26.11.2018 From G.Sundarrajan Poovulagin Nanbargal G1, 73, Sai Lakshmi Apartments 2nd Main Road, Kumaran Nagar Chinmaya Nagar, Koyambedu Chennai – 600 092 To The Chairman Atomic Energy Regulatory Board Niyamak Bhavan Anushaktinagar Mumbai 400 094 Sir
Subject: Representation seeking inspection on the continuous system failure and failure of various components in Kudankulam Nuclear Power Plant Units 1 & 2 reg I am associated with an environmental activists group called as “Poovulagin
Nanbargal”, which works for spreading awareness and education on ecology, sustainable development, safe food, renewable energy, etc., We have been working for the welfare of the people of Kudankulam and Kalpakkam in Tamil Nadu. I am the appellant in Civil Appeal No.4440 of 2013, filed before the Hon’ble Supreme Court of India, against the Kudankulam Nuclear Power Plant. In the said Civil Appeal, on 6.5.2013, the Hon’ble Supreme Court has given the following directions: “3. Maintaining safety is an ongoing process not only at the design level, but also during the operation for the nuclear plant. Safeguarding NPP, radioactive materials, ensuring physical security of the NSF are of paramount importance. NPCIL, AERB, the regulatory authority, should maintain constant vigil and make periodical inspection of the plant at least once in three months and if any defect is noticed, the same has to be rectified forthwith. லகி சி
ந
ப க , G1, சா ல
மயா நக , ேகாய ேப , ெச
மி அ
கக , 73, 2வ
பிரதான சாைல,
ைன 600092 ெதா.ேப– 90949 90900 மி info@poovulagu.org
ன
மர ச -
நக ,
4. NPCIL shall send periodical reports to AERB and the AERB shall take prompt action on those reports, if any fallacy is noticed in the reports.” From the abovesaid directions it can be understood that there is a legal mandate on the part of the NPCIL to report every major incidents happening in the Kudankulam Nucelar Power Plant. Since October 2013, the KKNPP Unit 1 has tripped over 40 times.
On 29.08.3013, in KKNPP Unit 1, reactor was shutdown for attending nonoperability problem of one valve in steam generators feed water line.
On 18.9.2013, automatic shutdown took place during changeover of standby pumps of primary system water make up pumps.
On 24.9.2013, when seam discharge valve opened due to condensate pump trip, Water level fluctuation in steam generator lead to automatic shutdown of reactor.
On 2.12.2013, automatic shutdown actuation happened due to non-updation of data in core instrumentation system.
On 29.1.2014, higher heating steam supply to secondary system deaerator led to steam relief. To conserve water in deaerator, operator reduced power and reactor was shutdown.
On 5.2.2014, Low Pressure Heater – 2 level variation and Steam generator level variation led to Automatic Reactor shutdown actuation.
On 18.2.2014, Automatic Reactor shutdown actuation during Commissioning test of reactor coolant pumps.
On 29.3.2014, Water spillage onto field mounted transmitters led to instrument malfunction and Reactor shutdown.
லகி சி
ந
ப க , G1, சா ல
மயா நக , ேகாய ேப , ெச
மி அ
கக , 73, 2வ
பிரதான சாைல,
ைன 600092 ெதா.ேப– 90949 90900 மி info@poovulagu.org
ன
மர ச -
நக ,
On 12.5.2014, during on-line valve maintenance, feed water pumps tripped and steam generator level decreased leading to Automatic Reactor shutdown.
On 30.5.2014, Condensate pumps trip caused water flow reduction to Low Pressure Heater – 2, deaerator and Steam generator. Its level decreased leading to Automatic Reactor shutdown.
On 10.6.2014, during increase of range of Steam generator flow sensor, levels in SGs fluctuated leading to Automatic Reactor shutdown.
On 14.1.2015, during charging of Generator Transformer of unit-2, Generator Circuit Breaker of Unit-1 tripped on protection leading to shut down of Turbine and reactor of Unit-1.
On 9.5.2015, due to slow operation of steam generator water level went high leading to Automatic Reactor shutdown.
On 5.2.2016, Reactor was shutdown for rectification of leak in pressure transmitter line in secondary system.
On 8.2.2016, Reactor was shutdown to attend the problem of isolating valve on steam line.
On 16.2.2016, Reactor was shutdown for rectification of leak in pressure transmitter line in secondary system.
The continuous lineage of trips and failures in the first two units of Kudankulam didn’t just stop with 2016 and it continues till date. Recently on 17th November 2018, the Kudankulam plant unit 1 that was under maintenance for 109 resumed operations post maintenance. Unfortunately just after 3 days of operations it was declared that the Unit 1 got tripped due to some malfunction in the Turbine. Globally, a nuclear reactor, on occasion of shut down, will be restarted within 45-60 days after maintenance. But in case of KKNPP Unit 1, it takes at least four months for the லகி சி
ந
ப க , G1, சா ல
மயா நக , ேகாய ேப , ெச
மி அ
கக , 73, 2வ
பிரதான சாைல,
ைன 600092 ெதா.ேப– 90949 90900 மி info@poovulagu.org
ன
மர ச -
நக ,
NPCIL to restart the reactor after maintenance. Which is an alarming situation. As directed by the Hon’ble Court, NPCIL never submitted reports, with regard to the various malfunction of KKNPP to the AERB. Also, recently NPCIL declared a “historical milestone” by declaring that the Nuclear plant in Kaiga produced power for more than 900 days continuously, whereas we don’t have any data to understand that the 2 units at Kudankulam ran successfully for atleast 600 days continuously. The failure on the part of the NPCIL in not sending any reports to the AERB and other authorities can be confirmed by the “Report of the Comptroller and Auditor General of India on Kudankulam Nuclear Power Project, Units I and II”, published on March,2017. The said report states as follows: “AERB granted, in August 2014, clearance to NPCIL for operation of KKNPP Unit I up to 100 per cent full power for limited duration (Phase C3 stage) till 31 December 2014; it later extended the date till 30 April 2015 subject to compliance with certain stipulations. AERB granted the license for regular operation of the plant on 10 July 2015. However, it was noticed in audit that NPCIL declared commercial operation of the Unit I of KKNPP on 31 December 2014 which was six months before receiving the license from AERB for regular operation of the plant. Moreover, the records pertaining to dates of completion of final safety review and its submission date to AERB were not produced to Audit despite repeated enquires. NPCIL also could not produce documents to substantiate whether it complied with the stipulations as mentioned in the AERB’s sanction letter dated 30 August 2014. In absence of this information, it is not clear whether NPCIL had complied with all the stipulated safety and security conditions at the time of declaration of the commercial operation of the plant on 31 December 2014. In absence of such information, the fact that Unit I of KKNPP was put into commercial operation after duly fulfilling the operational safety and security of the plant, as required under AERB guidelines, remained unverifiable in audit.” Further the report also states that: “The reply of the Management is not satisfactory as the reactor vessel which houses the reactor core is of immense safety significance.
லகி சி
ந
ப க , G1, சா ல
மயா நக , ேகாய ேப , ெச
மி அ
கக , 73, 2வ
பிரதான சாைல,
ைன 600092 ெதா.ேப– 90949 90900 மி info@poovulagu.org
ன
மர ச -
நக ,
Hence, the pre-service inspection of pressure vessel by an independent third party, other than the reactor pressure vessel manufacturer (M/s HRID) would have been appropriate.” The abovesaid fact indicates that there exist many serious technical problems in Kudankulam Nuclear Power Plant, which requires immediate actions by the AERB. Hence, I request you to form an expert committee, including independent experts from various fields, to inspect the Kudankulam Nucelar Power Plant (Units 1 and 2). And I also request you to take appropriate actions on the basis of the report of the said committee.
Thanking You
With warm Regards,
G. Sundarrajan For Poovulagin Nanbargal
லகி சி
ந
ப க , G1, சா ல
மயா நக , ேகாய ேப , ெச
மி அ
கக , 73, 2வ
பிரதான சாைல,
ைன 600092 ெதா.ேப– 90949 90900 மி info@poovulagu.org
ன
மர ச -
நக ,