Hier der Wortlaut:
Dear Mr. Sarkozy,
In the wake of the ongoing nuclear catastrophe in Fukushima, we are writing to you to
express our deep concern regarding the French Government’s upcoming decision on an
export guarantee for the Jaitapur Nuclear Power Project (NPP) in India.
Jaitapur is not only slated to become the world’s largest nuclear power complex, it is
sited in a “high risk” zone for earthquakes on India’s western coastline. Although three
tectonic faults transverse the area and an earthquake of over 6.3 on the Richter scale
took place only 17 years ago – killing some 9,000 people – these risks were ignored
during site selection for the NPP.
Currently, India has 19 operating nuclear reactors of which 17 are 220 MW reactors and
two are 540 MW reactors. The reactors proposed for Jaitapur are of an entirely different
scale (1,650 MW) and are designed to use high fuel burn-up, which places much higher
requirements on the quality of construction, maintenance and oversight. As India’s
safety record shows, however, even the management of its relatively small reactors has
been characterized by poor safety standards and immense technical problems – one of
the most extreme examples being the collapse of the Kaiga NPP containment in 1994.
In view of the four unit concurrent accident in Fukushima and the fact that regulators
have yet to evaluate lessons learnt here, it seems an extreme folly to support the
construction of one of the world’s largest nuclear complexes in a high risk earthquake
zone in a country with low nuclear safety standards, immense corruption problems, no
independent regulator and no experience with operating reactors of this magnitude.
While EU legislation requires that “member states shall ensure that the competent
regulatory authority is functionally separate from any other body or organization
concerned with the promotion or utilization of nuclear energy,” India’s Atomic
Regulatory Board (AERB) does not meet these requirements.
The AERB reports to the Department of Atomic Energy (DAE), which is responsible for
the promotion of nuclear power and is also the owner of NPCIL, the utility that wants to
build and operate Jaitapur. As stated by Dr. Gopalakrishnan, a former chairman of AERB,
this is a serious nuclear safety concern: “This dependency is deliberately exploited by
the DAE management to influence directly and indirectly, the AERB’s safety evaluations
and decisions. This interference has manifested itself in the AERB toning down the
seriousness of safety concerns, agreeing to the postponement of essential repairs (…)
and allowing the continued operation of installations when public safety considerations
would warrant their immediate shutdown and repair.” While the Indian Government
recently indicated its intention to create an independent and autonomous nuclear
regulatory authority sometime in the future, it has, however, not slowed down the
approval and preparation process for Jaitapur.
In this context, we would also like to point out that the units planned in Jaitapur show a
number of design weaknesses, which make them vulnerable to similar accident
scenarios as in Fukushima. Spent fuel ponds are for example located outside the
containment area, making them vulnerable to damage and a potential source of major
radiation releases into the environment; the control room is located close to the reactor,
making it inaccessible in case of serious radiation leakage; and the back-up diesel
generators are located close to the ground, making them susceptible to flooding.
As you are probably also aware, India is one of the very few countries that have refused
to sign the Nuclear Non-Proliferation Treaty. This makes it impossible to ascertain that
the acquired technology and nuclear material will not be used for military applications.
In addition, it should be noted that the environmental licensing process for Jaitapur has
violated both Indian law and the OECD common approaches for export credit agencies
by denying affected communities access to the Environmental Impact Assessment
Report and beginning forced acquisition of land without prior community hearings.
Accordingly, the project has already led to massive social conflicts and strong local
opposition. As recently as April 2011, a demonstrator was killed by the police and over
1,500 people were detained during protests against Jaitapur.
For all of the above reasons, the Jaitapur Project is extremely controversial.
The project’s seismic risks as well as the poor quality of management and safety
standards in the Indian nuclear sector make Jaitapur a prime candidate for a second
Fukushima. In the interest of nuclear safety, the undersigned organizations therefore
urge you to withhold export credit guarantees for this project.
We look forward to your reply and would welcome the chance to discuss this matter in
more detail in a meeting with your staff.
First signatories :
Heffa Schücking, Urgewald (Germany)
Yann Louvel, BankTrack (International)
Elvira Pöschko, Antiatom Szene (Austria)
Sophia Majnoni, Greenpeace France
Juliette Renaud, Friends of the Earth France
Peer de Rijk, WI
Uwe Hiksch, NaturFreunde Deutschlands