The Atomic Energy Regulatory Board, India’s nuclear regulator is completing 41 years of age. It is the time for calm contemplation and accounting of what AERB has done thus far. If any reader delves deeper, he may legitimately feel that my views are most likely to be biased. Let me declare my conflict of interest. I was one among the first handful of officers who joined the Board from Bhabha Atomic Research Centre (BARC). I was the Secretary of the Board from August 1987 to January 2004. I strongly defend my turf. However, I also make every effort to give references to authentic documents to buttress my views. One can get a bird’s eye view of the regulatory activities of AERB during its formative years here.
Pioneers recall that when India’s Department of Atomic Energy (DAE) started the design and construction of its first research reactor Apsara in 1955, there was no formal safety analysis report. Designers of various systems of the reactor on their own ensured the safety of the design. I hasten to add that it was the case all over the world. A robust regulatory system in which many specialists from different disciplines participated evolved soon. (One can read the history of the regulatory activities in the field of nuclear energy and its applications from here, here, here and here) .
Safety Reviews
The Board’s safety review covered unusual incidents at Rajasthan Atomic Power Station (1980-84), Quality Control and Quality Assurance at NPPs 1985, Radiation exposures in power plants 1988, Operational safety at Taraput Atomic Power Station (TAPS) 1985 and Rajasthan Atomic Power Station (RAPS) and Madras Atomic Power Station (MAPS) 1989, the Narora Fire Incident 1993 and the Failure of containment dome in Kaiga 1994,. This reference contains details of various reviews.
AERB appointed special committees to review safety features of Indian nuclear power plants considering accidents at Chernobyl and Fukushima. The AERB secretariat diligently followed up the recommendations of these committees.
Early reviews
AERB started safety review and licensing of Pressurized Heavy Water Reactors (PHWRs) from Narora 1 onwards. Over the years, Department of Atomic Energy (DAE) introduced newer projects, such as PHWRs of 540 MWe at Tarapur and 700 MWe at several sites, Kudankulam plant (VVER type Russian nuclear power reactors of 1000 MWe), Prototype Fast Breeder Reactor of 500 MWe etc. Safety reviews of foreign nuclear power reactors of higher capacity also started. Newer developments include SMR. These offer future challenges.
Regulatory control of medical x rays a daunting task.
A review of what AERB has done, particularly to enforce regulatory control on medical x-ray equipment and installations can be seen here . Effective regulatory control of medical x-ray units in India is a daunting task, as medical x-ray use grew in an unbridled way nationwide for many decades.
In 1986, AERB held a National Seminar on “Radiation exposures in Medical X-ray Practices: Consequences and Control”. Many senior officials (Directors of Health Services, Directors of Medical Education) from State Governments, radiologists, representatives of allied professional associations, radiographers, x-ray unit manufacturers, x-ray tube makers, officers from Medical Council of India and Director General of Health Services and others participated.
Simultaneously AERB set up a specialist committee with Dr Arcot Gajraj as Chairman. The committee had representation from Directorate General of Health Services, DRP/BARC and AERB. Its recommendations included type approval of equipment, organization of training courses with emphasis on safety, preparation of safety codes and guides, registration of x-ray equipment and installations among others. AERB enhanced the type approvals for x-ray equipment with the assistance from Radiological Protection and Advisory Division (RP&AD) of BARC. AERB implemented most of the recommendations.
AERB entered an MOU with CSIR and DRDO to organize a nation-wide x-ray registration program. AERB coordinated with Radiological Physics Division of BARC and trained 125 inspectors for the program. They were middle level officers from the respective regional laboratories of DRDO and CSIR.
The program covered all 500 districts in the country. AERB collected invaluable information on the status of medical x-ray safety. AERB conveyed remedial measures on obvious safety deficiencies to these institutions. To our knowledge, no country has attempted such a massive program anywhere else in the world.
The program covered over 30,300 x-ray units. In a mid-way analysis, AERB found that the age of nearly 9% of the 15528 units registered was unknown. One out of five units was over 15 years old. The AERB found several obvious deficiencies and recommended remedial actions.
AERB’s efforts to decentralize regulatory control on medical x rays by authorizing State Governments were not successful.
However, now there is some light at the end of the tunnel, as AERB developed and deployed its e-governance initiative for e- Licensing of Radiation Applications ‘e-LORA’. AERB extended e-LORA successfully to other areas as well. AERB received the “SKOCH Smart Governance Award -2015” for e-LORA.
AERB helps DAE in drafting new rules
The promulgation of Atomic Energy Act 1962 and the Radiation Protection Rules, 1971 gave the initial legal framework to safety. AERB issued surveillance procedures for medical applications of radiation under Rule 15 of the RPR 1971. AERB also published a safety code on medical x-ray equipment and installations. These documents provided a firmer legal basis for enforcing safety provisions.
Promulgation of Atomic Energy (radiation Protection) Rules 2004 helped to remove virtually all the legal infirmities. However, AERB’s constitution order needs revision
Some Past Regulatory Actions
Has AERB exercised its powers? AERB’s Annual report contains the regulatory actions taken by the Board. I recall that the first question a journalist asked me was whether AERB has any teeth! AERB was just born then. If an infant has teeth when born, it will be a freak I joked. The question inspired us to review the Atomic Energy Act 1962. When the Controller and Auditor General of India made an incorrect interpretation of certain provisions in the Atomic Energy Act we could easily identify it. (Please see here)
Recovery of highly active sources from Coovum River
!n 1993, someone stole three radioactive sources from the premises of a foreign company based in India, and engaged by Oil & Natural Gas Commission (ONGC) for oil well-logging operations. AERB ordered suspension of all its well logging operations using radioactive sources in India. Eventually based on the inputs from police, AERB’s team recovered the sources from Coovum River within the Chennai city limits. AERB permitted the use of sources after ONGC reinforced more measures to ensure security of the sources. The disgruntled workers involved got jail terms
Regulatory actions against hospitals
AERB endorsed the Division of Radiological Protection (DRP)’s decision on withdrawal of radium sources from hospitals as many of them were leaky or prone to develop leakage and were hazardous. Removal of radium led to the introduction of safer substitutes in cancer treatment, improved dosimetry, and better radiation protection.
On April 6, 1995, AERB barred a cancer hospital in Delhi from treating new patients because of safety violations. The Board lifted the ban when the hospital fulfilled the safety requirements.
Other developments
In 1987, AERB prescribed permissible limits for radionuclides in foodstuffs when there was a possibility of the import of contaminated foodstuffs after the Chernobyl accident. One can get related details here.
The Mayapuri radiation accident, which led to the death of one person and radiation injury to many, offered a wakeup call. AERB implemented stricter measures on keeping track of sources immediately.
AERB issued an advisory to medical/dental x-ray owners and the general public against indiscriminate use of dental x-ray examinations solely for the purpose of non-diagnostic applications such as age determination or birth registration.
In 2012, the Controller and Auditor General of India (CAG) gave a critical report on AERB. AERB staff noted that some reports criticized the CAG report (please see here, here and here). While noting in a lighter mood, that Accountants are seldom pleasant, we must admit that the appraisal of CAG offered an invaluable wake up call to AERB. The Parliament’s Public Accounts Committee endorsed CAG recommendations . As directed by CAG, AERB prepared a policy document.
Through e-LORA, it implemented an online program for all its licensing activities. It issued a large number of safety documents. Anyone can download them freely from AERB web site. CAG’s proposal to make AERB’ legal framework stronger is pending with the Ministry which hopefully may accord priority to it. Closer perusal of AERB’s Annual report shows that AERB strengthened all regulatory activities as directed by CAG.
The International Atomic Energy Agency carried out Integrated Regulatory Review Service (IRRS) mission during March 16-27, 2015. India is among the few countries, which published the report.
AERB’s Annual report, which summarizes AERB activities are available at www.aerb.gov.in
Safety Research Institute
The objective of Safety Research Institute(SRI) is to build a unique research and knowledge base with a strong research capability in important safety related areas to support regulatory functions of AERB. Under the initiative of Prof. P. Rama Rao, the then Chairman, AERB, Safety Research Institute was setup at Kalpakkam. The foundation stone for the institute was laid on February 20, 1999 by Dr. R. Chidambaram, the then Chairman, AEC during the IX Five Year Plan period with P. Rodriguez as first Director of the Institute.
SRI conducts independent safety research to supplement the Boards’ regulatory review and assessment activities.
Looking forward
AERB must be circumspect in enforcing changes in universally accepted radiation protection philosophy which has robustly and soundly stood the test of time. “Radiation hormesis” for instance is a very popularly discussed phenomena. A major problem is that it is not possible to arrive at a scientifically defendable threshold dose.
In order to appreciate the associated concepts such as Linear No-Threshold (LNT) model and ALARA (As Low As Reasonably Achievable) etc. the regulators must read the following references.
- Federal Register :: Linear No-Threshold Model and Standards for Protection Against Radiation
- )ALARA: The History and Science of Radiation Safety
I strongly endorse the following conclusion from Ref 2
“Despite its genesis in public opinion rather than scientific investigation, the ALARA protocol has successfully limited the exposure of radiation workers to impressively low levels of around 1 mSv. The grounding of ALARA is in the linear-no-threshold hypothesis, which states that risk is directly proportional to dose, even for the smallest exposures. Although significant costs are incurred to conform to ALARA and the validity of the LNT model is unclear below doses of 100 mSv, more research on the health effects of low radiation doses is necessary before alternatives to ALARA can become viable.”
I hope that AERB will stick to that view.
Further reading
- https://www.eurasiareview.com/17052018-radiation-doses-their-limits-related-issues-of-public-perception-analysis/
- https://www.eurasiareview.com/16112022-public-perception-on-nuclear-power-and-associated-technologies-oped/
(Key Note Address by the writer at the IEEE International Symposium on Technology and Society (ISTAS-2022)on 11 November 2022)
BEST WISHES TO ALL ON THE FOUNDATION DAY OF AERB
Please see this you tube documentary on one of the most important policy decisions by AERB- prescribing the permissible limits radionuclides in foodstuffs,- It is by Shri Ajitesh Sharma. He got many awards (a few international). Towards the end, I explain how AERB took the decision. This was shown in some OTT platforms in India
Here is the link: https://www.youtube.com/watch?v=Lcpaw9cX1zs
From a fledgling organization with a handful of members occupying two rooms at the Old Yacht Club, opposite Gate way India, Mumbai, AERB grew into a strong regulatory agency. AERB now occupies three buildings.
When I reviewed AERB staff strength and their qualifications on November 15, 2017, exactly seven years ago it had a total staff strength of 346, over 250 of them Group A officers. Of them, 21 have Ph.D. degrees. All of them had special training in one or more of the subjects such as nuclear engineering, radiation safety, medical physics etc. All of them are graduates or postgraduates; many of them have M. Tech degrees from IITs. Uniquely for a regulatory agency, five or six of them secured law degrees and they reinforce the legal cell of AERB. I look forward to the legal cell to defend their turf against any attempt unintended or deliberate to dilute the existing legal powers of the Board.
AERB looks forward to future challenges with renewed zeal, commitment and enthusiasm. The mood is upbeat in the AERB.