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12 th December 2011

Executive Summary


The Committee appointed by the Peoples Movement Against Nuclear Energy studied various reports, documents and papers on KKNPP in particular and nuclear energy and ionizing radiation in general. A 38 page report by the Central Expert Group (CEG) was made available to us. Besides responding to the assertions of the CEG report, we are also bringing forward our own studies that are relevant to the reactor safety Most of the documents that were asked by PMANE were not shared to the technical committee including the site evaluation study and other documents. Despite this handicap the committee has gone in depth and analysed various issues.

This compilation is divided into four parts.

Part I deals with the sitespecific problems of KKNPP. These includes (i) a review of geological and oceanographic studies in around KKNPP, (ii) inadequate provision of fresh water in the nuclear island and the township, (iii) limestone mining at the nuclear site, (iv) construction of a township for tsunami survivors within the sterilized zone which apparently escaped the attention of NPCIL, (v) contradictions and false statements by several expert groups that have studied the nuclear facilities during 2011 and (vi) possibility of station black out beyond a month due to space weather anomalies.

Part II deals with the human health concerns of low level radiation. This is based on epidemiological studies conducted among the (i) bomb victims of HiroshimaNagasaki, (ii) down winders of Madras Atomic Power Station (MAPS), (iii) workers of nuclear facilities and their families in India and (iv) people living in high natural background radiation in Kerala.

Part III is an in depth study of the effects of releases of radioactivity and 700 billion liters of hot water from each reactor every day on the marine eco system. The impacts include depletion of fisheries and multiplication of heat tolerant organisms like jelly fish. The depletion of fisheries will negatively impact the livelihood of fisherpeople and the food sovereignty of the people in general. Jelly fish attack can be a problem for the intake pipes for reactor coolant and raw water for desalination plants.

Part IV deals with other safe and sustainable alternatives for electricity generation and contains a detailed analysis of fuel shifting. In short, the infrastructure built with so much of investment will not have to be abandoned.



1.1) Geology and Oceanography

Kudankulam site is transected by sub volcanic intrusive cutting into the granulite grade of metamorphic rocks. The configuration of these sub volcanic intrusive, brought out by a recent ground magnetic survey, deems a horstgraben structure criss crossing the EW trend of the coast. These sub volcanic bodies have bisected the near surface crust in the form of plugs to the west and in the form of dyke swarms to the east, indicating a severe crustal dilation to the east. It is also suggested that crustal thinning and mantle upwelling have led to the emplacement of mantle hybrid rocks as dykes and plugs, near (200 meters deep) sub surface.

Places around Kudankulam have experienced small volume volcanic eruptions in the years 1998, 1999, 2001 and 2005. The nearest eruption occurred at just 26 kilometers away from the KKNPP site. The products of these eruptions have been confirmed by various researchers as the ones produced by volcanic activity. One cannot rule out such eruptions at the site itself. Issues of subduction, fire and impact of high speed missiles emanating from the burst need to be addressed.

Various researchers have found undersea volcanoes and volcano vents in the Gulf of Mannar (GoM) ever since 1975. Kudankulam site is located at about 100 kilometers from these structures. A magnetic survey conducted in the GoM in the year 1994 had revealed extensive emplacement of its crust by basltic rocks, eventually making the crust just 15 kilometers thin. A 1978 study by the volcanologist P.Hedervari places this site as one that belongs to the Indo Australian seismic zone.

The presence of dykes of trachytes, alkali basalts, sovites, phlogopite carbonatitic breccias and lavas, floats of volcanic bombs, ash tuffs and brecchias in Kudankulam site bring to the mind the case of High Radioactive Waste Repository at the Yucca Mountain, Nevada, USA, which has been put on cold storage after two decades of research.

The presence of slumps in Gulf of Mannar puts forward the possibility of submarine landslides causing near field mega tsunamis. Presence of sill holes at Pannayarkulam, 10 km away from Kudankulam indicates that this region might be a karst region.

These observations necessitate the need of volcanic hazards, karst hazard and tsunamihazard studies of the Kudankulam site before the reactor gets commissioned.

Report of the P-MANE Expert Committee


1.2) Water Reserves and Availability at KKNPP

The safety of the reactor core with spent fuel inside and the spent fuel pool depends ultimately on the availability of fresh water. Thousand odd employees and their families living in Anuvijay Nagar Township also require potable water. The potable water requirement of KKNPP is 1272 cubic meter a day. The two reactors require 6000 cub meters of water while operating and 1000 cubic meters while shut down. A year after commissioning, the spent fuel pools will also need water. Three desalination plants can produce the daily requirement of two reactors and the Township. One desalination plant will be on standby. The reserve water available at KKNPP campus are (a) domestic supply 1425 cubic meters (b) Fire water 2000 cubic meters and other industrial uses 8020 cubic meters.

The PostFukushima task force and the Expert Committee did not consider breakdown of the desalination plant. The desalination plants can fail either due to grid failure or due to damage of the machines or due to an attack from the jelly fish and other marine organisms. In the case of grid failure, the reactors will also be shut down. The reserve water is sufficient for maintaining the safety feature for 10 days. However, the township will face water shortage in about two three days. Where will they bring potable water if the grid failure lasts for more than three days? If the desalination plants fail due to other reasons, the reactors will have to be shut down immediately. Restarting may be delayed due to xenon poisoning.

AERB had placed several conditions on the question of fresh water. None of these conditions like two physically protected pipelines connected to Pechiparai and Upper Kodayar reservoirs, storage of 60,000 cub meter of water inside the island etc. None of these conditions has been met. (Chapter 2 – Fresh Water Availability)

1.3) Limestone Mining in the Exclusion Zone

During 19992003, the India Cement Co was engaged in limestone mining at the KKNPP site. There is no mention of this additional industrial activity at the site in any of the documents of NPCIL. Even though this activity was happening even while NEERI was doing its site studies for the Environmental Impact Assessment, there is no mention of it in the EIA for KKNPP 1 and 2. They have meticulously documented the details of mining happening at a distance of 5 and 18 km from the site. Were these activities in accordance with the regulations on the coast? What was the need for this mining lease? More details in chapter 3.

Report of the P-MANE Expert Committee


1.4) The un counted people in the Sterilization zone and Routine releases through stack

The expert committee says that nobody lives within 2 km of the plant boundary. The CASA Nagar tsunami township lies within about a km from the boundary. There are about 2000 people living in 450 houses in CASA Nagar. According to the rules, there should be no ‘unnatural’ population growth inside the sterilization zone. The township could have been constructed elsewhere, outside the sterilization zone. This could have prevented unnecessary exposure of children and women from stack emission. (Annual emission from stacks will be more than 30 trillion Bq of xenon, 14carbon, tritium and other radionuclides.) In the case of a radiological emergency, these are the people who would need to be evacuated immediately. Why KKNPP did not see them till now? (Chapter 4)

1.5) Flawed assumptions and false assurances of safety by the Expert Committees

The reports of the Post Fukushima task forces, AERB and the Expert Group of the Central government contain a couple of faked data, flawed assumptions and false assurances. This chapter is a comparison of the reports dealing with the safety of KKNPP reactors. (Chapter 5)

1.6) Station Black Out beyond 10 days due to Space Weather Anomalies

Space weather scientists and electricity planners in US and other countries are preparing for grid failures lasting for years as a result of solar tsunamis. According to the Oak Ridge National Laboratory, the probability of an event similar to the 1859 Carrington Event is one in hundred years. US NRC is currently considering a petition for rulemaking to protect the nuclear assets like the reactors and the spent fuel pool in the event of station black outs and desertion of the nuclear campuses. (Chapter 6 – Space Weather Anomalies and Nuclear Safety)


Health effects from ionizing radiation can be broadly classified into somatic and genetic effects.

2.1) Genetic effects Kerala High Background radiation region

People living in coastal regions of NeendakaraChavaraAlapat Panchayats in Kollam district of Kerala are exposed to higher natural radiation emanating from the monazite deposit in the beach sand. The mean exposure to about 40,000 people is 5 mSv (range 2 to 15 mSv). N Kochupillai et al reported a higher prevalence of Down Syndrome and Severe Mental Retardation in this region in 1975. A more detailed epidemiological study on 38,000 exposed people and 32,000 people living in normal areas in Alapuzha district was conducted by VT Padmanabhan This study found a statistically significant excess of several single gene anomalies in the children born in high radiation areas.

Report of the P-MANE Expert Committee


2.2) Flawed Genetic Studies in the Bombed Cities of Japan.

Genetic studies in HiroshimaNagasaki were designed by the US Army’s Atomic Bomb Casualty Commission in 1948. They included a group exposed to heavy doses of residual radiation from the fission products and neutron activation products in the control (unexposed) group in the genetic study. A review shows high aberration of sex ratio of the offspring of the unexposed control group. Summary of a paper presented at an international conference on radiation health risks.

2.3) Sex ratio aberration in Children of employees of BARC and TAPS

There were more boys among the progenies of employees of BARC and radiation workers of TAPS. The difference in birth sex ratio found in these populations was compared with the normal birth sex ratio in urban Maharashtra, The difference was statistically significant. Sex ratio of aberration of similar nature has also been reported in children of Sellafield workers and in progenies of atomic bomb survivors.

2.2) Somatic Effects Prevalence of cancer among atomic workers and their wives

Prevalence of cancer was significantly higher among the workers and their wives of TAPS and BARC when compared with MAPS. This may be because of the higher exposure from first generation reactors and higher maximum permissible doses during the sixties and the seventies. The Chennai cancer registry reports higher incidence of cancer than the registry in Mumbai. Prevalence of cancer among the male workers of BARC is three and a half times higher than that in MAPS workers. Parallel increase is seen in the case of wives as well. TAPS stands in between.

All the above studies are summarized in Chapter 7.

2.5 Somatic Effects – Autoimmune diseases, cancer etc among the Downwinders of MAPS, Kalpakkam

Dr Manjula Datta compared the health status of people living within 8 km of Madras Atomic Power Station with those living 50 people away from MAPS. The raw results of this study, funded by the Department of Atomic Energy were released by the managers of MAPS. For 10 diseases including diabetes, thyroid anomalies, cancer, mental retardation, infertility etc, the prevalence per 10,000 people in proximate areas was 79 as against 19.5 in the distant areas. A study of a smaller population living in villages located at 6 km, 40 km and 500 km from MAPS conducted by V Pugazhendi et al also had found significant excesses of goiter and autoimmune thyroid diseases among the people living in 40 km and 6 km from MAPS. Details Datta et al and Pugazhendi et al studies are summarized in chapter 7.

Report of the P-MANE Expert Committee



It is stated that the reactors we have a negative impact on the fisheries. It may be mentioned that the fishery resources of Caspian sea and the Black sea is depleted because of the effluence from the reactors and industrial waste. The release of radiated waste into the sea cannot be ruled out.



The alternatives, cost and the failure of Indian Nuclear Energy is details in this section

Report of the P-MANE Expert Committee




R Ramesh, VT Padmanabhan and V Pugazhendi

We have undertaken a critical review of the KKNPP site. We have used research papers from peer reviewed journals, international and national nuclear safety manuals (IAEA, USNRC and AERB), published books on various specific topics, and reports of recent natural events for conducting this in depth review. The review covers the fields of Geology, Oceanography and Hydrology.

The review indicates that this is one site that should have been selected with much caution. The review notes that the site selection and evaluation by the concerned authorities was not done with due diligence.

The site has the characteristics of a rift or an aulacogen. Presence of closely associated carbonatites and basic dyke swarms, escarpment along the coast and the drainage pattern substantiate this conclusion. The terrain is transected by mafic bodies cutting into the granulite grade of metamorphic rocks. The configuration of these sub volcanic intrusives, brought out by a recent ground magnetic survey, deems a horstgraben structure criss crossing the E W trend of the coast. These sub volcanic bodies have bisected the near surface crust in the form of plugs to the west and in the form of dyke swarms to the east, indicating a severe crustal dilation to the east. They are suggested as the surface expressions of an anomalous body found at a depth of 110 200 meters. It is also suggested that crustal thinning and mantle upwelling have led to the emplacement of mantle hybrid rocks as dykes and plugs, near (200 meters deep) sub surface. The finding in 2007, that Nagarcoil located 29 km from the Kudankulam site has the highest sub crustal heat flow value in South India supports this conclusion. A 1991 study has found and analysed a volcanic trchytic tuff collected from the same spot where the two reactor buildings are now located. The presence of dykes of trachytes, alkali basalts, sovites, phlogopite carbonatitic breccias and lavas, floats of volcanic bombs, ash tuffs and brecchias bring to the mind the case of High Radioactive Waste Repository at the Yucca Mountain, Nevada, USA. The primary argument against siting a high level radioactive waste repository at the Yucca Mountain Region (YMR) was centered on the possibility of small volume basaltic volcanism in the region. The presence of basaltic dykes in the YMR, had made the USNRC to conduct more than one Volcanic Hazard Study for the high level radioactive waste repository.

Report of the P-MANE Expert Committee


Places around Kudankulam have experienced small volume volcanic eruptions in the years 1998, 1999, 2001 and 2005. The nearest eruption occurred at just 26 kilometers away from the KKNPP site. The products of these eruptions have been confirmed by various researchers as the ones produced by volcanic activity. One cannot rule out such eruptions at the site itself. Issues of subduction, fire and impact of high speed missiles emanating from the burst need to be addressed.

Various researchers have found undersea volcanoes and volcano vents in the Gulf of Mannar (GoM) ever since 1975. Kudankulam site is located at about 100 kilometers from these structures. A magnetic survey conducted in the GoM in the year 1994 had revealed extensive emplacement of its crust by basltic rocks, eventually making the crust just 15 kilometers thin. A 1978 study by the volcanologist P.Hedervari places this site as one that belongs to the Indo Australian seismic zone.

The IAEA safety document titled “Volcanic Hazards in Site Evaluation for Nuclear Installations” released in May 2011 reveals the possible dangers of having subvolcanic inrusives at a site for nuclear facilities:

“Volcanic activity or igneous intrusions, such as dykes, may change groundwater flow patterns and cause

fluctuations in the depth of the water table. Magma intrusions also can trigger explosions in the hydrothermal system. Changes in the groundwater system may cause subsidence in karst terrains.” (p75, DS405 Draft 10

2010 1209)

All these findings point to one thing: the necessity to have a volcanic hazard analysis for the Kudankuulam site before the reactors are commissioned.

The site selection and evaluation committees have ignored the presence of the sub volcanic intrusives and the possibility of having small volume volcanic eruptions at the site itself. This negligence might prove costly in the future.

The formation of a sill hole at Pannayarkulam after the rain on 26 November 2011, and the occurrence of a similar incidence three years ago at Radhapuram suggest that this area might be a karst region. Pannayarkulam and Radhapuram are just 10 kilometers away from the reactor site. Extensive studies to understand these events should have been undertaken by NPCIL, but it remains unaware of these events. Commissioning the reactors without understanding these events might have disastrous consequences.

The clearance for excavation was given in October, 2001. The clearance was issued subject to compliance of stipulations like restriction on surface mining of limestone within Exclusion Zone and Sterilized Zone and design of embankment for water storage reservoir as ultimate heat sink. Both these stipulations have not been met by

Report of the P-MANE Expert Committee


the NPCIL till today. Had the NPCIL known that the crust over which KKNPP is located is a thinned out one by the subvolcanic intrusions, and that this region has the ability to turn into a karst region, it would not have allowed the mining activity in this area at all. Lack of this knowledge has prompted it to remain negligent.

There are studies that indicate that the Kudankulam site has an unstable shoreline. Studies by Brucknur, Altrin Armstrong Sam and others have proved that this shore had remained unstable in geological past. The case of the subsidence South Dhanushkodi, a town that was located in the same Gulf of Mannar coast, in the year 1948 1949 because of faulting, should have cautioned NPCIL about the issues it might have to face if this site is chosen. However, ignorance of this most important geological event has made NPCIL to choose the Kudankulam site and locate the reactor buildings within 300 meters of the shoreline. Despite taking this decision, NPCIL to the present day, has not conducted the necessary studies that prove a South Dhanushkodi like faulting phenomenon might not occur at the Kudankulam site itself. Even where research studies have been commissioned by NPCIL, they had remained largely substandard. This has been documented by a research paper published in Current Science in November 2004.

AERB has asked NPCIL to study the pattern of erosion and accretion occurring in the Kudankulam shore. The shore that is located west of the sea water intake dyke is accretional and the one that is located east of the dyke (where the sea water desalination plants are located) is erosional. Studies have confirmed that the rate of accretion has been declining in the western zone and the rate of erosion has been climbing up steadily in the eastern zone since the year 2006. Legal and illegal coastal sand mining near Perumanal (located about 5 km west) by private companies, is said to be the reason for the shoreline tending to become more erosional. However, NPCIL has neither bothered to study this phenomenon nor has taken the necessary steps to curb or restrict the coastal sand mining activity. This sheds light into the safety practices followed by the NPCIL.

NPCIL maintains that only far field tsunamis are possible for the KKNPP site. This happens to be an unproven assumption. It has not conducted a Tsunami Hazard Study as attempted by A.K.Ghosh for the Madras Atomic Power Station in the year 2006 and published in the year 2008. The manual on Tsunami Hazard Study published by USNRC in March 2009 warrants all coastal sites to perform a Tsunami Hazard Study. In order to do this, two main knowledge bases need to be created: 1) Studying Paleo Tsunamis for the area, and 2) identifying the near field and the far field tsunamigenic sources. While identifying the tsunamigenic sources, one need to identify:

a) potential tsunamigenic faults, b) undersea volcanoes, c) areas prone for sub marine landslides.

Report of the P-MANE Expert Committee


In 1982, two American researchers William Vestal and Allen Lowrie have studied the sea bed of south Gulf of Mannar and have identified two large slumps 90 and 35 kilometers long. They have named them as East Comorin Slump and Colombo Slumps. They have mapped these slumps intricately and have found evidences of past landslides in these slumps. Petrographic studies in Gulf of Mannar have revealed the presence of large scale clay stones in this area. Presence of claystones make the occurrence of submarine landslides easier. The volcanic vent found by V.V.Sastri et al in 1981 is located beneath the Colombo slump and the vent found by G.R.K.Murty in 1994 is located just beneath the East Comorin slump. Indrani fault extends into Gulf of Mannar and has the capacity to disturb these slumps. Any earthquake that occurs on this fault has the potential to casue the slump to slide down and thus trigger a near field tsunami. Earthquakes that occurred in 1938 (5.8R) and in 1991 (5.2R) have occurred nearer to these slumps. The earthquake that occurred on 19 November 2011 (5.2R) has occurred in the Indrani fault. Itwas about 400 km south of KKNPP. While the experts from Center for Earth Science Studies, IMD and INCOIS were busy debating about this earthquake, NPCIL remained unconcerned. Had it known that this eartquake had the potential to cause a slope failure in one of the GoM slumps and thus cause a mega tsunami (wave height reaching even 100 meters), it would have actively participated in a discussion about this earthquake. However, because of its ignorance about the existance of these slumps, it had remained silent and of course negligent toward its safety related work.

USNRC has warned about the issue of dry intake facing the coastal reactors. After the occurrence of the 2004 December tsunami, many episodes of sea water recession have occurred in the Gulf of Mannar coast. During such periods of sea water recession, the sea water intake process run into trouble. Instead of drawing the sea water, they would be drawing just air, and thus causing a severe damage to the reactor itself.

Without a volcanic hazard study, tsunami hazard study and a karst hazard study in place, if the reactor gets commissioned, the chances for the occurrence of an accident of the Fukushima type, are very real.

Report of the P-MANE Expert Committee



1. Ramaswamy R 1987. ”Reactivation of Eastern ghat paleorift system during tertiary and other periods”, Proc. In Nat. Sem. On Tertiary orogeny, Banaras hindu University, Varanasi, 107127 ; Ramaswamy R 1991. ” Occurrence of Soda trachyte near Kudangulam village, Tamilnadu”, Current Sci.,61, 401 402 ; Ramaswamy, R 1995. ” Occurance of olivine Tephorote and carbonate Tepharite in Kudangulam area, near Cape Comorin, Tamilnadu, India”, Journ.Geol.Soc. India, 45, 331333; Biju Longhinos, K.S.Anand, Mita Rajaram, “Subvolcanic intrusives of Kudamkulam, India a ground magnetic characterization of sub surface structure”, Lasi 4 Conference, Physical Geology of Sub Volcanic Systems: Lacoliths, Sills and Dykes, Moab and Mount Hillers, (Utah USA), 22 26 September 2010; M.Ramasamy, “The evidence of late Cenozoic volcano tectonic deformations in Kudangulam, near Cape Comarin, Tamilnadu”, International Geological Correlation Programme (IGCP), 1993; Biju Longhinos, Rama Sarma, Seismo Tectonic Signatures in and around Kudankulam, Tirunelveli District, Tamil Nadu”, February 2002, unpublished paper; A.Phillipots, “Introduction to Igneous and Metamorphic Petrology” , Prentice Hall, New Jersy, 1990; S.K. Agrawal, Ashok Chauhan, Alok Mishra, “The VVERs at KudanKulam”,Nuclear Engineering and Design 236 (2006) 812–835, p826

2. A. Boominathan, "Seismic site characterization for nuclear structures and power plants” CURRENT SCIENCE, VOL. 87, NO. 10, 25 NOVEMBER 2004

3. IAEA, “Volcanic Hazards in Site Evaluation for Nuclear Installations”, DS405 DRAFT SPECIFIC SAFETY GUIDE,27 May 2011. pp 54,74,75

4. yucca30 ;Charles B. Connor, John A. Stamatakos, David A. Ferrill,Bri ain E. Hill, Goodluck .Ofoegbu, F. Michael Conway,2Budhi Sagar,and John Trapp, “ Geologic factors controlling pa erns of small volume basal c volcanism: Applica on to a volcanic hazards assessment at Yucca Mountain, Nevada”,JOURNAL OF GEOPHYSICAL RESEARCH, VOL. 105, NO. 1, PAGES 417–432, JANUARY 10, 2000; Greg A.Valen ne, Frank V.Perry, Don Krier, Gordon N.Kea ng, Richard E.Kelley, Alen H.Cogbill, “Small Volume Basal c Volcanoes: erup ve products and processes, and post erup ve geomorphic evolu on in crator at (Pleistocene), southern Neveda”, Los Alamos Na onal Laboratory, December 2005; J. Spera and S. J. Fowler,“Conceptual model for smallvolume alkali basalt petrogenesis: implica ons for volcanic hazards at the proposed Yucca Mountain nuclear waste repository” , in Volcanic and Tectonic Hazard Assessment for Nuclear Facili es” , Charles B. Connor, Neil A. Chapman ,Laura J. Connor , August, 2009; Greg A. Valen ne and Naoto Hirano, “Mechanisms of low ux intraplate volcanic elds‐‐ Basin and Range (North America) and northwest Paci c Ocean”, Geological Society of America, 2010)

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G.victor Rajamanickam, N.Chandrasekhar. “Extrusion of Rockmelt in the vicinity of high tension electric line”, Journ. Geol. Soc. India, Vol.55, March 2000; R.Ramasamy, “Molten Rock Extrusions”, Journ. Geol.Soc. India, Vol.55, March 2000; G.Manimaran, P.Sivasubramaniyan, M.Senthiyappan, “ Rock Melt Extrusion at Abhishekappatti, Tirunelvelli district, Tamil Nadu,A Report” Journ. Geol.Soc. India, Vol.57, 2001; ;S.C.Jayakaran, “A note on the occurrence of fulgurite in Tamil Nadu”, Current Science 75 (8): 763 (1998) ; B J SAIKIA, G PARTHASARATHY, N C SARMAHand G D BARUAH, “Fourier–transform infrared spectroscopic characterization of naturally occurring glassy fulgurites”,Bull. Mater. Sci., Vol. 31, No. 2, April 2008, pp. 155–158; A. C. KERR, M. KHAN AND I.MCDONALD, “Erup on of basal c magma at Tor Zawar, Balochistan, Pakistan on 27 January 2010:

geochemical and petrological constraints on petrogenesis” , Mineralogical Magazine, December 2010, Vol. 74(6), pp. 1027–1036


SUKANTA ROY, LABANI RAY, ANURUP BHATTACHARYA and R. SRINIVASAN, “NEW HEAT FLOW DATA FROM DEEP BOREHOLES IN THE GREENSTONE GRANITEGNEISS AND GNEISSGRANULITE PROVINCES OF SOUTH INDIA” , Deep Continetal Studies in India Newsletter, Vol.17, No.1, January 2007; P.Hedervari, “Volcanism and Seismicity in the IndoAustralian Seismic Belt : Manifestations of Intraplate Tectonics”, March 1978 ; P.Hedervari, “ Catalog of Submarine Volcanoes and Hydrological Phenomena associated with Volcanic Events – 1500 BC to December 31, 1899”, Report SE 36, World Data Center A for Solid Earth Geophysics, September 1984


AERB, “Kudankulam Atomic Power Project”


R.Ramesh, “Sea Water Desalination work at the Kudankulam NPP:Possible Solution to the Risk prone Confusion, Indecision and Haste”, DOSE, October 2006


R.Ramesh,“Kudankulam Nuclear Power Project and the Pechiparai Reservoir of Kanniyakumari District :Can Pechiparai reservoir meet KKNPP’s fresh water demand?” DOSE, October 2006


P.Sheik Mujabar, "Quantitative Analysis Of Coastal Landform Dynamics Between Tuticorin and Knyakumari using Remote Sensing And GIS,” M.Phil Thesis, Center for Geotechnology, Manonmaniyam Sundaranar University, Tirunelveli, February 2010, p 166

11. 0628/chennai/28156215_1_bulkwaterpurchaseagreementmld ofpotablewaterkattupalli


Krishnamurthy et al., “ Interim Report Of Task Force On Safety Evaluation Of The Systems Of KKNPP Post Fukushima Event,” 21 May 2011


T. S. SUBRAMANIAN, “AERB for more power, water for nuclear stations”, The Hindu, 12 November 2011

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14. G.G.Vaz, M.Hariprasad, B.R.Rao, V.Subba Rao, “Subsidence of southern part of erstwhile Dhanushkodi township, Tamil Nadu evidences from bathymetry, side scan and underwater videography”, Current Science, Vol.92, No.5, 10 March 2007

15. BRUCKNER, H., 1988, “Indicators for formerly higher sea levels along the east coast of India and on the Andaman Islands” : Hamburger Geographische Studien, v. 44, p. 47–72 ; Bruckner H 1989 late Quaternary shorelines in India; In: Late Quaternary sealevel correlation and application; (eds) Scott D B, Pirazzoli P A and Honig C A, Kluwer Academic Publishers, pp. 169–194; Ramasamy, S., Armstrong Altrin Sam, J., 1998. Inferences on rhodoids from Neogene carbonates of Kudankulam, Tamil Nadu, India. Geol. Soc. Ind. J. 52, 341–344; S.Aemstrong Altrin, Yang Il Lee, Surendra Varma, S.Ramasamy, “Geochemistry of Sandstones from Upper Miocene Kudankulam Formation, Southern India : Implications for Provenance Weathering and Tectonic Setting ”, Journal of Seimentary Research, Vol. 74, NO. 2, 2004

16. (G.R.K. MURTY, Y. SATYANARAYANA AND T. PRADEEP KUMAR " Magnetic Profile Across Gulf of Mannar", JOURNAL GEOLOGICAL SOCIETY OF INDIA, Vol.44 , Oct. 1994, pp.443 449). ( SASTRI, V. V . VENKATACHALA, B.S. and NARAYAN, V. (1981) The evolution of East Coast India. Paleogeogr.Palacoclim Palacoeco., pp.366 23 54; PRABHAKAR, K.N. and ZUTSHI, PL. (1993) Evolution of southern part of Indian East Coast Basins.J.Geol.Soc.Ind., v.41, pp.215 230; NAINI, R. BHOPAL and TALWANI, M. (1982) Structural framework and evolutionary hisotry of the continental margin of western India. In: Studics in continental margin geology. (Eds) WATKINS, J.S. and DRAKE, C.L. Am.Assn.Petrol.Geol. Memoir, v. 34, pp. 167191; KHALE, HG., TALWANI, M. and ELDKLOM, O. (1976) Geophysical study on the continental margin of south India and west of Sri Lanka. EOS, Trans. ; EREMENKO, N.A., and GAGELGANZ. A (1966) New data on the tecionic framework of the New Indian Peninsula, Bull. ONGC, v.3(2), pp 13 ; CARL,W.S. (1966)

pp 25752581; Udintsev (1975), Geological and

Scismcily of the Indian Ocean, J.Geophy


Geophysical Atlas of the Indian Ocean, Moscow, Academy of Sciences, 151 p.)

17. Malai Malar, 26 November 2011


19. R.Prasad, ”Tsunami Hazard Assessment at Nuclear Power Plant Sites in the United States of America Final Report”, USNRC, March 2009

20. IAEA, “Volcanic Hazards in Site Evaluation for Nuclear Installations”, DS405 DRAFT SPECIFIC SAFETY GUIDE,27 May 2011

21. William Vestal, Allen Lowrie, “Large Scale Slumps Off Southern India and Sri Lanka", Geo Marine Letters,

Vol.2, 171177 (1982)

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1 AERB, clearance letter dated 10 November 1989

1 National Environmental Engineering Research Institute (NEERI) , 2003, EIA for KKNPP 1 and 2 Reactors, p 2-45

1 National Environmental Engineering Research Institute Chapter 3: Baseline Status and Impact Statement page 3.47

1 Krishnamurthy et al Interim Report Of Task Force On Safety Evaluation Of The Systems Of KKNPP Post Fukushima Event, 21 May 2011

1 Presentation to Tamilnadu Government nominees and the people (sic) representatives regarding safety of KKNPP on 18- 11-2011 in the office of the District Collector, Tirunelveli by Expert Group on KKNPP constituted by the Government of India, 18 Nov 2011

1 Rajeev Deshpande, Indian N-plants step up safety measures, Times of India TNN | Oct 19, 2011.

1 VT Padmanabhan, 2011, Space weather anomalies and nuclear safety. Paper presented at the National Seminar on Nuclear Safety at Kuvempu University on 10 Nov 2011.

1 More safety features at KNPP soon New Delhi. Deccan Herald, Nov 11, 3011, DHNS:

Report of the P-MANE Expert Committee




R Ramesh, VT Padmanabhan and V Pugazhendi


The main raw materials used in a pressurized water reactor (PWR), are uranium and water. A 1000 MW(e) reactor will burn about 3,000 grams of 235 uranium a day. The thermal energy generated in the core is taken out using water. The reactor requires about 3 million liters of fresh and pure water and 7.2 billion liters of seawater every day. If there is no uranium, there will be no fission, no heat and no electricity. Even when electricity is not generated, water is required to remove the decay heat from the spent fuel for a minimum of ten years. In short, water is the soul of the reactor. The campus of the Kudankulam Nuclear Power Plants (KKNPP) located on the Bay of Bengal coast in Tirunelveli Kattabomman district of Tamil Nadu, India is the only one in the world totally dependent on desalination plants for their industrial and domestic water requirements. The reserve water available is not even sufficient to meet the requirements for two days.


The Nuclear Power Corporation of India Ltd (NPCIL) constructed two 1000 MW(e) pressurized water reactors (PWR) at Kudankulam in Tirunelveli district of Tamil Nadu. The first unit was to be commissioned in December 2011. Local communities stalled the commissioning of the reactor as they fear that the reactor complex is a threat to their lives. Analysis of the official documents reveals that the peoples’ apprehensions are correct as there is not enough reserve water inside the campus for cooling the reactor cores and the spent fuel pools in case the desalination plant fails. None of the conditions regarding reserve water laid down by the Atomic Energy Regulatory Board in its sanction letter dated 10 Nov 1989 has been met. Hence, the construction of the campus is illegal. Commissioning the reactor in this condition may lead to Chernobylization of the peninsular India.

Report of the P-MANE Expert Committee


History of Kudankulam Nuclear Power Project (KKNPP)

The project, a product of the RajivGorbachev summit of 1988 was given conditional clearance by the Atomic Energy Regulatory Board (AERB) of the Government of India is 1989. In the original proposal, fresh water industrial and domestic purposes was to be brought from Pechiparai reservoir,65 km North West of the site on the river Kodayar, in Kanyakumari district. While giving its nod to the project, AERB made the following conditions regarding fresh water: i

“Facility to store at site adequate quantities of water should be provided to meet the makeup requirements of uninterrupted cooling of core and other safety related systems on a long term basis.

Facilities engineered at site should meet the requirements even in the event of possible disruption of piped water supply from Pechiparai Dam.

Ground water sources in the site area should be surveyed and developed to serve as an additional back up source to meet the safety needs of the plant if water supply from Pechiparai dam is interrupted due to any contingency.

The safety of the 65 km long pipeline from Pechiparai dam should be ensured by appropriate security arrangement.

The intake well at the dam should be provided at lower elevation than the minimum draw down level of the reservoir.

The Board desires that the structural stability of the reservoir should be assessed taking into account the recent work of strengthening the dam.

In the unlikely event of the breach of the dam, alternative sources of water supply should be available for the site within a reasonable time.

NPCIL should conceptualize schemes at the Detailed Project Report (DPR) stage for utilization of the water from Upper Kodayar reservoir for such an eventuality.”

The Environmental Impact Assessment (EIA) for the project prepared by the National Environmental Engineering Research Institute (NEERI) 13 years after the AERB clearance states that: ii

“For meeting fresh water demands, water from Pechiparai dam will be brought to the site through embedded pipeline. This pipeline will be adequately designed to withstand all design forces. At project site, it is proposed to construct a reservoir with a capacity to store 7 days requirement of

Report of the P-MANE Expert Committee


process and drinking water (of capacity approximately 60,000 m3 for 2 units). This reservoir is planned to be located at an elevation of 35 m. which is much above the safe grade elevation of the reactor building.”

“Fresh water for make up to the plant systems will be passed through sand filters and D.M. plant. For domestic use within the township, the sea water will be passed through reverse osmosis plant and will be treated in a conventional water treatment plant followed by chlorination. The capacity of RO plant would be 2 x 25 m3 per hour.” (1,200 m3 pd)

In 2004, NEERI wrote another EIA for the proposed 3 rd and 4 th unit at the same site, in which radical changes in the plan for the first two reactors under construction were announced: iii

‘Industrial Water requirement for Kudankulam Nuclear Power Project was originally envisaged to be drawn from Pechiparai reservoir. Due to severe drought due to poor rainfall in this region and due to the lack of underground ground water reserves, precarious water shortage exists in the region, Considering all this, and as Nuclear Power Plants require abundant and reliable source of Water supply, NPCIL has decided to set up captive desalination plant, which would meet total requirement of Nuclear Power Station. The desalination plant can produce 320cu.m/hr of fresh water from 670cu.m/hr of seawater for meeting the fresh water make up requirements.’

Water requirements of KKNPP

In KKNPP reactors fresh, demineralised and de ionized water will be used as primary and secondary coolant and sea water will be used as tertiary (condenser) coolant. While under operation, each reactor will require 3500 cub meters of fresh water and 7.2 million cub meters of sea water every day. Fresh water is also needed as a reserve for fire fighting. One year after commissioning, the spent fuel removed from the core and kept in the spent fuel pool will also need to be cooled using fresh water.

On the issue of availability and requirement of water, there are major differences in the official reports:

Altogether 6 desalination plants were set up at KKNPP site. The first two were based on reverse osmosis with a capacity of 600 cub meters per day each. These were to meet the domestic needs of the township and the plant site. Four more plants were constructed by an Israeli firm for production of industrial water for two reactors. These were based on multiple vapour compression (MVC) technology. Of the four plants, three would be online and one on standby. Official reports differ on production and allocation of water at KKNPP:

Report of the P-MANE Expert Committee


On production

According to Post Fukushima Task Force Report, the total production from 3 plants will be 7,200 cub meters a day. iv

According to the report of the Expert Group the total production is 7680 cub meters a day. v

On the potable water requirement:

According to NEERIEIA, is 414 cub meter a day.

According to the GOI Expert Committee is 1272 cub meters a day”.

Desalination plants

KKNPP constructed six desalination plants. The first two with a combined capacity of 1200 cub meters were based on reverse osmosis technology provided by BARC. There is no mention about these plants in any of the recent official reports. The other four plants are based on Multiple Vapour Compression (MVC) technology. The plants were built by an Israeli company at a cost of Rs 1150 million. BARC is known as a leader in sea water desalination. They have built small and large plants inside their campus, in villages of Lakshadweep and Rajasthan and also for private corporations like ESSAR and Reliance. There are also several desalination plants in India producing water for both industrial and domestic needs. However, KKNPP plants are the only one based on MVC technology. As such, it is doubtful whether India has the human power to handle major defects in the plants.

Reserve Water

The campus has 12 tanks with a combined storage capacity 12,445 cub meters. Of this, 2000 cub meter of water is in firewater tanks and 1425 cub meter is in tanks for domestic use located outside the KKNPP Island. Leaving aside these, KKNPP has a maximum storage capacity of 9020 cub meters, sufficient enough to run two reactors for about oneanda half days. The reserve in domestic water tanks will not even last that longer. According to EGR, “the inventory available in various tanks is adequate for cooling requirement of reactor Plant for at least ten days in case of power failure from the grid (even though the regulatory requirement is only 7 days.”

The reserve water available at the domestic water tanks is 1425 cub meters, whereas the daily requirement is 1272 cub meters. The township people will reduce their consumption, once they know that they are on reserve water. Even then, the reserve may not last for more than 3 days. Will the scientists and technicians report to duty, when there is not a drop of water in their apartments?

Report of the P-MANE Expert Committee


The Expert Group mentions grid failure as the cause of interruption in production of water. Under normal circumstances, the grid will be reconnected in a day or two. And when the grid fails, reactors will also be shut down and the cooling requirements are minimal. Longer term collapse of the grid, more than a month or even year is also a possibility. This issue is discussed in another section on Space Weather Anomalies.





Location of storage

Cub Meter


DM water storage tanks in DM Plant



DM water storage tank LCP near TB






Emergency water storage in SFP



ECCS tank stage 1



ECCS tank stage 2



Distillate storage tanks KBC



Boric acid tanks KBD



SFP filling tanks



Firewater tank



Desalination Plant



Domestic water tank






Total less domestic


Source: S Krishnamurthy et al, Task Force Report (ref 1)

Though a nuclear reactor generates electricity, all reactors are dependent on grid power for maintaining their safety related pumps and instrumentations. When the grid fails, reactors will have to be shut down. The cooling requirement during shut down being considerably lower, 9020 cub meter of reserve water can keep the reactors under control for 10 days.

A desalination plant is a complicated machine which has to clean and sterilize sea water a biologically complex medium. That machine can fail for reasons other than grid failure. These can be wear, tear and corrosion of its own components or the attack of those known and unknown life forms grouped as fouling agents.

Report of the P-MANE Expert Committee


During periods of such failures of two desalination plants (including the one on standby), the reactors also will have to be shut down. Unlike other machines, a nuclear reactor cannot be restarted immediately after the shut down, because of the phenomenon called the iodine pit. Since there is not much of expertise in MVC desalination in India, specialists may have to be brought in from Israel to solve the problems. If the desalination plants cannot be brought in stream within 10 days, where will they bring the water from?

By the middle of 2012, there would have been two reactors functioning at KKNPP. By the end of 2012, the spent fuel pool would also require fresh, de mineralized, deionized water as coolant. It is not clear if the existing reserve is sufficient to meet all these three demands for seven days.

The World of Virtual Water

Quoting the government sources several stories have appeared in the national media showing that the reactors have enough reserve water. Excerpts from a report that appeared in Times of India: (Oct 19, 2011):

“In case of an accident or a natural disaster necessitating the activation of emergency measures, the cooling of the core is top priority and drawing lessons from the Fukushima scenario where gusts of radioactive steam escaped into the atmosphere for days, India's plants are now supplied by alternate water sources that will not be vulnerable to disruption.” …“ Not depending on onsite water sources alone, water pipelines from remote locations will supplement and provide fall back apparatus . …India has ramped up safeguards at its atomic power plants with three layers of power back ups, water pipes drawn from offsite locations , elevated water towers and options for injecting nitrogen to prevent explosions.” vi

In a paper presented at a National Seminar on Environment and Nuclear Safety at Kuvempu University on 10 th Nov 2011, one of us had referred to the inadequate water reserve at KKNPP. vii Next day, Kasinath Balaji, site director of Kudankulam Nuclear Power Plant told the Deccan Herald: “We are setting up a tank of 8,000 cubic meter capacity as an additional source of water. Also there will be mobile power units to run the pump in case of station black out and failure of all emergency generators”. viii


NPCIL did not do its homework before signing a contract worth of Rs 130 billion. Prior studies had revealed that “during 1901 1989, Kanyakumari District (in which Pechiparai Dam is located) had faced 52 years of

Report of the P-MANE Expert Committee


draught and draught like situations. In a study on the run off in the Pechiparai Dam for the years 1963 to 1990 (27 years), it was found that the actual run off was about 15% to 37 % less than the expected average”.

NPCIL has constructed the KKNPP campus in violation of the terms and conditions laid down by the Atomic Energy Regulatory Board in 1998. NPCIL and elements within the Government of India have been spreading misinformation about the safety of the reactor complex. Since the backup for coolant water is insufficient, the commissioning of the reactor will be a dangerous gamble. Incidentally KKNPP is the only reactor campus in the world totally depending on a machine for meeting the industrial and the domestic water requirements.

The first project proposal stated that there will be a reservoir with a capacity of 60,000 cub meters of water brought from Pechiparai. Even though Pechiparai is off, they could still store this water with the product from four desalination plants working on full steam for 6 days. These plants have been lying idle for the past three years. But then why is it that they did not construct the 60,000 cub meter reservoir there?

Report of the P-MANE Expert Committee




VT Padmanabhan, R Ramesh, V Pugazhendi

NPCIL bought about 10 sq km of land at Kudankulam to set up nuclear power plants. Of this, about 2.2 sq km of land was leased for lime stone mining to a private cement factory. NPCIL did not carry out any mining activity as per the classification by the Expert Group appointed by the Government of India to Allay the Fear of the Locals 1 .

of India to Allay the Fear of the Locals 1 . Unlike other places of business,

Unlike other places of business, site of a nuclear power plant and its neighborhood is closely studied and proper records have to be maintained. NEERI had done this at KKNPP site. In their EIA Reports for reactors 12 and 3 6, the mining activities undertaken outside KKNPP area are given.

“There is a stone quarry at Erukkanthurai, which is at a distance of around 6 km from the site. Excavation and quarrying is done through soft mining. There is also a stone quarry at a distance of 5 km from the site near Vijayapati. Here, only open soft excavation is used up to 2 meters depth. The other stone quarries are at distances of more than 18 km from the site” 23 EIA for 1 and 2 reactors was drafted in Jan 2003).

The Honourable Mr.Justice K.Chandru in his order dated 20 September, 2007 noted that mining activities were carried out by M/s India Cement in 220 hectares of land during 1999 2004. Total extraction in the year 200304 was 1.4 million tons of limestone and the ‘mine site’ (currently reactor site) had a closing balance was 2.9

Report of the P-MANE Expert Committee


million tons as on 31 March 2004. “ It was stated that on enquiry, the petitioner has kept two stock points. One

near the mine and another at 5 KM away from the mines. In the stock point near the mine is a nonroyalty and

noncess paid raw material are stored. The other stockyard at 5 KM away is a royalty and Cess paid materials

are kept.” 4

NEERI even reports about the mining activities at 5 km and 18 km away from the site. It is strange that there is

no record of this heavy extraction anywhere in the documents available in the public domain. As on 1st April

2003, the Kudankulam nuclear site had 2.4 million tons of mined limestone as mentioned in the order of the

High Court.

While the heavy machineries of M/s India Cements were extracting limestone from KKNPP site, the following

nuclear related activities were also taking place there: 5

Ground Break


First Pour of Concrete


Completion of Foundation Slab


Completion of 0.00m Slab


Construction upto + 5.4 Slab


Acknowledgement : We are extremely grateful to Adv Guruswamy of the Madurai Bench of the Madras High

Court for providing this valuable information.


1 Presentation by the Central Government Expert Group on 18 Nov 2011

2 Dr RN Singh, VP Deshpande, PR Chouhan and R Sarin (EIA 1+2, chapter 1 page 1.4

3 EIA for KKNPP reactors 3-6, page 1.4

4 M/s.India Cements Ltd vs Cess Commissioner W.P.(MD)No.10169 of 2005, W.P.M.P.No.10871 of 2005 and W.V.M.P.No.67 of 2006

5 KKNPP Major milestones

Report of the P-MANE Expert Committee




VT Padmanabhan, R Ramesh and V Pugazhendi

The Expert Committee for Allaying the Fear of the Public says that there was nobody within a distance of 2 km from KKNPP in 2001. This is absolutely true. In response to P MANE Expert Group’s observation that the population data is outdated, Dr Muthunayagam, convener of the Government Expert Group said that the current population can be estimated by using the decadal growth rate.

can be estimated by using the decadal growth rate. It is possible to estimate the current

It is possible to estimate the current population from the 2001 census data, if there has not been any large scale population transfer. This is not the case in the sterilization zone of KKNPP. Around the middle of the last decade, about 2000 people have moved into a township known as CASA Nagar, a tsunami survivors’ rehabilitation project. There are 450 housing units in CASA Nagar. These residents were earlier living in Idinthakarai and nearby villages. CASANagar is only 900 meters from the KKNPP; dangerously close to a stack emitting 50 trillion Becquerel’s of assorted radionuclides every year. Since these homes are less than 2 km from the stack, the lung burden of the people living there can be estimated from columns 6 and 7 above.

Report of the P-MANE Expert Committee


KKNPP is having details of population to be evacuated in the case of a radiological emergency. It appears that they do not know anything about CASANagar. These are the people who need to be evacuated first. Unlike other tsunami victims, CASA Nagar people were given a conditional ownership to those buildings. The title deed says that in case of a disaster (nuclear?) they will have to vacate the place immediately. They have no right for compensation in such case. How did this colony come up so close to the stack, within the sterilized zone? The lower government officials who made the site selection, the NGOs who supervised the construction and the beneficiaries could have been ignorant about the rules regarding the sterilized zone. However, the scientists and the managers of KKNPP were present in and around the campus since 2004.

Gaseous Routine Emission From KKNPP

Is living so close to a nuclear stack risky at all? The Central Government Expert Group Report says:

all? The Central Government Expert Group Report says: KKNPP reactor has a 100 meter high stack,

KKNPP reactor has a 100 meter high stack, higher than the reactor buildings. Why are these stacks standing so tall? A retired regulatory scientist of AERB said that the stack height ensures that “the released radionuclides will not reenter the campus”. Obviously, the exhaust air from building ventilation systems cannot be that dangerous to throw away so much money on a stack. So what does a VVER reactor throws out through its stack?

KKNPP EIA for reactors 3 and 4 has some data on the radioactive gases that would be released from them. That list available in Chapter 4, page 4.1 of KKNPP EIA for 3 rd and 4 th reactors is partial and has lesser details. The United Nation’s Scientific Committee on Effects of Atomic Radiation (UNSCEAR) has published more details of VVER reactor emission. Details regarding the emission of radioactive xenon, iodine, tritium, radiocarbon and particulates per gigawatt (1000 MW) in the year 2002 from a Hungarian VVER reactor are given in column 3 of table below. UNSCEAR Report of 2000 has published the concentration of released radioactive particles at different distances from the stack and also the average volume of air breathed by people in different age groups. Column 3 of the table has the release data for the year 2002 as published in UNSCEAR, 2008. Column 4 has quantity released in a day, column 5 has the estimated concentration of the released radionuclide per cubic meter of air at a distance of 2 km from the stack. An average infant breathes 2860 liters of air and an adult (>17 year) takes in 22,200 liters a day. Estimated radioactivity breathed in by an infant and an adult in a day is given in columns 6 and 7.

Report of the P-MANE Expert Committee


These are maximum values. The concentration at a particular place will depend upon the wind direction. And

as wind blows in all directions, to arrive at the concentration in a particular place, we should have annual

average wind data.

The emitted radionuclides are either gases or nanoparticles and they know no limits. The concentrations at

distances greater than 2 km can be known by using the data is table 5 of UNSCEAR 2000 Report, Annex A.

Routine Releases from a VVER Reactor In Hungary In 2002 Becquerel’s And Concentration In A Cubic Meter Of Air At 2 Km From Stack And In The Air Breathed By An Infant And An Adult In A Day



Concentration in Air

in Air



Half life

One Year

One Day

at 1 km percub meter


by an








135Xenon (Noble gas)








3H Tritium

12.3 years















5745 years







Diverse (long lived)













Sources :

UNSCEAR, 2006, TABLES A4, A5 & A6, Generation of electricity and release of radionuclides

UNSCEAR, 2000 Annex A, Table 5

Dilution factors for the representative source and long-term average conditions

UNSCEAR, 2000 Annex A, Table 16

Age-weighted breathing rate for the world population

Report of the P-MANE Expert Committee





VT Padmanabhan, Dr R Ramesh, Dr V Pugazhendi


Post Fukushima, NPCIL appointed separate task forces consisting of nuclear experts to examine the entire commercial nuclear power plants, including the yet to be commissioned reactors at Kudankulam. The committees for Madras Atomic Power station (MAPS) and Kudankulam Nuclear Power