To
Shri Rajiv Gauba
Cabinet Secretary
Government of India
Dear Shri Gauba,
I had earlier written to the Department of Atomic Energy on 13-9-2019 on my concerns, both technical and financial, about the proposal to set up a nuclear power plant of 9,000 MW consisting of six EPR reactors to be supplied by EDF of France. It is possible that this proposal will figure in the bilateral discussion that is going to take place shortly when the Indian Prime Minister visits France.
There are technical concerns (https://www.bloomberg.com/news/articles/2022-10-27/edf-says-reactor-corrosion-repairs-are-on-track-as-winter-looms#xj4y7vzkg) that need to be resolved in the case of the reactors to be supplied by EDF, especially keeping in view the fact that the Jaitapur project comprising six reactors at one location is the largest of its kind and the cumulative accident risks associated with such a large reactor complex need to be addressed objectively. India’s civil nuclear liability legislation transfers the major portion of the liability arising from an accident (with the Fukushima nuclear accident in view) to the DAE/NPCIL. Further, though more than a decade has elapsed since the DAE introduced a draft nuclear regulatory authority Bill in the Parliament and the concerned Parliamentary Committee made several salutary recommendations to enhance the independence of the regulatory authority, the Department has not further acted on those recommendations, leaving the Bill still to be processed for enactment. India cannot afford to go ahead with such a large nuclear project complex in the absence of an independent regulatory authority.
Coming to the financial viability of the Jaitapur project, The time and the cost overruns in the case of the Flamville EPR reactors set up in Finland by Areva, a subsidiary of EDF should prompt the DAE to take into account similar delays and cost escalations likely to take place in the case of Jaitapur. In addition, considering that the Jaitapur reactors will run on imported uranium fuel, the recurring costs of Jaitapur power will be subject to foreign exchange rate variation, in addition to the fuel cost which is likely to harden as a result of the monopolistic trends appearing in the global uranium supply market. The EPR reactors themselves are being procured through a highly non-transparent procedure which makes it difficult to secure them at an internationally competitive price. All these factors will collectively escalate the unit cost of electricity supplied from the Jaitapur project. The increased cost burden on that account will ultimately have to be borne by the electricity consumers of Maharashtra and those in the Western Region. If such expensive electricity is to be subsidised, the corresponding burden will fall on the tax-payer.
The DAE and the Ministry of External Affairs should consider these concerns with the seriousness they deserve in providing appropriate inputs to the Prime Minister for the ensuing bilateral discussion.
Regards,
Yours sincerely,
E A S Sarma
Former Secretary to the Government of India
Visakhapatnam
