27 November 2020, NIICE Commentary 6519
Dr. Anamika Asthana
Under the National Disaster Management Act, the Atomic Energy Regulatory Board is mandated to coordinate with the disaster management force and devise effective ways to prevent and mitigate radioactivity related crisis events, if that happens. Though the Atomic Energy Regulatory Board (AERB), national nuclear regulatory authority, is not the governing authority for the purposes of the Civil Nuclear Liability for Nuclear Damage Act 2010 and the Civil Liability for Nuclear Damages Rules, 2011, it is supposed to notify occurrences of all nuclear incidents.
Based on the severity of the potential consequences, the AERB classifies nuclear power plant related emergencies into following categories: Emergency Alert, Plant Emergency, Site Emergency and Off-site Emergency. The first three are contained within the plant boundary and the operator is supposed to have comprehensive Emergency Preparedness and Response plans (EPR). Simulation exercises are carried out every quarter by each Nuclear Power Point to streamline response to such eventualities if they ever occur. A prior information is given to the AERB and it is up to the latter then to decide if it wants to observe the exercise. The off-site emergency classification, however, is not in sync with the IAEA classification.
An off-site emergency involves the local district administration under the district collector for providing necessary infrastructure. The AERB is obliged to observe the off-site emergency exercises (which happen every two years) while its presence for other emergency exercises is not mandatory. The review report is shared with the utility and the District Magistrate. The regulatory team also reports it to the AERB. These are mentioned in the annual reports. It is, however, the duty of the utility to ensure that the follow up action of the district authority is ensured. While the AERB may suggest measures in such cases, it does not involve itself in the coordination with the local authorities. It, however, has power to review the progress made by the utility.
The Integrated Regulatory Review Service (IRRS) team suggested that the Emergency Preparedness Response (EPR) management should be equipped with full-time specialists and the current arrangement (at the time of review in 2015) with a total of 8-12 personnel assigning 30 percent of their time to it, is inadequate. Also, the role of AERB in crisis situation is rather limited. As per Civil Liability for Nuclear Damage Act, AERB has to notify a nuclear incident after assessing the gravity of risk involved and ensure its wide publicity. For facilities which are not under the purview of AERB, the information of the incident is communicated to AERB by the Department of Atomic Energy (DAE) for notification. The IRRS team suggested that the regulatory presence on site during emergency could help in better assessment. At present, the assessment is done by the Crisis Management Group (CMG at DAE which has one AERB member) and then AERB analyses the assessment of this body. Direct verification by the AERB, therefore, is undermined.
After the radioactive exposure through abandoned Cobalt-60 in the scrap market of Mayapuri in Delhi, leading to death of 1 person and health issues in a few others, the nuclear establishment took efforts to account for the inventory of radioactive material imported before the establishment of AERB in 1983. In November 2011, a proposal to provide Mobile Radiation Detection Systems (MRDS) to 800 police stations covering 80 cities was reported by PTI. These MRDSs were to be fitted to police vehicles to “detect and get alerted in case a van approaches any radioactive source or a radiologically contaminated area or detects any radioactive source being transported”.
The National Disaster Management Authority (NDMA) started training police personnel with MRDSs since 2016. The NDMAs attempts at containing or preventing radiological hazards through MRDSs also get coordinated help from trained experts of specialized facilities of the DAE and national disaster response force stations. The implementation, however, was at snail pace; from 2016 to 2017, 5 batches of trained personnel were reported, that too, not from all Indian states and union territories.
These centres manage responses to radioactive crisis, events and maintain trained emergency response teams and radiation detection instruments and systems. The Emergency Response Teams (ERT) comprise of several specialized teams like the Aerial Survey Team, Field Monitoring Team and so on, with Bhabha Atomic Research Centre (BARC) being the nodal agency. In case of an event, first of all, a Quick Impact Assessment is made through the help of an Impact Assessment Software developed by the BARC. The nearest ERT is activated by the CMG of the DAE, on receipt of confirmation. The CMG investigates the damages and coordinates between state and central agencies to generate an effective response to the crisis.
Specific institutions like NDMA have been created to deal with nuclear accidents over the years but the efficacy of such bodies, remain unevaluated as there has not been any major nuclear emergency in India. The absence of a relatively major crisis within India has tacitly been heralded within the policy circles as an important rationale for continuing more or less with the same regulatory structure, along with a few technical and medium level modifications. Though the possibility of a nuclear accident is not categorically denied by the establishment, there appears to be a strong sentiment that India’s safety, security preparedness is advanced enough to not let an adverse event spiral into a crisis.
The disaster preparedness, in India, however, has been in question for being ineffective and formal. Nuclear Scientist M. V. Ramana has argued that many emergency preparedness exercises conducted as part of the regulatory requirement in India demonstrated several deficiencies and lack of infrastructure. An eye-opener piece by Smita Nair at Indian Express in 2014 highlighted the near absence of infrastructure, command and coordination centres, medical expertise to deal with radioactive contamination, highly lackadaisical attitude of state governments, inadequate disaster management personnel especially given the vast geographical territory of India, overall compromising swift response as well as evacuation requirements in the immediate aftermath of the crisis. While a lack of major crisis in Indian nuclear power plants espouses confidence in the nuclear safety culture in Nuclear Power Corporation of India Limited (NPCIL) and other DAE wings, a complacency, can be risky.