By Dr. A .Gopalakrishnan (a past chairman of the Atomic Energy Regulatory Board)

The government, through its Department of Atomic Energy (DAE), the Nuclear Power Corporation Limited (NPCIL), and the Atomic Energy Regulatory Board (AERB) is racing to bring the Kudankulam Nuclear Power Project, Unit-1 (KNPP-1) to full-power operation at the earliest. The questions predominantly troubling the conscientious public today are simply these: Is the Kudankulam Unit-1 ready for introduction of nuclear fuel assemblies into its core (‘fuelling’), having fully completed all the safety modifications and additions recommended by AERB’s Post-Fukushima Committee to Review Safety of Indian Nuclear Power Plants? What other mandatory, pre-fuelling safety-related tasks such as conducting proper emergency drills in villages within a 30 km-radius of the reactors remain? What are the serious implications to public safety if NPCIL and AERB move forward with fuelling activity and bring this reactor to its full power of 1000 MWe in the current state of inadequate and incomplete safety status?

On some of the glaring defaults of the current actions of the DAE, NPCIL and the AERB vis-à-vis KNPP-1, there are three Special Leave Petitions (SLPs) currently before the Supreme Court of India. The next hearing of one SLP that seriously pleads for stopping fuelling activity is set for September 27. As early as on March 26, 2012 , a writ petition (no. 8262) was filed in the Madras High Court for a direction against the DAE, NPCIL, AERB and others to implement all the recommendations of the AERB’s Post-Fukushima Report before fuel-loading is started. In response, the AERB counsel informed the court , “— that before initial fuel loading is done, the compliance of all the requirements under Annexure-8 (of the AERB report) will be ensured by the AERB and it is only after its satisfaction any direction (for loading fuel) will be given—” . Subsequently , the High Court decided to reserve its orders on August 2, 2012 , pending detailed judgement to follow.

n the interim, since the court had not imposed any stay on actions by NPCIL and AERB, chairman, AERB, used this opportunity to issue a clearance for initial fuel loading of KNPP-1 on August 10 after reviews by their internal committees. The original petitioner then filed yet another writ petition (no. 22253) in the Madras HC on August 13, challenging the fuel-loading clearance given by AERB, even while 11 out of the 17 safety recommendations of the AERB’s Post-Fukushima Report still remained to be implemented. AERB, in reply to this writ petition, submitted two affidavits, first one on August 18 and another on August 22.

he post-Fukushima evaluations by an independent AERB committee, headed by a past chairman of the AERB had recommended 17 safety upgrades in Annexure-8 of its report. The committee, however, did not sort these on the basis of relative importance, urgency or priority. The sense you get from this report is that all 17 corrective steps are equally important and AERB must insist on all of them being fully implemented and tested before fuel-loading is permitted. This is consistent with the affidavit earlier submitted to the Madras HC by Mr R. Suresh Kumar, counsel for AERB, “ — that before initial fuel loading is done, the compliance of all the requirements under Annexure-8 will be ensured by the AERB and it is only after its satisfaction that any direction will be given—–” .

However, in their affidavits to the same court on August 18 and 22, AERB reversed its stand by stating, “—recommendations in Annexure-8 of the Post-Fukushima Report were considered (by the internal AERB committees) during review of the application for fuel loading submitted by NPCIL. The review indicated that KNPP-1 has adequate safety measures against external events — In order to further enhance safety , as an abundant measure , some additional safety enhancements proposed by NPCIL were reviewed in depth and accepted for implementation in a phased manner.”

“Based on the review and resolution of NPCIL submissions, AERB agreed for short-term (less than six months) and long-term ( less than two years) implementation of the Post-Fukushima recommendations from the date of the fuel-loading clearance”.

Ultimately, the Madras HC did not agree with the plea of the protesters for full implementation of Annexure-8 safety steps before fuel loading is initiated and the matter is now being heard by the Supreme Court. Even as the Supreme Court hearings are going on, the NPCIL and the AERB are already loading the nuclear fuel into KNPP-1.

What the AERB has done is a total volte face of its earlier stated positions in the Madras HC, and contrary to the spirit and recommendations of the AERB Post-Fukushima Safety Evaluation Committee.

This has happened because the DAE, NPCIL and AERB appear to be under the direct control of the PMO on the Kudankulam issue, and none of them dares to take any decisions on their own.

The PM, is for months accused in the national and international press for India’s policy paralysis, the dwindling performance of the power sector, and for substantial slippage in the execution schedules of many major projects. During his last two visits to Russia, the PM promised expeditious completion of KNPP-1&2. The local protests at site have put a monkey wrench into his promises and timetable. PM and his PMO consider their face-saving to be more important than the possibility of imperiling the lives of people living near KNPP-1, and appear to have clearly instructed the DAE-AERB combine to rush through with commissioning the plant. The subservient DAE and AERB seem to be complying with his directions.

In this hurried approach to starting the KNPP-1 project, what essential safety precautions are the NPCIL and AERB tossing by the wayside? As per current plans, the reactor will be operated at least for the first two years or more at the full power level of 1000 MWe, without its primary containment being assessed for its ultimate load-bearing capacity; without the availability of a portable diesel-powered unit with sensors and instrumentation to monitor essential safety parameters in case of a total blackout; in the absence of a set of mobile self-powered pumping set for emergency area use; without rectifying the serious inadequacies in instrumentation for independent monitoring of plant status during major accidents; and without the addition of mobile back-up power units like air-cooled diesel sets. Why each of these actions should take as long as 24 months to complete is unimaginable, but these actions have to be indeedexpedited, since they are all essential for mitigating the consequences of a major accident.

The AERB committee has also strongly recommended the urgent installation of an additional seismically-qualified 8,000 cubic-meter capacity back-up water storage tank as an alternate source for use under emergency situations where such actions as injection of borated water into the core and into the spent-fuel pool, charging water into the steam generator secondary side, etc will require excessive amounts of water. The already provided emergency water-storage facility has not been seismically-qualified and may not withstand moderate earthquakes. This anomaly has to be urgently rectified through analysis and repair. This existing storage was also found to be inadequate in holding capacity , for removing decay heat for a period of a minimum one week . This too is to be rectified. In case of a beyond design basis accident (BDBA), the emergency operating procedures to be used are still to be formulated and documented, to help impart training on BDBA to the operating staff.

It is more than 16 months since the Fukushima accident occurred and NPCIL has not even started planning for these procedures. Each of the above tasks is put in for “short-term” completion, namely, within the next six months. I doubt whether a satisfactory completion of many of these tasks can be achieved in six months, each may take more like one year at least.

As it stands, the important point to note is that NPCIL and AERB are NOT going to carry out any of the short or long-term tasks mentioned above, before the reactor is fuelled and brought to 1000 MWe power level. This approach is totally unacceptable from the safety point of view. Whether these 17 safety corrections are implemented or not, the probability of a major accident will remain more or less the same. But, ALL these safety corrections are necessary to ensure that the mitigation of the consequences will be far more acceptable with the corrections implemented than without, and these safety corrections will provide a distinctly safer environment for populations around the KNPP-1. Therefore, ALL the above-mentioned long-term and short-term safety corrections recommended by the AERB committee must be completed before the reactor is fuelled. Whatever fuel so far loaded into the core can be taken out safely and stored for future use.

The author Dr. A. Gopalakrishnan is a past chairman of the Atomic Energy Regulatory Board (AERB).

Reproduced from DNA

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