A (nuclear) passage to India29 September 2014
The vast potential market of civil nuclear development in India persuaded USNRC analyst N. Prasad Kadambi to quit his job and move to Hyderabad to set up a consultancy business. But his adventure did not turn out quite as expected.
My journey to discover, and in some small way positively influence, the practice of nuclear safety in India began with the US-India nuclear deal. My perch for observing the dynamics of the shifting scenarios over the period leading up to the US-India nuclear deal was at the US Nuclear Regulatory Commission. The USNRC is an independent agency (meaning that it is not within the US President's Executive Branch of government) that sets the rules for nuclear safety regulation. I was a member of the technical staff, and felt privileged to share in hallway conversations and non- sensitive internal descriptions of high level wheeling and dealings that characterized the participation of various US agencies. My perspective was focused on the regulatory challenges that would inevitably arise with expansion of nuclear power capacity in India of the magnitude that was foreseen in some quarters. In my mind, what was being envisioned was almost unprecedented within an open democratic system. However, again from my perspective, the timing for confronting such challenges was perfectly aligned for India because the research that I was working on specifically dealt with developing regulatory strategies that could tackle power reactors employing a variety of nuclear designs in the manner some were suggesting would happen in India.
The current perspective that many people hold on nuclear safety is unfortunately shaped by the Fukushima disaster of March 11, 2011. When I was at the USNRC, I would have maintained that the nuclear part of what happened at Fukushima was not possible. It is emerging only now, three years after the accident, how different the nuclear safety practices in Japan were as compared with
the US. Information about the sequence of nuclear events following the earthquake and tsunami at Fukushima shows how modern methods and tools for nuclear safety could have been so much more successful at preventing the disastrous events. Hence, the key lesson of Fukushima, it seems to me, is that all countries that hope to employ nuclear power in a big way should modernize their use of analytical and regulatory methods.
The research that I was involved with at the USNRC gave me a strong sense of what it takes to achieve safe outcomes from nuclear power operations. My career there involved a wide range of activities, including working with companies to bring into operation a new design of nuclear power plant. Later on, the safety research that I was involved with showed how existing methods and tools were fine as far as they went, but were deficient toward handling things that were not foreseen (but the USNRC continues to develop its risk-management framework). Ten years ago, there was great promise that a nuclear industry renaissance was in the offing that would enable a new generation of safer nuclear power plants by putting this research to use. However, it became evident about five years ago that the nuclear renaissance was not going to happen in the US, but was likely to happen in other parts of the world, including India. Hence, in 2008 I retired from the USNRC after 26 years of service and set up a nuclear safety consulting company in Hyderabad, India.
It has become conventional wisdom in India that the abundance of its thorium resources drives it toward a phased transition to a uranium(233)-thorium fuel cycle. When consideration started to be given to a US-India nuclear deal about 10 years ago, India's operating reactors were reported to be functioning at about 50% capacity factor on account of a lack of fissionable material. There was no distinction then between reactors for civilian power production and those that served strategic (meaning military) purposes as well. Reconciling the tension between the twin objectives of meaningful nuclear power production capacity and maintaining strategic autonomy kept India's commentators and political leaders quite busy over the years leading up to the finalization of a key stage of the US-India nuclear deal. The crescendo occurred in 2008 with important details being worked out, and the US Congress approving legislation consistent with Section 123 of the Atomic Energy Act.
My professional career had included a brief stint with the Indian Department of Atomic Energy (DAE). I lost track of the Indian nuclear program over the years, and so in 2008 the robust program that was being implemented came as a surprise. The technology mix envisioned included light- water, heavy-water, and liquid-metal reactors. There were plans for an independent regulatory body. Although there was not much information about current regulatory approaches, it appeared that international standards established by the International Atomic Energy Agency (IAEA) played an important role. I reestablished contact with acquaintances in India and found a high level of confidence that an aggressive expansion of nuclear electricity generating capacity would occur. It appeared impossible to me that conventional safety approaches could suffice to meet safety and regulatory needs. To take advantage of these factors, which appeared to me as opportunities, I made plans to travel to India in early 2009.
Setting up shop in India
In India, I found officials with DAE quite forthcoming about discussing expected developments in the civil nuclear power sector. I was asked what capabilities I would bring forward with my company, which I established that year. As the regulatory research that I did at the USNRC was entirely in the public domain, I had no hesitation to describe how the US was preparing to license advanced reactors using modern probabilistic methods, models and tools. I was asked if I would be willing to present a seminar describing this work. I accepted the invitation and set about preparing a presentation that showed the common ground that can be found between safety criteria as described in IAEA documents and those that are the bases for USNRC regulations. My objective was to convey that accomplishment of the objectives as described in IAEA documents can be done more efficiently and effectively using modern methods.
The DAE has far flung elements all over India covering a wide range of activities. Nuclear safety considerations probably have significance for most of them. I was told that my seminar would have invitees from many branches of the organization. This excited me because research shows the possibility of employing a common set of modern methods, models and tools for nuclear safety while catering to the needs of a wide range of applications. These can be integrated under the right organizational structure to improve safety in a more transparent and predictable way.
The seminar I presented in the fall of 2009 was quite well-attended. I had clearly indicated that the presentation would cover risk-informed and performance-based approaches to nuclear safety. The USNRC work in this area had received international exposure over the previous ten years, and so I thought that these modern methods may be known well enough to draw a large audience. As I was keen to work on regulatory matters, I saw reason to be optimistic about having a broader impact. I was to discover later that the attendance was more an indication of the clout of the regulatory body that arranged the seminar. Although the regulatory body, called the Atomic Energy Regulatory Board, falls within the structure of DAE, my conversations with people in India had given me the firm impression that AERB was exercising a great deal of independence over all participants in the nuclear enterprise. I also discovered that, as an operational matter, there was no way for the regulatory body to engage my services as a private sector participant. Hence, I was disappointed to learn, my first choice for offering nuclear safety consulting was closed off.
Within DAE is the national utility the Nuclear Power Corporation of India Ltd. (NPCIL). NPCIL is a public-sector body that operates somewhat like a private corporation. Having worked within the US government structure for two-and-a-half decades, I expected that NPCIL would be something like the Tennessee Valley Authority. In the US, in my situation, I would have had to show to an agency with a known scope of responsibility that I had a service to offer that was valuable in some way. I would need to persuade the agency that it could do its job better by engaging my services. In India, I found, what I had to offer technically was of very little interest because the system in place just worked quite differently. It appeared that work was accomplished by committees that engaged the talents of highly-qualified people from other government organizations, universities and research entities, all operating within the public sector structure. It seemed to be unprecedented that a private company would jump in and do the technical work being done by other groups.
I discovered that NPCIL at least was able, within its operational rules, to engage a private sector company like mine to perform a needed service. I pursued this opening by seeking out information as to the technical areas in which safety analysts in the organization needed help. I found out that human error analysis as applied to modelling of post-accident scenarios was such an area. Further enquiries revealed that there was interest to develop the capability within the organization to employ state-of-the-art type of predictive analysis in the context of a probabilistic safety analysis. There appeared to be a need for a pilot project on human reliability analysis to improve India's ability to provide operator guidance in postulated accident conditions.
I was asked to provide a description of the work in this area that I would perform if I were given the opportunity. Since modelling of human performance is not my specialty, I associated myself with a world-class expert in this area who was located close to me in the US, and who was also attracted to the prospect of getting a business foothold in India.
About a year passed with nothing of note happening relative to NPCIL. I was spending a couple of months a year in India cultivating contacts and trying to keep track of policy changes. I sought out private-sector corporate representatives who had interest in exploring business prospects in nuclear technology. One medium-sized steel fabrication company had me visit their facility to offer observations on their prospects. My feedback that nuclear grade fabrication would need to incorporate a much higher level of formality, rigour and quality-consciousness was not received favourably. I got the impression that my assessment lacked credibility because I was not impressed by the fact that an international consensus standard was used in their operation. I was not impressed because the standard, a copy of which I got to see (and was convinced was pirated) was not being implemented as intended. The standard only works within a certain structure, and nowhere did I see evidence of independent conformity assessment being part of the operation.
I spoke to the owners of a small but prosperous construction company. There was not much enthusiasm for my suggestion that they think strategically about having some younger people become familiar with nuclear construction issues and participate in the Indian nuclear effort in small ways just to gain experience. I knew that several large corporations performed major projects for NPCIL and probably would be able to use the services of smaller companies. Contacts with people knowledgeable about the larger companies supporting the Indian nuclear power programme indicated that they had committed relationships with NPCIL that enabled the needed work to get done without advertisement or publicity. Industry players outside the system seemed content to stay out even though there was plenty of money to be made. The lack of transparency in the nuclear effort seemed to cause the program to be viewed with intimidation and trepidation. Other enterprising people seemed content to wait for policy changes that were occasionally covered in the news media.
From the start of my explorations about setting up shop in India to offer modern nuclear methods as a consulting service it was clear to me that the nuclear efforts in the country had been cloistered, but not shut out of, what was going on globally. My hope was that a realization would occur that existing practices were inadequate to the challenges of analyzing the safety of a broad mix of nuclear activities. Something like this happened at the USNRC in the mid-1990s.
It was in the mid-1990s that the USNRC came to the strategic conclusion that the old conventional safety approaches were not effective enough to meet current needs. In the current environment where only spotty information is available, it appears that Indian technical decision makers are totally unimpressed with what they have come to know and call "RIR" for risk-informed regulation. However, the need to perform human reliability analysis and estimate human error probabilities seems relevant only in the context of a probabilistic safety analysis. It was not within my role as a consultant to address the questions regarding the need to employ probabilistic human performance models. Perhaps NPCIL's foray into human reliability analysis would increase the appreciation for the capabilities of modern methods and widen the applications of such methods.
The process of engagement with NPCIL in human reliability analysis culminated in the issuance of a tender notice to a number of institutions including my company. I found that the description of the work to be done under the tender bore a strong resemblance to the work proposal that my company had provided to NPCIL. I was naïve enough to think that the work I had previously described may have been used in the tender to emphasize the need to apply the latest research for NPCIL. Hence, the bid that my company submitted included service of people who had participated in the huge amount of research that had been sponsored by the USNRC and was available to the public.
It was quite educational to participate in the NPCIL bidding process. My company's bid went into great detail as to how NPCIL could look forward to lasting benefits from state-of-the-art research information. In recognition for the sticker shock that would likely occur if the tender were considered in a US or European context, the bid I provided was discounted by about 25-50%. The sealed bids were received in a highly formalized procedure assuring that no interested person would be able to come to know the contents of another's bid. A bid opening date and time were set. A highly ritualized bid opening was conducted, and it was announced that the low bid had won the tender. There was no room for any discussion regarding technical merits of the bids. I got the impression that finding a consultant to help with nuclear accident response was treated no differently than choosing a contractor for, say, grounds maintenance.
As it turned out, the tender for human reliability analysis drew three bids. Two were from private-sector companies and the third was from a university. The work proposed by the university appeared to be add-ons to an ongoing research program. Their bid was at least an order of magnitude lower than my company's. The clear lesson learned was that any hope of succeeding at helping NPCIL with modernizing their nuclear safety practice would need to be done on a low-bid basis.
It is not clear whether and how the supply of technical services can be expanded in India given existing procurement practices. The procurement practices seem to be based on protecting against corruption, but also exhibit a deep ambivalence about including private sector participants in the nuclear effort. Many people view secrecy as a necessity for all things nuclear. The "non-proliferation ayatollahs" in the US did not alleviate the problem. Some of these issues are unique to India, but there is a more widespread problem that affects nuclear technology all over the world. That is a conviction among many thought-leaders that the hazard posed by radioactivity is qualitatively more threatening to human health and safety than other types such as chemical and biological hazards. In India, the spectre of the Bhopal accident and its aftermath is a prominent part of the background of any discussion of nuclear accidents. The government has a key role to play in assuring people that it has the capacity and competence to safeguard the public interest without necessarily having to do it all. It is my observation that private sector participants in nuclear analysis and similar services would step forward only if technical people in DAE are willing to take responsibility for objectively overseeing the conduct of such services.
It has been my personal observation that the integrity of people involved with nuclear safety is beyond reproach. Whatever problems exist I believe are structural and procedural. Where my own hubris may be involved is to think that I would be able to carry the message of modern methods of regulation to the nuclear institutions in India when such methods were not embraced fully even in the US where they were developed. I am so convinced of the merits of these methods that I do not think that I have to do anything but communicate what is spelled out in dozens of publicly-available reports from the USNRC.
It remains to be seen how my India project progresses. The recent elections have brought with them a sense of possibilities that did not exist previously. Effective leadership includes recognizing that which does not work. In that sense, perhaps the new leadership will allow questions to be asked about the effectiveness of existing practices and encourage pursuit of improved alternatives.
N. Prasad Kadambi, Ph.D, P.E., consultant. The author recently retired from the USNRC after 26 years.