The article "Nuclear threat to Karachi? - I" carried by Business Recorder on 12 March 2014, by Syed Akhtar Ali, was circulated earlier through emails on 26th February, 2014, as 'Occasional Paper on' "The Nuclear Threat to Karachi". The PAEC response was indirectly sent to all email recipients and the same is attached for publication in your newspaper to clarify PAEC's position on the issue. Part of the response is reproduced here.
Reference to the statement from the article regarding "Universal siting norm": "As a general Siting Rule, almost universally, away-from-population centers is a norm and makes common sense. Let me reproduce, the excerpts from NRC(USA) Guidelines on the subject;
As stated in 10 CFR 100.21(h), "Reactor sites. As stated in 10 CFR 50.47, the plume exposure pathway EPZ for nuclear power plants generally consists of an area about 16 km (10 ml) in radius, and the ingestion pathway EPZ generally consists of an area about 80 km (50 ml) in radius."
Response: The criterion of 500 persons per square mile (up to 20 miles) dates back to 1978 when USNRC issued Revision 3 of its Regulatory Guide t70. This was the time when large Generation II Nuclear Power Plants (NPPs) were being built in USA. This value has not been revised ever since.
In fact, this population density limitation is directly linked with the plume exposure pathway Emergency Planning Zone (EPZ) for nuclear power plants (related to evacuation zone) which in USA had been prescribed as an area of about 16 km (10 mi) in radius, and the ingestion pathway EPZ (requiring monitoring of food and water) which was set at an area of about 80 km (50 mi) in radius.
It may also be noted that the goal for the Core Damage Frequency (CDF) given to the NPPs by USNRC was and still is set at less than 10E-04/reactor year, that is likelihood of no more than one core damage in 10,000 years. Today, the Pakistani regulatory authority, PNRA, will not give a license on that CDF value. It requires Core Damage Frequency (CDF) to be less than 10E-05/reactor.year, that is likelihood of no more than one core damage in 100,000 years. CDF is determined by a very sophisticated probabilistic approach which comprises detailed modelling of plant systems and consideration of huge amount of plant data. It takes more than three years to conduct this analysis.
K-2/K-3 are Generation III NPPs. The safety target for Generation III NPPs is to reduce the possibility of core meltdown to less than 1 in 100,000 years, improve mitigation of severe accidents ( after core meltdown and station blackout) so as to minimise the effect on the environment, thus reducing the radii of EPZ as far as possible. The main difference between Gen II and Gen III plants is that the older Gen II plants provided a defence against design basis accidents only, but the Gen III plants cater for beyond basis accidents and severe accidents and ensure that there are no unacceptable releases even in the worst case scenario.
In K-2/K-3, the enhanced safety features like double containment, passive heat removal system, containment cooling, cavity flooding, containment filtration and exhaust system, etc, have reduced the plume exposure pathway EPZ to less than 3 kms in radius. Compare it with 16 km for USA and one can get an idea of the advanced safety measures that have been incorporated in K2/K3, and the need for smaller distances thus making it a much safer plant and the population living around less susceptible. It should be noted here that the CDF for K-2/K-3 is less than 10E-06/reactor. year, or less than one core damage in 1,000,000 years, which is two orders of magnitude lower than the goal still applicable in USA.
In fact recommendations on these distances vary from country to country. Given below is comparison of Emergency Planning Zones (EPZs) which is followed in different countries of the world:
Belgium: The general EPZs are associated with the following protective actions: evacuation (10 km), sheltering (10 km), stable iodine intake (20 km) and food chain (whole country). The size of these zones has been defined taking into account a rough (presumably largely deterministic) estimation of the associated risks.
China: The zones as follow are applied for NPP Tianwan (PWR): internal zone 3-5 km, outer zone 7-10 km and ingestion exposure pathway zone 20 km.
France: Around each NPP there are two zones defined. The emergency planning zone of 5 km radius around a nuclear power plant is the zone where evacuation is pre-planned and prepared in detail. The emergency planning zone of 10 km radius around a NPP is the zone where sheltering is preplanned.
The Netherlands: The various zones for direct measures are defined geographically as follows: 1) Evacuation zone circle with a radius of 5 km, 2) Iodine prophylaxis circle with a radius of 10 km, 3) Sheltering zone: circle with a radius of 20 km. The measures in cases of nuclear emergencies are co-ordinated at the national level.
South Africa: In an effort to develop effective emergency plans, the utility (Koeberg Nuclear Power Station, Eskom Generation) implemented a program to derive the risk to the public and to use these risk insights to aid the optimisation of the emergency planning actions, zones and response times. The emergency plans are based on a comprehensive threat assessment which takes into account the most likely accidents while also addressing the less probable but more severe events. Internal zone of 5 km and outer zone of 16 km have been established on the basis of severe accidents reference scenarios analyses.
As one can see, these numbers vary from country to country, and are determined by a variety of considerations. No surprise then that IAEA guidelines GS-R-2 "Preparedness and Response for a Nuclear or Radiological Emergency Safety Requirements" and GS-G-2.1 'Arrangements for Preparedness for a Nuclear or Radiological Emergency" recommend that these limits should be determined on the basis of calculations to determine the ultimate value of Emergency Planning Zones.
Conclusion: All countries have their own regulatory framework based on requirements dictated by national conditions. In Pakistan, we have to abide by the national nuclear regulations issued by Pakistan Nuclear Regulatory Authority. These regulations are based on IAEA's requirement documents which require EPZ to be calculated and implemented. In fact, it requires the operator to calculate at least three distances for emergency planning, ie, Precautionary Action Zone (the area in which protective actions are required immediately in case of release), Urgent Protective Action Planning Zone (the area where preparations are made to promptly shelter in place, to perform environmental monitoring and to implement urgent protective actions on the basis of the results of monitoring within a few hours following a release) and Food Restriction Planning Zone (the area around the facility where preparations for effective implementation of protective actions are to be made to reduce the long-term dose). All of these distances have been calculated for K-2/K-3 based on conservative assumptions and there is no data to believe that emergency planning will be required beyond a distance of 10 km from K-2/K-3.
Having covered that, it is worth pointing out that the project was planned at this site because sites at greater distances from Karachi along the coast are vulnerable to a higher seismic risk due to their proximity to seismic fault lines; or they do not have an appropriate height above Mean Sea Level; or there are greater flood risks. The rock type under the surface and the absence of groundwater are also important considerations for selection of the present site.
With reference to the "PNRA Gazette Guidelines" referred in the paper at page 10, it may be stated that all requirements of PNRA have been met. The distance from the installation to the outer boundary of the low population zone has been determined which is 1.7 km. The nearest locality with at least 25,000 residents, ie, population center distance is 12.2 km that is well beyond the least required distance of one and one-third times the distance from the installation to the outer boundary of the low population zone.
It may also be emphasised that PAEC applied for environmental clearance from SEPA as per procedure. Due legal procedure was followed and that is the way how PAEC operates. The question of siting distances relevant to radiation releases is not in SEPA domain as it absolves itself of the responsibility of handling the radiation release aspect which is the domain of PNRA. For other overall environmental impact, no base load electricity generation plant can match nuclear - and that is a fact.
Some factual corrections
1. Extracted from the Article, "13 most dangerously located reactors . . ." In the category of 10 miles (17 kms) distance, even Indian Point (NY) would fare better than our proposed KK-2; a population of 272,539 as opposed to more than a million living within 17 kms of KK-2.
Factual position (PAEC) First of all 10 miles=16.09 kms and not 17 kms.Although the 1998 Census data and the growth rate provided by National Institute of Population Census, Islamabad, have been used for population estimation, the population around K-2/K-3 Site in 0-10 km has also been estimated from a field survey. This was done as the people near the site are at the greatest risk.
Based on the above, the estimated population around 16 km radius is 103,583. Even if you increase it by 50%, it will still be 76% of the population near Indian Point (NY) which has almost 40 years old Generation II reactors reaching the end of their design life. The plant has applied for 20 years life extension, but they are allowed to operate until 2016 when USNRC will take a decision.
In fact, the population around 16 km radius of K2/K-3 is less than what it is near the 8 nuclear power plants mentioned in the report under the heading of "13 most dangerous nuclear reactors located in USA" and they are all Gen II plants with single Containments and designed to cater for design basis accidents and not severe accidents.
2. Extracted from part of the Article on first page, "Hawkesbay Scheme..." HAWKESBAY Scheme-42 has been floated and allotments have been made. Within a few years, lacs of people are going to be populated there.
Factual position (PAEC) HAWKESBAY Town is not a new scheme; it was notified in July, 1984 by Karachi
Development Authority. It is still waiting for those lacs of people to reside there. KDA has also notified in 1985 that there will be no residential scheme within 5 km of KANUPP and this scheme is well beyond that.
The following is the response that we expect would appear in the next part of the Article in your paper:
3. Extracted from the article, "Rejection Criteria (1) Population Considerations"
Population Centers of more than 10,000 should not be within 10 km of the site.
Factual position (PAEC) The population centre of more than 10,000 is not within 10 km from the K-2/K-3 site. The exact distance if measured from Google Earth is 12.2 km at the start of the population centre.
4. Extracted from Article, "Chinese NPP location Framework"
Factual position (PAEC)In reality, the population density near K-2/K-3 compares well with that given for China in the table below.
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Comparison of K-2/K-3 Site and Chinese NPP location Framework
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Chinese NPP Population Data Given by Author
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Site Hubei Liaoning Guangdong Fujian Guangdong Zhejiang Guangxi K-2/K-3
Xiainning Hongyanhe Taishan Ningde Ling'ao Sanmen Farigcheng (2011
gang Data)
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No of villages
and Towns 3 1 1 2 2 2 1 11 Goths
Population
0-5 km Size 12,850 1,654 1,015 6,945 864 16,036 7,684 5,160
Population
density
(people/km2) 163.7 21.1 12.9 88.5 11 204.3 97.9 66
No of villages
and Towns 7 3 3 7 3 8 6 47 Goths
Population
0-10 km Size 51,175 16,233 13,126 64,481 12,349 42,358 42,380 15,960
Population
density
(people/km2) 163 51.7 41.8 205.4 39.3 134.9 135 51
Population
Densityof
Province 325 295 482 288 482 460 191 278*
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* National Institute of Population Studies
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