Regulation matters
It must be stressed that having a strong nuclear industry regulator, with adequate training, skill and
experience, is not a luxury but an absolute necessity
Dr A Rahman
Of all the industries, nuclear industry is the most highly regulated industry throughout the whole world and very rightly so. The reason being nuclear industry poses the highest risk not only to man and material in the immediate neighbourhood but also over a wide area affecting hundreds of thousands, if not millions, of people. Technical knowledge and requisite skill coupled with strict regulatory regime are prime pre-requisites for safe and secure management of nuclear industry, particularly the civil nuclear
industry.
Before going into the need for regulatory control, one needs to know where the risks from nuclear activities arise. The risks of detrimental effects from nuclear activities arise from radiation and radioactive material both of which are invisible and cannot be detected by any of the human senses. Hence, we need to rely on detectors to alert us of their presence. The use of detectors and measurements carried out using those detectors are required for safe use of nuclear activity. The detrimental effects can be chronic or acute and can be somatic or genetic, depending on the severity of the event.
Ignorance can be lethal in nuclear related work. Marie Curie who invented x-radiation in the late 19th century, whence unseen metallic objects can be seen on a photographic plate by its image, had to pay the ultimate price of her life because of the ignorance of deleterious effects at that time. She started putting her hand in the path of the x-rays and taking images on the photographic plate; and she also carried a test tube containing radium solution in her coat pocket. A few years later she was diagnosed with cancer and she died of it soon thereafter! However, her pioneering work with radioactivity offered the humanity the knowledge that radiation can offer not only immense benefits but also deleterious effects such as cancer. It had also been found out that radiation can be used to treat cancer by killing the cancerous cells in the human body.
A nuclear power plant is one of the highest sources, if not the highest source, of radiation that man has ever produced. Of course, nuclear bombs which had been specifically designed to kill human lives, are excluded from the present consideration. At the heart of the nuclear power plant is the nuclear reactor where nuclear fission processes do take place producing high energy gamma radiation as well as hard neutrons leading to activation products around the reactor. Activation products are themselves sources of gamma and x-rays. The containment of this radiation and radioactive materials is the prime objective of nuclear regulation.
The main building block of nuclear regulation is the specification of safety objectives. In the UK, the home of the worlds first commercial nuclear reactor back in 1956, these objectives are specified in Safety Assessment Principles (SAPs). The SAPs giving details of technical and engineering objectives include such items as
(i) Fundamental principles
(ii) Engineering principles
(iii) Shielding criteria
(iv) Single and multiple failure
criteria
(v) Risk and hazard assess ment
(vi) Radiation dose limits
(vii) Probabilistic and deter ministic safety principles
(viii) Seismic event criteria
and many other aspects related to nuclear safety. Each of these issues are further elaborated by a suite of guides, called the Technical Assessment Guides (TAGs) to assist the safe and consistent approach to nuclear safety. These books are of paramount importance to both the regulators and the nuclear operators.
The underlying need for all of these principles and guides is the availability of suitably qualified and skilled manpower, who would work as safety inspectors to oversee that all of these criteria are complied with. The safety inspectors are the operating arm of the nuclear regulation. Without safety inspectors, all of these good books, all of the safety management procedures etc. would be totally useless.
The primary purpose of the nuclear regulators (regulatory organisation, safety inspectors, researchers etc.) is to offer clear and consistent set of rules for the safe operation of nuclear activity in the country. Regulator must be able to hold the plant operator, the stakeholders, in general the whole industry, accountable for functions, processes and culture, which may contravene extant regulations and best industrial practices. To do so, regulators must be suitably qualified and experienced personnel (SQEP); without SQEP, the whole operation will descend into a farce.
Now let us concentrate on the situations prevailing in Bangladesh with regard to Rooppur Nuclear Power Plant. The Russians are offering $12.65 billion loans to build two VVER-1200 (1200 MWe) reactors at Rooppur. The site is not suitable, which even the Russians admit now that. But Bangladesh government wants to steam ahead with the project. To support the massive reactor structure on the sandy soil of river sediments at least an additional $1,000 million will be needed for soil stabilisation and that is going to be on top of the previously agreed $12.65 billion. Additionally, the waste disposal provision had not been agreed and Bangladesh cannot possibly store HLWs for hundreds of years in safe and secure places. For Russia to take back these waste will cost additional tens of billions of dollars. The transfer of highly active radioactive waste is contrary to international regulations. If Bangladesh cannot manage it and Russia is forced to take it, then obviously Russia will ask for suitable compensation to do so. This compensation is not a million or two, but few tens of billions of dollars!
However, the main objective of this article is to set out the need for proper regulation. Bangladesh has no trained or qualified manpower within the country who can act as regulators. At the moment, a chemist, a bio-chemist, a medical doctor etc. are the key personnel which form the backbone of the regulatory body.
The idea they hold is that the Russians will train them to be regulators. How farcical could it be that the Russians will train the Bangladeshi regulators to regulate Russian nuclear activities? It is like bricklayers will train engineers to be able to manage bricklayers work! It is more farcical than that. Russians will charge Bangladesh to train regulators to regulate their activities!
But what would be the main thrust of the Russian vendors training the Bangladeshi regulators? Wouldnt the Russians tell Bangladeshis that whatever they are doing are the best in the world. And Bangladeshi student regulators knowing only one method would agree that the methods Russians are doing are the best! The Bangladeshi regulators will rubber stamp those activities and Russians will go home laughing to their wits ends.
But the fact remains Russian nuclear safety standards are quite horrendous. When Bulgaria, Lithuania, Latvia and other erstwhile Soviet block countries wanted to join the EU in the early part of this century, the European Union demanded decommissioning of Russian designed civil nuclear power plants as accession requirement, as those plants were deemed to fall short of western nuclear safety standards. Indeed, subsequent studies under the 5th Framework Programme of the EU with the author of this article as the Team Leader identified many regulatory shortfalls vis--vis western safety standards. All of those countries had to agree to decommission those nuclear reactors in order to gain access to the EU.
Bangladesh has no SQEP regulator to scrutinise, let alone challenge, Russian nuclear activities. These activities include supply of quality controlled material, install and commission the reactors. The student regulators will be looking at the Russian trainers and masters to tell them what to approve and what to delay. Would they have the technical skill and knowledge to scrutinise and, if necessary, challenge the Russian nuclear safety standards? Even India, with far more technical skill than Bangladesh, is struggling to rein in the Russians at Kudankulum in Tamil Nadu both in terms of costs, quality of material and safety provision.
It must be stressed that having a strong regulator, with adequate training, skill and experience, is not a luxury but an absolute necessity. Trying to cut corners, with incompetent manpower, would haunt the country not only with exorbitant costs but also with serious safety violations that would devastate the country for years to come.
The writer is a retired nuclear safety specialist, UK
