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Analysis: Reasons why India's nuclear safety index score lower than Pakistan's

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Summary: On July 22 Nuclear Threat Initiative (a private NGO) released it's 2020 report on Nuclear safety where Pakistan was ranked five places above India.
But a close study of report showed that it is solely because of differences in legal Acts/Laws and not due to actual on-site protection or capabilities.

Here are the three reasons enumerated below:

1) Radiological users rules: In 2018, Pak parliament passed an amendment for rules to be followed by civilian irradiator facility users for safety of irradiators equipment and medical radiological devices.
India's AERB has also issued the same rules in the form of an Order to all similar users in India in 2010 itself but since those guidelines have been not issued through a Parliamentary law, Pak got +2 pts and India +0.

2) Joint exercises: Pak PNRA mentioned in last years public report that all on site and off site response teams must conduct joint exercises once a year.
But India has not mentioned in public whether on-site & off-site response teams conduct joint exercises or not (No information has been given publicly on it).

3) Regulator Independence: Pak's regulator PNRA has been made legally independent from PAEC by an Act passed by Pak parliament in 2001-02.
Whereas Indian AERB is not independent from DAE and AERB is infact a part of DAE. Indian parliament has also not passed any law to make the regulator independent.
Thus as India does not have a regulator independent from main nuclear use agency, India scored 0% and Pak 100% in this area.

Therefor India's lower score is solely because of differences in legal Acts/Laws/regulations passed by the
respective legislatures of both nations.


India scores same or better than Pakistan in all other areas including Armed response capabilty, cyber-security, inventory management, personnel control, LEA response, emergency response and insider threat prevention and Threat environment

References:
https://www.ntiindex.org/wp-content/uploads/2020/07/2020_NTI-Index_Report_Final.pdf

https://www.ntiindex.org/wp-content/uploads/2020/07/2020_NTI-Index_EIU-Methodology_Final.pdf
 
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3) Regulator Independence: Pak's regulator PNRA has been made legally independent from PAEC by an Act passed by Pak parliament in 2001-02.
Whereas Indian AERB is not independent from DAE and AERB is infact a part of DAE. Indian parliament has also not passed any law to make the regulator independent.
Thus as India does not have a regulator independent from main nuclear use agency, India scored 0% and Pak 100% in this area.

Independence of regulators is very important. Reports of AERB can be overridden by DAE because DAE is the boss of AERB. That should not happen. AERB should be able to create and publish its findings to the public without DAE having a say in the matter. DAE will then be forced to act on the points raised by AERB. This will make India's nuclear reactors safer.
 
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Therefor India's lower score is solely because of differences in legal Acts/Laws/regulations passed by the respective legislatures of both nations.
This is a lame argument. That's like saying N.Korea is lower on the human rights index solely because they don't pass acts/laws/regulations to protect their people. India circumventing required safety mechanisms shows its complacency with handling nuclear tech. And yes, they need to be passed into law to be effective and not be relied upon to be voluntarily carried out.
 
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Summary: On July 22 Nuclear Threat Initiative (a private NGO) released it's 2020 report on Nuclear safety where Pakistan was ranked five places above India.
But a close study of report showed that it is solely because of differences in legal Acts/Laws and not due to actual on-site protection or capabilities.

Here are the three reasons enumerated below:

1) Radiological users rules: In 2018, Pak parliament passed an amendment for rules to be followed by civilian irradiator facility users for safety of irradiators equipment and medical radiological devices.
India's AERB has also issued the same rules in the form of an Order to all similar users in India in 2010 itself but since those guidelines have been not issued through a Parliamentary law, Pak got +2 pts and India +0.

2) Joint exercises: Pak PNRA mentioned in last years public report that all on site and off site response teams must conduct joint exercises once a year.
But India has not mentioned in public whether on-site & off-site response teams conduct joint exercises or not (No information has been given publicly on it).

3) Regulator Independence: Pak's regulator PNRA has been made legally independent from PAEC by an Act passed by Pak parliament in 2001-02.
Whereas Indian AERB is not independent from DAE and AERB is infact a part of DAE. Indian parliament has also not passed any law to make the regulator independent.
Thus as India does not have a regulator independent from main nuclear use agency, India scored 0% and Pak 100% in this area.

Therefor India's lower score is solely because of differences in legal Acts/Laws/regulations passed by the
respective legislatures of both nations.


India scores same or better than Pakistan in all other areas including Armed response capabilty, cyber-security, inventory management, personnel control, LEA response, emergency response and insider threat prevention and Threat environment

References:
https://www.ntiindex.org/wp-content/uploads/2020/07/2020_NTI-Index_Report_Final.pdf

https://www.ntiindex.org/wp-content/uploads/2020/07/2020_NTI-Index_EIU-Methodology_Final.pdf


https://www.dawn.com/news/1245823


Accidents at nuclear power plants in India. ... April 2003 Six tonnes leak of heavy water at reactor II of the Narora Atomic Power Station (NAPS) in Uttar Pradesh (4), indicating safety measures have not been improved from the leak at the same reactor three years previously.



India have a horrid history of accidents at their nuclear plants, both civilians and military...the reason for their lower score in safety index than Pakistan...



  • by officials alternately say there was no fire, that there was only smoke and no fire, and that the fire was not in a sensitive area (2). Details from the AERB are awaited.
  • November 2009 Fifty-five employees consume radioactive material after tritiated water finds its way into the drinking water cooler in Kaiga Generating Station. The NPCIL attributes the incident to “an insider’s mischief” (3).
  • April 2003 Six tonnes leak of heavy water at reactor II of the Narora Atomic Power Station (NAPS) in Uttar Pradesh (4), indicating safety measures have not been improved from the leak at the same reactor three years previously.
  • January 2003 Failure of a valve in the Kalpakkam Atomic Reprocessing Plant in Tamil Nadu results in the release of high-level waste, exposing six workers to high doses of radiation (5). The leaking area of the plant had no radiation monitors or mechanisms to detect valve failure, which may have prevented the employees’ exposure. A safety committee had previously recommended that the plant be shut down. The management blames the “over enthusiasm” of the workers (6).
  • May 2002 Tritiated water leaks from a downgraded heavy water storage tank at the tank farm of Rajasthan Atomic Power Station (RAPS) 1&2 into a common dyke area. An estimated 22.2 Curies of radioactivity is released into the environment (7).
  • November 2001 A leak of 1.4 tonnes of heavy water at the NAPS I reactor, resulting in one worker receiving an internal radiation dose of 18.49 mSv (8).
  • April 2000 Leak of about seven tonnes of heavy water from the moderator system at NAPS Unit II. Various workers involved in the clean-up received ‘significant uptakes of tritium’, although only one had a radiation dose over the recommended annual limit (9).
  • March 1999 Somewhere between four and fourteen tonnes (10) of heavy water leaks from the pipes at Madras Atomic Power Station (MAPS) at Kalpakkam, Tamil Nadu, during a test process. The pipes have a history of cracks and vibration problems (11) . Forty-two people are reportedly involved in mopping up the radioactive liquid (12).
  • May 1994 The inner surface of the containment dome of Unit I of Kaiga Generating Station collapses (delaminates) while the plant is under construction. Approximately 130 tonnes of concrete fall from a height of nearly thirty metres (13), injuring fourteen workers. The dome had already been completed (14), forming the part of the reactor designed to prevent escape of radioactive material into the environment in the case of an accident. Fortunately, the core had not then been loaded.
  • February 1994 Helium gas and heavy water leak in Unit 1 of RAPS. The plant is shut down until March 1997 (15).
  • March 1993 Two blades of the turbine in NAPS Unit I break off, slicing through other blades and indirectly causing a raging fire, which catches onto leaked oil and spreads through the turbine building. The smoke sensors fail to detect the fire, which is only noticed once workers see the flames. It causes a blackout in the plant, including the shutdown of the secondary cooling systems, and power is not restored for seventeen hours. In the meantime, operators have to manually activate the primary shutdown system. They also climb onto the roof to open valves to slow the reactions in the core by hand (16). The incident was rated as a Level 3 on the International Nuclear Event Scale, INES.
  • May 1992 Tube leak causes a radioactive release of 12 Curies of radioactivity from Tarapur Atomic Power Station (17).
  • January 1992 Four tons of heavy water spilt at RAPS (17).
  • December 1991 A leak from pipelines in the vicinity of CIRUS and Dhruva research reactors at the Bhabha Atomic Research Centre (BARC) in Trombay, Maharashtra, results in severe Cs-137 soil contamination of thousands of times the acceptable limit. Local vegetation was also found to be contaminated, though contract workers digging to the leaking pipeline were reportedly not tested for radiation exposure, despite the evidence of their high dose (18).
  • July 1991 A contracted labourer mistakenly paints the walls of RAPS with heavy water before applying a coat of whitewash. He also washed his paintbrush, face and hands in the deuterated and tritiated water, and has not been traced since (19).
  • March 1991 Heavy water leak at MAPS takes four days to clean up (20).
 
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https://www.dawn.com/news/1245823


Accidents at nuclear power plants in India. ... April 2003 Six tonnes leak of heavy water at reactor II of the Narora Atomic Power Station (NAPS) in Uttar Pradesh (4), indicating safety measures have not been improved from the leak at the same reactor three years previously.



India have a horrid history of accidents at their nuclear plants, both civilians and military...the reason for their lower score in safety index than Pakistan...



  • by officials alternately say there was no fire, that there was only smoke and no fire, and that the fire was not in a sensitive area (2). Details from the AERB are awaited.
  • November 2009 Fifty-five employees consume radioactive material after tritiated water finds its way into the drinking water cooler in Kaiga Generating Station. The NPCIL attributes the incident to “an insider’s mischief” (3).
  • April 2003 Six tonnes leak of heavy water at reactor II of the Narora Atomic Power Station (NAPS) in Uttar Pradesh (4), indicating safety measures have not been improved from the leak at the same reactor three years previously.
  • January 2003 Failure of a valve in the Kalpakkam Atomic Reprocessing Plant in Tamil Nadu results in the release of high-level waste, exposing six workers to high doses of radiation (5). The leaking area of the plant had no radiation monitors or mechanisms to detect valve failure, which may have prevented the employees’ exposure. A safety committee had previously recommended that the plant be shut down. The management blames the “over enthusiasm” of the workers (6).
  • May 2002 Tritiated water leaks from a downgraded heavy water storage tank at the tank farm of Rajasthan Atomic Power Station (RAPS) 1&2 into a common dyke area. An estimated 22.2 Curies of radioactivity is released into the environment (7).
  • November 2001 A leak of 1.4 tonnes of heavy water at the NAPS I reactor, resulting in one worker receiving an internal radiation dose of 18.49 mSv (8).
  • April 2000 Leak of about seven tonnes of heavy water from the moderator system at NAPS Unit II. Various workers involved in the clean-up received ‘significant uptakes of tritium’, although only one had a radiation dose over the recommended annual limit (9).
  • March 1999 Somewhere between four and fourteen tonnes (10) of heavy water leaks from the pipes at Madras Atomic Power Station (MAPS) at Kalpakkam, Tamil Nadu, during a test process. The pipes have a history of cracks and vibration problems (11) . Forty-two people are reportedly involved in mopping up the radioactive liquid (12).
  • May 1994 The inner surface of the containment dome of Unit I of Kaiga Generating Station collapses (delaminates) while the plant is under construction. Approximately 130 tonnes of concrete fall from a height of nearly thirty metres (13), injuring fourteen workers. The dome had already been completed (14), forming the part of the reactor designed to prevent escape of radioactive material into the environment in the case of an accident. Fortunately, the core had not then been loaded.
  • February 1994 Helium gas and heavy water leak in Unit 1 of RAPS. The plant is shut down until March 1997 (15).
  • March 1993 Two blades of the turbine in NAPS Unit I break off, slicing through other blades and indirectly causing a raging fire, which catches onto leaked oil and spreads through the turbine building. The smoke sensors fail to detect the fire, which is only noticed once workers see the flames. It causes a blackout in the plant, including the shutdown of the secondary cooling systems, and power is not restored for seventeen hours. In the meantime, operators have to manually activate the primary shutdown system. They also climb onto the roof to open valves to slow the reactions in the core by hand (16). The incident was rated as a Level 3 on the International Nuclear Event Scale, INES.
  • May 1992 Tube leak causes a radioactive release of 12 Curies of radioactivity from Tarapur Atomic Power Station (17).
  • January 1992 Four tons of heavy water spilt at RAPS (17).
  • December 1991 A leak from pipelines in the vicinity of CIRUS and Dhruva research reactors at the Bhabha Atomic Research Centre (BARC) in Trombay, Maharashtra, results in severe Cs-137 soil contamination of thousands of times the acceptable limit. Local vegetation was also found to be contaminated, though contract workers digging to the leaking pipeline were reportedly not tested for radiation exposure, despite the evidence of their high dose (18).
  • July 1991 A contracted labourer mistakenly paints the walls of RAPS with heavy water before applying a coat of whitewash. He also washed his paintbrush, face and hands in the deuterated and tritiated water, and has not been traced since (19).
  • March 1991 Heavy water leak at MAPS takes four days to clean up (20).
Epic fail.
All the incidents you listed are no higher than INES-3 Lvl.
Both NTI and IAEA do not consider INES-3 & below incidents in safety rating of a country.
 
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