Koodankulam: PMANE’s Complaint to AERB on Breach of Contract

The People’s Movement Against Nuclear Energy (PMANE)
Idinthakarai & P.O – 627 104
Tirunelveli District
Tamil Nadu

The Chairman
Atomic Energy Regulatory Board
Niyamak Bhavan
Mumbai 400 094

Dear Sir,

Greetings! We, the members of the People’s Movement Against Nuclear Energy and people of southern districts of Tamil Nadu and Kerala, write to demand immediate halt of the Koodankulam Nuclear Power Project (KKNPP) at Koodankulam in Tirunelveli district, Tamil Nadu, and a thorough scrutiny of the following issues before AERB (Atomic Energy Regulatory Board) gives a green signal to the commissioning of the Koodankulam project.

The KKNPP reactors from Russia are being set up without sharing the Environmental Impact Assessment (EIA), Site Evaluation Study and Safety Analysis Report with the people, people’s representatives or the press. After a 23-year-long struggle, we obtained a copy of the outdated, incomplete and erroneous EIA only a few months back. No public hearing has been conducted for the first two reactors either. The KKNPP project has been imposed on an uninformed and unwilling population throwing all democratic precepts and values of our country to the wind.

The Central Information Commissioner (CIC) has ordered “to provide an attested photocopy of the Safety Analysis Report and Site Evaluation Report after severing any proprietary details of designs provided by the suppliers to the appellant before 25 May, 2012.” But the NPCIL refuses to share these two public safety reports by arguing that the Safety Analysis Report (SAR) “is a ‘third party document’ and therefore, without the prior consent of the third party, the same cannot be shared with anyone.” Obviously, the NPCIL is more interested in the safety of the Russian company and the Russian benefactors but not in the safety of the people of India.

NPCIL has informed the CIC in their recent letter dated May 18, 2012 that “the ‘Site Evaluation Report’ for Reactor I & II at Koodankulam could be made available to the Appellant. Accordingly, a copy of the said ‘Site Evaluation Report’ has been sent to the Appellant.” On May 17, 2012 we received a letter and a bunch of 12 lose papers without any head or tail as the ‘Site Evaluation Report.’ When we questioned the validity and integrity of this so called SER, Dr. S. K. Jain, the chief of the Nuclear Power Corporation of India Ltd. (NPCIL), claimed that it was the executive summary and not the whole report.

The KKNPP and the NPCIL officials have not conducted any mock drills and evacuation drills in the 30 km or even the 16 km radius of the project. On June 9, 2012, the Tirunelveli district administration and the NPCIL officials conducted a haphazard safety drill in a remote hamlet called Nakkaneri of hardly 300 people and claimed that the mock drill was a great success. If we organize fire drills in all the schools and movie theatres all over the country, should we not conduct nuclear safety drills in all villages and towns in the project area?

More than 1.5 million people live within the 30 km radius of the KKNPP which far exceeds the AERB stipulations. It is quite impossible to evacuate this many people quickly and efficiently in case of a nuclear disaster at KKNPP.

According to AERB instructions of 1998, the Koodankulam project requires two sources of water from the reservoirs of Pechiparai and Upper Kodayar in Kanyakumari district to ensure adequate supply in the event of a loss-of-coolant accident. Since water from Pechiparai and Kodyar is ruled out, four desalination units, each producing 106,000 litres of water an hour, are provided for the first two units of KKNPP. The desalination plants that are close to each other and vulnerable to accidents and terror attacks cannot be the reliable sources of fresh water. However, the Site Evaluation Report clarifies that Pechiparai dam water will be taken for the KKNPP reactors. There are so many conflicting and contradictory reports about the fresh water needs of KKNPP and its fulfillment.

The issue of liability for the Russian plants has also not been settled yet. Defying the Indian nuclear liability law, Russia insists that the Inter-Governmental Agreement (IGA), secretly signed in 2008 by the Indian and Russian governments, precedes the liability law and that Article 13 of the IGA clearly establishes that NPCIL is solely responsible for all claims of damage. If the Russian reactors are the best in the world, as claimed by Russians, why do they refuse to offer any liability?

Most importantly, the VVER reactor under commissioning at Koodankulam nuclear power project differs from the one featured in the inter-governmental agreement between Russia and India.  According to documents published in 2006, there was no weld on the beltline (middle portion) of the reactor pressure vessel (RPV).  NowAERB says that there are two welds on the beltline of the RPV installed at KKNPP. This is a breach of the contract by the supplier in Russia.  NPCIL officers who have known this are guilty of installing an unsafe machine with high risk of RPV failure leading to offsite radiological contamination besides causing  financial loss to the company in case of premature retirement of the reactors.  By consenting to its erection, AERB has also reneged on its responsibilities. If the reactor is hot-commissioned, it will be virtually impossible to subject the vessel to a detailed inspection.  This will lead to destruction of evidences of the crimes. From a safety perspective, the IAEA-mandated study of pressurized thermal shock (PTS) has to be done before commissioning the reactors at Kudankulam.

The people of Tamil Nadu and Kerala are deeply concerned about our safety and wellbeing as the KKNPP reactors pose grave and serious threats.  The actual siting of the reactors, the quality of construction and the pipe work and the overall integrity of the KKNPP structures have been called into question by the very workers and contractors who work there in Koodankulam. Our own Expert Team has identified several serious safety issues with regards to the geology, hydrology, oceanography and seismology issues of the KKNPP project such as Karst, geysers and sub-volcanic intrusions in our locality; slumps in our sea and possible tsunamis; recurrent huge earthquakes in the Indian Ocean and so forth. Our Expert Team’s findings and our long struggle against the KKNPP are completely ignored by the concerned authorities and the governments ignoring our safety and wellbeing completely.

In the light of the above situation, we would very much like to request you to intervene in the KKNPP matter, halt its commissioning immediately and order a thorough enquiry into all of the above issues.

Looking forward to hearing from you soon, we send you our best regards and all peaceful wishes.


S.P.Udayakuamr, Ph.D.     M. Pushparayan     M. P. Jesuraj     Fr. F. Jayakumar

Copies to

The Head
Safety Research Institute
IGCAR Campus
Kalpakkam 603 102
Tamil Nadu

International Atomic Energy Agency
Vienna International Centre
P.O. Box 100
A-1400 Vienna

United Nations Environment Programme
United Nations Avenue, Gigiri
PO Box 30552, 00100
Nairobi, Kenya

International Committee of the Red Cross
19 Avenue de la paix
CH 1202

Amnesty International
1 Easton Street
Lonndon WC1X 0DW

International Alert
346 Clapham Road
London SW9 9AP

Human Rights Watch
350 Fifth Avenue
34th Floor
New York, NY 10118-3299
International Commission on Radiological Protection
280 Slater Street
Ottawa, Ontario K1P 5S9

Greenpeace International
Ottho Heldringstraat 5
1066 AZ Amsterdam
The Netherlands


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