Improving nuclear security: The risk of counterfeits

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India's nuclear establishment has always preferred to function behind a thick veil. While its network of associations is well-known, the establishment’s inner workings are often less transparent. The opaqueness is attributed to protecting national security. However, the same opaqueness does have a major drawback. The lack of transparency in supply chains, vendor processes, and certifications can lead to an increase in counterfeit goods that may hamper the function of such facilities. Often dubbed Counterfeit or Fraudulent Substitution Items (CFSIs),^[1] these goods pose a significant threat to the safety of nuclear systems, structures, components and devices. Whether their presence is due to negligence from archaic certification systems or malicious infiltration, the consequences can be catastrophic.

So far, India has not experienced any case attributed to CFSIs in the nuclear supply chain. However, there have been other cases from which India has learnt. In 2020, India witnessed a blast in the Boiling Water Reactors (BWRs) of its oldest nuclear power plant, the Tarapur Atomic Power Station (TAPS). This blast was attributed to cracks in the BWR that were installed in 1969. The age of the reactors, alongside the lack of upkeep, contributed to the incident. The new materials, which are to be sourced from Italy, have still not been received, so the TAPS functioning is still on hold. This incident has highlighted not only the need for better maintenance but also the need to increase indigenous reliance and ensure the longevity of materials in the nuclear supply chain.

In 2020, India witnessed a blast in the Boiling Water Reactors (BWRs) of its oldest nuclear power plant, the Tarapur Atomic Power Station (TAPS). This blast was attributed to cracks in the BWR that were installed in 1969.

Globally, too, there have been cases highlighting a need for greater stringency in monitoring and deterring CSFIs, many of which have been listed by Hobbs et al. in their report on CFSIs. Between 2006 and 2007, the United States (US) government recalled counterfeit switch breakers in their nuclear supply chain on three occasions. While nothing happened, many counterfeit goods being produced highlighted the need to upgrade policies addressing CSFIs.

Indian regulation and room for improvement

India’s approach to monitoring and regulating the nuclear supply chain is well-woven. One of the central bodies here is the Atomic Energy Regulatory Board (AERB). The AERB, by employing safety codes on nuclear power plants, ensures quality and safety from manufacturing to installation. The AERB also interacts with other government bodies, like the Bureau of Industry Standards (BIS), to ensure quality assurance. Another essential government body is the Nuclear Power Corporation of India Limited (NPCIL), which plays a crucial role in overseeing the prevention of CFSIs. Its main power in overseeing and monitoring nuclear power plants and facilities is to ensure that they adhere to safety standards, supported by rules, guidelines, and standards to ensure that nuclear materials, systems, and components meet the highest quality requirements.

While India is interested in becoming indigenous for its manufacturing and production of critical goods, the reliance on global supply chains cannot be disconnected overnight.

Despite the impact made by these government organisations, the policies overseeing nuclear supply chain governance still have some gaps and challenges. One such challenge is the dependence on international trade. While India is interested in becoming indigenous for its manufacturing and production of critical goods, the reliance on global supply chains cannot be disconnected overnight. Components and materials sourced from overseas could be vulnerable to substandard manufacturing or counterfeit practices. Ensuring the authenticity of imported parts is difficult, especially when they pass through multiple vendors and intermediaries. This highlights the second significant gap, the lack of certifications and regular audits. While the above government bodies offer contracts to reliable bidders, the lack of supplier audits, third-party audits, and regular certification processes decreases the reliability of materials sourced and assurances of the material's longevity. Further, India has thus far not scaled its nuclear forensics^[2] and counterfeit detection technologies and cybersecurity measures, adding more vulnerabilities to this supply chain.

The way forward: Need for enhanced nuclear security guidelines

The Indian defence establishment highlights its protocols for responsible acquisition through the Defence Acquisition Procedure (DAP). It is updated regularly to reflect changing defence requirements, technological advancements, and strategic priorities. The DAP, however, does not directly concern nuclear facilities. Quality assurance and CFSIs are primarily under the mandate of the NPCIL, as mentioned earlier. Thus, the NPCIL is a prime candidate requiring reforms. It must include the following recommendations in an explicit approach to CSFIs laid out similarly to the DAP:

• Vendor certifications: The first challenge must be addressed by necessitating vendor certifications. Such certifications must be a requirement for direct and indirect vendors to nuclear facilities. They must be regularly updated through routine audits to avoid outcomes like the TAPS incident in 2020 due to dilapidated materials. The DAP’s primary focus is promoting indigenous defence production, reducing dependence on imports, and ensuring that defence acquisitions are made cost-effectively and promptly, so such a shift is difficult to make in the short term. The NPCIL can include the certification of imported materials that require regular audits and recertifications.
• Detection and Databasing: Employing non-destructive testing (NDT) methods such as X-ray inspection, ultrasonic testing, and advanced chemical analysis, as already recommended by the International Atomic Energy Agency (IAEA), can help identify compromised parts before they are integrated into critical systems. It may also help to establish a minimum threat level required to report an incident to collaborating organisations.
• Cybersecurity: Finally, cybersecurity is imperative not only for supply chain management but also for nuclear facilities’ security. Post the Kudankulam incident, India has established measures to certify different suppliers and localise the supply chain, especially through the National Critical Infrastructure Information Protection Centre (NCIIP) and guidelines under the AERB. However, to make such guidelines under the NPCIL policies, it is important to make them independent as well. Thus, a third-party certified security organisation may be included to ensure that the vendor’s data, storage information, and material databases are kept secure.
• Information Transparency: Global collaboration, while being something India shies away from in areas of national security, is critical in nuclear supply chains. India must establish a minimum threat and risk level that will require communicating with the IAEA and allied countries in case of the injection of CSFIs in nuclear facilities. India has already shown an inkling in this direction by collaborating with the US under the National Defence Authorisation Act (NDAA).
• Public-Private Interactions: The nuclear establishment must work closely with not only regulatory agencies but also private sector suppliers and industry stakeholders to share information on known counterfeit parts or malicious actors. Further, the focus on indigenous production by the DAP could help encourage cooperation between the Indian government, defence contractors, and industry bodies, which the government has opened up through programs like the Innovation for Defence Excellence (iDEX).

The global defence industry is not immune to the risks of counterfeit products, and India’s defence procurement system must evolve to address this vulnerability. While the DAP has been vital for ensuring fair and transparent procurement practices, it lacks specific provisions to prevent counterfeit items from entering the nuclear supply chain. India would benefit from expanding its approach to CFSIs and adopting guidelines akin to the DAP, including enforceable guidelines on certification, reporting methods, and collaboration, to ease counterfeit detection and attribution.

Shravishtha Ajaykumar is an Associate Fellow with the Centre for Security, Strategy and Technology at the Observer Research Foundation.

[1] CFSIs refer to any items or materials introduced into the supply chain that are intentionally or unintentionally misrepresented as conforming to specifications, standards, or regulations.

[2] Forensic methods to detect radiation, leaks and damage in nuclear materials, to enhance security.

• Defence and Security
• CFSI
• nuclear facilities
• nuclear power plant
• nuclear regulation bodies
• nuclear security
• nuclear supply chain

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