A.Gopalakrishnan: Address concerns on nuke plant

[Sukla Sen]

http://newindianexpress.com/opinion/Address-concerns-on-nuke-plant/2013/05/15/article1590216.ece
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Address concerns on nuke plant

Author: A Gopalakrishnan

Published Date: May 15, 2013 7:17 AM
Last Updated: May 15, 2013 7:20 AM

Through an article titled “Resolve Koodankulam Issues” in TNIE (April
19, 2013), I had brought out certain serious safety issues emanating from
the supply of substandard components and equipment imported and installed
in the Russian VVER 1000 MWe Units 1 and 2 at the Koodankulam Nuclear Power
Project (KKNP) under construction in Tamil Nadu, India. I had also pointed
out that a major Russian government company, ZiO-Podolsk, might have
supplied components and equipment of poor quality to KKNP, possibly
impacting the reliability and safety of the two nuclear reactors there.

My article brought forth clarifications on this matter from the Nuclear
Power Corporation of India Limited (NPCIL), a public sector undertaking of
the Department of Atomic Energy (DAE), Atomic Energy Regulatory Board
(AERB) which is the captive nuclear safety regulator reporting to the
secretary, DAE, and Atomic Energy Commission (AEC). All of them and the
Prime Minister’s Office (PMO) knew of these serious shortcomings, but kept
quiet until I spoke out.

The AERB statement was merely a rehash of their quality control
procedures, while NPCIL’s April 19th press release said, “Contrary to press
reports, the passive heat removal system (PHRS) has worked during the
integral testing as designed.” This is false, because the actual full
performance of the PHRS cannot be tested in situ until after a few months
of reactor operation at full power. No simulated testing of the PHRS was
done at the manufacturer’s works, and at the KKNP site NPCIL found out that
the damper-air vane-heat exchanger combination was not working as required.
Therefore, for the first year of operation at full power, we have no
assurance that the heat exchange processes in the PHRS will work as per
design intent.

NPCIL, in an additional clarification released on April 20, admitted
that “four valves in the passive core-flooding system, though initially
tested in factory premises under simulated conditions, showed variations
from expected performance during integrated testing at the KKNP site.” This
underplays the gravity of the entire situation. These four are “special
check valves”, and they are crucial to the long-term core-cooling under
severe accident conditions, including a total loss of electric power. It is
a fact that no adequate testing of these valves was done in Russia. How
could this happen in spite of the highly-lauded, multi-tier quality control
programme under which NPCIL claims that an inspection team of theirs,
stationed in the Russian factory, has witnessed and signed off on this
testing?

On April 29 and May 6, 2013, V Narayanaswamy, minister of state in the
PMO, appeared on the NDTV debate and answered few questions regarding the
KKNP problems. In response to specific points I had raised in my TNIE
article, the minister said, “The four valves which were found faulty did
not come from ZiO-Podolsk. These are four small components and they have
now been replaced. The replacements did not come from the same (Russian)
supplier. If some company official of theirs has erred, the Russians will
act on this. We have nothing to do with it.” The minister’s shallow
appreciation of the seriousness of the matter is evident from his reply.

On August 31, 2012, the Madras High Court had delivered its judgment on
a set of writ petitions filed against commissioning of the KKNP-Units 1 &
2, until a thorough review of several outstanding safety issues are settled
first. Its 281-page judgment gave some important directives, which NPCIL,
AERB and the Tamil Nadu Pollution Control Board (TNPCB) were to fulfill
before commissioning the reactors. Unsatisfied with this judgment, the
petitioners filed a special leave petition (SLP) in the Supreme Court of
India (SC) on September 11, 2012, seeking an injunction on NPCIL from
initiating further pre-commissioning activities. The SC sought several
clarifications and affidavits from the petitioners and respondents, and
held several hearings on this SLP till December 2012. The judgment was
reserved, to be delivered after the court’s vacation recess.

Meanwhile, new doubts regarding the import and installation of
substandard parts in KKNP-1&2 from foreign suppliers including ZiO-Podolsk
of Russia came to light through Russian media reports. The petitioners,
therefore, filed an additional SLP on April 23, 2013, in the SC, bringing
out the question of these supplies of dubious quality, and the
consequential implications on the safety of these reactors. My TNIE article
dated April 19, 2013, and other documents were also appended to this SLP.

Taking into account all submissions of the petitioners, the Supreme
Court pronounced its final judgment on May 6, 2013. There are many parts of
this judgment with which many learned critics are in disagreement. But,
what is of immediate importance are the specific “directions” given in the
judgment, which need to be implemented before these nuclear reactors are
commissioned. Viewed from this perspective, from among the SC directions
which must be addressed prior to commissioning, the following two
directions given under S. Nos (1) and (15) are the ones that directly
relate to the reliability and quality of components and systems:

(1) “The plant should not be made operational unless AERB, NPCIL, DAE
accord final clearance for commissioning of the plant ensuring the quality
of various components and systems, because their reliability is of vital
importance.”

(15) “The AERB, NPCIL, MoEF and TNPCB would oversee each and every
aspect of the matter, including the safety of the plant, impact on
environment, quality of various components and systems in the plant before
commissioning of the plant. A report to that effect be filed before this
Court before commissioning of the plant.”

Only in the SLP dated April 23, submitted to the SC after all the
hearings were over, did the petitioners first raise concerns regarding the
quality of components and systems received from abroad. In spite of the
delayed submission of the SLP dated April 23, 2013, the SC appears to have
taken cognisance of that SLP, as clearly evident from the above two
directions given by them.

Under their direction No (15), the court has enumerated three different
areas for application of focused oversight by the four listed
organisations, viz. AERB, NPCIL, ministry of environment & forests (MoEF)
and the TNPCB. These three areas are: (a) safety of the plant (b) impact on
environment and (c) quality of various components and systems in the plant.

I have the following considered views and recommendations on how these
four bodies must proceed to comply fully with the SC directions:

1) The chief administrators of the three regulatory entities (AERB, MoEF
and TNPCB) among the four organisations must understand that the intent of
the SC is that each one of them will apply their mind and use their
expertise to the maximum extent to independently examine all the three
areas (a), (b) and (c) above. They can seek whatever relevant information
and data they need from the NPCIL and the Koodankulam station director.

2) NPCIL is bound by the SC order to co-operate, and there shall be no
interference or adverse external influence on the four agencies from the
PMO, the TN government, AEC and the DAE while they are carrying out this
independent examination on behalf of the SC.

3) The final report to the SC must be prepared by all four organisations
entrusted with the task, and reflect that they have jointly and severally
examined all three subject areas and reached conclusions. If any one of the
organisations has a dissenting view from that of the majority on any
aspect, it is incumbent upon it to express this in writing. Keep in mind
that the final report, after it is submitted to the SC, will be a document
which can be sought in toto by the public, under provisions of Section 4 of
the Right to Information (RTI) Act.

As far as the process of evaluation in each subject area is concerned,
the committee of representatives from the four organisations needs to
discuss the details at the outset and chalk out a comprehensive plan for
each area, so that the SC’s direction can be fully met in letter and
spirit. As for subject area (c), on the quality of various components and
systems in the plant, the choice of which components and systems to
retrospectively re-examine and how this should be done at this late stage
may indeed pose a dilemma. Obviously, all components and subsystems in a
nuclear plant cannot be physically examined. Examining whether quality
assurance checks have been done adequately is possible to some extent from
reviewing the available documentation and their authenticity.

From my past experience over decades of occasionally being called upon
to do such policing work in some of the world’s best nuclear energy
establishments, if I were to be in such a committee, I would come up with a
priority list of components and subsystems based on where the suspicion of
poor quality or significance to safety lies. In the present case, I will
certainly take a close look at all supplies from ZiO-Podolsk because even
the Russian federal agencies doubt their integrity, all items which came
from the suppliers of the original check-valves in the HA-2 system which
failed, the components of PHRS and their integrated testing at Russian
works, etc. In the best of organisations, one will have a Level-2
Probabilistic Risk Analysis (PRA) report available, from which one can
discern the safety significant components and subsystems to focus on. To
the best of my knowledge, no such PRA exists for the Koodankulam reactors.

A Gopalakrishnan is a former Chairman of India’s Atomic Energy
Regulatory Board

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