Co-Written By VT Padmanabhan & Joseph Makkolil

Introduction

The water-water-energy-reactor (WWER) at the Kudankulam Nuclear Power Plant (KKNPP) has been transferred from the Russian vendor, Rosatom, to the Indian operator – the Nuclear Power Corporation of India Ltd (NPCIL) in a video conference presided by the Russian President Vladimir Putin and the Indian Premier Narendra Modi on 10 August, 2016. This is the fist and the only Russian reactor certified as belonging to Generation-III. We had earlier reported about the defective reactor pressure vessel and underperforming polar crane, the failure of the reactor in clearing the commissioning tests and the reactor’s world record for highest rate of scrams, its poor score card and the hasty transfer by the Russian vendor to the Indian operator without fulfilling the warranty clauses. In the midst of all the failures and falls, the reactor has also performed extremely well, generating more electricity than its installed capacity by a process known as power-uprating

This article, which is about this brave and bizarre experiment, is in three parts. Part-I traces the history of uprating experiment at KKNPP by analyzing the performance of the reactor during December 2014 and August 2016, which reveals there were 188 successful uprated days. Part-II deals with the safety codes, regulatory guidelines and practices of power uprating laid down by the International Atomic Energy Agency (IAEA), US Nuclear Regulatory Commission (NRC), the Russian agencies, the Ministry of Environment, Forest and Climate Change (MoEFCC) of India and the Atomic Energy Regulatory Board (AERB). This part also contains a detailed description of uprates done in Russia. Part-III describes some of the serious events at KKNPP-1 prior to and during the uprate experiment and defects of select equipment, failure of which can initiate an accident or prevent the mitigation of an accident.

REPORT OF THE 14 MAY 2014 ACCIDENT AT THE KUDANKULAM NUCLEAR POWER PLANT VT Padmanabhan,* R. Ramesh, V Pugazhendi, Raminder Kaur, Joseph Makolil Author affiliations 1. VT Padmanabhan, Society of Science, Environment and Ethics, (So-SEE), Karippat, Western Baazar, Aranattukara, Thrissur, Kerala, India -680616 2,3. Ramesh Radhakrishnan and V. Kudankulam Nuclear Power Plant (or Koodankulam NPP or KKNPP) is the single largest nuclear power station in India, situated in Koodankulam in the Tirunelveli district of the southern Indian state of Tamil Nadu.

PART – I: POWER UPRATE EXPERIMENT– DEC 2014- AUG 2016

A more advanced NPP Unit than the promised one

On 10 August 2016, four days after the reactor’s virtual transfer through video-conference, Vasily Zhurko, member of the Energy Committee of the Duma, the Upper House of the Russian Parliament, announced that “the actual values of the (KKNPP) Unit 1 main parameters are considerably better than the designed characteristics, its efficiency is 2.4% higher than the designed figures, and so India got a more advanced NPP unit than it had been initially planned.”[1] Earlier, on 31 May 2016, Vladimir Angelov, an official of the Rosatom had informed Anjali Ojha of the Indo-Asian News Service (IANS) that “KKNPP-1 crossed its installed capacity of 995 MW and generated 1,006 MW of power on 30 May 2016 and the existing parameters of the reactor plant make it possible to generate 1,020 MW”. He also revealed that the leadership of KKNPP and NPCIL know this and “we hope in near future they will take decision to increase power of the NPP unit” as it is “very important that we can generate 25 MW more for the Indian people.”[2] (Emphasis added)

Power Up-rate Experiment

What is being done at KKNPP-1 is known as ‘power up-rate experiment’ defined as “the operation beyond the power level licensed by the regulatory body” (IAEA). There are three types of power uprates: (i) “measurement uncertainty recapture” uprate, which involves an increase of less than 2% and is achieved by implementing enhanced techniques for calculating reactor power levels, (ii) “stretch” uprates where increases are between 2 and 7% and (iii) “extended” uprates with increases of up to 20%. Stretch and extended uprates involve changes to instrumentation settings and significant modifications to turbines, condensate pumps, motors, main generators and/or transformers.[3]

The Beginning at KKNPP-1

Generation data of KKNPP-1 published by the Southern Regional Load Dispatch Centre (SRLDC) on their website www.srldc.org show that the uprate experiment began on 14 December 2014, a week after the overhauled turbine-generator was grid-connected. As the installed capacity of the reactor is 995 MW, days with a gross generation of 1000 MW or above are treated as uprated days. Out of 630 days in the study period (14-Dec-14 to 14-Aug-16), December 2014- June 2015 represents the first fuel cycle and January -August 2016 represents the second fuel cycle. (The first refueling and maintenance was done during June 2015 –January 2016). During the 188 uprated days, the plant generated an excess of 1816 MW, over and above its installed capacity. Details are given in table-1.

TABLE -1 : SUCCESSFUL DAYS OF POWER UPRATING- DEC 2014- AUG 2016

Source: Daily reports of the Southern Regional Load Dispatch Centre (SRLDC)

The maximum generation of 1018 MW was achieved on 7 January 2015, seven days after the commercial commissioning; the excess on that day was 2.3%. The gross was above 1009 MW during 12 days -the average excess generation 1.8%, while the average during the whole period was 1%. Please see table 2 for details:

Table-2 : KKNPP1 – SUMMARY OF EXCESS GENERATION

Source: Daily reports of the Southern Regional Load Dispatch Centre (SRLDC)

The NPCIL has kept a studied silence about this successful, first of a kind experiment in the world. We will return to KKNPP after familiarizing the regulatory norms and legal requirements of power uprating as laid down by the IAEA, the US NRC and the Indian regulators.

PART –II SAFETY AND ENVIRONMENTAL ISSUES

While uprating will generate more electricity with a lower investment, there are also negativities which must be factored in the planning and decision making. Several uprated reactors like units 2 and 3 of the San Onofre NPP in California and Crystal River 3 NPP in Florida were permanently shut down within a year of uprating.

1. International Atomic Energy Agency (IAEA) on uprating

Considering the “potential impact on safety”, the IAEA has identified five major risks which include “increase in consumption of fissile materials and generation of radioactive wastes, and increased risk for severe accident sequences, calling for a review of severe accident management procedures”.[4] According to the IAEA “the maximum thermal power level of a plant is included in the license and technical specifications for the plant” and any change must be approved by the regulatory body and therefore the licensing analyses that demonstrate the safety of the plant must be performed when planning the power uprate. The essential part of such analyses is the demonstration that the plant structures, systems and components can support safe operation after the power uprate and that the results of the safety analysis remain within regulatory limits.”[5]

2 US Nuclear Regulatory Commission (NRC) on uprating

According to the NRC, “the process for amending commercial nuclear power plant licenses and technical specifications related to power uprate is the same as the process used for other amendments; therefore, power uprate requests are submitted to NRC as license amendment requests. After a licensee submits an application to change the power level at which it operates its plant, the NRC notifies the public, by issuing a public notice in the Federal Register. The public has 30 days to comment on the licensee’s request and 60 days to request a hearing. The NRC reviews the application, public comments, and requests for hearings, and notifies its findings and safety evaluation. On the basis of its findings, the NRC may approve or deny the request. Press releases are issued if a power uprate is approved.”[6]

3 India – Ministry of Environment, Forests and Climate Change (MoEFCC)

According to the MoEFCC’s Environmental Impact Assessment (EIA) Notification of 2006, the power uprate is an expansion of an existing project and the procedures for environmental clearance for this is the same as that of a new project. New EIA will have to be prepared and approved in the public hearing and by the experts after which the Environmental Impact Assessment Authority (EIAA) at the MoEFCC approves or rejects the project.

4 India – AERB: Safety Codes

A reactor has a Technical Specifications for Operation (TSO) also called as “operational limits and conditions (OLC), approved by the regulatory body. The document covers the operational limits and conditions, surveillance and administrative control requirements for safe operation of the facility. OLC “shall form an important part of the basis on which the plant management (PM) is authorized to operate the plant.” According to AERB’s Safety Code for NPP Operation[7]:

“7.1.2. OLCs shall be developed covering technical and administrative aspects to ensure that the NPP is operated in accordance with the design assumptions and intent. OLCs shall cover actions to be taken and the limits to be observed by the operating personnel. OLCs shall reflect the provisions made in the final design and shall be related to the results of safety analysis. OLCs shall include requirements for different operational states, including shutdown and startup.”

“7.1.12 Violation of any of the OLCs shall be notified to AERB or its designated body as per the established event reporting system by the PM. Consequent action specified by AERB, if any, shall be implemented in a timely manner.”

“7.2.6 Special procedures/tests which could result in the deviation from approved OLCs shall be carried out only with the prior approval of AERB or its designated agency. During execution of these procedures/tests, the overriding authority of the persons who manipulate the reactor controls and who supervise such operation to terminate the procedure and to bring the plant to a safe state shall not be jeopardized.”

The license for regular operation of KKNPP-1, issued by AERB’s on 8 July 2015 and“valid up-to the end of July 31, 2020” is subject to the conditions that (a) “the Consentee shall not operate the plant in excess of the maximum capacity authorized by the Regulatory Body;” and (b) “No changes shall be made to the programs, procedures or technical specifications, which have been approved by the Regulatory Body without such changes being given prior approval by the Regulatory Body.”[8]:

5 History of Uprating of VVER-1000 reactors in Russia

Power uprate experiment of the VVER-1000 reactors at Balakovo in Russia was consented and initiated in 2011, after four years of monitoring, data collection and regulatory evaluations. As of May 2016, there were 10 reactors uprated to 104% in Russia. According to the Russian experts, the basis for these uprating are: (a) Operating experience, (b) Equipment reserve capacities, (c) regulatory oversight, (d) Improvement of design development and (e) Lifting up of initial conservatism.[9] (Please see Box 1 for more one the Russian upates.)

The timeline of 10 VVER-1000 reactors under uprating in Russia is given in graph below:

Timeline : VVER-1000 Power Uprates- to 104% as of 2014

Courtesy: Maxim Bugakov, 2014, Rosenergoatom: knowledgable investor-customer-owner-operator , SLIDE No 16, https://www.iaea.org/NuclearPower/Downloadable/Meetings/2014/2014-04-07-04-11-TM-INIG/Presentations/03_Russia_Bugakov.pdf

PART –III : EVENTS AND CONDITIONS BEFORE AND DURING THE EXPERIMENT

Since an uprated machine is made to work beyond the design limit, there is always a risk of an accident and this explains the elaborate planning and preparations as outlined in Part –II above. Briefly, before initiation of uprate experiment, the plant should be stable and the operators must be familiar with it. In the following paragraphs, we will see if these conditions have been met at KKNPP-1.

1 Events during the experiment

Shutdown of the plant due to a trip/unscheduled maintenance or a drop in gross generation (to less than 990 MW) is treated as an event. There were 7 events during 384 days in 2014-15 (the first fuel cycle) and 10 events during 246 days in 2016 (the second fuel cycle.) During the first and the second fuel cycle, there was one event per 27 and 20 worked days respectively. On 15 Nov 2015, 11 months after the initiation of the uprate experiment, Sekhar Basu, the Chairman of the Atomic Energy Commission (AEC) said that the reactor is having teething troubles.[10] This is evident from table-3 which shows the tantrums of the toddler.

TABLE-3: EVENTS DURING THE UPRATING EXPERIMEMT

2 Short duration power excursions

The Southern Regional Load Dispatch Centre’s (SRLDC) daily reports contain generation of electricity at 03:00 hrs and 19:00 hrs and the maximum generation of the day. (The last variable represents the values for a minimum of 15 minutes.) The average generation at hours 03:00, 19:00 and the maximum of the for 160 full-power days are 993, 994 and 1012 MW respectively. On 4 days during May and July 2016, the maximum generation rose well above 1080 MW. (Table-4)

Table – 4: KKNPP-1 -Short duration power excursions

Source: SRLDC Daily Reports

Koodankulam Nuclear Power Plant

On 26 May 16 (ser 3) the generation at 03.00 hrs was 1001 MW, which rose to 1183 MW 24 minutes later. Likewise on 24 May, the generation increased from 994 MW to 1055 MW in 30 minutes. Under the normal operating conditions, when the power level reaches 107%, the reactor shuts down automatically (scramm). Since this did not happen on those four days, when the power level increased by 9% to 18% it appears that the scram set point was raised. It is not known whether these excursions were due to operator action and if yes, why the reactor power had to be raised to such dangerous levels.

3 Fuel Rod Damage at KKNPP-1 on 26 Jan 2014

On 26 January 2014, the reactor core of KKNPP-1 experienced fuel rod damage and the reactor fell into an iodine pit and scrammed four days later. (Details in box 1). The concentration of total iodine in primary coolant after the event was 8880 Bq/gm as against an expected value of 100 Bq/gm. The first six months of the uprate experiment (Dec 2014-June 2015) was conducted with the damaged fuel assemblies inside the reactor core. Incidentally, in the Russian VVER-1000 reactors, the fuel assembly used during uprating experiments was TVS-2М type. KKNPP fuel assemblies belong to UTVS, which is an older version. Differences between these fuel types are given in table below:[11]^,[12]

Table – 5: FUEL ASSEMBLIES USED DURING UPRATE

TRIALS IN RUSSIA AND KKNPP

5 Plant Conditions

1 Control Rod mal-functioning

The AERB attributed the fuel rod damage mentioned above to misaligned movement of the control and protection system – absorbing rods (CPS-AR) and its use in power ascensions were discontinued. A month after the event, a KKNPP official visited the Gidropress and “conducted hydro-testing of censors of ShEM-3 CRDM supplied to Kudankulam as part of quality tests.”[13] The Control rod drive mechanism (CRDM) of KKNPP were manufactured by OKB Gidropress. The NPCIL had received 115 CPS-AR drives before 2010 and the “AERB had completed their shop testing, installed them in position and their operability checks were completed from the main control room (MCR) in 2010.”[14] In 2012 and 2013, NPCIL representatives had gone to Gidropress and collected 32 pieces of CRDM.

2. Underperforming Equipment -Polar Crane

The polar crane is a safety grade component, which can cause an accident as well as prevent or mitigate one. According to the manufacturer, the maximum hoisting capacity of the crane before its shipment to India in 2004 was 450 tons. However, the AERB says that its maximum capacity was only 332 tons, and its installation was delayed for 27 months. Instead of disqualifying the crane, consent for its installation was granted after an India-Russia joint protocol in 2007. Eight years after its installation, the AERB’s stated in November 2015 that the polar crane was re-rated to 350 tons. Barely a month later, had the NPCIL said that the crane’s capacity is 320 tons, 30 tons lower than the AERB’s re-rated capacity in 2015 and 12 tons lower than the capacity at the time of installation in 2007.[15]

The actors, their omissions and commissions

1. NPCIL

An earlier draft of this paper was submitted to the MoEFCC and the Department of Atomic Energy (DAE) along with an application under the Right to Information (RTI) Act. The DAE transferred the application to the NPCIL. The NPCIL replied that no power uprate experiment is being done at KKNPP-1.[16] the attached paper. The NPCIL, which is a science-driven enterprise, should have explained as to how the power level went up to 102.3% and why the maximum power was raised to 118%

Why did they not announce this experiment before the initiation or after the announcement of their Russian partners or during the transfer ceremony on 10 Aug 2016? Was it because of the dismal performance of the reactor since its grid connection and the possible opposition against a bizarre experiment on an unstable reactor, which could not even clear its commissioning tests during the two of years of its grid connection?

2. ROSATOM

In contrast to the NPCIL’s denial, the Russian partner is more assertive, hoping that the NPCIL will “in near future take decision to increase power” the KKNPP-1”. Did they initiate this experiment out of their magnanimity to “generate 25 MW more for the Indian people” or did they have any private agenda? May be the Rosatom wants to use the uprated capacity for the price negotiations of additional units that will be set up Kudankulam and other parts of India. Russia is investing heavily on new reactor designs and there are about half a dozen of them in the pipeline. The reactor pressure vessel of VVER TOI (installed capacity of 1200 MW) which is in the advanced stage of development, is similar to the one in KKNPP in dimensions and volume. Was the power increase to 118% a test intended for this?

The Rosatom executive’s statement that “the director of the KKNPP and the management of NPCIL know” about the reactor’s super-performance raises doubts about the role of the Site Director and the reactor operators at KKNPP. Does he mean that the experiment was designed and run by the Rosatom with the NPCIL personnel as bye-standers? As per the Rule Book, during the commissioning phase, the commissioning crew under the supervision of the regulator is in charge of the reactor. Post-commissioning, the Station Director of KKNPP is license holder.

3 AERB

The uprate experiment at KKNPP-1 commenced on 14 December 2014 and is still ongoing. Till the end of the first fuel cycle (June 2015) the reactor was under commissioning trial and the AERB had “granted clearance for operation of the reactor up-to 100%FullPower” till 31 July 2015.[17] Even though the AERB Observers Team (AOT) posted at KKNPP-1 was keeping a close watch of the operations, the Regulator did not restrain the operator from moving beyond the consent.

4 Ministry of Environment, Forest and Climate Change (MoEFCC)

In response to the query under the Right to Information Act, MoEFCC said that they “have no information about the excess generation of electricity more than its installed capacity by KKNPP unit.”[18] The Environmental Impact Assessment (EIA) Notification of 2006 issued by the MoEFCC mandates that an “expansion and modernization of existing projects or activities with addition of capacity beyond the limits specified for the concerned sector”, “shall require prior environmental clearance from the concerned regulatory authority”[19]. For all projects related to the nuclear energy, the MOEFCC is the regulatory authority. In the case of KKNPP, the Supreme Court of India had ordered that the “MoEF should oversee and monitor whether the NPCIL is complying with the conditions laid down, while granting clearance vide its communication dated 23 September2008 under the provisions of EIA Notification of 2006”.[20] MoEFCC is also abdicating from its responsibilities by not monitoring the performance of the reactor and ignoring the illegal experiments.

Conclusion

The Chernobyl accident of 1986 happened during a short-duration experiment designed for enhancing the safety of the reactor. Here is a long term experiment which could run for over 1000 days, has been initiated clandestinely. In Russia and other countries, uprate experiments are preceded by impact assessments and public participation. Here, the people of India and the rest of the world learn about the experiment from the sales executive of a Russian engineering company, a year and a half after its initiation.

This is the first project in India whose transfer ceremony was presided by the heads of the Governments of India and Russia. So much political importance and festivity for an unstable and under-performing device that generates less than 1% of the total installed capacity of India! The transfer without fulfilling the terms of warranty introduces a brand new business model for reactor purchases in future.

The loss of billions of rupees to the exchequer pales into insignificance, when we consider the safety risks. The non-clearance of initial start up tests, unusually large number of scrams and accidents and long-duration maintenance shutdowns during the first two and a half show that the reactor is highly unstable. The initiation of the uprating experiment in a machine whose key safety grade equipment are sub-standard and under-performing, the midnight declaration of its commercial commissioning and the AERB’s decision to award the license to operate without clearing the commissioning tests are decisions which violate the laws of the land and the safety codes in force in India and globally.

Koodankulam Nuclear Power Plant Is Located In

As the AERB and the Ministry of Environment have been reduced to by-standers as they cannot fulfill their roles and even the tasks assigned by the Supreme Court of India, the Kudankulam plant is operating without any meaningful regulatory oversight. The least one expects from the Government –if there is one around- is an immediate freeze of the illegal experiment. Besides, the independent safety and financial audit demanded by eminent scientists and other professionals who have held important positions in the government – civil as well as military-, and above all millions of people in Tamil Nadu and Kerala cannot be delayed. As the saying goes, a stitch in time saves nine and harms none, except probably the corrupt.

VT Padmanabhan researches and writes on environmental and food safety issues.Email: vtpadman@gmail.com

Dr Joseph Makolil is a nano-scientist with the Cochin University for Science and Technology (CUSAT).

Acknowledgement: This product is part of an independent initiative by KK-Risk-Audit-Group consisting of Dr Ramesh Radhakrishnan, Dr V Pugazhendi, Prof Raminder Kaur, Prof Christopher Busby, Dr Paul Dorfman and Dr Anisur Rahman. We thank Dr EAS Sharma for his comments on an earlier draft. .

Box- 1

Preparation of justification calculations, identification of required modernizations. Changing the reactor plant engineering design

Stanislav Antipov, a senior official of Rosenergoatom – the Russian Nuclear Electricity Corporation lists the following main actions for unit power uprating:[21].

Modernization of monitoring and control facilities at the unit.

Obtaining changes in licensing conditions for power uprate to 104% Nnom and tests performance.

Step-by-step power uprate to 104%, performance of tests, issuing reporting materials.

Completion of modernizations with due account of the testing results.

Obtaining changes in licensing conditions for pilot operation at 104% power level during 2 to 3 fuel cycles.

Unit pilot operation during 2 to 3 fuel cycles.

Preparation of reports «Environment protection in NPP unit power uprating and operation at power beyond nominal level» «Environment impact assessment».

Nuclear Power Plants List

Preparation of report on pilot operation results.

Post-modernization unit engineering design updating.

Obtaining Statement of the State environmental expert review.

Obtaining changes in licensing conditions for commercial operation.

The highlighted actions at 3, 6, 8, 11 and 12 involving licensing are also the occasions when the public can express their views. Kudankulam-I is midway through action 7 (unit pilot operation), without obtaining the consents from the Ministry of Environment and Forest and the AERB. The citizens do not even know about the brave new experiment which might continue for two or more years.

Box 2: FUEL ASSEMBLY DAMAGE AND CONTROL ROD DEFECTS

On 23 Jan 2014, the power generation at KKNPP-1 was in the range of 410 MW. The Atomic Energy Regulatory Board (AERB) had consented to raise the power level to 750 MW. Control rods were raised on 26 January to raise the power level to 750 MW. AERB says that the fuel rods were damaged because of the flawed movements of the control rods. As a result of the fuel rod damage, fission gases and volatile isotopes like iodine and cesium leaked out of the fuel assembly. The immediate result of this accident was xenon poisoning, a temporary phenomenon which caused the reactor to trip and remain off the grid for four days. The other impact, leakage of fission products, would continue till the leaking fuel assemblies are removed. The AERB report, presented at the annual meeting of the VVER regulators at Helsinki in June 2014 mentions the concentration of total iodine, which means 5 isotopes in all – iodine 131 to iodine 135. The concentration of total iodine in the coolant water of KKNPP on 25^th January, while the reactor was operating at 49% of full power was 1110 Bq/gram. (This means that there will be 1110 radioactive disintegration from a single gram of water every second.) The concentration increased to 8880 Bq/gram during the attempted power ascension.

According to the AERB’s narrative of the event, presented at the annual meet of VVER regulators’ forum held in Helsinki in June 2014, “after the incident, reactor power raise program was reviewed and power raise is presently by boron dilution in controlled manner instead of withdrawal of Control and Protection System Absorber Rod (CPS-AR).”[22] Boron dilution impacts the entire fuel assemblies, whereas CPS-AR alone can manage the power level of individual fuel rod.

The fuel assembly damage could have significantly increased radiation dose inside the plant. The contract workers engaged in removing the spent fuel assemblies could have been at increased risk. In Dec 2015, SP Udayakumar, of the People’s Movement against Nuclear Energy (PMANE) said that a 42 year old worker from local area “got affected while involved in loading spent fuel rod in Kudankulam and the NPCIL administration has kept mum regarding his death”.[23]

Notes

[1] IANS, August 14, 2016, http://www.business-standard.com/article/news-ians/knpp-actual-parameters-better-than-original-design-russian-mp-116081400641_1.html

[2]http://www.financialexpress.com/article/industry/companies/power-generation-in-kudankulam-1-crosses-installed- capacity/270213/

[3] U.S. NRC Blog, http://wp.me/p1fSSY-1UE

[4] IAEA, 2004. Implications Of Power Uprates On Safety Margins Of Nuclear Power Plants IAEA, Vienna, 2004 IAEA-TECDOC-1418 – http://www-pub.iaea.org/MTCD/publications/PDF/te_1418_web.pdf

[5] IAEA, 2004. Implications of Power Uprates on Safety Margins of Nuclear Power Plants, TECDOC-1418 – http://www-pub.iaea.org/MTCD/publications/PDF/te_1418_web.pdf

[7] AERB, 2008, Safety Code No. AERB/NPP/SC/O (Rev. 1) Nuclear Power Plant Operation. http://www.aerb.gov.in/AERBPortal/pages/English/t/publications/CODESGUIDES/sc-o.pdf

[8] AERB letter No.AERB/CN/SARCOP/L-IIl/13311/20 dated July 10, 2015

[9] Berkovich Vadim Ya. Semchenkov Yury M., 2006, Up-to-date issues of VVER Technology Development, 10th International Scientific and Technical Conference“Safety, Efficiency and Economics of Nuclear Power industry” http://mntk.rosenergoatom.ru/mediafiles/u/files/2016/Materials_2016/Plenar_en/ MNTK_Berkovich+Semchenkov_ENG.pdf

[10] http://economictimes.indiatimes.com/news/politics-and-nation/kudankulam-delays-are-on-teething-problems-says-aec-chairman/articleshow/49793357.cms

[14]http://www.aerb.gov.in/AERBPortal/pages/English/t/annrpt/2010/chapter2.pdf Page 13

[15] Padmanabhan VT, 2015, Quality of Components In Kudankulam Nuclear Power Plant in India- Case Study of the Defective and Prematurely aged Polar Cranes, DOI: 10.13140/RG.2.1.3026.1528

[16] NPCIL/CPIO/MUMBAI-HQ/475/2016/1159/482 dated 25 Jul 2016 addressed to VT Padmanabhan

[17] AERB letter No CH/AERB/KK-1,2/199/2015/1453 dated 30 April 2015

[18] MoEFCC letter No J-11012/29/2016-IA-I (M) dated 11 August 2016 addressed to VT Padmanabhan

[19] Ministry Of Environment And Forests, EIA Notification, 2006, New Delhi 14th September, 2006 http://envfor.nic.in/legis/eia/so1533.pdf

[20] The Hon’ble Mr. Justice K.S.Radhakrihnan & The Hon’ble Mr. Justice Dipak Misra, 2013 Judgment in Civil Appeal No. 4440 OF 2013 (Arising out of S.L.P. (C) No.27335 of 2012, p.242) http://judis.nic.in/supremecourt/chejudis.asp

[22] Power point present presentation by AERB at VVER Regulators’ Forum 2014 Helsinki, June 2014

[23] News Today 18 Dec 15 http://newstodaynet.com/chennai/kudankulam-production-will-begin-jan-aec