I forgot to mention that Siddharth Varadarajan has an very detailed article in the Hindu concerning the separation plan and the text of the implementation agreement between the US and India.
The bottom line, according to Varadarajan, is that India has created two “strategic hubs”: the Bhabha Atomic Research Centre and the Indira Gandhi Centre for Atomic Research that will comprise the largest portion of the military complex:
India, it says, will include in the civilian list “only those facilities offered for safeguards that, after separation, will no longer be engaged in activities of strategic significance.” At the same time, “a facility will be excluded from the civilian list if it is located in a larger hub of strategic significance, notwithstanding the fact that it may not be normally engaged in activities of strategic significance.”
Thus, all facilities run in the two strategic hubs—the Bhabha Atomic Research Centre and the Indira Gandhi Centre for Atomic Research in Kalpakkam—belong to this category, including their fuel fabrication, reprocessing and uranium and boron enrichment facilities, as well as the Beryllium Machining Facility. The uranium enrichment facilities at Rattehalli will similarly remain unsafeguarded as will the heavy water plants at Baroda, Thalcher, Nangal, Manuguru and Kota.
Both “hubs” are on the BIS Entity List, in case you are wondering.