Kudankulam Nuclear Power Plant Has An Incomplete
Emergency Operating Procedure - AERB
By VT Padmanabhan, R Ramesh & V Pugazhendi
27 August, 2012
Countercurrents.org
Emergency Operating Procedures (EOP)
There have been three accidents involving 6 nuclear power plants and the spent fuel pools between 1979 and 2011. All these were unthinkable and unanticipated before their occurrences. Nuclear operators and regulators have learnt a couple of lessons from these accidents. They hope to avert similar catastrophes by incorporating appropriate operating procedures. NPPs today have three types operating procedures. These are normal operating procedures, abnormal operating procedures and emergency operating procedures. “The normal operating procedures is for operation within specified operational limits and conditions. The abnormal operating procedures is for an operational process deviating from normal operation which is expected to occur at least once during the operating lifetime of a facility but which, in view of appropriate design provisions, does not cause any significant damage to items important to safety nor lead to accident conditions. Emergency operating procedures is for deviations from normal operation more severe than anticipated operational occurrences, including design basis and beyond design basis, which deal with the accident conditions from safety injection of reactor trip actuation up to the point of core damage . (1)
The International Atomic Energy in its Safety Guidelines issued in 2000 states that “operating procedures shall be developed which apply comprehensively for normal, abnormal and emergency Conditions…The guidance provided in the procedures shall be clear, concise, and as far as possible verified and validated…Strict adherence to written operating procedures shall be an essential element of safety policy at the plant”. (2)
According to the International Nuclear Safety Advisory Groups (INSAG), emergency operating procedures (EOPs) are an important component of the defence in depth concept for nuclear power plant operation. “Emergency operating procedures are established, documented and approved to provide a basis for suitable operator response to abnormal events”. (3)
Kudankulam has an incomplete Emergency Operating Procedure
On 21 st of August 2012, 10 days after giving clearance for the Initial Fuel Loading (IFL) of KKNPP Unit No 1, AERB submitted a counter affidavit in the Madras High Court in the writ petition No 22353/2012 – Sundararajan vs Union of India, Department of Atomic Energy (DAE) and others. AERB says that “NPCIL had submitted schemes and schedules for implementations of the recommendations (of Post Fukushima Task Force) and the same was reviewed and resolved satisfactorily by AERB as part of the Clearance for Initial Fuel Loading (IFL) of KKNPP Unit No 1. 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 post Fukushima recommendations from the date of IFL clearance”. (4)
After the Fukushima Nuclear Disaster, the Nuclear Power Corporation of India Ltd (NPCIL) had appointed task forces to evaluate the safety systems of all nuclear power stations in India . The Task Force on Kudankulam Nuclear Power Plant headed by Shri S. Krishnamurthy of Madras Atomic Power Station submitted its report on May 11, 2011 . The committee had made 17 recommendations, 11 to be implemented on a short term basis. One of the short term items was “ finalization of emergency operating procedures for Beyond Design Basis Accidents (BDBA) conditions”. In May 2011, reactor No 1 was almost ready for commissioning. One wonders as to why they did not have the EOP in place. Even fifteen months after the receipt of the Task Force Report, only “EOPs for some postulated initiating events (PIEs) have been made. Remaining are in progress.” (Ref 4). AERB has graciously given six months for finalization of EOP for KKNPP.
Some 8 months before Dr Soumen Sinha, Scientific Officer at AERB made this statement, a Central Government Expert Committee of 15 scientists headed by Dr AE Muthunayagam had made the following statement: “ An elaborate set of emergency operating procedures has been developed to cater to all conceivable off - normal situations and the operators are thoroughly trained in their execution which includes training on a full scope training simulator”.(5) Both these statements cannot be true which means one of them is not telling the truth.
EOP for other VVERs
KKNPP is the first pressurized water reactor (PWR) to be commissioned in India . VVER reactors have been commissioned in Czech Republic , China , Bulgaria and Iran during this century. At Temelin in Czech Republic “t he set of the symptom-oriented operating procedures for the Temelin NPP was developed according to the Emergency Response Guidelines methodology elaborated by the Westinghouse Owners Group. At present these EOPs are fully implemented at the Temelin NPP, being verified and validated on the full scope simulator. Temelin personnel are regularly trained to use them”.(6) Similarly, the Institute for Nuclear Research and Nuclear Energy of Bulgarian Academy of Sciences (INRNE-BAS), Sofia with assistance from the Pacific Northwest National Laboratory (PNNL), under the International Nuclear Safety Program (INSP) of the United States Department of Energy, prepared the symptom based emergency operating procedures for their VVER-1000 reactor at Kozloduy Nuclear Power Plant (KNPP). (7)
International co-operation in EOP
Under the aegis of the Lisbon Initiative, teams consisting of DOE personnel (mostly from the Argonne and Pacific Northwest national laboratories), together with industry experts in power plant operations and operator training, were engaged to provide training and advice to staff members at VVER plants in Russia, the Ukraine, and Eastern Europe for learning to develop symptom-based emergency operating procedures for VVERs. Four meetings were held overseas each year, and numerous US plants allowed the team to train on their simulators ( Russia had no full scope simulators at the time, although their development was taking place concurrently under other assistance programs). (8)
Even India benefitted from this international co-operation. AERB has been interacting with other regulators on EOP and reactor-safety related issues. Between 2003 and 2008 (AERB Silver jubilee year) “nine meetings have been held between AERB and US Nuclear Regulatory Commission (NRC) with the meeting venues alternating between India and USA . Some important topics discussed during these meetings include Probabilistic Risk Assessment Technology, License renewal of old reactors, emergency operating procedures , passive systems reliability evaluations and severe accident analysis”. (9)
They did not complete the EOP during the 15 months since the submission of the Task Force Report. EOPs contain instructions for operators to deal with emergencies. How can a machine with potential for catastrophic accident be commissioned without an emergency operating procedures? AERB has given six months time for NPCIL to prepare that document. What will the operators do if that initiating event happens during that grace period?
Dr. V. Pugazhendi is acclaimed for his rigorous and credible studies on health impact of radiation around Kalpakkam nuclear site. He is an activist belonging to the Doctors for Safer Environment
>>>>>>>>>>>
Dr. R. Ramesh a medical practitioner, who has written books on the geology of Kudankulam
>>>>>>>>
VT Padmanabhan is a researcher in health effects of radiation. He has led epidemiological investigations among people exposed to high radiation in Kerala. He has also studied the occupational radiation hazards among workers of Indian Rare Earths, genetic effects of children exposed to MIC gases in Bhopal, health hazards to workers in a viscose rayon unit in Madhyapradesh and reduction of birth weight of babies near a beverage bottling plant in Kerala. He has visited several contaminated sites in Belarus and Japan and had extensive interactions with the survivors.His papers have been published in International Journal of Health Services, Journal of American Medical Association, International Perspectives in Public Health, the Lancet and Economic and Political Weekly. He is a member of the European Commission on Radiation Risk, an independent body of experts appointed by the Green MEPs in Europe. He can be reached at [email protected]
1. Design of Digital Operating Procedure for FuQing NPP 1/9 , Zhangli General Design Department, CNPE China, entrac.iaea.org/.../Zhang
2. International Atomic Energy Agency, Safety of Nuclear Power Plants: Operation, IAEA Safety Standards Series No. NS-R-2, IAEA, Vienna (2000).
3. International Nuclear Safety Advisory Group, Basic Safety Principles for Nuclear Power Plants, 75-INSAG-3 Rev.1, INSAG Series No. 12, IAEA, Vienna (1999).
4. Soumen Sinha, 2012, Counter affidavit dt 22 Aug 2012 in writ petition No No 22353/2012 – Sundararajan vs Union of India, Department of Atomic Energy (DAE) and others
5. AE Muthunayagam, et al, 2011, Safety Of Kudankulam Nuclear Power Plant And Impact Of Its Operation On The Surroundings Report By Expert Group Constituted By Govt. Of India, page 18
www.barc.ernet.in/egreport.pdf
6. The Expert Mission With Trilateral Participation Established Under The Melk Protocol , (Chapter iv), 2001 , Executive Summary , www.Anti.Atom.At/Uploads/Studien/010727eu_Ber.Pdf
7. M.P. Pavlova , P.P. Groudev , Vassil Hadjiev , 2007, Systematic approach for the analytical validation of Kozloduy NPP, VVER-1000/V320 symptom based emergency operating procedures, DOI:10.1016/j.pnucene.2007.10.002, https://www.researchgate.net/publication/223293027
8. Michael K. Launer, Ph.D. Rosatom Seeks To Certify Its VVER (PWR) Nuclear Plant Design in the U.S. and U.K. , 2012 , http://www.renewableenergyworld.com/rea/partner/russtech-inc/news/article/2012/07/rosatom-seeks-to-certify-its-vver-pwr-nuclear-plant-design-in-the-u-s-and-u-k
9. A.R. Sundararajan, K.S. Parthasarathy, S. Sinha (ed), 2008, Atomic Energy Regulatory Board 25 Years Of Safety Regulation, www.aerb.gov.in/T/sj/book/chapter13.pdf
Comments are moderated
