaitapur on the coast of Maharastra.
India’s scenario and safety aspects
14. In order to make any substantial impact in the context of India’s total GHG emissions, the nuclear power capacity in India has to contribute to at least about 30-33% of the total electricity production. As on 18.3.2019, India had 6,780 MW of nuclear power capacity out of the total electricity generating capacity of 350,162 MW, which makes nuclear power capacity only 1.9% of the total capacity. In the Indian scenario, the renewable energy sources, which are considered as the greenest of the energy sources, have already reached the total installed capacity level of 74,082 MW, and which is 21.2% of the total capacity, and is exclusive of hydro power capacity, which also is generally considered as renewable and green. Even assuming all the proposed reactors are commissioned by 2030, the nuclear power capacity as a percentage of total electricity capacity at the national level cannot be much more than 1%. Looking at the past experience of Indian nuclear reactors getting commissioned within the budgeted cost & time, it seems unlikely that the nuclear power capacity in the country will be even 1% of the total capacity by 2030.
15. In this context, well considered opinion pieces from two nuclear energy regulatory authorities (now retired) on the relevance of nuclear power to the global community can be seen as credible enough not to need much more elaboration. The first one is from one of our own regulators, Dr. A Gopalkrishnan, former Chairperson of the Atomic Energy Regulatory Board (AERB). He says: “Japan (which could not prevent the Fukushima disaster) is a country that has a superb disaster management organisation throughout their nation, and an often rehearsed working team to handle such emergencies. In contrast, in India, we are most disorganised and unprepared for the handling of emergencies of any kind of even much less severity. The Atomic Energy Regulatory Board’s (AERB’s) disaster preparedness oversight is mostly on paper and the drills they once in a while conduct are half-hearted efforts which amount more to a sham.” He has recommended that the nuclear power policy of the government should be thoroughly debated in parliament and openly discussed with energy specialists in the country. “It should be preceded by a re-look of the overall energy policy of our country to assess whether all viable non-nuclear electricity generation schemes have been given their due priority, before we jump-start an extensive nuclear power programme.”
16. The second such opinion is from Gregory Jaczko, who served on the Nuclear Regulatory Commission of US from 2005 to 2009, and as its chairman from 2009 to 2012. In an article, as in the link below, he clearly states that “The danger from climate change no longer outweighs the risks of nuclear accidents”. It is very crucial to note what Gregory Jaczko has said about Japan’s effort in minimizing its GHG emissions. “Would shutting down plants all over the world lead to similar results? Eight years after Fukushima, that question has been answered. Fewer than 10 of Japan’s 50 reactors have resumed operations, yet the country’s carbon emissions have dropped below their levels before the accident. How? Japan has made significant gains in energy efficiency and solar power. It turns out that relying on nuclear energy is actually a bad strategy for combating climate change: One accident wiped out Japan’s carbon gains. Only a turn to renewables and conservation brought the country back on target.”
I oversaw the U.S. nuclear power industry. Now I think it should be banned.
17. Two assumptions made by pro-nuclear advocates in the context of Climate Change are fundamentally flawed. One is that Global Warming can be contained without fundamentally changing the Western pattern of energy consumption; because nuclear energy is a tiny contributor to energy mix worldwide (hence has no discernible impact on Global Warming). It is generally considered to be impossible to contain Global Warming, through a particular power generation technology alone, without significantly reducing the energy consumption levels of Western / developed countries. The second flawed assumption is that adoption of nuclear power can make sense as a strategy to lower aggregate carbon emissions. In this regard an example of Japan, a pro-nuclear energy country can be given. As Jinzaburo Takagi, a Japanese nuclear Chemist, has showed, from 1965 to 1995 Japan’s nuclear power plant capacity went from zero to over 40,000 MW. During the same period its CO2 emissions increased from about 400 million tons to about 1,200 million tons. Increased use of nuclear power did not really reduce Japan’s emission levels
18. The risks and the true overall costs to our communities are so high, that the nuclear power is not considered essential at all in Germany, where the decision has been taken to shutter all the operating nuclear reactors by 2022, and in France, which gets about 80 percent of its electricity from nuclear power, has proposed reducing that figure to 50 percent by 2035, because safety could not be guaranteed. Trying to make accidents unlikely wasn’t enough.
19. Whereas these discussions should suffice to conclude that the nuclear power is not green in true sense, and that its relevance in addressing the concerns of Climate Change is at best credibly questionable. The other concerns on nuclear power are the enormous capital cost, long gestation periods, safety issues, credible risks of nuclear accidents, disaster preparedness, long term storage costs, inter-generational concerns, much benign options available to our society etc. can also become clear in various reports/discussions as in the references listed towards the end of this representation.
20. From the above discussions it should become clear that the nation as a whole, do not require nuclear power either for reducing the total CO2 emissions from the energy sector or for its sustainable development; that the risks and cost of nuclear power are unacceptably high and are increasing all the time; and that there are very many benign alternatives to meet the legitimate demand for electricity of the country on a sustainable basis. In view of the multifarious problems associated with nuclear power plants and its tiny contribution to the overall power scenario in India even by 2030, and in view of credible concerns by very responsible leaders, our society should thoroughly review whether the resources made available for nuclear power sector is well spent on other suitable alternatives, such as developing the new & renewable energy sources, which can eliminate all the thorny issues associated with nuclear power sector and provide reliable and sustainable electricity for the future.
From the civil society perspective, it is a matter of increasingly worrisome governance scenario that despite repeated representations and growing popular opposition, the enormously risky and costly nuclear power plants are being thrust on our communities, against all wisdom. In this context, may I request you to prevail upon DAE/AEC to thoroughly examine all the associated issues of nuclear power from Indian context, and satisfactorily explain to the people of this country how nuclear power is relevant from India’s overall welfare perspective.
May I also request that the Comptroller and Auditor General of India be advised to conduct a diligent auditing of all the associated costs, decision making processes, and risks involved in the procurement of nuclear reactors not only of imported technology but also of the indigenous technology? A detailed auditing of the performance of the already commissioned reactors in comparison to the original targets set for each of them will also reveal the true relevance of nuclear reactors to India’s developmental perspective.
A welfare oriented society like India, should not continue to ignore the ongoing and serious concerns such as the poor performance of Russian supplied nuclear reactors at Kudankulam NPP in Tamil Nadu, as in three such media reports below.
Doubt persists in Kudankulam nuclear plant
AEC calls Kudankulam shut-downs serious, but institutionalised nuclear complacency continues: Dr. EAS Sarma
Failures of Kudankulam Nuclear Power Plant Units 1 & 2: Representation by Environmental Organisation Poovulagin Nanbargal
Few additional references in the context of the relevance of nuclear power to our country are also indicated below for your kind consideration:
(1). A representation to the Comptroller and Auditor General of India on the issue of auditing need of the procurement process followed w.r.t nuclear reactors
(2). High level analysis of costs and benefits of nuclear power plants in India
(3). An overview of nuclear power in the context of additional capacity to Kaiga NPP http://www.countercurrents.org/2017/07/01/an-overview-of-nuclear-power-in-the-context-of-additional-capacity-to-kaiga-npp/
(4). Integrated Power Policy for India, Sept. 2012
(5). Power Sector Road Map for Tamil Nadu – 2050; April 2016
It is unfortunate to notice that the Vice Presidential staff, who might have briefed you in this context, were either ignorant of these crucial aspects/concerns, or have simply ignored to bring to your kind attention. It is also a matter of grave concern if the bureaucrats in our country are intentionally keeping such crucial aspects/concerns hidden from the Constitutional authorities.
If the honorable Vice President desires so, a group of people from the civil society who have been studying the associated issues for years, will feel privileged to be able to make a detailed presentation.
Power Policy Analyst