The nuclear sector (PAEC) has been in news recently for its NPP K2 siting proposal/decision within the city limits of Karachi. A lot of criticism has been made (including by this scribe) by the residents and community representatives of Karachi and other knowledgeable circles. PAEC response has been rather cryptic and wanting in appropriate detail. A deeper examination of this and some sober thinking reveals that Pakistan's nuclear power and strategic sector require some vitally-needed reforms. The issues and problems are deeper than one would tend to dub as a mere siting issue, although a large part of controversy has emanated from it. Those who ask questions should be able to point out possible solutions as well. It is in this spirit that I am writing this piece. Before proposing a package of reforms, we would like to outline the history of Pakistan's nuclear programme in order to get a perspective.
1. Phase 1 started in sixties under the Atom for Peace programme and culminated with the installation and commissioning in 1971 of KANNUP (Karachi Nuclear Power Plant), a 121 MW power plant energised by a heavy Water reactor, supplied by Canada and called CANDU. It started with a mandate on peaceful uses of nuclear energy, although some other currents might have been there as well.
2. Phase 2 (1974-1998) started with the nuclear explosion In Pokharan (Rajhastan) by India in 1974 which triggered a Nuclear arms race in South Asia. In this period, the whole of nuclear sector had largely a military purpose and pursuit of nuclear weapons.
3. In Phase 3 starting about 1995, pursuit of peaceful and overt nuclear power projects started. Chashma 1 and 2 were installed and commissioned and Chashma 3 is under construction, while a programme of installing 8 NPPs (8x1100=8800 MW) in various parts of Pakistan has been launched, with foundation stone laying ceremony of 1100 MW K2 project being sited in the city limits of Karachi.
Clearly, after being busy for almost 2-3 decades in a more or less secret nuclear weapons programme, the nuclear power programme (civilian) has come on an equal keel with the nuclear weapons programme, if not having surpassed the latter. PAEC has largely been busy in programmes of military nature and thus has acquired a character of a secret military organisation with taboos on its public profile, contact and communication. Let me now propose a package of reforms for our nuclear sector.
1. A separate organisation (possibly named as Pakistan Nuclear Power Corporation - PNPC) under a loose control of PAEC or totally independent of it be launched to manage the civilian nuclear programme, namely the erection and operation of NPPs (Nuclear Power Plants). Nowhere in the world, perhaps, are the military and civil programmes run by the same organisation, even the declared nuclear powers. Even in India, NCIL (Nuclear Power Construction of India-NCIL) runs the civilian programme. PNPC would develop its own rules, culture and modus operandi more in keeping with its role as a civilian and open institution.
2. For the sake of completeness, I would repeat here my proposal to introduce a nuclear liability insurance scheme to protect and cover the victims of nuclear accidents. In all countries of the world where there are nuclear installations including China and India, such scheme are there. Readers are referred to my piece on Nuclear Power Economics, published in these pages recently.
3. The secrecy syndrome from the civilian sector should be removed and at least as much information should be made available to the Citizen's of Pakistan as is released to outsider institutions. Nothing remains secret when a report is sent to IAEA and other multinational bodies, even the confidential documents. For example, various reports are filed including reports on Convention on Nuclear Safety, which give out tremendous amount of data, which they would not have liked to share in a true EIA process ie, radioactivity data around KANNUP. Information on proposed sites of other NPPs in 8800 MW package is available at WANO website but there is none either on PAEC or PNRA. In the international reporting false claims are made about openness and transparency. IAEA Guidelines clearly require public consultations on nuclear power plant siting decisions including comparative choices, mitigation and extra considerations for large population centers, none of which has been practiced in the case in point and others.
4. Even China has laid down requirements of EIA and consultations with local community. China has published a part of the EIA in an international journal concerned with one of their reactors ÁP 1000 in Sanmen. Maybe they have published more. I know of only one. They have published the results of a simulation concerning radioactive fallout as a result of a severe nuclear accident. Why does the duo of PAEC-PNRA think it as a taboo? After all, it is not their own design or technology. Generic data concerning radioactive releases is widely available on internet as several comparable projects are under implementation. In fact, the relevant (source terms) and nuclear accident modes and assumptions have been standardised. All that is required is to run a computer programme concerning radioactive dispersion and simulation, which is also available free of charge. In fact had Pakistani universities or civil society been so organised and financed, they should be able to conduct such an exercise and send the results to PAEC as a gift and discuss its implications that may have removed some of the controversies. Till to date, people are not convinced that under a nuclear accident ala Fukushima (INES-7), people would be safe from the radioactive fallout. PAEC maintains that only a 5-10 kms of area around Paradise Point would be affected and that densely populated areas like Orangi and Lyari and important socio-economic centers like I.I. Chundrigar Road and the Seaport would remain unaffected. In the US, a 50-mile area is considered to be contaminated and area under 16 kms requires emergency evacuation. The rules there also require that such areas should not be densely populated. In India, an NPP can be installed within a range of 30 kms from population centers of 100,000 or more. Here we are concerned with a population of millions living in densely-populated areas.
PAEC keeps repeating its words inscribed in stones that there is no safety issue or concern but refuses to share credible data reassuring citizens of Karachi. We are living in 21st century when the role of public oversight and consultations (genuine and not propaganda) has been universally recognised. Obviously PAEC organised in secret and the Cold War fashion cannot obviously meet these challenges effectively, hence my proposition of separating the nuclear power function from PAEC. PAEC would still be left with a lot of important functions.
5. Reform is also needed in PNRA (Pakistan Nuclear Regulatory Authority) which is equally secretive if not more than PAEC. PNRA is keeping shut on the K2 issue. It has not taken cognisance of so much public concern and bothered to utter a word. It does not tell as to what is the next procedure. It does not announce that it has accepted the PAEC proposal on K-2 siting. It posts a lot of information on its rules, but keeps mum on what it is doing about it. All it is ready to divulge about is on X-ray machines used in medical clinics and the like. This is rather unbecoming of a regulatory agency. If PNRA is to become a truly regulatory body, it has to come out of the shadow of PAEC, the organisation it has to regulate on. A perfunctory reporting to the Cabinet Division is not enough. PNRA cannot function without nod and support from PAEC, after all the manpower comes from PAEC and the vice versa. Even then, some measures can be taken to enable PNRA to independently exercise its regulatory role, although cordially and not quarrelsome and hostile manner.
6. Some structure has to be given to the EIA processes of NPPs. Regional EPAs and PEPA are concerned with non-nuclear activities, although these should not be restricted in such a manner. While PNRA is adequately equipped with nuclear issues, it is tight lipped and does not believe in public consultation. Either nuclear pollution issues are to be brought in the ambit of EPAs or NPRA is to be reorganised to be open and consultative as has been discussed earlier. The irony is that they were not prepared to discuss openly, the rather unimportant aspects of chemical pollution and got the NOC under strategic clause or the so-called national interest. Part of the problem is that the city is being managed by Deputy Commissioners and not the public representatives who permitted a NPP within the city limits. Sindh Government kept quiet and continues to do so, as Sindhis are under political and psychological pressure of not appearing unpatriotic by asking some legitimate questions and requiring the compliance to full scope EIA. As we have mentioned, a special treatment on EIAs of NPPs has to be included mandating full-scope EIA. Also, consideration may be given to forming a specialist core group on NPPs, which may be consulted on EIA and nuclear safety issues. Civil Society organisations, professional bodies, former PAEC/PNRA professionals, University professors, consultants and other prominent scientists and professionals may be included in this group. A total of around one hundred or so experts may be included so that adequate representation of all sectors is there. This would solve many problems in advance of those who have a problem or fear with the word public. Some indiscipline reportedly took place in a recent NEPRA public hearing in Karachi on the issue of K-electric's fuel adjustment charges. Irrelevant and people with less or no knowledge of the subject appear on such hearings as well wasting time and diverting focus from the real issues. NEPRA which has a lot of experience in these matters may come up with a feasible proposal which may be a guide for all other agencies. Although screening of this sort may not be liked by some democrats, some via media including their concerns may be worked out.
Some project proponents fear the EIA process and incorrectly think that it would necessarily block their project. This is not so. Through EIAs, one studies the negative impacts of the proposed activity on the health, jobs and well-being of the communities these are proposed to be placed in. The negative impacts can be ameliorated through changes in project design or implementation. For example, fishermen and their representatives would like to know what kind of effluents and at what temperature is to be discharged into the sea which may affect their livelihood of fish catches. The proponents can treat the effluent adequately, install adequate cooling facility for the water discharged, or if technical solutions are not feasible agree to provide and develop similar fish catching and breeding facilities elsewhere in the neighbourhood. It is a political economy question. The project may cause unequal impact on various parts of the societies. You are not supposed to create a surplus for some to be extracted from the deficits of others. Fisherman would not directly from a nuclear power plant but the textile tycoon would definitely benefit with their increased output, profits and exports along with other sections of the society. Empty appeals to the patriotism of the poor fisherman are exploitative without compensating him in some form. Large projects used to be cruel in 1960s such as hydro dams, no more. Today, dam affectees are being compensated.
7. A major overhaul is to be done in the nuclear siting rules and processes. Existing rules are too broad and qualitative and have given rise to the present controversies. Other projects are coming up near rivers and agricultural areas where contamination issues are paramount. There are enough bodies of rules and examples that could be made use of in bringing some limitation on the project proponent who currently relies on a mere declaration that we have checked it even without sharing it with stakeholders.
8. Concerns have been shown by some quarters in terms of quality issues in Chinese origin supplies generally which may also affect nuclear supplies that may have a safety nexus. Involvement of third-party consultants may be considered to vouchsafe our national and client interest, as the requisite know-how may be lacking within our own establishment. Reportedly, in smaller Chashma series projects, this element has been lacking.
9. Pakistan can only get nuclear technology from China due to NSG (Nuclear Suppliers Group) guidelines and full-scope safeguard issues prohibiting adequate competition and broad based technology input. Efforts should be made to get a status similar to India. China can also sell possibly to Pakistan due to its image problem with respect to quality. It does not appear from the K2 pricing that this factor of mutual dependence has been respected. The prices as reported are higher than some of the Russian deals in Europe and elsewhere. This factor should be brought into consultation with China in a friendly manner and a discount may be attempted to bring down the levelled cost of nuclear power generation competitive with coal which is being quoted in local market at 7-8 US cents. It is a combination of EPC pricing and financing terms that together influence the cost of generation. Consideration should also be given to BOO (build, own and operate) contracts ala Russia-Turkey deals agreed to recently.
10. If this proposed reform agenda is not adopted by the higher competent authorities, nothing prevents the concerned organisations to initiate these reforms themselves and to evolve a formal communication policy after due consultation within and getting the input from other stakeholders. An external resource person or consultant may be engaged for the purpose to have a third-party input and flavour. They certainly need this input for fashioning an acceptable communication policy. K2 is far from over and other projects would run into snag. The possibilities of lengthy litigations cannot be avoided in an atmosphere of public concerns.
11. Finally, two important issues related with the going times and organisational interests and workings have to be understood by those who are in charge of managing such organisations with huge purpose and budgets. Firstly, it is an age of information democracy. People are able to acquire a lot of information on all kinds of subjects by pressing and clicking on websites. Of course, some background is required; a doctor cannot invariably follow engineering websites and vice versa. There is a large body of people and experts and semi-experts who understand the subject including a lot of retired experts, professionals and technocrats. Hence to reject public concerns and arguments and bypassing consultations would finally harm those who hold such opinions and views. They are out-of-sync with times. Secondly, perceptions should not be dubbed away as unimportant or incorrect. The whole of the present-day world is based on one form or other of perceptions, right or wrong; share and commodity prices, forecasts and predictions or all sorts, even the political power and institutions. Gone are the days of kings, today even a military or civil dictator also tries to manage perceptions and put the right kind of coalitions in his favour. Organisations have to shape and manage perceptions which they think are right and adequate. It can be achieved through a genuine communication process and not a five pager Q & A communicating half-truths and incomplete and convenient data and information only. Such organisations put their political bosses and their supporting security institutions to do the job that has not been adequately handled by the project proponents. States coercive instruments and institutions are unnecessarily utilised which compromise these very institutions. Political bosses seldom take such risks and rather relieve the incumbents from their jobs.
(The views expressed in this article may not be necessarily those of the newspaper)