(Remarks made by Dr.A.Gopalakrishnan, Former Chairman, Atomic Energy Regulatory Board at Chennai on Jan.30,2016)

Ever since the Fukushima nuclear melt-down in Japan in March 2011, dramatic course-corrections have been initiated in various countries having nuclear power plants .

Immediately after Fukushima, eight of 17 functioning nuclear plants in Germany were shut down, and in June 2011 , that nation decided to  establish a timeline for shutting down all their remaining plants by 2022.  In 2010, Germany’s electricity mix had 23 % nuclear and 17% renewables ; in 2014, it had shifted to 16 % nuclear and 28 % renewables.

In May 2015 , France’s lower house of Parliament  approved a Bill aiming to reduce France’s dependency on nuclear power from the current 75 % to 50 % by 2025. The new Bill also fixes the goal of increasing the proportion of renewables in French electricity production to 40%  by 2030 .

Till very recently , the Indian target for nuclear power was 63,000 MWe by 2032, of which 40,000 MWe was to be generated from imported foreign reactors. This figure was developed during the later stages of the India-US Nuclear Deal to justify that without these reactors imported through this Deal , and an indigenous  fast breeder reactor program linked to it , India’s electricity needs of 2050 cannot be met adequately . But, the real reason for this convoluted argument was that the UPA government had by then already committed to the US , France and Russia that India will purchase at least 10,000 MWe worth reactors from each of these countries as a quid pro quo for their support at the Nuclear Suppliers’ Group (NSG) in getting the India-specific concessions agreed to by the NSG.

Thus, today’s NDA government may have a legitimate right to claim that the path to a large growth rate in Indian nuclear power was handed down to them as a fait accompli  by the UPA government through formalized agreements and understandings with foreign governments , and that the NDA is only following through these UPA commitments.

But considering the drastic change in the outlook of various countries towards nuclear power after the Fukushima accident , it would be wise for the current government to halt the expansion of the nuclear power sector in India and make a re-assessment of the government’s  near-term and long-term plans , in consultation with national experts from outside the government , which may provide some fresh inputs to the government for their consideration . This  will also be in the interest of demonstrating  the ‘transparency in governance’ which the government is trying hard to propagate . After all , we are talking about the civilian nuclear sector and there cannot be any unsurmountable secrecy in this sector which prevents a wider technical, financial , environmental and social audit of our nuclear power plans to be urgently carried out in the public interest. I hope the government will seriously consider this request , especially in view of the soaring costs of nuclear power and the immense dangers inherent in the “Make-in-India” policy intended to be applied mainly to achieve cost-reduction of these reactors from the first Indian unit onwards , especially when you consider that the very first unit of some of these foreign reactors is yet to be constructed and operated by its developer-country itself !

A vivid example on how not to ‘Make-in-India’ even a well-established foreign reactor (about which none of our engineers or local industrial contractors have any complete understanding of the design , construction, and commissioning aspects) is seen in the continuing problems the Kudankulam VVER reactor Unit-1 is  experiencing. For reducing the costs of this very first Russian reactor project in India , the Nuclear Power Corporation of India Limited (NPCIL) had taken on the responsibility of locally procuring several fabricated auxiliary parts as well as most of the erection and commissioning work of the secondary and teritiary systems , except for the larger equipment . In addition , no in-depth and independent quality control checks appear to have been done by NPCIL for bought-out foreign supplies , again in the interest of saving the cost of quality control . Added to this there appear to have been  suspected instances of corruption and malpractices in material procurement , with serious possibility of some of those sub-standard items having been received and installed in Kudankulam Unit-1 before its start-up.

Russia has full experience with different types of VVER reactors and a team of Russian consultants were made available on-call to guide the NPCIL teams and contractors at site , if needed . These consultants appear to have been rarely used during the erection and commissioning stages , which were executed mainly by NPCIL engineers and their Indian contractors , again because of the resistance from the these contractors and in the interest of saving on cost.

The best example of a ‘Make-in-the Nation’ procedure I have come across is how China handled its indigenisation of the second- generation nuclear technology (Gen-2) they imported two decades ago for the Daya Bay project . Li Yulun , a former vice-president of the China Nuclear Power Corporation , has said China was more prudent then , and added that former Chinese premier Li Peng followed what he called the “normal practice” in introducing foreign technology,by insisting on having a precedent reference plant , for which the  total  responsibility rested with the foreign plant supplier . This was a less risky approach since the reference plant’s actual performance parameters were then typically used as the basis for resolving contractual disputes on technical issues, he said. But , these days  China too has been rushing to set up  the world’s first AP-1000 Gen-3 commercial project , under joint responsibility with Westinghouse . In this case, according to Li Yulun , China was taking on higher risks.

The same earlier practice was used when China imported the first two VVER-1000 MWe Russian reactors for the Tianwan Project Phase-1 . Like in the case of Daya Bay Phase-1 , the plant itself was constructed and commissioned under Russian responsibility and subsequently a two-year warranty operation was carried out by the  Russians . This warranty run of the plant was completed in September 2009, and the plant was then formally handed over to the Chinese .This  earlier Chinese practice is a more trouble-free way to introduce a foreign technology product into a country. Any cost reduction through indigenous participation is attempted only after a satisfactory reference plant is operated under full responsibility of the foreign partner.

Unlike the Tianwan Phase-1 reactors , the Kudankulam Units-1 &2 cannot be considered ‘reference plants’ for VVERs in India . The responsibility for the problems at KKNP-1&2 may end up as a disputed  area , with the Russians partly blaming the Indian side, since India had taken the responsibility for erection and commissioning. This approach to ‘Make-in-India’ will always leave the liability for the total plant as a vague shared and disputed area of responsibility of India & Russia.

All this has also cast a grave question mark on the safety of the Kudankulam reactors. Proper answers from the NPCIL and the Atomic Energy Regulatory Board (AERB) to the valid doubts and questions raised by competent critics in the country were not forthcoming .

There is an item under the title ‘Quest for Transparency’ in the Prime Minister’s Office (PMO) website , which says “Prime Minister Narendra Modi firmly believes that transparency and accountability are the two cornerstones of any pro-people government. Transparency and accountability not only connect the people closer to the government but also make them equal and integral part of the decision making process.” This is quite a laudable approach , if it can be seen to be forcefully implemented.  Though such transparency which the PM desires is generally absent  in the nuclear issues , in the Kudankulam case , it certainly raises the doubt that NPCIL and AERB together may be hiding some serious deficiency from the public. This impression needs to be removed by the AERB & NPCIL  by honestly answering the doubts & questions raised by the public on the plant .

The AERB as an “independent” regulator is more of a myth than reality . In 1999 , I was  the first  person to openly bring out the total lack of independence of the AERB from its masters in the Department of Atomic Energy(DAE) . Ever since I left as Chairman / AERB in 1996 , every new Chairman the government has appointed had been a long-standing DAE or NPCIL ex-employee , whose loyalty was almost entirely to the DAE organisations than to the general public. Since then , very scathing criticism about the lack of independence of the AERB has come formally from the International Atomic Energy Agency (IAEA) , the Controller and Auditor General (CAG) of India , the JSCOT  Committee of the Australian Parliament , etc. In recent years , there was an inadequate Bill presented before the Parliament for creating an ‘improved’ nuclear safety regulator. But I understand , because of inaction of the government , that Bill has lapsed and the work has to be re-done. It is high time that the Government considers bringing a fresh Bill before Parliament after due consultation with experts in this field. Until then, AERB is only seen as subservient to the Government , and their opinions will not carry the weight of credibility or conviction anywhere in the world.