1. PAEC argument is premised on a 5km land use and population control zone and 10kms evacuation zone. They are able to demonstrate that in these zones, a population of no more than 150,000 in a few Goths is there and that PAEC would be able to manage this much load of evacuation, should there be an emergency release of radioactivity.
2. My contention is that 5-10 kms zoning considerations are too low which were probably worked out for a much smaller KANUPP reactor of 125 MW. We are now talking about a much larger reactor of 1100 MW and may be two or three of these, although admittedly of much safer design. Guidelines in many countries require that consideration of populations and population density be given in much larger area than PAEC is prepared to consider. For Example, in the US emergency zone is spread over 17 kms and contamination zone over 85 kms. Also, the population density (PD) in an area up to 34 kms has to be considered and PD should not exceed 400 persons per square kms. In India, a potential site is rejected, if there is a population centre of 100,000 or more at a distance of 30 kms. Actual data from Fukushima indicates that, evacuation had to be done up to 30 kms and contamination zone extended to 85 kms. Not many nuclear reactors are being built to enable us to come forward with still more data. The data of Europe that PAEC has provided is outdated. There is a new standard (Europe -JRC) recommending a minimum distance of 25 kms for evacuation zone and 300 kms for contamination zone, as can be seen from the adjoining table. PAEC planning norm of 5-10 kms matches with only Chinese criteria, the latter generally not known for strict safety and environmental adherence. Even in China, changes appear to be on the horizon in the light of the paper on Sanmen that we have already mentioned.
Thus it becomes abundantly clear that a much larger area (say of 30 kms) and its population and other characteristics are to be considered. If this is the case, then highly population and dense areas like Lyari, Baldia, SITE, Orangi and even parts of Keamari become relevant. Population density in these areas averages at 20,000 per sq kms. We have summarised distance and population criteria in the adjoining table. It can be seen that in such a dense population case, no country and its guidelines would permit installation of NPPs of the size that has been proposed. The proposed siting of K2 does violate most planning norms prevalent in other countries, despite unique law and order problems that we are facing.
==============================================================================
Comparative populations and Population Density
==============================================================================
USA India Fukushima Sanmen PAEC-K2
==============================================================================
Maximum Population Density 300* 20000
Minimum Distance-kms 30kms**
Population density-5kms 174.6 204 66
Population density-10kms 151.3 135 51
Population Density-20 kms 68.8 20000
Population density-30kms 55.5 20000
Population-5kms 13700 16036 5160
Population-10kms 47500 42358 15960
Population-20 kms 86300 800000
Population-30 kms 156800 2000000
County -Town density 400 1357
==============================================================================
US MPD@20 miles from a population centre of 100,000
==============================================================================
3. Coming to more esoteric level, PAEC maintains and I agree that radioactivity dispersion modelling is to be done, which would predict the radioactivity levels at various distances both as routine or incase of nuclear accident. Such levels would be considered against allowed maximum dose levels (say of 1 mSv), and zoning would be done accordingly and also a determination whether such site would be safe and feasible. PAEC says, it would take three years to undertake this analysis. However, the proposed site has been already approved and a construction license is scheduled to be awarded in about 12 months. In fact land levelling activities have already been started.
My concern is and as it is for many, that a conclusive analysis, as claimed by PAEC, would come out after three years but the approvals and go-ahead have either already been given or would be given prior to the scientific risk and safety analysis. In that case, either such a risk analysis would not be done at all or would be of no use ex-post-facto. I believe that based on the earlier discussion, the site appears to be highly risky and would be violating many siting norms and guidelines including that of IAEA which mandates feasibility of an evacuation plan or the site is to be rejected. PAEC is making its case on unacceptably smaller distances. I also believe that a first order risk analysis consisting of dispersion modelling may be done within one year and that such an exercise be commissioned by PAEC in an open manner, results of which h are to be shared with public and the siting decision be based on such an exercise. Till such a time, the siting decision should be postponed.
=====================================================================
Comparative zoning distances in countries
=====================================================================
PAEC USA Fukushima Europe-JRC India
=====================================================================
Evacuation Zone(kms) 5 17 30 25 16
Ingestion Zone 10
Contamination Zone 85 85 300
=====================================================================