Nuclear Power Plant 1100 MW poses safety threat to a large section of Karachi Population.It is being sited within city limits too close to densely populated areas in violation of internationally accepted planning norms and guidelines.

1. Nuclear Threat to Karachi:K2 NPP
siting controversy and its solution
Syed Akhtar Ali
Chairman Research on Economy and
Politics of Pakistan(REAP)-0345-
2447714,akhtarali1949@gmail.com

2. I am Pro-Nuclear, Others may differ
I believe that:
• Nuclear Power is Economic
• It is an effective solution for our energy
needs(100 Sunar Ki 1 Luhar ki)
• Nuclear Weapons have served as useful
deterrent guaranteeing our freedom
• Chinese are our time-tested friends. They are
highly developed now. Chinese reactors would
be as safe as from anywhere

3. Proposed location of K2 is unsafe
• Recognize that proposed GEN-III NPPs are
safer than the previous GEN-II reactors, but
• Nothing is 100 % safe
• Accidents ala Fukushima, Chernoble may
occur
• What happens to Karachi esp the following;
• Densely populated Karachi
West(Sadar,Lyari,SITE,Baldia & Orangi)
• Economically important areas like
Seaport, I.I.Chundrigar Road, Grain Market

4. Proposed Site violates …….
• Proposed K2 Site is in violation of all
international planning guidelines and norms
• It is against principle of uncertainty
• It is not prudent
• It is infact quite a rash siting decision
approved in indecent haste
,surreptitiously, bypassing due EIA process
• Infact it is out of line with PNRA Rules as well

5. Main Objection and criterion
• Proposed site lies within the Emergency
Evacuation Zone EEZ or UPZ as defined by
most international norms.
• The neighborhood area is one of the most
densely populated of the world.

6. Population Density
• Karachi-6000 persons per Sq.kms
• Karachi West-20,000 persons per sq.kms
• Japan : 337
• Fukushima :55.5

7. Population density around Fukushima

13. 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 atleast 40% more than the
1998 Census
2)Straightl ine distances have been assumed to be 75% of the

15. NPP Emergency planning zones
• On-Site: Internal zone, under control of NPP operator
• PAZ: Precautionary Action Zone (5 kms)
• UPZ: Urgent Protective action planning Zone(17-25
kms)
• LPZ: Long-term Protective Zone (Food Restriction
Planning Zone-FRPZ) -85-300 kms
•
• .

17. US NRC Guidelines
• 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.
• Reactor sites should be located away from
very densely populated centers. Areas of low
population density are, generally, preferred.

18. USNRC: distance to Population Centres
• The nearest distance to the boundary of a
densely populated center containing more
than about 25,000 residents must be at least
one and one-third times the distance from
the reactor to the outer boundary of the
LPZ.(10 kms from the outer boundary of LPZ
of 25-30 kms)

19. US NRC rule 3:
• A reactor should preferably be located such 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 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.

20. AERB India code ‘Code of practice on
safety in nuclear power plant siting’,
• provides three desirable parameters for ready
acceptance of the site.
• 1. Population within sterilised zone (5km
radius) : less than 20000
• 2. Distance of population centres (>10000
person) : More than 10km
• 3. Distance of large population centers
(>100000 person) : More than 30 km

21. Para 5.2.i of SRO 911(I) PNRA,
• concerned with Nuclear Siting, requires impact
evaluation under accident condition, although it does
not specify the severity on INES scale, a flaw that one
would like to be rectified in the light of similar rules in
other countries. “For each proposed site, the potential
radiological impacts in operational states and in
accident conditions on people in the region, including
impacts that could lead to emergency measures, shall
be evaluated with due consideration of the relevant
factors, including population distribution, dietary
habits, use of land and water, and the radiological
impacts of any other releases of radioactive material in
the region.”

22. PNRA Guidelines
• PNRA’s gazette guidelines provide for special
considerations for large cities. 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

23. No hindrance to Ingress and Egress(IAEA
Safety Guide)
• Before final approval of a nuclear power
plant site, the feasibility of an emergency
plan should be demonstrated. There should
be no adverse site conditions which could
hinder the sheltering or evacuation of the
population in the region or the ingress or
egress of external services needed to deal
with an emergency.

24. Proximity to a City-hindrance to
Evacuation(IAEA Safety Guide)
• 6.4. The presence of large populations in the
region or the proximity of a city to the nuclear
power plant site may diminish the
effectiveness and viability of an emergency
plan. 6.6. If, upon evaluating the
aforementioned factors and their possible
consequences, it is determined that no viable
emergency plan can be established, then the
proposed site should be considered
unacceptable.”

25. Comparative populations and Population Density
USA India Fukushima Sanmen PAEC-K2
Maximum Population
Density 300* 20000
Minimum Distance-kms 30kms **
Population Density-20
kms 68.8 20000
Population density-
30kms 55.5 20000
Population-20 kms 86300 800000
Population-30 kms 156800
200000
0
US MPD@20 miles
**from a population
centre of 100,000
*

26. Table___: Comparative
zoning distances in
countries
PAEC USA Fukushima Europe-JRC India
Evacuation
Zone(kms) 10 17 30 25 16
Ingestion
Zone
Contaminat
ion Zone 85 85 300

27. Lack of Due Process
• Convention on Nuclear Safety and IAEA NPP
Siting Guidelines require open and
transparent NPP Siting Process and decision-
making.
• Pakistan’s National Reports to CNS reaffirm to
that requirement

28. Has PAEC considered possibility of
nuclear accident at all ?
• PAEC claim of very low level radiological impact of
0.02 mSV as opposed to EIA results elsewhere(10-
100 mSV)
• False value
• Incomplete statement(normal operation)
• Hiding inconvenient details
• Nuclear accident has not been considered.

31. US NRC: ref exposure level
• 10 CFR Part 50, "Domestic Licensing of
Production and Utilization Facilities,"
requires that at any point on the exclusion
area boundary and on the outer boundary of
the LPZ the exposure of an individual to a
postulated release of fission products (as a
consequence of an accident) be less than 25
rem(250 mSV- a person dies @1000 mSV)
total effective dose equivalent, for specified
time periods.

32. Exceptions donot prove the rules
• NewYork Indian Point Reactor;26 kms away;
much less population density ;strong public
demand to close it down
• Netherlands: very small geographical area
• EU New Guideline has increased its Hazrdous
area to 30 kms from a previous lower level of
20kms.

33. Union Carbide Tragedy-Encroaching
Population
• Others estimate 8,000 died within two weeks
and another 8,000 or more have since died
from gas-related diseases. A government
affidavit in 2006 stated the leak caused
558,125 injuries including 38,478 temporary
partial injuries and approximately 3,900
severely and permanently disabling injuries.
• Initial

34. KeMari Town_required for expansion
and not for restriction
• Population around Union Carbide Plant was very
small, it grew later. Can the proponent guarantee
that the population around its site will not grow.
Can it buy-out the whole Kemari Town Land? Would
it be possible? Or adviseable.
• In fact, we look forward to the closing down of
Kannup, at its designed life. No extension is
awarded to it any more.

35. Recommendation
• Affected Population is whole Karachi West
including vital socio-economic Centres of
I.I.Chundrigar Road , Seaport and Food Grain
market, and not a few Goths as claimed by
PAEC
• Proposed location endangers Karachi
generally, and Karachi-West in particular
• Go towards Gadani@ 50 miles
• Adopt USNRC distance standards of 16-50
Miles
• Shun Secrecy: Organise a full scope EIA with
public oversight and participation