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Dr. A. Gopalakrishnan, former chairman of the Atomic Energy Regulatory Board cautions, based on the sparse specifics available in the public domain and comments by authority figures that the government may be concealing information about the magnitude of the accident at KAPS (Kakrapar Atomic Power Station) Unit 1

 

The Kakrapar Unit-1 PHWR Primary System Leakage Incident on March 11, 2016

The Kakrapar Unit-I nuclear reactor in Gujarat is undergoing a moderately large leakage of heavy water from its Primary Heat Transport (PHT) system since 9.00 AM on March 11,2016. From the very limited information released by the Nuclear Power Corporation of India Limited (NPCIL) and the Atomic Energy Regulatory Board (AERB) of the government , as well as from the conversations I had with press people who have been in touch with nuclear officials, few inferences can be drawn.

Till 7.00 PM on March 12,2016 , the DAE officials have no clue as to where exactly the PHT leak is located and how big is the rate of irradiated heavy water that is leaking into the reactor containment . However, some reports indicate that the containment has been vented to the atmosphere at least once , if not more times , which I suspect indicates a tendency for pressure build up in that closed space due to release of hot heavy water and steam into the containment housing . If this is true, the leak is not small , but moderately large , and still continuing. No one confirms that any one has entered the containment (in protective clothing) for a quick physical assessment of the situation , perhaps it is not safe to do so because of the high radiationfields inside . When NPCIL officials state that the reactor cooling is maintained , I believe what they may be doing is to allow the heavy water or light water stored in the emergency cooling tanks to run once-through the system and continue to pour through the leak into the containment floor through the break .

All this points to the likelihood that what Kakrapar Unit-1 is undergoing is a small Loss-of-Coolant Accident (LOCA) in progress. It is most likely that one or more pressure tubes (PT) in the reactor (which contain the fuel bundles) have cracked open , leaking hot primary system heavy-water coolant into the containment housing . The reactor cooling is said to be maintained which , in view of the PT breach , can only be by supply of heavy water or light water from the storage tanks of the emergency cooling systems . While it may perhaps ensure bulk coolant temperatures in the PHT system to be well under control , it could still mean fuel centreline temperatures in the channel which may have a breach could be quite high . The seriousness of the accident and the potential high risks to the plant and personnel in the near vicinity are yet to be assessed , because NPCIL and AERB do not yet know where the location of the leak is or how to initiate actions to stop it. They were waiting for a team of AERB Specialists to reach Kakrapar in the afternoon of March 12 th. (today) to jointly decide between AERB & NPCIL how to proceed from here on. This is therefore a potentially serious accident in progress , and the DAE, NPCIL and AERB appear to be clearly saying at the moment that they know very little of what is happening. I was just told that a senior team from AERB has reached Kakrapar this evening and now the serious accident investigations will hopefully begin and decisions initiated .

In August 1983 , the Pickering Heavy Water Reactor in Canada had a serious Small LOCA , due to a sudden two-meter long rupture of a pressure tube (PT). Upon later analysis , the cause was found to be the mislocation of annulus gas spacer springs which allowed the pressure tube to sag and contact the calandria tube , leading to hydrogen enrichment of the cooler areas of the PT. This made the tube more brittle in such cooler locations and it ruptured due to the internal fluid pressure. In 1983 , when this accident in Canada occurred , India was under international nuclear sanctions following the Pokhran-1 test and it took some time before root causes of this accident were understood by our Department of Atomic Energy (DAE) institutions. But , the Bhabha Atomic Research Centre (BARC) did commendable work immediately in analysing the phenomenon of hydriding of PTs in a PHWR , and carried out experiments, developed computer programs and the appropriate PT Integrity Inspection Equipment within the next decade. Based on all this work , a Pressure Tube Aging & Integrity Management Program was develop jointly by BARC & NPCIL , for strict adherence to and use by NPCIL in all their PHWRs. Besides , it was found essential that the PT material has to be changed to Niobium-stabilized Zircalloy , and accordingly all previous Indian PHWRs including Kakrapar Unit-1 were re-tubed with the new alloy tubes in subsequent years . But , this re-tubing did not preclude the need for strictly following of the PT Aging Management Program and the periodic checking of the garter spring position between the PT and the Calandria tube to minimize the PT sagging within the calandria tube. It may be possible that , having built more than 20 PHWRs , NPCIL and AERB in recent years have become overconfident and relaxed their strict adherence to this Aging Management Program , which might have been the reason for the current accident.

Let me caution the reader that the above conjecture is based on bits and pieces of reliable and not so reliable information gathered from different people close to the accident details and in positions of authority. Future detailed evaluation may or may not prove my entire set of conclusions or part of them to be not well-founded. But , technical experts are compelled to put out such conjectures because of the total lack of transparency of the Indian cilvilian nuclear power sector and the atomic energy commission (AEC) , the Dept. of Atomic Energy (DAE) , the NPCIL and the AERB . Public have a need to know and , therefore , the AEC and its sub-ordinate organizations need to promptly release status reports on the progressing safety incident which could affect their lives , to alleviate their concerns and anxieties . It is a series of such lapses in communication over the years which has built up the ever-increasing trust deficit in the DAE system among the general public. All future plans for expanding the civilian nuclear power sector should be put on hold until a truly independent nuclear safety regulator is put in place , who is not controlled by the AEC or the Prime Minister’s Office (PMO) , who will then be answerable to openly communicating with the public on all civilian nuclear power matters.

(Dr. Gopalakrishnan is a Former Chairman of the Atomic Energy Regulatory Board , Government of India. He can be reached at agk37@hotmail.com )

This article was originally published on the Dianuke website.

2-10-2012

KUDANKULAM NUCLEAR PLANT SAFETY

AERB & BARC RESPONSIBLE.

MoEF, CPCB, SPCB MINIMAL FORMAL ROLE.

  1. ENVIRONMENTAL CONCERNS:

The National Environment Policy, 2006 sets human beings at the centre of sustainable development. People are entitled to a healthy and productive life in harmony with nature. The object of environmental governance is to be achieved by application of ‘ the principles of good governance ( transparency, nationality, accountability, reduction in time and cost, participation, and regulatory independence) to the management and regulation of use of environmental resources. The above object is based on the principles ‘depending upon their relevance feasibility in relation of the cost, and technical and administrative aspects of their application.

(1.2) ENVIRONMENTAL STANDARD SETTING:

The environmental standards must reflect the economic and social development situation in which they apply. Standard adopted in one society or context may have unacceptable economic and social costs if applied without discrimination in another society or context. Setting environmental standard would involve several considerations, i.e. risk to human health, risk to other environmental entities, technical feasibility, cost of compliance, and strategic considerations.

(1.3) PREVENTIVE ACTION:

It is preferable to preventenvironmental damage from occurring in the first place, rather than attempting to restore degraded environmental resources after the fact.

Extracts from National Environment Policy, 2006, Government of India.

    1. ENVIRONMENT( PROTECTION) RULES, 1986:

Rule 12 of the EP Rules, 1986 provides names of agencies which are to be intimated in case of discharge of pollutants in excess of the prescribed standard or apprehension of accident or other unforeseen event, namely

  1. Disaster management agencies at the district or state level.

  1. Central Pollution Control Board.

  1. State Pollution Control Board.

  1. Statutory Authorities and Agencies specified in column 3 in schedule v to these rules which are reproduced below:

1

Factories as defined under the Factories Act, 1948-

(a) Owned by the Central Government and engaged in carrying out the purposes of the Atomic Energy Act, 1962

(i) Atomic Energy Regulatory Board (AERB)

(ii) The Ministry of Environment & Forests

The Atomic Energy Act, 1962.

  1. GENERAL STANDARDS FOR DISCHARGE OF ENVIRONMENTAL POLLUTANTS.

SCHEDULE –VI: ( See Rule 3(3a):

Sl.No.

34

Parameter

Radio Active Materials:

(a) Alpha emitters

[Micro curie/ml] Max

  1. Beta emitters

[Micro curie/ml]

Max

Inland surface water

107

106

Public sewers

107

106

Land for Irrigation

108

107

Marine Costal Areas.

107

106

    1. HAZARDOUS WASTES MANAGEMENT RULES 2008

Rule 2. Application : The rules shall apply to the handling hazardous wastes as specified in the schedules and shall not apply to:

  1. radio- active wastes as covered under the provisions of the Atomic Energy Act, 1962 (33 of 1962), and the rules made there under;

    1. The Atomic Energy Act, 1962

Section 2(i): Radio active substance or radio active material means any substance or material which spontaneously emits radiations in excess of the levels

prescribed by notification by the central government.

Section 3 (c) The central government shall have power to declare as ‘restricted information’ any information not so far published or otherwise made public relating to:

    1. To provide for the production and supply of electricity from atomic energy and for taking measures conducive to such production and supply and for all matters incidental thereto; [either by itself or through any authority or corporation established by it or a government company]

Section 18(i): The Central government may by order restrict the disclosure of information:

  1. Nothing in this section shall apply:

  1. to the disclosure of information with respect to any plant of a type in use for purposes other than the production, development or use of atomic energy, UNLESS the information discloses that plant of the type is used or proposed to be used for the production, development or use of atomic energy or research into any matters connected therewith;

4.2. The Supreme Court in AIR 2004 SC 1442 PUCL Vs. UOI, in para 68 says, “once provisions of Section 18 of the Act, and the order framed there under are held to be intra vires, the only question which arises for consideration is as to whether exercise of such power should be held to be invalid by this court. The jurisdiction of this court in such matter is very limited. The court will not normally exercise its power of judicial review in such matters unless it is found that formation of belief by the statutory authority suffers from mala fied, dis- honesty or corrupt practice. The order can be set aside if it is held to be beyond the limits for which the power has been conferred upon the authorities by the legislature or is based on the grounds extraneous to the legislation and if there are no grounds at all for passing it or if the grounds are such that no one can reasonably arrive at the opinion or satisfaction required there under. No such case has been made out by the appellant.” (PUCL)

Section 28 : EFFECTS OF OTHER LAWS: The provisions of the Act shall have effect not withstanding any thing consistent therewith contained in any enactment other than this Act or any other instrument having effect by virtue of any enactment other than this act.

    1. BARC AGENCY FOR MEASURING RADAITION.

The Bhabha Atomic Research Centre is the only agency qualified for measuring radiation and its services are available to all nuclear power plants.. The data collected by other agencies is sent to it for analysis. In the case of (1987) 3 SCC 231 M.K.Sharma Versus Bharat Electronics, the supreme court in para 4 states, “4. The Respondent Company has a system of film badges for measuring radiation absorbed during a month and the data which is sent to the BARC for evaluation on monthly basis. The result of such analysis shall be duly publicised and would also be communicated to the petitioner- union at reasonable intervals.”

CONCLUSION:

Reading of the above relevant extracts leads to only one conclusion that in India the Atomic Energy Regulatory Board (AERB) and BARC are the two agencies responsible for matters relating to production and supply of electricity from atomic energy and to ensure safe disposal of radio active wastes. The Ministry of Environment,Central Pollution Control Board, State Pollution Control Board play a formal limited role only because they neither have the expertise nor the necessary equipment to analyse radiation from radio active material/wastes. Thus, in view of the above conclusion even though environmental clearance notification 1994/2006 (amended from time to time) may legally apply to a new atomic energy producing plant but in fact the entire regulatory responsibility is of AERB and not MoEF.

VIJAY PANJWANI

ADVOCATE

SUPREME COURT OF INDIA

NEW DELHI

DATED: 2-10-2012