This article by Dr. A Gopalakrishnan, the former Chairman of India’s Atomic Energy Regulatory Board, is a sequel to the article highlighting sub-standard supplies in Koodankulam that he wrote last month which has triggered intense debates and concerns. [Courtesy: The New Indian Express]

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.

Dr A. Gopalakrishnan

Dr A. Gopalakrishnan

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.