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VERSION 1.1 The Nuclear Threat to Karachi Occasional Paper Syed Akhtar Ali-Energy Consultant 2/26/2014 Draft Research on Economy and Politics of Pakistan-REAP 

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VERSION 1.1

The Nuclear Threat to

KarachiOccasional Paper

Syed Akhtar Ali-Energy Consultant2/26/2014

Draft

Research on Economy and Politics of Pakistan-REAP 

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"What happened at Fukushima was, yes, a warning to the world," he said. The resulting lesson was clear: "Try to

examine all the possibilities, no matter how small they are, and don't think any single counter-measure is foolproof.

Think about all different kinds of small counter-measures, not just one big solution. There's not one single

answer."We made a lot of excuses to ourselves … Looking back, seals on the doors, one little thing, could have

saved everything."  

"But we have to explain, no matter how small a possibility, what if this [safety] barrier is broken? We have to prepare

a plan if something happens … It is easy to say this is almost perfect so we don't have to worry about it. But we have

to keep thinking: what if  … 

Source: , Naomi Hirose, president of the Tokyo Electric Power Company (Tepco,owners of

Fukushima Nuclear Power Plant), interview to Guardian,19th

 Nov,2013 

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About the Author  

Akhtar Al i (B.E., M .S.)is an eminent energy expert and consul tant, advising publ ic and pr ivate sector

cli ents on energy poli cy, investments and tar if f issues and has authored a number of books on the

subject. He is a visiting Prof essor of Energy at I oBM and teaches energy management to MBA

students. He has held senior management appointments in Pakistan’s public and private sector. He

was Rese arch Fellow Energy at Harvard University’s Kennedy School of Government. He is an author

of eight books on various subjects such as energy, governance, poli tical economy and resources. H e

heads Proplan Associates, a consul ting company having a current f ocus on Energy. He is also

Chairman (REAP) Research on Economy and Poli tics of Pakistan, a think tank that bri ngs out

research publi cations on national i ssues. 

Books by Akhtar Ali: 

  Pakistan Nuclear Dil emma: Energy & Securi ty Dimensions. (1984). 

  Pakistan Energy Development: the Road Ahead.(2010). 

  I ssues in Energy Poli cy, 2012  

  The Poli tical Economy of Pakistan: an Agenda for Reforms. (1994). 

   Pakistan’s Development Challenges :Federalism, Security and Governance

2010  

   Pakistan’s development; economy, resources and technology, 2012. 

  Nuclear Poli tics and Chal lenges of Governance. (1998)  

  South Asia: Nuclear Stalemate or Conf lagration. (1987). 

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defending their position. As I have already mentioned that I do not agree with the first two categories of

objections, I would limit myself to the NPPs siting issue as proposed and defended by the PAEC in their

brief and make a few recommendations in this respect.

Whoever has read the PAEC brief is not convinced as to the siting decision. Karachi is a city of more than

25 Million or so now. Siting a nuclear power plant so close to it at Paradise Point, is definitely going to

cause fear and controversy. As we will demonstrate in this space from the evidence in many countries,

that in almost all the countries effort is made to locate nuclear power plants quite away from the

population centers, and in particular the large cities .Even PNRA’s gazette siting guidelines require

additional considerations for large cities. It is not sufficient to argue that KANNUP has operated for the

last 40 years without any catastrophe thus more of the same can be done without any compunction or

reservation. Firstly, It was in 1950s that the decision on KANNUP was taken. KANNUP was a small

reactor (125 MW originally), Karachi was smaller then and no security and terrorist threats were there

as these are now. Karachi is no Mianwali where Chashma projects could have been sited without having

received any reservations or opposition. PAEC first surreptitiously got the environmental clearance from

SEPA, without following the due process and brow-beating the small SEPA officials. They did not

consider it necessary to engage public and are doing now when nascent public pressure has forced them

to do so.

People , experts and non-experts are rightly arguing that in a vast country with a large shoreline, is

KANNUP location the only choice and whether all other options have been examined adequately.

Although it has been claimed that Karachi would be safe, a non-technical brief without credible

documents , is hardly enough to dispel the doubts and skepticism that is there. Let me take up the siting

issue point by point in the following:

2. 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 should be located away from very densely populated

centers. Areas of low population density are, generally, preferred…. Locating reactors away from densely

 populated centers is part of the NRC's defense-in-depth philosophy and facilitates emergency planning

and preparedness as well as reducing potential doses and property damage in the event of a severe

accident. Numerical values in this guide are generally consistent with past NRC practice and reflect

consideration of severe accidents, as well as the demographic and geographic conditions characteristic

of the United States.

Preferably a reactor would be located so that, at the time of initial site approval and within about 5 years

thereafter, the population density, including weighted transient population, averaged over any radial

distance out to 20 miles (cumulative population at a distance divided by the circular area at that

distance), does not exceed 500 persons per square mile. A reactor should not be located at a site whose

 population density is well in excess of the above value.

 Additionally, 10 CFR 50.47(a)(1) requires reasonable assurance that adequate protective measures can

and will be taken in the event of a radiological emergency before an operating license for a nuclear

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 power plant can be issued. Adequate plans must be developed for two areas or Emergency Planning

 Zones (EPZs). 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 mi) in radius, and the ingestion pathway EPZ generally

consists of an area about 80 km (50 mi) in radius.

Source: Regulatory Guide 4.7 - General Site Suitability Criteria for Nuclear Power Stations,

(Draft issued as DG-4004),Revision 2,April 1998http://www.nrc.gov/reading-rm/doc-collections/reg-guides/environmental-

siting/rg/04-007/

There are 100 nuclear power reactors in the U.S. with a total installed capacity of slightly more than100,000MW. In the enclosed Table, we have provided population data for 13 most dangerously locatedreactors. Out of these, only 4 nuclear reactors namely Indian Point(NY),TMIslands(Penn),Limerick(penn),and Mcquire (NC) have a populations of 880,820- to1187284 livingwithin 20 miles of the nuclear reactors. In most other locations, this number is typically under

200,000. Even in this list of dangerous locations, one would find sparse populations in quite a numberof situations. In the category of 10 miles(17 kms) distance, even Indian Point(NY) would fare betterthan our proposed KK-2 ;a population of 272,539 as opposed to more than a million living within 17kms of KK-2.Typically, less than 50,000 people live within 17 kms of nuclear reactors in the U.S. ascan be seen readily from the table. The figures match even with China where environment and safety

issues may fare lesser on agenda, as is the common belief. We have provided numbers on China aswell in a table. PAEC has selected only the worst possible example to prove its case. (May be God haschosen New York for potential catastrophes for its sins).

In the case of Pradise Point (KK-2), it may be noted that it is situated in the densest part of Karachicalled Karachi West; the adjoining communities of Orangi, Lyari, Baldia, SITE area etc have acombined population of 8.55 million people living within 20 miles. Also Clifton and Defence and PECHSare also within more or less 20 miles. It must also be noted that in these advanced and affluentcountries, it is a lot easier task to evacuate. Most people have cars and money to eat and survive fordays if not weeks on their own. The disaster management data from Japan, for example, tells us thatonly a few persons have to be assisted in most emergencies. People leave on their own unassisted. Inour case, neither the people nor the government have money and resources and nor are we organized

adequately. I have personal experience of evacuation during the Oil-Spill tragedy of Karachi and knowhow difficult and painful it can be.

13 most dangerous nuclear reactor locations in the U.S.

Reactor Name State

10

miles(1)

20

miles(2)

Seabrook New Hamshire 118747 464872

Vermont

Yankee Vermont 35284 147109

Pilgrim Massachusetts 75835 307359

Millstone Connecticut 123482 317466

Indian Point New York 272539 1187284Oyster Creek Philadelphia 133609 485719

Limerick Pennsylvania 252196 1168871

TM Island Pennsylvania 211261 880821

Salem New Jersey 52091 545820

Calvert Cliffs Maryland 48798 181324

Saint Lucie Florida 266595 420273

Mcquire North Carolina 199869 1013135

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Source: NBC http://www.nbcnews.com

(1)population living within 10 miles of nuclear reactor

(2)population living within 20 miles

Population of nearby communities to KK2

Community Population

Road distance-

km St.line distance

Orangi 1,540,200 25 18.75

Baldia 406,165 22 16.5

Lyari 2,700,000 24 18

Saddar 616,051 28 21

SITE 467,560 22 16.5

Kemari 383,788 22 16.5

Total(1998

census) 6,113,764

Estimated

current 8,559,270

1)current population should be at least 40% more than the 1998 Census

2) Straight line distances have been assumed to be 75% of the road distances.

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Source:  Akhtar and Dhanani , Population Distribution in Karachi City ,Sindh Univ. Res. Jour.

(Sci. Ser.) Vol.45 (1): 59-64 (2013);(dots represent population density. It is evident that the proposed

location is near highly populous parts of the Karachi city)

Source: Wikipedia

Karachi South

1. Lyari Town 

2. Saddar Town 

B. Clifton & DHA 

Karachi West 

12. Kemari Town 

13. SITE Town 

14. Baldia Town 

15. Orangi Town 

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NPP Siting Framework in India; A full scope EIA with public participation is provided in Indian law.Apart

from AERB(Atomic Energy Regulatory Board),there is jurisdiction of local and regional bodies and

EPAs.EIA and AERB guidelines provide for the following distances and rejection criteria of potential sites.

You may note that no population centers of more than 100,000 are to be there within 30kms of the NPP.

Rejection Criteria (1)

Population Considerations:

1) Population Centers of more than 10,000 should not be within 10 km of the site

2) Population density within a radius of 10 km of the plant should be less than 2/3 of the state

average

3) No population centers of more than 100,000 within 30 km from the plant

4) Total population in the sterilized area should be small (< 20,000)

Source: EIA Manual for Nuclear Power Plants, India.2)AERB Guidelines 

Chinese NPP location Framework: 

Let me also produce a table from the relevant policy in China:

Malaysian Framework:

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Malaysian Guidelines provide for rejecting a potential site if the distance to a population center of

25000 persons is less than or equal to 10 kms. 

Nuclear Power Plant Siting Rejection Criteria (Malaysia)

Rejection criteria are requirements based on physical characteristics of a potential NPP site and

potential sources of external events which could jeopardize its safety.

The brief rejection criteria established are:

1. Potential sites must not be within surface faulting and geologically unstable

areas.

2. Potential sites must not be within flood prone areas.

3. Potential sites must not be located within Rank 1 Environment Sensitive Areas (ESA).

4. Potential sites must not be located within an area whereby man induced events such as installations

with explosive, flammable, corrosive, toxic or radioactive materials, airports and the approach, take -

off and flight path zones, military installations and military target practice areas etc. is within the NPP

surrounding Emergency Planning Zone (EPZ).

5. Within a Mukim with population density of more than 250 persons / km2and / or straight line distance to existing major population center of more

than 25,000 people is less than 10km.

5. PNRA’s Gazetted Guidelines provide for special considerations for large cities. Let me reproduce ,part

of para 6;

 A population center distance of at least one and one-third times the distance from the installation to the

outer boundary of the low population zone. For this purpose, the boundary of the population center shall

be determined upon consideration of population distribution. Political boundaries are not controlling in

the application of this requirement. Where very large cities are involved, a greater distance may

be necessary because of total integrated population dose consideration.

There is no evidence that special consideration and assessments have been made as per legal

requirements. If such is the case, it should be made public.

6. Fukushima Lessons: There are various comments on Fukushima and the lessons learnt. Let me quote

from a respectable institution:

By contrast, the issue of the potential consequences of Fukushima had the wind direction been less

 favourable has led for calls to tighten the siting regulations, especially with regard to population

densities downwind of nuclear plants. In a 2012 report Greenpeace said: “Governmental data

released only later revealed that in a worst-case –  but possible –  scenario, evacuation would haveincluded the megapolis of Tokyo and other settlements up to 250 km away. Clearly, evacuation

 planning based on circles with diameters of several kilometres is too rigid and hopelessly

inadequate in the case of nuclear power plants.”138 (As noted earlier, the UK approach has been

based on 30 degree sectors rather than circles.) Commentators like Paul Dorfman have argued for

much more vigorous international involvement, including international reviews of security and

safety, binding international standards on safety and security and international cooperation ..

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Annexures

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Fukushima and Chernobyl compared

Category Fukushima Daiichi Chernobyl

SOURCE: NUCLEAR AND INDUSTRIAL SAFETY AGENCY, JAPANESE AUTHORITIES, UNSCEAR. *BECQUERELS

ARE A MEASUREMENT OF RADIATION

Date of

accident 

11 March 2011 26 April 1986

Accident

details 

 A magnitude-9.0 earthquake and

resulting tsunami damaged the plant's

power systems, causing cooling

systems to fail. A series of gasexplosions followed

 A sudden power output surge during a

systems test caused a reactor vessel to

rupture, leading to a series of blasts. An

intense fire burned for 10 days

Severity

rating 

Level 7 - major accident Level 7 - major accident

Number of

reactors 

Six; but only three of concern, plus

pools storing spent fuel

Four; but only one reactor involved

Type of

reactors 

Boiling-water reactors. Japanese

authorities stress that unlike at

Chernobyl, the containment vessels at

Fukushima remain intact. Also, unlike

Chernobyl, the reactors at Fukushimado not have a combustible graphite

core

Graphite-moderated boiling water reactor. The

graphite made it highly combustible. The

reactor also had no containment structure and

nothing stopped the trajectory of radioactive

materials into the air

Radiation

released 

370,000 terabecquerels* (as of 12

 April)

5.2 million terabecquerels*

Area

affected 

Officials say areas extending more

than 60km (36 miles) to the north-west

of the plant and about 40km to the

south-southwest have seen radiation

levels exceed annual limits

Contamination of an area as far as 500 km

(300 miles) from the plant, according to the

UN. But animals and plants were also affected

much further away

Evacuation

zone 

20km; 20-30km voluntary zone. Five

communities beyond the existing

evacuation zone have also been

evacuated

30km

People

evacuated 

Tens of thousands The authorities evacuated, in 1986, about

115,000 people from areas surrounding the

reactor and subsequently relocated, after

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Fukushima and Chernobyl compared

Category Fukushima Daiichi Chernobyl

1986, about 220,000 people from Belarus, theRussian Federation and Ukraine

Related

deaths 

No deaths so far due to radiation A UN report places the total confirmed deaths

from radiation at 64 as of 2008. Disputes

continue about how many will eventually die

Long-term

health

damage 

Not yet known, but risks to human

health are thought to be low

 Among the residents of Belarus, the Russian

Federation and Ukraine, there had been up to

the year 2005 more than 6,000 cases of

thyroid cancer reported in children and

adolescents who were exposed at the time of

the accident, and more cases can be expected

during the next decades

Current

status 

Engineers have brought the plant to a

"cold shutdown condition", a key

milestone in bringing it under control. It

will take decades to dismantle it

completely however.

The damaged reactor is now encased in a

concrete shell. A new containment structure is

due to be completed by 2014

Source: BBC ,16 Dec,2011. http://www.bbc.co.uk/news/world-asia-pacific-13050228 

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Fukushima nuclear disaster is warning

to the world, says power company boss  The Guardian, Tuesday 19 November 2013 18.10 GMT

The catastrophic triple meltdown at the Fukushima Daiichi nuclear plant in March 2011 was "a

warning to the world" about the hazards of  nuclear power  and contained lessons for the British

government as it plans a new generation of nuclear power stations, the man with overall

responsibility for the operation in Japan has told the Guardian.

Speaking at his Tokyo corporate headquarters , Naomi Hirose, president of the Tokyo Electric Power

Company (Tepco), which runs the stricken Fukushima plant, said Britain's nuclear managers "should

be prepared for the worst" in order to avoid repeating Japan's traumatic experience. "We tried topersuade people that nuclear power is 100% safe. That was easy for both sides. Our side explains

how safe nuclear power is. The other side is the people who listen and for them it is easy to hear

OK, it's safe, sure, why not?

"But we have to explain, no matter how small a possibility, what if this [safety] barrier is broken? We

have to prepare a plan if something happens … It is easy to say this is almost perfect so we don't

have to worry about it. But we have to keep thinking: what if …"  

British ministers recently agreed a commercial deal with the French state-owned energy

company EDF Energy to build the UK's first new nuclear reactor in a generation at Hinkley Point in

Somerset. The agreement included the UK government providing accident insurance.

Tepco's Fukushima Daiichi facility on the coast about 124 miles (200km) north-east of Tokyo,

comprising six nuclear reactors, was hit by a giant tsunami with waves peaking at 17 metres high

caused by the Great East Japan earthquake on 11 March 2011. In what quickly became one of the

world's worst nuclear disasters, operators lost control of the plant when the power supply, including

emergency back-up, failed amid massive flooding. As cooling systems malfunctioned, reactors 1, 2

and 3 suffered meltdowns.

Reactor 4 was closed for routine maintenance at the time. But one of several hydrogen explosions

blew the walls and roof off the reactor building. This week a delicate and lengthy operation to

remove fuel rods from that reactor began.

Radiation leakage following the explosions forced the evacuation of tens of thousands of people

from the surrounding area. An exclusion zone roughly 11 miles by 19 miles remains in force around

the plant two and half years later. The entire facility is now being decommissioned, but Tepco's

clean-up, which has been strongly criticised by environmentalists, is expected to take up to 40 years.

Hirose said that although the situation facing Fukushima Daiichi on 11 March was exceptional,

measures could have been adopted in advance that might have mitigated the impact of the disaster.

Tepco was at fault for failing to take these steps, he said.

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"After I became president [in 2012], we formed a nuclear safety review committee. We focused

mainly on what we could do, what we could learn. We had a lot of data by then. Three other reports,

one from the Diet [Japan's parliament], one from government. We had a lot of information. Tepco's

own report, too. We concluded that we should have avoided that catastrophic accident, and we

could have. We could see what we should have done."

Preventative measures included fitting waterproof seals on all the doors in the reactor building, or

placing an electricity-generating turbine on the facility's roof, where the water might not have

reached it. In addition, wrong assumptions were made, he said.

"I don't know if I could have seen or thought this before the accident … Probably I assumed that

people had discussed counter-measures to avoid a huge tsunami by something very special like a

complete shutdown."

It transpired that the huge cost and technical complexity of a multiple shutdown, in what was

considered the unlikely event of an abnormally large tsunami, had led managers to discount such a

scenario as implausible and inefficient, he said.

"What happened at Fukushima was, yes, a warning to the world," he said. The resulting lesson was

clear: "Try to examine all the possibilities, no matter how small they are, and don't think any single

counter-measure is foolproof. Think about all different kinds of small counter-measures, not just one

big solution. There's not one single answer.

"We made a lot of excuses to ourselves … Looking back, seals on the doors, one little thing, c ould

have saved everything."

Tepco was willing to share its experience with British and other nuclear plant operators if they

wished, Hirose said. "We can share all the information, all the data we obtained, that we learned

from this accident, and then hope that people will use the data and information to prevent the same

thing happening."

Hirose confirmed that his company has paid a large price for the disaster. It planned to "streamline"

the business and shed hundreds of jobs through voluntary retirement to keep itself in business. "We

have a huge debt for the compensation for damages and losses and for decommissioning … We

have to be sustainable as a going concern."

Concerned that Tepco may be unable to cope and responding to criticism that the company has

bungled parts of the clean-up operation, Japan's government has agreed to spend 47bn yen

(£292m) on dealing with hundreds of static tanks to store radiated water at the plant.

It is also considering paying part of the cost to decommission Fukushima's damaged nuclearreactors. Tepco will reportedly seek 500bn yen (£3.1bn) in bank loans by the end of the year to help

keep itself afloat.

 Asked about the severe domestic and international criticism that followed the discovery in July of

leaks from some of the tanks storing contaminated water, Hirose said the problem stemmed from a

"simple mistake" in managing the tanks. Since the discovery, the monitoring system had been

changed and new welded tanks installed, instead of the old bolted together versions.

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