Safety and regulatory issues of Kudankulam Nuclear Power Plant in India and the need for a global nuclear regulatory framework

VT Padmanabhan, Paul Dorfman and A Rahman

This article has contributed to the Nuclear Heritage Network by VT Padmanabhan, one of the authors of the study.

Executive Summary
The Nuclear Power Corporation of India Limited (NPCIL) started construction of two 1000 MWe VVER reactor at Kudankulam in Tamil Nadu in 2002. On 31 Dec 2014, 26 months after the initial fuel loading, the NPCIL declared the commissioning of the first reactor completed, without the consent of the regulator, as it could not clear the mandatory tests. Two more attempts also failed and during April 2015, the reactor's output started declining systematically for two months, leading to a 60-day maintenance shut down on 24 June 2015. In the midst of this chaos, on 8th July 2015, the Atomic Energy Regulatory Board (AERB) granted the 'licence for regular operation' of the reactor, 1008 days after the initial fuel loading (IFL). This interval is 3 times the average for 10 other 1000 MWe reactors commissioned in this century. During 666 days of its grid connection, the reactor worked for 380 days only, as 16 SCRAMs and three maintenance outages kept it off-grid for 286 days. The instability of the reactor is attributable to (a) defective, counterfeit and underperforming equipment such as the pressure vessel, steam generators and turbo-generator and (b) shoddy construction practices. India, in collaboration with Russia is also planning to export nuclear power plants to other Asian-African countries.

Both the acts of commissioning and the award of licence to operate without the completion of the mandatory tests violate the internationally accepted standards and guidelines, which were adopted in India. The hurried declaration of commissioning and the grant of licence were for speeding up the deal for two more reactors at the same site. Finally, there will be eight 1000 MW(e) reactors at Kudankulam. Clipping the wings of the national regulator, operating an un-commissionable reactor, importing more plants from the same vendor and others and attempts to enter the export market impose unacceptable risks not only for the people and the eco-system of the sub-continent, but also the entire planet.

Recognizing the lack of autonomy of AERB, which reports to the Atomic Energy Commission, the International Atomic Energy Agency (IAEA) had recommended in March 2015 that “the Government should embed the AERB's regulatory independence in law, separated from other entities having responsibilities or interests that could unduly influence its decision making”. Besides the absence of an autonomous regulator, there has been no effective parliamentary oversight on nuclear issues in India. IAEA also has nothing much to contribute for prevention of nuclear disasters, other than making recommendations and publishing tooth-less safety guidelines.

Nuclear safety is becoming a cause of tension between nations. The recent examples are the Temelin project in Czech Republic and the life extension of old reactors in Ukraine. The Sri Lankan concern about the Indian reactor has not received the attention it deserves.

After the Chernobyl and the Fukushima accidents, the safety community, from among both the pro- and anti-nuclear camps, is realizing that “change is warranted as the current regulatory approach has not produced the desired results,” and is demanding a “proactive, internationally accepted, regulatory framework” which “anticipates accidents, constantly challenges accepted practices, and prevents major accidents.” Both the ageing fleets in the ‘old world’, the new ones coming up in the ‘new world’ with lax regulations and low awareness of radiation hazards multiply risks many fold. A new global regulatory regime can alone reduce the risk of major releases.

Recommendations:
 * 1) Kudankulam and other contentious projects should be subjected to safety audit by groups of independent experts, whose recommendations should be binding.
 * 2) Discussion for setting up a global-level nuclear regulatory body should be organized simultaneously.
 * 3) The peoples’ organizations which are addressing the issue of nuclear safety and transparency at regional levels will have to become global.

About the Authors
VT Padmanabhan is an epidemiologist. Among the studies he conducted are: He has published in the Lancet, JAMA, International Journal of Health Services, International Perspectives in Public Health, Economic and Political Weekly etc. Most of his papers can be accessed from:
 * 1) He led a team which conducted genetic studies of children born to parents exposed to high and background natural radiation in coastal villages of Kerala, India. Total study population – 80,000.
 * 2) Part of a team which studied the genetic effects of MIC exposed parents’ children in Bhopal, India (1984 accident).
 * 3) Occupational health hazards among the radiation workers of a thorium processing unit in Kerala, India.
 * 4) Environmental radiation hazards from thorium milling unit in Kerala India.
 * 5) Ecological studies of Radiation-induced Auto-immune thyroid anomalies among women living near the Madras Atomic Power Plant ( 400 km radius).
 * 6) Reviewed the genetic and somatic studies of the bomb victims in Hiroshima-Nagasaki. Since 2012, he has been studying the safety issues related to the Kudankulam Nuclear Power Project in India.
 * https://www.researchgate.net/profile/Padmanabhan_VT

Dr Paul Dorfman is Senior Research Assiocate at the Energy Institute, University College London (UCL): Joseph Rowntree Charitable Trust (JRCT) Energy Policy Research Fellow; Founder of the Nuclear Consulting Group (NCG); Member, European Network of Scientists for Social and Environmental Responsibility (ENSSER); Advisory Group Member, UK Ministry of Defence (MoD) nuclear Submarine Dismantling Project (SDP); Member, European Nuclear Energy Forum (ENEF) Transparency and Risk Working Groups; External Examiner, Aberdeen Business School, Robert Gordon University; served as Secretary to the UK government scientific advisory Committee Examining Radiation Risks from Internal Emitters (CERRIE).

Dr Rahman is a retired nuclear safety specialist with over 35 years of experience in both civil and military nuclear establishments in the UK and Europe. He was involved from inception to commissioning of Sizewell ‘B’ nuclear power plant (1200 MWe PWR) in the UK covering technical areas such as transient (thermal-hydraulic) analysis, radiological consequence assessment and shielding. He worked as a Radiation Consultant to the Kingdom of Saudi Arabia for three years. He also worked as a Senior Lecturer at the Ministry of Defence in the UK dealing with nuclear submarine radiological protection. He was the Work-Package Manager under the 5th Framework Programme of the European Commission producing a report on ‘Institutional, Legal and Regulatory Aspects; Licensing and Decommissioning Plan; Radiological Protection and Industrial Safety’ to harmonise nuclear regulations across the EU. He is the author of a book called ‘Decommissioning and Radioactive Waste Management’ which is used as a text book in many British and European Universities in graduate and post-graduate studies on the subject. This book has been translated into Chinese by China Atomic Energy Commission. He published numerous research papers

Address for correspondence: [mailto:vtpadmanATgmailDOTcom vtpadman AT gmail DOT com]

Abstract
Though the trans-boundary contamination and trans-generational health impacts of the nuclear fuel cycle are recognized, there is no international regulatory framework to enforce uniform safety codes and standards and resolve the conflicts between nations. As the reactors are ageing and the nuclear technology is becoming wide spread, there are risks of more Fukushima-type ‘surprises’ in future. One such surprise has been unfolding in India's Kudankulam Nuclear Power Plant (KKNPP) since the fuel-loading of a 1000 MWe pressurized water reactor (PWR) in October 2012. During the 33 months of its ‘operation’, the reactor could not clear the final mandatory test. Frustrated owner of the utility declared the commissioning of the reactor completed on 31 Dec 2014, without the consent from the Regulator. Two more attempts to clear the test during the first five months of 'commercial' operation also failed, leading to two SCRAMs, instability in the form of systematic decline in output for two months and an eventual shutdown for maintenance lasting two months. In the midst of this mayhem, the regulator granted the ‘licence for regular operation’ on 8th July 2015. This is the only civilian nuclear reactor in the world, operating without clearing the commissioning tests. This case study reveals a total collapse of the regulatory mechanism for the first time in the three decades long history of civil nuclear sector. Post-Fukushima, experts from both pro- and anti-nuclear camps are seeking an international regulatory framework, which would be transparent, and participatory. There is no reason to delay this process now.

Introduction and Brief History of the Project
The construction work of two reactors at the Kudankulam Nuclear Power Plant (KKNPP) started in 2002 at a coastal village, off the Bay of Bengal, in Thirunelveli district of Tamil Nadu State, 98 km North-East of Thiruvananthapuram in Kerala State (8°10′08″N 77°42′45″E). The first reactor had been under ‘operation’ since October 2012 and the second reactor is still under construction. Under the India-Russia inter-governmental agreement, the Rosatom supplied the equipment and designs, while the Nuclear Power Corporation of India Ltd (NPCIL) did the construction and commissioning works. An independent safety evaluation of the project was impossible as the utility refused to share the documents like the Preliminary Safety Analysis Report (PSAR), the Detailed Project Report (DPR), inspection reports of components etc. with any outside individual or organization. The only sources of information about the reactor were the press releases and annual reports of the utility, the regulator and the industry sources in Russia.

Equipment Defects of the AES-92 Reactors at Kudankulam, India
In spite of the ‘iron curtain’, a fairly accurate description of the reactor plant construction - counterfeit, underperforming and obsolete equipment and shoddy construction practices – could be made using the bits and pieces of information available from the official sources in India and Russia. A summary of the issues are given below :
 * 1) Reactor Pressure Vessel (RPV) defects. According to a journal article authored by senior scientists at KKNPP, the RPV - had been stated to have no weld-joints in the core-region, its life time was 60 years and the core damage frequency (CDF) was one in 10 million reactor years (10-6 per reactor year). The NPCIL  and AERB later on admitted that the RPV has four welds at the core-region, its life time is 40 years and its CDF is 100 times higher!
 * 2) Polar Crane. The Russian manufacturer claimed that the maximum hoisting capacity of the polar crane is 450 tons. The AERB reported “tilting of the main hoist fork under a load of 350 tons” and “decided to temporarily limit the maximum load capacity of the crane up to 332 Tons.”  Polar crane is safety grade equipment with key functions during operations, maintenance as well as accidents.
 * 3) Overhaul of the turbo generator. The turbo-generator was overhauled even before it was grid connected. After working for less than half a year, the turbine blades got damaged and had to be replaced.
 * 4) Steam Generators. The latest problem for the NPCIL is the steam generators which caused a SCRAM in May 2015, leading to the instability of the reactor for two months and eventual shutdown for 2 months. The manufacturer is the St. Petersburg based Zio Podolsk, whose Procurement Manager is facing trials for buying low-quality steal from Ukraine for making safety-grade equipment.
 * 5) The double containment, considered as the ultimate barrier that protects the environment, was broke open and re-sealed to accommodate the cables that were missed earlier.

Alarmed by the detailed studies and reliable media reports regarding the sub-standard equipment and components, 60 eminent scientists from India's national institutes, including those “who believe that nuclear energy has a legitimate role in securing our energy future” appealed on 13th May 2013, that the Government “should consult independent national experts to formulate an inspection regime and carry out a full-fledged inspection into the safety” of the reactors, paying “particular attention to the allegations of sub-standard equipment and components”.

Delays with safety implications- International Comparison
According to the AERB the initial fuel loading (IFL) is “considered as commencement of operation”, and “the time interval between IFL and the first act criticality (FAC) should be as short as possible.” (Para,5.2.4.2, Ref 8). According to US Nuclear Regulatory Commission (NRC), commissioning test, known as “Initial start-up testing”, consists of performance tests, “normally completed during fuel loading, pre-critical, initial criticality, low power and power ascension phases to confirm the design bases and demonstrate, to the extent practical, that the plant will operate in accordance with design and that it is capable of responding to anticipated transients and postulated accidents as specified in the FSAR. The power-ascension test phase should be completed in an orderly and expeditious manner. Failure to complete the power-ascension test phase within a reasonable period of time may indicate inadequacies in the applicant’s operating and maintenance capabilities, or may result from basic design problems”.

The mainstream media has attributed the delays at KKNPP to the people’s movement against the project. According to NPCIL’s annual report for 2011-12, total days lost due to this is 122 only. “There was an agitation against the During the period 13th October 2011 to 19th March 2012, there was a local agitation in the villages around KKNPP. Due to this agitation, though the progress of work at KKNPP slowed down, the erection and commissioning activities of balance work of Units-1&2 got delayed.” Moreover, in this analysis, we are looking at the events since 01 October 2012.

Intervals between IFL, FAC and FAC-Commissioning and IFL-Commissioning of eleven 1000 MW PWRs and two 540 MW PHWRs commissioned during this century are given in Table 1. (Dates of FAC and commissioning –not shown in the table are from IAEA PRIS database. Dates from IFL are from assorted sources like media reports.) It may be pointed out that Commissioning means completion of commissioning. The Indian reactor stands out from all others. It should be noted that it has not been commissioned properly even after more than 1000 days.

'' Notes: IFL = Initial Fuel Loading. FAC = First Act of Criticality. COMM= Commercial Operation.  Hyperlink on the (a) the reactor name shows link for IFL and (b) in FAC-COMM shows link for commissioning.''

The commissioning data for two pressurized heavy water reactor (PHWR) of 540 MW(e), constructed and commissioned by the Indians at Tarapur (at ser (12) and (13) of table-1) in Maharashtra in 2005 and 2006, rules out the possibility of inadequacies in the applicant’s operating and maintenance capabilities.

All the reactors other than those at serial (2), (3) and (4) are VVERs from Russia. The reasons for the delay are unknown; but it is evident that there were serious problems. Incidentally, reactor at KKNPP is the only certified Gen-III VVER reactor in the world and all others in the Table are known as Gen-II. This certification was the product of a co-operation between the nuclear establishments in India and Russia and few European energy companies.

Commissioning of a Commercial Nuclear Reactor
Commissioning of a large reactor is an intensive operation, lasting for about 8 to 12 months, done by a crew consisting of personnel from different utilities and outside experts. The commander of the crew takes over the reactor from the construction group and hands over the same to the station director on successful completion of all the mandatory tests. The International Atomic Energy Agency (IAEA) and AERB have laid down codes and guidelines for commissioning.

International Atomic Energy Agency (IAEA). The main objective of commissioning a reactor, according to IAEA “is to confirm that the design intent of the components, systems and the plant as a whole are achieved. Commissioning objectives also include optimisation of the plant system functions, verification of the operating procedures, getting operating personnel familiar with plant systems, and producing the plant initial start-up and operating historical records. ...When full power is reached, a number of tests are performed to demonstrate safe and reliable operation of the plant before it is turned over to the operating organization.”

According to AERB, “acceptance criteria of all the tests should be as per the PSAR and/or as per the approved commissioning procedures. The tests results should meet the acceptance criteria as specified in the relevant documents”(5.2.7,page 22 –Ref 6). The chairman of the AERB writes that commissioning is also a stage at which the ownership of the systems/plant is handed over from the construction organisation to the commissioning/ operating organisation, requiring assurance of compliance of a number of aspects and results of the “commissioning tests and reviews are required to be incorporated in the PSAR of the plant, to produce the Final Safety Analysis Report (FSAR), which forms the basis for the operating license of the NPP.” AERB has three apex committees, one of which is the Advisory Committee of Project Safety Review -LWR-1 (ACPSR) for overseeing the safety of KKNPP during construction and commissioning. All the consents issued by the AERB so far were based on its recommendations.

Commissioning drills of KKNPP-1. The utility and the regulator had jointly planned the commissioning drills consisting of three phases, well before the completion of construction. In Phase A, equipment and systems are tested before the fuel loading. The B Phase tests conducted after the IFL include FAC and low power physics experiments (LPPE). Phase-C (Power ascension) tests are conducted after the connection of the generator with the electricity grid. Since the reactor's grid connection on 22nd October 2013, the Southern Regional Load Despatch Centre (SRLDC) has been publishing the data on power generation and outages of KKNPP on a daily basis. The assessment of the reactor's performance in this report is based on the data from http://www.srldc.org.

C Phase – Power Ascension Tests
The AERB lists 45 different tests in the C Phase Power Ascension Tests (page 66, Ref 6) in three sub-phases of C-1, C-2 and C-3. In C-1 and C-2, reactor power is raised to 50 % of Full Power (FP) and to 75% (FP) respectively. The main tests of C-3 phase are non-stop operation at 90% FP for 7 days and at 100%FP for 100 days. C-1 and C-2 tests take about 10 days, while C-3 tests need 120 days. Adding another 30-40 days for regulatory deliberations and the utility should have received the licence for regular operation in 160-170 days after the grid connection. The C-Phase tests and the regulatory evaluations were scheduled to be completed within 180 days of the grid connection, i.e. on or before 22 April 14.

Hurdles in Commissioning tests
The commissioning could not progress as pre-planned because of (a) shutdowns due to trips (SCRAMs) and maintenance shutdowns and (b) under-performance of the reactor during working days. The first trip occurred immediately after the grid connection. The reported cause was 'reverse power' in which the rotor, which should have produced electricity and delivered it to the grid started behaving like a motor, sucking electricity from the grid. During the 435 days of grid connection from 22 Oct 13 to 31 Dec 14, the reactor experienced 19 SCRAMs and 3 maintenance outages. Five of the SCRAMs that kept the generator off-grid for a total of 580 minutes could have been initiated by the operator as part of the commissioning tests.

Remaining 14 SCRAMs - the 'real ones' - and three maintenance outages kept the reactor down for a total of 92 days and 139 days respectively. The rate of trip is calculated per 7,000 reactor hours (which is equivalent to one reactor year). With 14 trips during 4701 hours of its operation, the rate for KKNPP is 20.8 per year. According to the World Nuclear Association (WNA), the trip rate per year is 0.37 for all the reactors in the world and 0.25 for 10 best performing reactors. Average loss of productivity per trip is 6.5 days at KKNPP as against 1.5 days for the reactors in WNA analysis.

On 15th September 2014, the reactor was on stream after a maintenance outage for two months. Eleven days later, the turbine was damaged and its replacement kept the reactor down for 73 days. During 666 days of its grid connection from 22 October 2013 to 22 August 2015 (the day it is expected to restart after the maintenance), 286 workdays were lost in 16 trips and 3 maintenance outages. (see Table 2) Unfortunately, the reactor could not clear the last test (100 days 100% FP) till now and this cannot be accomplished before 31 Dec 2015.

The Status of the reactor as of 30th December 2014
After the completion of the 'non-stop 7 days 90%FP' test on 23 June 2014, the reactor attained 100%FP on 4th July 2014, but slipped down to 991 MW the next day. This sequence was repeated on 7th and 14th July 2014, after which the reactor was shut down for two months' maintenance and restarted on 15 September 2014. The maximum output was less than 900 MW during 15 to 27 September 2014 and then the reactor tripped due to turbine problem. The reactor resumed the operation on 7 Dec 14 and attained full power three days later, heralding the fourth attempt for non-stop 100%FP. On 30th of December 2014, the reactor had completed 20 days' non-stop operation at 100%FP.

A new generating unit under commissioning tests has to obtain prior permission from the Central Electricity Regulatory Commission (CERC) for injecting electricity (known as infirm power) to the grid. KKNPP had permission to do this till 22 April 2014, which was the deadline set for completion of C-3 tests. The CERC had further extended the permission for injection of 'infirm power' three times to 22 Jul 2014, 22 Oct 2014 and 22 Jan 2015. The AERB also had on 30th December 2014 extended the deadline to complete the C-3 test till 30 April 2015.

Commissioning Without the Regulator's Consent
However, on the 31st December 2014, a day after the AERB extended the deadline for the penultimate test, the NPCIL hurriedly declared that the commissioning of the reactor was complete. A press release signed by the KKNPP site director says: “unit No 1 has been declared commercial operation from midnight (0000 hours) of 31st December 2014.” Quoting him, a national newspaper reported: “We’ve received the nod from our high command (emphasis ours) for commencing the commercial power generation”. By using the term 'high command' meaning reserved politicians, did the Site Director, who is also a distinguished scientist of NPCIL, mean that the act of commissioning was dictated by political exigency? As the 'nod' was received just six hours before the appointed time, there was no celebration, no song and dance, no fireworks and no press conference. As the timing given was “0000 hours”, the commissioning might as well have been a non-event!

The Performance of the reactor after Commissioning
On 14th January 2015, on the 36th day of the non-stop 100%FP test, the reactor SCRAMed for the 15th time and was down till 17th January. Full power was resumed on 20th January and continued for 89 days till 18th April 2015. From 19th April 2015 onwards, the output started declining systematically and on 9th May 2015, the reactor tripped for the second time since its commissioning due to “problem in steam generator level control”. The decline of output continued even after the restart and the unit was shut down for 60-days’ maintenance on 24 June 2015.

Meanwhile, AERB had on 30 April 15, extended the deadline for undertaking the final test till 30 July 2015. The commissioning crew has missed this deadline also. If the reactor restarts at the end of August and if it attains full power during the first week of September and if it runs non-stop 100 days at 100% FP, it could qualify for the licence as per the protocol, by the end of 2015. Performance details after the replacement of turbine are given in Table 3. Column (d) shows the number of days the reactor was off line or the maximum generation of the day was less than 100%. Column (f) shows the average of the maximum generation and column (g) gives the averages of electricity supplied to the grid, after deducting the in-house consumption. During 6 days the maximum generation was between 995-999 MW and these are considered as 100%FP. During the 258 days under consideration, the reactor worked on full power only for 124 days.

AERB grants Licence for Regular Operation to an unstable reactor in ICU
Instead of asking the utility to repeat the 100%FP test, the AERB granted the Licence for Regular Operation of KKNPP on 8th Jul 2015. The announcement of this consent made through a press release issued six days later, is different from all other consents issued so far by AERB. Until now the official letters signed by the Chairman AERB and addressed to the CMD of NPCIL used to be posted on the AERB website on the same day. These letters included the details of the test conducted and a statement that the consent is based on the recommendation of the apex Advisory Committee -ACPSR. The press release is silent about the final test which has delayed the much awaited licence for more than a year and there is no mention about ACPSR. It says that the decision to grant the licence “is the culmination of in-depth review over many years of the safety aspects related to the design, construction and commissioning of the unit with respect to compliance with the specified requirements”.

Reconstitution of ACPSR in November 2014
In November 2014, the AERB had reconstituted the ACPSR which has been overseeing the commissioning process since 2010. The press release announcing the reconstitution does not state the reason for the reconstitution, at a time when the reactor was under the advanced stages of commissioning. Though the committee members were mostly serving and retired scientists of various atomic energy institutions, there were occasions, when ACPSR delayed the grant of consent for as long as two years – as in the case of the obsolete reactor pressure vessel or the underperforming polar crane mentioned above.

Decision on licensing taken much earlier
It appears that the decision to grant the licence was taken in ACPSR's 175th meeting held on 27th and 28th April 2015, which deliberated on two applications from the NPCIL. The first one dated 03 April 2015 sought the authorization for regular operation of the reactor. (On the date of application, the reactor had completed 72 days of 100% FP test and the utility was anticipating the successful completion of the test by 30 April 2015.) The second application dated 28 April 2015 requested a further extension of 120 days for undertaking the final test. This was in recognition of the drop in output since 20th April, which meant that the utility had again missed the bus. Though the first application dated 3 April 14 stood cancelled by the second application, the AERB considered both the applications!

AERB's consent letter dated 30 April 2015 noted that “the unit-I is presently operating at ~ 100% FP since January 20, 2015 and it is expected that 100 full power days of operation would be completed by April 30, 2015 and thereafter, the site would be submitting its performance data”. The AERB was feigning ignorance of the instability of the reactor since 20th April. The maximum generation on 26, 27, 28 and 29 April 2015 was 916, 904, 897 and 884 MW respectively. AERB could have obtained the latest production statistics of the reactor from the NCPIL, the AERB Observers Team (AOT) at the site and from http://www.srldc.org. By granting the extension for 90 days only as against 120 days sought by the utility, the regulator had foreclosed the option for another round of test. In other words, they might have decided to grant the licence for regular operation without clearance of the test on or before 30th April 2015.

The Russian Version of Commissioning and Licensing
Why did the NPCIL declare the commissioning of the reactor before its safe and reliable operation could be demonstrated, just one day after the deadline for the final test was extended by the AERB? And why did the AERB confer the licence for regular operation of the reactor, without passing the commissioning test when it was shut down after two months' long instability? The following despatches from the Russian Federation throw more light on this.

Commissioning - The Russian News Agency TASS reported on 2nd January 2015 that “the reactor has been commissioned for warranty-period operation. An act on a provisional transfer of power unit No. 1 to operation was signed by the Russian and Indian sides. This means that a year-long period of operation on warranty has begun. Upon the results of these twelve months, the power unit will be fully transferred to the Indian side”. India will start paying back the Russian credit, about 60% of the total cost after the full transfer of the plant.

The grant of licence to operate. The Government of India had accorded the administrative/ financial sanction for the Kudankulam second phase around the first week of July 2015. On 8th July 2015, the day AERB Board of Directors met in Mumbai to grant the licence to KKNPP, the Prime Minister of India met the President of the Russian Federation at Ufa in Russia. At the press conference after the bilateral meeting, the Indian Ambassador to Russia said: “The Kudankulam 3 and 4 contracts have already been signed. There is a General Framework Agreement which has been signed. There is what is called the Long Cycle Supply of Equipment which is a contract that has been signed. So, it is in the process of implementation. That is what the (Indian) Prime Minister and President Putin noted with satisfaction as progress in the nuclear energy cooperation”.

In short, the purpose of the completion of commissioning was facilitation of provisional transfer of the reactor to India, linked to the repayment of loan. Similarly, the grant of licence for regular operation was to make way for the third and the fourth reactors from the same vendors at Kudankulam. A reactor which could not qualify for the licence even after 32 months of operation could be an embarrassment for the second phase of the deal. Safety sciences can wait!

International Peer-review of India's Nuclear Regulator
In March 2015, two months after the declaration of completion of commissioning and three months before the grant of licence, an International Atomic Energy Agency (IAEA) mission consisting of senior nuclear safety experts reviewed India's regulatory framework for safety of nuclear power plants (NPPs). The main recommendation of this 12-day mission was that “the Government should embed the AERB's regulatory independence in law, separated from other entities having responsibilities or interests that could unduly influence its decision making”. Barely three months after this recommendation for its autonomy, the AERB had certified a reactor which had repeatedly failed in the commissioning test. This is a grim reminder of the reality that our decision makers have neither heeded to nor learnt any new lesson.

Discussion
Construction of two reactors at Kudankulam started in 2002. The second reactor is still under construction and the first one was fuel-loaded in October 2012. During the 33 months’ of the first reactor’s operation, the utility and the regulator could not confirm that “the design intent of the components, systems and the plant as a whole are achieved”. The commissioning and the grant of licence to operate the reactor in violation of the codes and safety guidelines are illegal acts. While the future of the reactor is uncertain as it has been shut down for long-term maintenance, the NPCIL is busy constructing the third and the fourth units from the same vendors. Besides, India is also planning to import 20 more reactors from Russia, France and the USA during the next two decades. The Russian roulette being played by the NPCIL and their international collaborators must be seen as preparation for a global catastrophic risk.

Some six decades after the birth of the civilian nuclear energy and meltdown of six reactors, the world is now realizing the need for a global regulation that works. J.J. Bevelacqua, theoretical nuclear physicist, health physicist and senior reactor operator and a key player in the Three Mile Island and Hanford cleanup activities says that “three major reactor accidents in a span of 35 years offer a sobering reminder that the current regulatory approach has not produced the desired results, and that change is warranted” and “an ideal regulatory framework would be proactive, internationally accepted, supported by the public, anticipate accident events, constantly challenge accepted practices, and prevent major accidents”.

A quarter century after the first hemispheric level nuclear event at Chernobyl and two years after the second event at Fukushima, a Europe wide network - “the European Network Nuclear Transparency Watch (NTW)” has been launched in 2013 in response to a call from Members of the European Parliament from different political parties. NTW has since been raising safety issues of plants in Europe. Such efforts will have to be include all countries as the so-called nuclear renaissance is projected to happen in Asian- African continents, where the environmental legislation is in the nascent stage and the awareness of nuclear hazards among the people and the opinion makers is fairly low.

Conclusion
The presence of a junk reactor in the South Indian coastal village loaded with 4,000 kg of fissile materials and fission products, poses a persistent threat of a global catastrophic risk. The experiences so far show that those who crafted this Frankenstein's monster will not de-craft it. As the reactor's instability has been demonstrated repeatedly and its future is unpredictable, the best option is to remove the fuel from the reactor core and subject the project to a peer review by a credible international agency consisting of nuclear regulators, safety scientists and civil society representatives. The past nuclear disasters were real accidents, in the sense that they were not predicted in advance. This predicted one, whose trans-boundary impacts may even be larger than the last one, can only be prevented by global action in which scientists, technologists and law makers will have major roles to play. In this process, we will also be creating a truly global and democratic regulatory mechanism for the so-called civilian side of the fission technology. Like for the fissile material, we need an international regime for the control and regulation of fission technology also.