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14.5. It is denied that the plant model was V-320 as contended by the petitioners and it is stated that the model based on Indian side requirements as agreed by USSR and later Russian Federation was always V-412 and there is no change at any point of time from the original design intent as envisaged in 1988 and, therefore, there is no need for any fresh consent or clearance from MoEF on this score. It is also stated that KKNPP is also submitting periodical compliance reports to MoEF.

14.6. In respect of the necessity for public hearing post tsunami from MoEF, it is stated that there is no statutory requirement as such under any guideline or rule to conduct public hearing post tsunami in respect of units for which clearance was accorded in 1989 by MoEF. It is estimated that the water level cannot raise beyond 5.4 Meters due to tsunami, water surge and high tide all put together; and that the plant is situated at a height of 7.6 Meters elevation and all the important buildings like Reactor building, Diesel Generator building, etc. are located at further higher levels and, therefore, the KKNPP is highly protected plant. It is further stated that the AERB has also undertaken a thorough review of safety measures at Kundankulam in the wake of the Fukushima nuclear disaster.

17.13. While speaking about the difference between the KKNPP and Fukushima, reiterating the stands of the Union of India that KKNPP is situated about 1500 Kms. from epicenter and the safe grade level for the site has been decided as 7.44 Metres above the mean sea level, it is stated that the strongest tsunami or storm surge has been determined as 5.44 Meters and all emergency power supply equipment are located well above the elevation and, therefore, there is no chance even in the worst case of tsunami for the project to be affected leading to radiation. It is stated that even under a hypothetical accident condition of core melt, the molten core is retained and cooled in a core catcher that is provided below the reactor vessel and radioactivity from the damaged or molten fuel cannot come out of the inner containment building inside which the reactor is housed and it is stated that it is an air tight pre-stressed concrete building designed for maximum pressure generated from the worst possible accident and is periodically tested for its leak tightness and any small leak from cable and pipe penetrations are retained by the outer containment building.

2. Although tsunami hazards were considered both in the site evaluation and the design of the Fukushima Dai-ichi NPP as described during the meetings and the expected tsunami height was later increased (without changing the licensing documents) after 2002, the tsunami hazard was underestimated.

3. Furthermore, considering that it was not possible to provide for a 'dry site condition for these operating NPPs, the additional protective measures taken as result of the evaluation conducted after 2002 were not sufficient to cope with the unexpectedly higher tsunami run up values and all associated hazardous phenomena (hydrodynamic forces and debris impact). Moreover, the re-evaluation of the hazard after 2002 and the adequacy of the protective actions taken were not reviewed by the Regulatory Authority. Because failures of SSCs when subjected to floods are generally not incremental, the plants were not able to withstand the consequences of tsunami heights greater than those expected (cliff edge effect).

4. Apparently, the tsunami warning and notification system, was not available to provide appropriate and timely response for plant reaction to the event. Japan, and JNES in particular, has developed the TIPEEZ System which was given to IAEA through EBP Tsunami for distributing to member states. This system was not used at 1F plant and the operators were not aware of the approaching tsunami waves.

5. It is recognized worldwide that Japan has a high level of expertise and also experience regarding tsunami hazard and provides leadership in this topic worldwide. This is reflected in the major influence that Japanese academic, scientific and technical institutions have on the international research and development of this topic. In this regard, the IAEA recognizes the valuable support received from JNES on tsunami safety for nuclear power plants which is transferred to Member States through the ISSC. It seems that organizational issues have prevented this expertise to be applied to practical cases at the three NPPs visited during this Mission."