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SANDIA REPORT

SAND2015-0233

Unlimited Release

Printed January 2015

Nuclear Security Governance in India:

Institutions, Instruments, and Culture

Sitakanta Mishra Happymon Jacob

Research Fellow Assistant Professor

Centre for Air Power Studies School of International Studies

New Delhi, India Jawaharlal Nehru University

 New Delhi, India

Prepared by

Cooperative Monitoring Center

Sandia National Laboratories

Albuquerque, New Mexico - 87185 and Livermore, California - 94550

Sandia National Laboratories is a multi-program laboratory managed and operated by Sandia Corporation a wholly owned subsidiary of 

Lockheed Martin Corporation, for the U.S. Department of Energy’s National Nuclear Security Administration under contract DEAC04-94AL85000.
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SAND2015-0233

Unlimited Release

Printed January 2015

Nuclear Security Governance in India: 

Institutions, Instruments, and Culture

Sitakanta Mishra and Happymon Jacob

Visiting Research Scholars

Cooperative Monitoring Center

Sandia National Laboratories

P.O. Box 5800

Albuquerque, New Mexico 87185-MS1373

Abstract

Nuclear security has gained a great deal of prominence in the recent past thanks to high-level 

international political attention − especially during the Nuclear Security Summit (NSS) process. 

India has been an enthusiastic participant in the NSS initiative and is currently in the process of 

adopting measures to strengthen and enhance its nuclear security governance structures. 

India’s nuclear security culture is based on the beliefs that a credible threat exists and that 

nuclear security is important; and that the various recent global initiatives on nuclear security are 

also in India’s own interest. The imperatives of ensuring greater nuclear security in India lies, 

first of all, in the fact that the country has embarked on an ambitious civil nuclear expansion 

plan. Secondly, it has a fairly large, dispersed countrywide, nuclear infrastructure that needs to 

be secured adequately. Thirdly, radiological materials are used in many sectors and chances of 

their misuse or misappropriation cannot be completely ruled out. Above all, India is situated in a 

volatile region, and hence, vulnerable to nuclear terrorism.

Therefore, this study takes a comprehensive look at India’s approach to nuclear security, in 

general, and critically examines the physical security measures that the country has put in place.

Particular focus is placed on the evolution and strengths, as well as weaknesses, of the country’s 

nuclear security institutions, instruments, practices, and culture. Given that the strengthening of 

India’s nuclear security governance is an ongoing endeavour, the paper also puts forward a 

number of policy recommendations. 
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ACKNOWLEDGEMENTS

In the process of conducting this study, we have accumulated a series of intellectual and 

professional debts. At the outset, we wish to thank Kent Biringer, Manager of the Cooperative 

Monitoring Center, Sandia National Laboratories, for providing us with a truly enabling and 

encouraging ambiance to carry out this subject. We are particularly grateful to David Betsill, and 

Adriane Littlefield, for their consistent support, guidance and inspiration which helped us to 

formulate and streamline our arguments and findings. We are also indebted to the generous 

feedback and advice extended by Geoffery Forden, Amir H. Mohagheghi, Thomas Ciccateri, 

Riyaz Natha, Eric Wallace, and Toby Dalton.

The views expressed in this paper are those of the authors and 

do not necessarily reflect on the position of their respective institutions 

or Sandia National Laboratories.
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TABLE OF CONTENTS

1. INTRODUCTION..............................................................................................................................13

2. INDIA AND THE GLOBAL NUCLEAR ORDER ..........................................................................15

2.1 India’s Integration with the Global Nuclear Order ...............................................................15

2.2 India and the International Export Control Regime.............................................................16

3. STATE OF INDIA’S NUCLEAR PROGRAM................................................................................19

3.1 The Three-Stage Program......................................................................................................20

3.2 Use of Radiological Material...................................................................................................23

3.3 The Strategic Program ............................................................................................................24

4. NUCLEAR SECURITY GOVERNANCE IN INDIA......................................................................26

4.1 Institutions: Roles and Responsibilities ................................................................................27

4.2 The Regulatory Framework ....................................................................................................28

4.2.1 Concerns about Regulatory Framework.......................................................................30

4.2.2 The Nuclear Safety Regulatory Authority (NSRA) Bill................................................32

4.3 The Legal Framework..............................................................................................................34

4.4 India and the Global Nuclear Security Regime....................................................................35

4.5 The Physical Protection System (PPS) ................................................................................37

4.5.1 Inbuilt Security ..................................................................................................................39

4.5.2 Perimeter Security............................................................................................................41

4.5.3 Physical Protection...........................................................................................................41

4.5.4 Personnel Reliability ........................................................................................................43

4.5.5 Material Protection Control & Accounting.....................................................................45

4.5.6 Transportation Security ...................................................................................................46

4.5.7 Air and Water Front Defense..........................................................................................46

4.5.8 Security of Radiological Materials ........................................................................47

4.5.9 Information & Cyber Security ...............................................................................51

4.5.10 Nuclear Forensics................................................................................................51

4.5.11 Security of Strategic Assets .................................................................................52

5. NUCLEAR SECURITY CULTURE IN INDIA: AN EVALUATION........................................53

5.1 Absence of an Overarching Security Apparatus..........................................................54

5.2 Regulatory Autonomy .................................................................................................54

5.2.1 Program Confusions ............................................................................................55

5.2.2 Conceptual Tensions ...........................................................................................56

6. RECOMMENDATIONS FOR ENHANCING NUCLEAR SECURITY GOVERNANCE, 

INSTITUTIONS, INSTRUMENTS, AND CULTURE ..................................................................58

6.1 Recommendations for India ........................................................................................58

6.2 Recommendations for the International Community....................................................59

7. NEXT STEPS ....................................................................................................................60
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FIGURES

Figure 1: India’s Three-Stage Nuclear Power Program ............................................................21

Figure 2: Number of Radiological Units in the Country .............................................................24

Figure 3: Five Elements of India’s Approach to Nuclear Security ..............................................27

Figure 4: Organizational Structure of India’s Nuclear Establishment .........................................28

Figure 5: The Security Envelope ...............................................................................................39

Figure 6: Perimeter Security Zoning System .............................................................................41
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NOMENCLATURE

AEA Atomic Energy Act

AEC Atomic Energy Commission

AERB Atomic Energy Regulatory Board

AHWR Advanced Heavy Water Reactor

BARC Bhabha Atomic Research Centre

BHAVINI Bharatiya Nabhikiya Vidyut Nigam Ltd.

BSF Border Security Force

CAG Comptroller and Auditor General of India

CII Critical Information Infrastructure

CISAG Computer Information and Security Advisory Group

CISF Central Industrial Security Force

CPPNM Convention on the Physical Protection of Nuclear Material

CSI Container Security Initiative

CTBT Comprehensive Test Ban Treaty

DAE Department of Atomic Energy

DBT Design Basis Threat

DCI Department of Commerce and Industry

DFGT Directorate General of Foreign Trade

DFSL Directorate of Forensic Science Laboratories

DGCA Director General of Civil Aviation

DRP Directorate of Radiation Protection

ENR Enrichment and Reprocessing

EWA Early Work Agreement

FBR Fast Breeder Reactor

FBTR Fast Breeder Test Reactor

FRFCF Fast Reactor Fuel Cycle Facility

FTA Foreign Trade (Development and Regulation) Act

GCNEP Global Centre for Nuclear Energy Partnership

GICNT Initiative to Combat Nuclear Terrorism

HEU Highly Enriched Uranium

HRD Human Resource Development

IAEA International Atomic Energy Agency

ICSANT International Convention for the Suppression of Acts of Nuclear Terrorism

IGCAR Indira Gandhi for Atomic Research

IGP Inspector General of Police

IPFM International Panel on Fissile Materials

IPR Institute of Plasma Research

IRRS Integrated Regulatory Review Service

ITDB International Trafficking Data Base

JNPP Jaitapur Nuclear Power Plant

JNPT Jawaharlal Nehru Port Trust

KNPP Kudankulam Nuclear Power Plant

KRIBHCO Krishak Bharati Cooperative Ltd.
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L&T Larson & Toubro

LWR Light Water Reactor

MEA Ministry of External Affairs

MRDS Mobile Radiation Detection Systems

MTCR Missile Technology Control Regime

MUs Million Units (or Unit) is a gigawatt hour

MWBC Mobile Whole Body Counter

NALCO National Aluminum Corporation 

NC&PW Nuclear Control & Planning Wing

NCA Nuclear Command Authority

NPCIL Nuclear Power Corporation of India Ltd.

NPPs Nuclear Power Plants

NPT Nuclear Non-proliferation Treaty

NSG Nuclear Suppliers Group

NSRA Nuclear Safety Regulatory Authority

NSS Nuclear Security Summit

NTI Nuclear Threat Initiative

NTRO National Technical Research Organization

NUMAC Nuclear Material Accounting

ONGC Oil and Natural Gas Corporation

OSART Operational Safety Review Team

PAC Public Accounts Committee

PFBR Prototype Fast Breeder Reactor

PHWR Pressurized Heavy Water Reactor

PPS Physical Protection System

PRP Personnel Reliability Program

PSUs Public Sector Undertakings

PWR Pressurized Water Reactor

RMP Rare Materials Plant

SAIL Steel Authority of India Limited

SASA Strategic Armament Safety Authority 

SCOMET Special Chemicals, Organisms, Materials, Equipment and Technology

SDV Screen Distance Value

SFC Strategic Forces Command

SOPs Standard Operative Procedures

UCIL Uranium Corporation of India Ltd.

UGC University Grant Commission

WANO World Association of Nuclear Operators

WMD Weapons of Mass Destruction
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EXECUTIVE SUMMARY

Nuclear terrorism and clandestine proliferation continue to pose a serious threat to international 

security. India fully shares the continuing global concern on possible breaches of nuclear 

security.

Plenary Statement by External Affairs Minister Salman Khurshid at the Nuclear Security Summit 2014.

India has significant reasons to ensure stringent safe-keeping of its nuclear infrastructure. The 

worsening regional security environment, clandestine proliferation, and thriving terror and 

smuggling networks in the neighbourhood, and above all, the unique nature of its nuclear 

program necessitates nuclear security in India to be a priority. India is conscious of the fact that

credible threats to nuclear infrastructure exist; consequently, in coordination with international 

agencies and stakeholders, it has undertaken several security measures to strengthen its nuclear 

security system. Over the years, India has nurtured a comprehensive security arrangement in and 

around its nuclear infrastructure. However, there exists ample scope for further improvements in 

all aspects relating to nuclear security governance in the county.

In retrospect, India has had a checkered history with the international nuclear order. Initially, it 

was engaged in nuclear disarmament activism, proposing an end to nuclear testing, and was 

instrumental in the setting up of the International Atomic Energy Agency (IAEA). Subsequently, 

as a result of its 1974 nuclear test, a nuclear embargo was imposed, whereby India was denied 

nuclear technology and material for more than three decades. The end of this moratorium came 

in 2005, when President Bush and Indian Prime Minister Manmohan Singh began a sustained 

nuclear dialogue, culminating in an agreement facilitating nuclear cooperation. Today, India is 

well on its way to becoming an integral part of the international nuclear order. The Indo-US 

nuclear deal signed in October 2008 virtually ended India’s isolation in the global nuclear order. 

In 2008, the Nuclear Suppliers Group (NSG), which normally prohibits its members from 

nuclear commerce with states which have not signed the Nuclear Non-proliferation Treaty 

(NPT), agreed on a special waiver in the case of India. 

As of now, India has 21 operational reactors, 6 are under construction, and 16 more are planned 

based on cooperation with Russia, France, and the US. India is pursuing development of nuclear 

power plants by using a mix of indigenous Pressurized Heavy Water Reactors (PHWRs), Fast 

Breeder Reactors (FBRs), and Light Water Reactor (LWRs) based on foreign technical 

cooperation and fuelled by imported enriched uranium. Beyond 2030, large expansion based on 

FBRs, and later thorium-based reactors are planned as part of India’s closed fuel cycle approach. 

The three-stage nuclear power program, based on ‘reprocess to reuse’ strategy, strives to extract 

the maximum energy from the limited uranium resources, provide (arguably) “inherent 

proliferation resistance,” and ensure long-term energy security.
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Besides energy production, India is pursuing comprehensive programs in radiation and isotope 

technologies for societal benefit in the areas of food preservation, development of superior 

mutant varieties of seed/crops, nuclear medicine for diagnostics and radiation therapy, industrial 

radiography, sewage and waste management, etc. These areas have registered phenomenal 

growth. A large number of radioactive consignments (nearly 80,000 per year) containing 

radioactive materials are being transported within, and many more also transit through the 

country. Besides the civilian application of nuclear resources, India has a strategic nuclear 

program based on the doctrinal posture of ‘no-first-use’ and ‘second-strike’ capability.

Owing to the past practice of mixing civil and strategic nuclear programs, nuclear security 

structure and arrangement in India seem to have been intertwined. With the separation of India’s 

civilian nuclear installations from the strategic programme, India’s nuclear security architecture 

has been streamlined. India’s approach towards nuclear security constitutes broadly five 

elements: institutions; technology; nuclear security practice and culture; governance; and 

international cooperation. Though India’s nuclear organizational structure is well laid out, the 

relation between the promoting agency (DAE) and the regulatory agency (AERB) requires a 

fresh look. 

In India, security of nuclear facilities and material is the responsibility of the individual operator; 

the AERB specifies the safety requirements through codes and guides, in which it lays down the 

necessary requirements. The primary responsibility for the safety of nuclear installations and 

material, and their transport and disposal lies with the user/facilities. The AERB periodically 

issues and updates safety and security related documents for the concerned agencies to adhere to.

As the domains of nuclear security and nuclear safety in India have traditionally been considered 

as two sides of the same coin, the legislative framework and institutional architecture that were 

responsible for nuclear safety also catered to nuclear security considerations. Various rules were 

established under the 1962 Atomic Energy Act such as: Atomic Energy (Working of Mines, 

Minerals and Handling of Prescribed Substance) Rules, 1984; Atomic Energy (Safe Disposal of 

Radioactive Wastes) Rules, 1987; Atomic Energy (Factories) Rules, 1996; Atomic Energy 

(Control of Irradiation of Food) Rules, 1996; and Atomic Energy (Radiation Protection) Rules, 

2004; the WMD Act 2005 – all in different ways address security related issues of India’s 

nuclear programme. Meanwhile, India has clearly been steadfast in its adherence to the 

instruments and norms stipulated by the global nuclear security regime.

The Indian nuclear security architecture is based mainly on five pillars: 1) national legal 

provisions in consonance with IAEA guidelines; 2) oversight agency (AERB) that stipulates the 

SOPs; 3) the security (and intelligence) agencies in charge of threat assessment and physical 

protection; 4) the human element (personnel) with the responsibility of oversight or observance; 

and 5) surveillance and detection technology for detection, delay, and response approach.
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The physical protection system around Indian nuclear facilities is designed on the basis of their 

nuclear threat assessment, taking into account the Design Basis Threat (DBT) and Beyond DBT 

(BDBT) to create a layered protective envelope – consisting of inbuilt reactor security, material

security, perimeter security, personnel reliability, material protection and accounting, 

transportation security, air and water front defense, emergency preparedness, legal provisions, 

and in extreme situations, the military protection, etc.

The Central Industrial Security Force (CISF) is in charge of providing security to nuclear 

facilities in the country. Each nuclear facility is guided by a CISF team headed by a 

Commandant. At many sites, the CISF team is supplemented by a Special Task Force. A 

Departmental Committee headed by an Inspector General of Police (IGP) at the Secretariat 

oversees the physical security at the sites. The CISF has developed the necessary ability to 

deploy specially-trained First Responders in case of a nuclear emergency. However, the CISF is 

not in charge of all nuclear related installations in the country.

India has put in place a comprehensive material protection control and accounting programme 

comprised of three basic elements: (1) the legislative and regulatory framework; (2) an integrated 

physical protection programme for facilities and materials; and (3) a comprehensive “Nuclear 

Material Accounting and Control System” (NUMAC). A Nuclear Control & Planning Wing 

(NC&PW) was created in the DAE as of in 2013 to take “the lead on international cooperation 

on nuclear security” by integrating DAE’s safeguards, export controls, and nuclear security 

related activities. However, questions have been raised regarding the physical protection at the 

sites where radiological sources, materials, devices, and instruments are used. Also, smuggling 

of radioactive materials in and around India is often reported.

One can find that though security concerns are not overlooked, there is the absence of an 

overarching security apparatus. For instance, the physical security of nuclear installations is 

provided by multiple organizations such as the CISF, the local police, and sometimes even 

private security organizations. On the other hand, material accounting is done by the DAE, and 

the review of security practices is the responsibility of the AERB. Thus, there are multiple 

organizations in charge of the various aspects of nuclear security in the country, resulting in nonuniform nuclear security culture, norms, and standard operating procedures. 

This study has identified a number of areas where much more needs to be accomplished in order 

to improve the nuclear security culture and architecture in India. First, India should demonstrate 

more confidence and clarity in the essential elements of its nuclear security practices, and make 

“transparency” a key feature of its nuclear security culture. In this pursuit, complete autonomy of 

the regulatory body from the promoting agency should be ensured. In pursuit of controlling the 

movement of radioactive materials it is suggested that all major Indian seaports should be 

equipped with technology similar to Container Security Initiative (CSI). Meanwhile, the 

international community must help mainstream India in the global nuclear order. It would be in 

everyone’s interest to facilitate India’s entry into the export control organizations. India can be 
12

invited to observe nuclear security training, practices, simulation exercises, etc. in other nuclear 

states and vice versa. India and the NSS process should also consider convening Regional 

Nuclear Security Summits.

In the end, the study also outlines a set of steps that may be undertaken within a specific 

timeframe to amplify India’s nuclear security culture.
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1. INTRODUCTION

A nuclear renaissance is on the anvil in India given the widespread belief in the country that 

nuclear energy is perhaps a credible option in ensuring the availability of great amounts of 

energy in a relatively short span. This optimism about nuclear energy in India necessitates a 

debate on the security of the country’s nuclear material and facilities. However, in addition to its 

ambitious plans for nuclear energy expansion, India has other significant reasons to ensure 

stringent safe-keeping of its nuclear infrastructure. The worsening regional security environment, 

thriving terror and smuggling networks in the neighbourhood, prevalent domestic dissident 

groups, and above all, the unique nature of its nuclear program and the exceptions it has 

bargained for itself over the years imply that nuclear security in India is not just a mere

requirement for compliance with the International Atomic Energy Agency (IAEA) recommended 

guidelines: nuclear security for India is fundamental and indispensable, and it is clearly in its 

own interests to be more forthcoming about the steps it has taken in this regard. Given India’s 

enthusiastic participation and official statements during the various Nuclear Security Summits

(NSS), in 2010, 2012, and 2014, acknowledging the importance of nuclear security, one could 

say that India is conscious of the fact that credible threats to its nuclear infrastructure do exist. 

Because of its commitment to the NSS and its own endeavor to secure its nuclear infrastructure, 

India, in coordination with international agencies and stakeholders, has undertaken several

security measures to strengthen its nuclear security system. Since security threats are dynamic in 

nature, and the global nuclear security regime is still evolving, constant review of the threat and 

consequent national measures to meet the unfolding challenge are needed. 

This study offers a critical examination of India’s nuclear security governance – the strengths 

and weaknesses of the security system in place, taking into account several allegations advanced

by a variety of institutions/actors both inside and outside the country. In doing so, an attempt is 

made to describe the nature and current status of India’s nuclear program, India’s contemplation 

of the concept of nuclear security, and its integration with the global nuclear security regime.

This study, relying purely on open sources, also scrutinizes the physical protection system (PPS) 

in place in and around India’s civilian nuclear installations. The major conclusion reached by this 

study is that although India has nurtured a comprehensive security arrangement, there exists

ample scope for further improvement in all aspects relating to nuclear security governance in the 

county. 

During the last seven decades of India’s involvement with nuclear technology, no major nuclear 

disaster is known to have occurred with the exception of sporadic misconducts, industrial 

anomalies, and negligence. Indeed, India claims to have the distinction of over 379 “reactor 
14

years” of safe operation. 1 However, reported smuggling of radioactive materials, terrorists’ 

interest in nuclear assets, and expanding usage of radiological materials in various industrial 

sectors make it important for India to address the weak links in its nuclear security governance to 

ensure that there is absolutely no slippage of nuclear technology and material into the wrong 

hands. 

It is pertinent to inquire why India is ranked low in the nuclear security index created by the 

Washington D.C.-based Nuclear Threat Initiative (NTI), especially since India has a robust nonproliferation record and a long history of dealing with nuclear material. As India regards 

‘secrecy’ as a vital element of its counter strategy to any threat in the nuclear field, it is difficult 

to get a clear picture from the outside on the security measures in place. Often, unavailability of 

information is mistaken for the absence of measures. Moreover, the historical complementarities

between India’s civil and strategic nuclear programs have added to the difficulty in 

distinguishing the line that separates the related organizations from the safety and security 

measures in place. Finally, the tradition of secrecy seems to have manifested in a culture of 

‘insularity’ and devotion to ‘sticking with the program’ as it is. With the Indo-US nuclear deal,

followed by the Nuclear Suppliers Group (NSG) waiver, and the India-specific IAEA safeguards 

agreement, India has been able to widen its civil nuclear network involving various supplier 

countries and industrial houses. This has heralded the process of India’s reengagement with the 

global nuclear order and, at the same time, a thorough rearrangement of its nuclear safetysecurity systems. 

While aspiring for NSG membership and massive expansion of the nuclear energy program, 

India has to manage the dual challenge of maintaining its ‘responsible state’ status at the global 

level, while promoting greater acceptance of new nuclear energy projects at home with the 

domestic public. Therefore, this study, while mapping the contours of India’s nuclear security 

architecture in place, recommends that India develop confidence in its nuclear status to nurture 

‘transparency’ as a major factor in its nuclear security culture; nuclear information management 

through calibrated academic curricula; and graduated autonomy of the regulatory system,

including adoption of international best practices across the board. 

Owing to unavailability of information and sensitivities involved in the steps India takes to 

prioritize nuclear weapons security, this study focuses mainly on the civilian nuclear facilities 

and program. The effort is to bring to the fore the major aspects of the nuclear security 

architecture in India, which is largely understudied, and highlight the scope for improvement in 

various domains related to nuclear security management. 

 

1

Statement by Ratan Kumar Sinha, Chairman of the Atomic Energy Commission and Leader of the Indian 

Delegation to the 57th General Conference, Viena, 18 September 2013. Available at 

http://dae.nic.in/writereaddata/gc2013_stmt.pdf, p. 2.
15

2. INDIA AND THE GLOBAL NUCLEAR ORDER

India has had a checkered history with the international nuclear order. It has engaged in antinuclear activism, proposed an end to nuclear testing in 1954 after the United States (US) nuclear 

testing in Bikini Atoll2, and signed the Partial Nuclear Test Ban Treaty (PTBT) in 1963. India

played a major role in the discussions to establish the IAEA and actively participated in the 

negotiations on the Nuclear Non-proliferation Treaty (NPT), but decided not to sign when it 

became clear that it would become an unequal treaty. As Scott Sagan points out, “In the actual 

negotiations creating the NPT text, Sweden and India proposed to include a commitment to a 

number of ‘tangible steps,’ including security assurances for non-nuclear-weapons states, an end 

to nuclear testing, and a freeze on the production of nuclear weapons in the treaty. The US and 

the Soviet Union refused to allow such specific measures to be included in the final text of the 

NPT.”

3

India, although not a party to the NPT, voluntarily made subject six of its nuclear 

reactors to IAEA inspections even though it was under no obligation to do so. The Indian nuclear 

tests of 1974 prompted a number of NPT countries to set up the NSG, in order to govern the 

supply of nuclear materials and technology. 

As a result of the 1974 nuclear tests, a nuclear embargo was imposed on India whereby India was 

denied nuclear technology and material, such as nuclear fuel and uranium. This prevented the 

Indian scientists from getting adequate exposure to international nuclear research and 

institutions, and unfortunately, early indoctrination into a culture of safety and security. This 

also, in a sense, led to an unhealthy tradition of secrecy regarding nuclear matters in India, as the 

Indian nuclear establishment had to keep the developments in the country’s nuclear program

under wraps so that it was not interrupted by external actors. 

2.1 India’s Integration with the Global Nuclear Order

Despite its past, today, India is well on its way to becoming an integral part of the international 

nuclear order, both in its strategic and civilian nuclear programs. Sustained nuclear dialogue with 

the United States began in 2005, when President Bush and Indian Prime Minister Manmohan 

Singh began discussing nuclear cooperation. This engagement led to a new Indo-US partnership, 

which, in turn, redefined the Indian engagement with the international nuclear order. After years 

of sustained negotiations, India and the US announced an Indo-US nuclear deal in 2005, and

eventually signed it in October 2008, virtually ending the Indian isolation in the global nuclear 

order. The bargain the two countries had struck was a useful compromise: New Delhi didn’t have 

 

2

Indian Prime Minister Jawaharlal Nehru asked the two superpowers to reach a ‘Standstill Agreement’ on nuclear 

weapon testing. Text of Nehru’s demand is available at:

http://www.pugwashindia.org/Issue_Brief_Details.aspx?Nid=73

3

Scott D. Sagan, “Convenient Consensus and Serious Debate about Disarmament,” Discussion Paper Presented to 

the Working Group on an Expanded Non-Proliferation System, Washington, DC, June 8-9, 2010. Available at 

http://www.nti.org/media/pdfs/ConvenientConcensusDebateDisarmament-ScottSagan060610_2.pdf?_=1326132026
16

to give up its nuclear weapons to be part of the international nuclear order; and the NPT did not 

have to be rewritten to accommodate India. 

In 2008, after considerable negotiations, the NSG, which normally prohibits its members from 

nuclear commerce with states which have not signed the NPT, agreed on a special waiver in the 

case of India.4 However, there is a certain lack of clarity as to whether India will be able to 

benefit from enrichment and reprocessing (ENR) technology transfer, for which the NSG is now 

framing new rules. In amending its guidelines in 2011, the NSG stressed it would restrict ENR 

commerce to parties to the NPT. However, the US, France, and Russia have said that they will 

continue with the clean exemption the NSG gave India in 2008, meaning the future NSG 

guidelines would not adversely affect their ENR trade with India.

5

India has played an active role in the IAEA since its inception and has always emphasized the 

importance of the latter’s role in promoting the peaceful uses of nuclear science and technology,

as well as extended support to its safety-security-safeguards related responsibilities. India has 

been participating in IAEA’s Advisory Groups and Technical Committees and contributes to its

activities by providing experts, organizing training programs and workshops, and providing 

equipment. India is one of the founding members of the IAEA’s International Project on 

Innovative Reactors and Fuel Cycles (INPRO). It also contributes $50,000 annually towards the 

program.6

On February 02, 2009, India and the IAEA signed an Agreement for Application of Safeguards 

to Civilian Nuclear facilities in India that entered into force on May 11, 2009. As part of the 

Agreement, India pledged to place 14 civilian reactors under the IAEA inspection regime.7India 

is implementing a separation plan for civilian and military reactors/facilities so that there is no 

cross-feeding of nuclear material from one to the other. As of March 2014, India has placed 20

nuclear facilities under the IAEA safeguards.8

2.2 India and the International Export Control Regime

Other than the major treaty commitment of the NPT, one of the major features of the 

contemporary nuclear order is the existence of international nuclear cartels. These export control 

 

4 Wade Boese, “NSG, Congress Approve Nuclear Trade with India,” Arms Control Today, October 2008. Available 

at https://www.armscontrol.org/act/2008_10/NSGapprove

5

SiddharthVaradarajan, “Challenges ahead for India's nuclear diplomacy,” The Hindu, November 01, 2011. 

Available at http://www.thehindu.com/todays-paper/tp-opinion/challenges-ahead-for-indias-nucleardiplomacy/article2586970.ece

6

“India and the IAEA,” Indian Embassy (Vienna), Government of India. Available at 

http://www.indianembassy.at/pages.php?id=64

7

“India notifies separation plan to IAEA,” Economic Times, October 16, 2009. Available at 

http://articles.economictimes.indiatimes.com/2009-10-16/news/27657210_1_separation-plan-iaea-board-safeguardsagreements

8

“Agreement between the Government of India and the International Atomic Energy Agency for the Application of 

Safeguards to Civil Nuclear Facilities,” INFCIRC/754/Add.5. 28 March 2014. Available at 

http://www.iaea.org/Publications/Documents/Infcircs/2014/infcirc754a5.pdf, pp. 1-2.
17

organizations have traditionally sought to isolate India. However, post-2008, New Delhi has also 

been in negotiations to gain membership of various international export control regimes: the 

NSG, which ‘governs the export of items that are especially designed or prepared for nuclear 

use;’

9

the Missile Technology Control Regime (MTCR), which aims to control the ‘nonproliferation of unmanned delivery systems capable of delivering weapons of mass destruction, 

and which seeks to coordinate national export licensing efforts aimed at preventing their 

proliferation;’

10 the Australia Group (AG), which ‘seeks to ensure that exports do not contribute 

to the development of chemical or biological weapons;’

11 and the Wassenaar Arrangement 

(WA), which aims to promote ‘transparency and greater responsibility in transfers of 

conventional arms and dual-use goods and technologies, thus preventing destabilizing

accumulations.’

12 Of the four, the NSG, which deals directly with nuclear issues, is the most 

significant in regard to the civilian reactors in India. While New Delhi formerly viewed these 

informal arrangements as technology-denial regimes, today it feels the need to engage them in a 

mutually beneficial manner. 

Although India has not been admitted to any of these strategic associations, membership remains

a possibility since India fulfills most of the criteria for inclusion in these groups. According to 

Rajiv Nayan, “India fulfills all the membership criteria of the MTCR and the Australia Group. 

Similarly, it also fulfills all the criteria for the NSG, except on the counts of NPT adherence and 

some existing nuclear free zone treaties. Equally, India fulfills the adherence criteria for the 

Wassenaar Arrangement, except in the NPT.”

13 Even as New Delhi would prefer the 

membership of NSG to that of the others, it is the membership of NSG that is the most difficult 

to obtain. 

India has also revised its domestic export control regime to align it with the control lists 

stipulated by the various international export control organizations. Rajiv Nayan writes: “The 

Special Chemicals, Organisms, Materials, Equipment and Technology (SCOMET) list is the 

principal regulatory mechanism for Indian export controls. It is regularly updated and expanded 

frequently, depending on the pace of technology... The Indian export control system was 

revamped in keeping with the guidelines and technology control lists of the NSG and the MTCR 

as per the July 18, 2005 joint statement.”

14

India has been an enthusiastic participant in the NSS process started in 2010. It supported the 

Washington Summit Communiqué and Work Plan of the first NSS in 2010, and announced that 

it would establish a Global Centre for Nuclear Energy Partnership, which has since been formed. 

India hosted a NSS ‘Sherpa’ preparatory meeting in New Delhi on January16-17, 2012. At the 

 

9

For more on NGS see http://www.nuclearsuppliersgroup.org/Leng/02-guide.htm

10 For more on MTCR see http://www.mtcr.info/english/

11 For more on the Australia Group see http://www.australiagroup.net/en/index.html

12 For more on the Wassenaar Arrangement see http://www.wassenaar.org/introduction/index.html

13 Rajiv Nayan, “Integrating India with the Global Export control Systems: Challenges Ahead,” Strategic Analysis, 

35: 3, 2011, p. 443.

14 Ibid, p. 441. 
18

second NSS in 2012, India pledged $1 million towards the IAEA’s Nuclear Security Fund for 

2012–13. Many view that “the summits failed to convince New Delhi to increase transparency” 

and “have proved unable to break through India’s penchant for secrecy on what it considers to be 

matters of national security....”15 India was also an enthusiastic participant at the NSS 2014.16 In 

the Plenary Statement, the leader of India’s delegation, External Affairs Minister Shri Salman 

Khurshid, underlined that “India had not wavered in its commitment to global efforts to prevent 

the proliferation of weapons of mass destruction and their means of delivery.”17 India has also 

declared its intention to establish an independent Nuclear Safety Regulatory Authority (NSRA) 

to enhance oversight of nuclear security and strengthen synergy between safety and security.18

The legislation to establish the Authority was tabled in the Indian Parliament, but the bill has

since lapsed, as the last session of the 15th Lok Sabha could not pass the bill before the general 

elections in April 2014.

19 The new government is likely to reintroduce the bill in the parliament 

soon. 

 

15 P. R. Chari, “India’s Role in the Hague Nuclear Security Summit”, Proliferation Analysis, March 18, 2014.

Available at http://carnegieendowment.org/2014/03/18/india-s-role-in-hague-nuclear-security-summit/h4iw

16 Nuclear Security Summit 2014, “National Progress Report –

India,”https://www.nss2014.com/sites/default/files/documents/india.pdf ;P.R. Chari, “India’s Role in the Hague 

Nuclear Security Summit,” Proliferation Analysis, Carnegie Endowment. March 18, 2014. Available at 

http://carnegieendowment.org/2014/03/18/india-s-role-in-hague-nuclear-security-summit/h4iw

17 Statement by Bhaswati Mukherjee, “3rd Nuclear Security Summit The Hague, Netherlands (March 24-25,

2014).”Available at http://mea.gov.in/in-focusarticle.htm?23194/3rd+Nuclear+Security+Summit+The+Hague+Netherlands+2425+March+2014, 09 April 2014.

18 “Nuclear Security Summit National Progress Report,” India, March 27, 2012. Available 

athttp://www.mea.gov.in/bilateral-documents.htm?dtl/19074/. For more details on the Indian participation at the 

2012 NSS meeting see, http://www.mea.gov.in/global-issue-detail.htm?85/Nuclear+Security+Summit+2012

19 “The Nuclear Safety Regulatory Authority Bill, 2011.” Available at 

http://www.prsindia.org/uploads/media/Nuclear%20Safety/Nuclear%20Safety%20Regulatory%20Authority%20Bill

%202011.pdf
19

3. STATE OF INDIA’S NUCLEAR PROGRAM

The ‘Integrated Energy Policy of India’ considers the role of nuclear power, among other 

options, as “the most potent means to long-term energy security,” and therefore prescribes

“accelerated development of nuclear source for sustainable development of the country.”

20 The 

Nuclear Power Corporation of India Ltd. (NPCIL) has planned to launch 16 more reactors –

eight 700 MW Pressurized Heavy Water Reactors (PHWRs) and eight Light Water Reactors 

(LWRs), based on cooperation with Russia, France, and the US – at an outlay of Rs 230,000 

crore (approximately $3.8 billion USD (September 2014 rates) during the 12th Five Year Plan 

period (FYP) (2012-17).21 The total installed capacity is scheduled to reach 9,980 MWe during 

this planning period which will help India in “building strategic stockpile of nuclear fuel to 

counter the risk of disruption of international fuel supply”.22

Today, nuclear energy constitutes around 3% of the total electricity produced in the country and 

the vision is “to have 14,600 MWe nuclear capacity on line by 2020;” in the long-term, India 

aims “to supply 25% of electricity from nuclear power by 2050.”

23 With the civil nuclear 

agreement with the US, the India-specific safeguards agreement with IAEA, and the NSG waiver 

in 2008, India has initiated civil nuclear cooperation with around two dozen countries and three 

dozen industrial houses.24 Currently, 21 nuclear power reactors are in operation in six states 

producing around 5000 MW. Six reactors under construction are expected to generate an 

additional 4,800 MW, while another 33 are planned.25

Nuclear power output has increased by over 80% (i.e., from 18,634 million units (MUs)26 in 

2006-07 to 35,333 million units during 2013-14).

27 Uranium supplies from Canada, France, 

Kazakhstan, and Russia have helped Indian reactors to operate with high capacity. The capacity 

factor rose to 79% in 2011-12 from 71% in 2010-11. Nine reactors recorded an unprecedented 

97% capacity factor during 2011-12, and with imported uranium from France, the Kakrapar 

reactors recorded 99% capacity factor during 2011-12.28 The target of nuclear energy generation 

in the 11thFive Year Plan (2007-2012) was 163,395 MUs, which was revised to 124,608 MUs.

 

20 Government of India, “Integrated Energy Policy: Report of the Expert Committee,” 2006, Planning Commission, 

New Delhi, p. xxii.

21 “Nuclear Power Corporation of India to Launch 16 New Nuclear Reactors,” The Economic Times, June 01, 2012.

22 Press Information Bureau, Government of India, “Integrated Energy Policy.” Available at 

http://www.pib.nic.in/newsite/erelease.aspx?relid=46172, December 26, 2008.

23 “Nuclear Power in India”, http://world-nuclear.org/info/Country-Profiles/Countries-G-N/India/?, September 2014.

24 Sitakanta Mishra, “India’s Civil Nuclear Network,” Air Power Journal, Vol. 5, No. 4, (October-December 2010), 

pp. 107-32.

25 Nuclear Power Corporation of India Ltd., “Nuclear Power Generation (2006-07 to 2014-15),” 

http://www.npcil.nic.in/main/AllProjectOperationDisplay.aspx; “Status of Projects Under Construction,” 

http://www.npcil.nic.in/main/ProjectConstructionStatus.aspx

26 1 MU = 1 Gigawatt-hour

27 NPCIL, “Nuclear Power Generation (2006-07 to 2014-15).” Available at 

http://www.npcil.nic.in/main/allprojectoperationdisplay.aspx

28 Namrata V Lotia, et al, “Development of Framework for the Evolution of Alternative Energies Supply and 

Demand: A Review,” IOSR Journal of Mechanical and Civil Engineering. Available at http://iosrjournals.org/iosrjmce/papers/ICAET-2014/me/volume-6/13.pdf?id=7622, p. 58.
20

But, “the actual generation in the 11th Five Year Plan was 109,642 MUs”.

29 Reportedly, this

“target could not be achieved because of non-availability of uranium.”

30 The Unit 1 reactor at 

Kudankulam Nuclear Power Plant (KNPP) attained its full power status on June 07, 2014.31 On 

April 19, 2014, India and Russia signed a framework agreement for building the third and fourth 

units of the KNPP.32 A Memorandum of Understanding (MoU) has been signed for an Early 

Work Agreement (EWA) between NPCIL and Westinghouse for the Mithivirdi plant in 

Gujarat.33 Meanwhile, India and France have reportedly agreed on the cost of power that will be 

generated by Jaitapur Nuclear Power Plant (JNPP) in Maharastra.34 During his July 2014 visit to 

Bhabha Atomic Research Centre (BARC), Prime Minister Narendra Modi said “the DAE should 

strive to meet the target of increasing nuclear capacity threefold from the present level of 5,780 

MW by 2023-24, within the projected cost.”35

3.1 The Three-Stage Program

In a quest to leverage its nuclear industry, India is pursuing development of nuclear power plants 

using a mix of indigenous PHWRs, Fast Breeder Reactors (FBRs), and LWRs based on foreign 

technical cooperation and fuelled by imported enriched uranium. In addition, these plants are 

planned to be under IAEA Safeguards. Presently, 15 PHWRs, totaling around 3,800 MWe

capacity, are in operation. Among the other designs, sixteen more PHWRs of 700 MWe at five 

different inland sites are planned.36 Today, the PHWRs comprise over 80% of India’s installed 

nuclear reactors, and are claimed to have some safety and operational advantages over the PWRs

“such as not requiring refueling outages, as well as greater fuel cycle flexibility...can more 

easily utilize lower enriched uranium, reprocessed fuel, and potentially thorium.”

37 Beyond 

2030, large expansion based on FBRs, and later thorium-based reactors are planned as part of 

 

29 “Uranium Shortage Hit Nuclear Power Generation Target in 11th Plan,”, Firstpost.com, 23 July 2014. Available 

at http://www.firstpost.com/india/uranium-shortage-hit-nuclear-power-generation-target-11th-plan-1631071.html

30 Ibid.

31 PallavaBagla, “Kundankulam Nuclear Plant Attains Full Power Status for First Time,”, NDTV.com, June 07, 

2014. http://www.ndtv.com/article/india/kundankulam-nuclear-plant-attains-full-power-status-for-first-time537695?pfrom=home-lateststories. 

32 Alexander Korablinov, “Rosatom Chief Confirms Kudankulam 3 & 4 Agreement Signing,” Russia & India 

Report, 23 May 2014. Available at 

http://in.rbth.com/economics/2014/05/23/rosatom_chief_confirms_kudankulam_3_and_4_agreement_signing_3545

1.html

33 “Westinghouse Signs MoU for Building N-Plants in India,, Zeenews.india.com, June 13, 2012. Available at 

http://zeenews.india.com/news/nation/westinghouse-signs-mou-for-building-n-plants-in-india_781702.html.

34 “India, France Agree on Cost of Power Generated by Jaitapur Nuclear Power Plant,” The Economic Times, March

09, 2014.

35 “India's Nuclear Capacity could Jump Threefold by 2023-24: Modi,” Business Standard, July 22, 2014. Available 

at http://www.business-standard.com/article/current-affairs/india-s-nuclear-capacity-could-jump-threefold-by-2023-

24-modi-114072101107_1.html.

36 Sinha, n. 1, p. 3.

37 Bill Linton, “Market Overview: The Outlook for Nuclear Power in India”, April 16, 2014. Available at

http://www.power-eng.com/articles/npi/print/volume-7/issue-2/nucleus/market-overview-the-outlook-for-nuclearpower-in-india.html.
21

India’s closed fuel cycle approach38– this three-stage nuclear power program strives to extract 

the maximum energy from the limited uranium resources, provide (arguably) “inherent 

proliferation resistance,”

39 and ensure long-term energy security.

Figure 1: India’s Three-Stage Nuclear Power Program

Source: http://www.barc.gov.in/reactor/tfc_3sinpp.html

The three-stage Indian nuclear power program, according to India’s nuclear establishment, is 

devised to utilize the available resources efficiently and in a sustainable manner. The essence of 

the ‘reprocess to reuse’ nuclear strategy is that it avoids both the buildup of stockpiles as well as 

the need to store large amounts of spent fuel that could be prone to malefactors. The first stage, 

which mainly comprises the PHWRs, uses the domestic natural uranium as fuel to generate 

electricity. In this stage, natural uranium (U235, 0.72%) undergoes fission and a portion of the 

remaining U238 gets converted to Pu239; the spent fuel generated from this stage will be 

“reprocessed to recover” the Pu239 to be utilized as fuel in the FBRs in the second stage.40 These 

reactors, besides using Pu239 as fuel, will also make use of thorium as blanket in the reactor 

core. The thorium (Th232) will undergo nuclear mutation in the reactor core to produce U233. 

Therefore, the second stage constitutes the FBRs along with reprocessing plants and plutoniumbased fuel fabrication plants. The U233 produced in the second stage, along with thorium, will 

be used as fuel in the third stage of reactors, thus “to make optimum use of our vast thorium 

reserves for sustained power generation to cater to the long-term needs of the nation.”

41

 

38 BARC, “Indian Programme on Reprocessing.” Available at 

http://www.barc.gov.in/publications/eb/golden/nfc/toc/Chapter%206/6.pdf

39 Ibid.

40 Ramendra Gupta, “Nuclear Energy Scenario of India.” Available at 

http://www.ucil.gov.in/web/nu_energy_of_india.pdf

41 Interview with IEEMA Journal, Dr S K Jain, CMD, NPCIL, Face2Face. Available at 

http://npcil.nic.in/pdf/ten_06feb2012_01.pdf, p. 48.
22

Currently, India is entering into the second stage of the three-stage program and has established 

three reprocessing plants to extract plutonium.42

According to AEC Chairman R.K. Sinha, “The construction of the 500 MWe Prototype FBR 

(PFBR) is nearing completion at Kalpakkam” and expected to achieve criticality this year.

43 A 

co-located Fast Reactor Fuel Cycle Facility (FRFCF) to reprocess and re-fabricate the fuel from 

PFBR is also being built at Kalpakkam with the cost of 9,600 crore (roughly $1.5 billion based 

on November 2014 exchange rates).

44 A Fast Breeder Test Reactor (FBTR), fuelled with unique 

mixed carbide fuel, located at the Indira Gandhi Centre for Atomic Research (IGCAR), has 

“performed well,”

45 providing valuable operating experience and technical inputs. An Advanced 

Heavy Water Reactor (AHWR) is under development by BARC “to expedite the transition to 

thorium based systems.”

46

 The successful running of the KAMINI research reactor at 

Kalpakkam, based on uranium-233 fuel derived from thorium marks the beginning of the third 

stage of operation.

47 It is viewed that “this mammoth program has the potential to provide energy 

security to the country for about 400 years supplementing the potential of other resources.”

48

For expediting its ambitious nuclear industry, India imports about 40% of its uranium 

requirements.49 While reaching out to potential uranium suppliers across the globe, India also 

plans for optimal utilization of the country’s scarce uranium resources. In four States, 13 

uranium mining projects are currently in different stages of exploration.50 The two Processing

Plants at Jaduguda and Turamdih prepare yellow cake and send it to the Nuclear Fuel Complex 

at Hyderabad for further processing into UO2 pellets. The plant at Jaduguda has the capacity to 

process 2500 tonnes of ore per day.51 India has continued to make progress in finding new 

uranium resources in the country through extensive exploration work, using multiple 

technologies. In 2012, with the use of advanced techniques, India has been able to identify new 

sources of uranium and reserves have registered an increase of about five percent. 52 During 

2012-13, the “performance of all operating units of UCIL has been quite satisfactory, recording 

 

42 Gupta, “Nuclear Energy Scenario of India.”

43 “DAE Aims to Produce More Fuel this Year, Assures Sinha”, October 01, 2014. Available at 

http://freepressjournal.in/dae-aims-to-produce-more-fuel-this-year-assures-sinha/

44 “Rs 9,600-crore Nuclear Fuel Facility to Come up at Kalpakkam,” July 20, 2013. Available at

http://www.dnaindia.com/india/report-rs9600-crore-nuclear-fuel-facility-to-come-up-at-kalpakkam-1863491

45 “IGC Annual Report 2012.” Available at http://www.igcar.ernet.in/igc2004/igcanr2012.pdf, p. 12.

46 S.V. Kumar, “Reprocessing In India: Development, Demonstration And Deployment.” Available at

http://www.barc.gov.in/presentations/svkspeach.html

47 “Ramtanu Maitra”, Thorium: Preferred Nuclear Fuel of the Future. Available at 

http://www.21stcenturysciencetech.com/Articles%202005/Thorium_nuclear.pdf, p. 46.

48ibid

49 “Nuclear Power in India,” World Nuclear Association, 30 July 2014. Available at http://www.worldnuclear.org/info/Country-Profiles/Countries-G-N/India/. 

50 Uranium Corporation of India Ltd., “Uranium Occurrence and Production Centres in India.” Available at 

http://www.ucil.gov.in/web/operetions_of_ucil.html

51 Gupta, p. 7.

52 Statement by Ratan Kumat Sinha, Chairman of the Atomic Energy Commission and Leader of the Indian 

Delegation to the 57th General Conference, Vienna, 18 September 2013. p. 4.
23

highest ever mineral production as well as ore processed and dispatch to Nuclear Fuel 

Complex.”53 The monitoring of the recovery process of uranium and by-products from the ore is 

undertaken by the UCIL Control Research & Development Department.54

To achieve the target and judicious mobilization of expertise and resources, India has put in 

place an integral and coordinated framework involving specialized agencies, academic 

institutions, public sector undertakings, and private industrial houses. By mobilizing both 

domestic and international stakeholders, India plans to strengthen its technological and human 

resource base and acquire more uranium and technology. Assuming India receives NSG 

membership, India aspires to participate in international nuclear commerce as a supplier. As a 

long-term strategy, India has plans to diversify its nuclear industry, involving both domestic and 

international private industrial houses such as Larson & Toubro (L&T), Tata, Relience, Punj 

Lloyd, Westinghouse, Areva, GE, Sandpit, etc. In order to reduce the burden of the two Public 

Sector Undertakings (PSUs) in charge of nuclear-related activities – NPCIL and BHAVINI –

India is planning to diversify the operational and management responsibilities of nuclear plants 

among other PSU. The National Aluminum Corporation (NALCO), Indian Oil Corporation, 

Indian Railways, Oil and Natural Gas Corporation (ONGC), Steel Authority of India Limited 

(SAIL), and NTPC have also expressed interest in such projects.55 However, diversification of 

the nuclear energy program, though warranted, will equally pose additional safety-security 

challenges.

3.2 Use of Radiological Material

Besides energy production, India is pursuing comprehensive programs in radiation and isotope 

technologies for societal benefit in the areas of food preservation, development of superior 

mutant varieties of seed/crops, nuclear medicine for diagnostics and radiation therapy, industrial 

radiography, sewage and waste management, etc. These areas have registered phenomenal 

growth. In the medical sector alone, more than 57,443 medical X-ray units are in operation in 

various parts of the country.56 According to a 2008 Atomic Energy Regulatory Board (AERB)

estimate, radioactive materials used in India for industrial and medical applications are estimated 

at over 12,000 devices, which include 300 telecobalt therapy units, 100 accelerators, over 2,000 

 

53 Uranium Corporation of India Ltd., 46th Annual Report 2012–2013. Available at 

http://www.ucil.gov.in/web/Annual%20Report%20-%20English%20-2012-13.pdf, p. 9.

54 “Control Research and Development.” Available at www.ucil.gov.in/web/control_research_&_development.html

55 “Nuclear Power in India,” World Nuclear Association, July 30, 2014. Available at http://www.worldnuclear.org/info/Country-Profiles/Countries-G-N/India/, p. 12-14.

56 “Report of the Comptroller and Auditor General of Indian on Activities of Atomic Energy Regulatory Board for 

the Year Ended March 2012,” Report No. 9 of 2012-13. Available at 

http://www.indiaenvironmentportal.org.in/files/file/Performance%20audit%20on%20activities%20of%20Atomic%2

0Energy%20Regulatory%20Board.pdf
24

computed tomography scan units, 150 nuclear medicine centers, 1400 industrial radiography 

cameras, 8000 nucleonic gauges, and 14 gamma radiation processing plants (Fig. 2).57

Figure 2: Number of Radiological Units in the Country

Source: Compiled from CAG Report, March 2012.

A large number of radioactive consignments (nearly 80,000 per year) containing radioactive 

materials are being transported within, and many more also transit through the country.58 Given 

the surging economic development and demand in various sectors of economy, application of 

radiological material in the country is bound to increase.

3.3 The Strategic Program

Besides the civilian application of nuclear resources, India has a strategic nuclear program based 

on the doctrinal posture of ‘no-first-use’ and ‘second-strike’ capability with “punitive 

retaliation...to inflict damage unacceptable to the aggressor.”59 India is also preparing its third 

leg of the nuclear triad – INS Arihant, the first 6,000-ton submarine with a 83MW pressurized 

light-water reactor onboard, is being readied for extensive sea-trials. 

Although no exact number on India’s nuclear weapons inventory is available, it is speculated that 

New Delhi roughly possesses enough weapon-usable plutonium to build between 100 and 130 

nuclear bombs, and these numbers are expected to grow in the coming years. 60 No public 

 

57 A.R. Sundararajan, K.S. Parthasarathy, and S. Sinha, “Application of Radiation in Medicine, Industry and 

Research,” in Atomic Energy Regulatory Board: 25 Years of Safety Regulation November 2008. Available at 

http://www.aerb.gov.in/AERBPortal/pages/English/t/publications/SJBook.pdf, p. 146.

58 Ibid, p. 137.

59 “Draft Report of National Security Advisory Board on Indian Nuclear Doctrine,” August 17, 1999. Available at 

http://www.mea.gov.in/in-focusarticle.htm?18916/Draft+Report+of+National+Security+Advisory+Board+on+Indian+Nuclear+Doctrine

60 “Not All Indian Fissile Material Being Used for Bombs: Analysts,” July 25, 2012, Nuclear Threat Initiative. 

Available at http://www.nti.org/gsn/article/not-all-indian-fissile-material-being-used-bombs-analysts/.
25

information is available on the holding of unirradiated civilian plutonium, but India is believed to 

have several tons of unirradiated reactor grade material, i.e., weapon-usable plutonium that it 

plans to use in its breeder reactor program. According the International Panel on Fissile 

Materials (IPFM), “India’s stockpile of fissile materials is estimated to include 2.4±0.9 tonnes of 

Highly Enriched Uranium (HEU) (0.8±0.3 tonnes of 90% HEU equivalent), 0.54±0.18 tonnes of 

weapon-grade plutonium, and 4.9±0.4 tonnes of reactor-grade plutonium, that includes 4.7±0.4 

of material considered strategic reserve and 0.24 tonnes of safeguarded plutonium.”61 And, the 

total amount of HEU produced through enrichment route by India is “estimated to be 2.4±0.9 

tonnes, with enrichment of about 30%, which corresponds to 0.8±0.3 tonnes of 90% HEU 

equivalent.”

62 Currently, the Trombay reprocessing plant reprocesses the spent fuel from 

research reactors with the capacity of 60 tonnes per year. 63 The plants at Tarapur and 

Kalpakkam, each with an operating capacity of 100 tonnes per year, process off-site fuels from 

PHWRs. Moreover, additional reprocessing facilities are being set up with the active 

participation of the Indian industry to accelerate the programme.64

 

61 International Panel on Fissile Materials,, “Global Fissile Material Report 

2013,”http://fissilematerials.org/library/gfmr13.pdf, p. 79; “Countries: India,”

http://fissilematerials.org/countries/india.html, February 04, 2013.

62 Ibid.

63 Rajeev Sharma, “Coming to India’s Aid on KNPP’s Spent Nuclear Fuel, India & Russia Report, May 13, 2013. 

Available at 

http://in.rbth.com/economics/2013/05/13/coming_to_indias_aid_on_knpps_spent_nuclear_fuel_24903.html

64 Indian Programme on Reprocessing,” BARC.gov.in. Available at 

http://barc.gov.in/publications/eb/golden/nfc/toc/Chapter%206/6.pdf
26

4. NUCLEAR SECURITY GOVERNANCE IN INDIA

The Ministry of External Affairs (MEA) media briefing on the eve of the third NSS (2014) 

categorically claims that “India is no stranger to nuclear security. At the dawn of India’s nuclear 

power programme, Prime Minister Nehru minuted that source materials for nuclear energy was 

not an ordinary commodity and needed to be handled with care.”65 It further claims that “there 

has been no breach of nuclear technology security of the kind that allowed AQ Khan to access 

and proliferate sensitive nuclear technology and materials.” Even more pertinently, “India’s 

efforts to secure its nuclear materials, facilities and activities did not begin with the recent rise in 

international awareness about the dangers of nuclear terrorism.”66 The NSS process that brought 

momentum to “national action and responsibility for securing nuclear and radiological materials, 

has, according to an Indian commentator, universalised a threat that India was fighting a lonely 

battle against” for the last few decades.67 Owing to the past practice of mixing civil and strategic 

nuclear programs, nuclear security structure and arrangement in India seem to have intertwined. 

Prior to the NSS process, the AERB Safety Code of October 2009, described ‘nuclear security’ 

as “all preventive measures taken to minimize the residual risk of unauthorised transfer of 

nuclear material and/or sabotage, which could lead to release of radioactivity and/or adverse 

impact on the safety of the plant, plant personnel, public and environment.”68 In its 2014 media 

briefing, the MEA described the concept of nuclear security as “prevention and detection of, and 

response to unauthorized removal, sabotage, unauthorized access, illegal transfer or other 

malicious acts involving nuclear or radiological material or their associated facilities.”69 Both 

definitions largely parallel the definition used by IAEA since 2003: “The prevention and 

detection of and response to theft, sabotage, unauthorized access, illegal transfer or other 

malicious acts involving nuclear material, other radioactive substances or their associated 

facilities.”

70 Suffice to say that the idea of nuclear security perception in India is in line with the 

global concern. The former Prime Minister Manmohan Singh’s acknowledgement at the 2010 

NSS that “nuclear security is one of the foremost challenges we face today” and that the Summit 

process is in India’s own interest, acknowledges the fact that the threat to nuclear infrastructure 

is credible and India is conscious of the issue. Given this recognition of the threat to nuclear 

security, India has been an enthusiastic partner of the NSS process to explore innovative 

approaches and best practices for nuclear security.

 

65Ministry of External Affairs (MEA), “Nuclear Security in India.” Available at 

http://www.human.ula.ve/catedralibreindia/documentos/india_nuclear.pdf

66 Ibid.

67 Manpreet Sethi, “Fighting Nuke Threat is No Joke,” The New Indian Express, May 01, 2014.

68 Atomic Energy Regulatory Board, “Glossary of Terms for Nuclear and Radiation Safety,” Guide NO. 

AERB/SG/GLO, March 2005. p. 43.

69 MEA, “Nuclear Security in India.”

70 IAEA, Nuclear Security Plan 2010-2013, document GOV/2009/54-GC(53)/18(17 August 2009), pp. 1-2. 

Available at http://www.iaea.org/About/Policy/GC/GC53/GC53Documents/English/gc53-18_en.pdf
27

However, analysts have argued that “for years, neither the Indian strategic community nor the 

Indian government paid serious attention to the problem of nuclear terrorism” publicly. Rather, 

the Indian government joined almost all the international initiatives without any major debate on 

it domestically.

71 Information regarding India’s approach towards nuclear security was largely 

confined to the nuclear establishment and government officials. The Indian strategic community

first became aware of India’s nuclear security strategy only in 2010, when the country’s foreign 

policy establishment briefed the media and the Prime Minister Singh made his statement at the 

NSS in Washington, DC. The MEA media briefing in the eve of the 2014 NSS broadly described

five elements of India’s approach to nuclear security: institutions; technology; nuclear security 

practice and culture; governance; and international cooperation (Fig. 3).

Figure 3: Five Elements of India’s Approach to Nuclear Security

Source: http://www.mea.gov.in/Images/pdf/Brochure.pdf

4.1 Institutions: Roles and Responsibilities

India’s Atomic Energy Commission (AEC) was established in August 1948 within the 

Department of Scientific Research, which was set up in June 1948. The Department of Atomic 

Energy (DAE) came into existence in August 1954 through a Presidential Order. Thereafter, a 

Government Resolution in1958 transferred the DAE within the AEC. The Secretary to the 

Government of India in the DAE is the ex-officio Chairman of the AEC. The other Members of 

the AEC are appointed on the recommendation of the Chairman of the AEC.72 The AERB of 

India, which is the country’s civilian nuclear regulatory authority, was established in 1983 by the 

Government of India. The primary authority of the institution comes from the Atomic Energy 

 

71 Rajiv Nayan, “India’s Nuclear Security Policy,” IDSA Comment, 05 January 2012. Available at 

http://idsa.in/idsacomments/IndiasNuclearSecurityPolicy_rnayan_050112.html

72 Government of India, “Atomic Energy Commission.” Available at http://dae.nic.in/?q=node/394
28

Act of 1962. Figure 4 shows the institutional structure and organizational chart of India’s atomic 

energy establishment. 

Figure 4: Organizational Structure of India’s Nuclear Establishment

Source: DAE, Government of India, (http://dae.nic.in/?q=node/634)

4.2 The Regulatory Framework

The AERB reviews the safety and security of the country’s Operating Nuclear Power Plants, 

Nuclear Power Projects, Fuel Cycle Facilities, and Other Nuclear/Radiation Facilities and 

Radiation Facilities.73As far as the unusable radioactive material is concerned, “any imported 

source, after the useful life-time is over, is sent back to the supplier abroad for safe disposal.”

74

 

73 Ibid.

74 Ibid.
29

“Such sources are exported back to the supplier only after completing all the regulatory 

procedures ensuring that the source is safe for transport. The user is required to intimate to 

AERB once the export of the disused source is complete... However, in some cases, particularly 

for sources imported long ago, the user is not able to export the source for safe disposal. In such 

cases, AERB helps the user to dispose of the disused sources at any authorized waste 

management agency in the country after completing all the regulatory formalities”.

75 The rule 

with regard to the unusable radioactive material from domestic sources is that “once a disused 

source is known to be lying in the facility, the user is advised to arrange transport of the source 

for safe disposal to the domestic supplier. Such transport for safe disposal to the domestic 

supplier is done after completing the required regulatory procedures. Once the disused source is 

safely received by the domestic supplier for safe disposal, intimation is sent to AERB.”76

Safety and security of nuclear facilities and material is the responsibility of the individual 

operator; the AERB specifies the safety requirements through codes and guides, in which it lays 

down the necessary requirements. The primary responsibility for the safety of nuclear 

installations and material, and their transport and disposal lies with the user/facilities.77 Indeed, it 

has issued a number of guides for both safety and security of nuclear facilities and material. It 

also ensures compliance to safety standards, as it controls the licensing process of setting up a 

nuclear facility and running it. The AERB also conducts occasional reviews of the safety and 

security standards of nuclear power plants. More importantly, since license is given to nuclear 

power plants for a maximum of five years, the renewal of a license requires a safety review of 

the plants. AERB conducts monthly inspections of nuclear projects under construction, quarterly 

inspections for nuclear power projects, bi-annual inspections for operating plants, and yearly 

inspections for high-hazard radiation facilities.78

The AERB has been periodically issuing and updating safety and security related documents 

such as the “Nuclear Security Requirements for Nuclear Power Plants,” the “Security of 

Radioactive Sources in Radiation Facilities,” and the “Security of Radioactive Material During 

Transport.”

The following are some of the key documents that have been prepared by the AERB on nuclear 

security related aspects:

79

– Nuclear Security Requirements for Nuclear Power Plants (NPPs)

– Guidelines for Reporting of Nuclear Security Events 

 

75 Government of India, Department of Atomic Energy, “Lok Sabha Starred Question No.404 Due on 25.8.2010 by 

Shri Abdul Rahman Regarding Radioactive Material.” Available at 

http://dae.nic.in/writereaddata/lssq404_250810.pdf

76 Ibid.

77 Ibid.

78 R. Bhattacharya, “Nuclear Regulatory Framework in India.” Available at

http://www.abdan.org.br/download/encontro/india.pdf

79 Fredric Lall, “Regulatory Inspection on Nuclear Security Aspects of Civilian Nuclear Power Plants/Projects,” 

December 2012. Available at www.nrcsecurityconference.org/slides/Dec5/India.pdf
30

– Checklist for Regulatory Inspection of Nuclear Power Plants (NPPs) 

– Checklist for Regulatory Inspection of Nuclear Power Projects 

– Procedure for Identification of Vital Areas 

– Security of Radioactive Sources in Radiation Facilities 

– Security of Radioactive Material during Transport 

– Other documents under preparation

o Security requirements for Heavy Water Plants 

o Security requirements for Nuclear Fuel Processing Facilities 

4.2.1 Concerns about Regulatory Framework

One of the major concerns regarding any nuclear regulatory framework is the lack of autonomy

of the regulator from the nuclear energy establishment. The nuclear regulator, AERB, is not an 

independent entity, as it depends on the government for funding and expertise, and reports to the 

Atomic Energy Commission, of which the Chairperson is the Secretary of the Central 

Government’s Department of Atomic Energy. The government also appoints the regulatory 

body’s head. As A. Gopalakrishnan, former head of the AERB, points out, “[S]imilarly, we have 

almost all AERB Advisory Committees stacked with vast majority of Ex-DAE personnel, who 

all jointly skew their opinion mostly in the DAE’s favour.”80

Indeed, these long-standing concerns have found a prominent place in recent reports by India’s

Comptroller and Auditor General of India (CAG) and the Parliament of India’s Public Accounts 

Committee. Both reports highlighted a number of institutional, safety, performance, and other 

related issues regarding nuclear regulation in India. Most of the concerns raised by these reports 

have direct or indirect implications for the larger issue of nuclear security. The CAG report of 

2012-13 submitted to the President of India reported the following problems with the functioning 

of the AERB:

81

- “The legal status of AERB continued to be that of an authority subordinate to the Central 

Government, with powers delegated to it by the latter.

- AERB did not have the authority for framing or revising the rules relating to nuclear and 

radiation safety.

- The maximum amounts of fines were too low to serve as deterrents against 

offences/contraventions related to nuclear and radiation facilities, which involve 

substantial risks. Further, AERB had no role in deciding the quantum of penalties and no 

powers with regard to imposition of the same.

 

80 A Gopalakrishnana, “Nuclear safety regulator: The US model,” December 13, 2011. Available at 

http://www.dnaindia.com/analysis/column-nuclear-safety-regulator-the-us-model-1624980

81 “Executive Summary,” Report No. 9, 2012-13. Available at 

http://saiindia.gov.in/english/home/Our_Products/Audit_report/Government_Wise/union_audit/recent_reports/union

_performance/2012_2013/SD/Report_9/Exe_Summ.pdf
31

- The consenting process and system for monitoring and renewal were found to be weak in 

respect to radiation facilities. This led to a substantial number of radiation facilities 

operating without valid licenses.

- On-site emergency preparedness plans were being put in place by the Plant Management 

of NPPs, and nuclear fuel cycle facilities were being tested by them. Though actual

periodic exercises prescribed (based on various types of emergencies) were conducted by 

them, AERB only reviewed the reports of these exercises and did not directly associate 

itself in these exercises, even as observers. Off-site emergency exercises carried out,

highlighted inadequate emergency preparedness. Further, AERB was not empowered to

secure compliance of the corrective measure suggested by it.

- Although AERB maintained liaisons with international nuclear organisations, it was slow 

in adopting international benchmarks and good practices in the areas of nuclear and

radiation operation. AERB had not yet availed of the opportunity of the peer review and 

appraisal services of IAEA to get its regulatory framework and its effectiveness reviewed 

by them.”

Following up on the CAG report, which was clearly critical of the nuclear governance structures 

in India, the Public Accounts Committee of the Indian Parliament (2013-2014) carried out a 

sustained inquiry into the activities of the AERB and submitted a report entitled “Activities of 

the Atomic Energy Regulatory Board” to the Parliament in November 2013. The report reaches 

conclusions that are very similar to those of the CAG report. The following are some of its 

conclusions:

82

- “The Committee observe that the failure to have an autonomous and independent 

regulator is clearly fraught with grave risks.

- Regarding the proposed Nuclear Security Regulatory Bill that is currently pending in the 

Parliament – The Committee recommends that the DAE should seriously re-examine the 

provisions of the Bill and take necessary steps urgently so as to ensure that the nuclear 

regulator becomes an independent and credible body at par with similar regulators in 

other Countries.83

- The Committee are concerned to note that AERB did not have any authority for framing 

rules relating to nuclear and radiation safety as the rule-making power under Section 30

of the AE Act, 1962 vests with the Central Government, that is, with the DAE and the 

AERB is involved in the consultative process.84

 

82 “Activities of Atomic Energy Regulatory Board” Public Accounts Committee 2013-2014, Ninetieth Report.” 

December 2013. Available at http://164.100.47.134/lsscommittee/Public%20Accounts/15_Public_Accounts_90.pdf, 

p. 47.

83 Ibid, p. 48.

84 Ibid., p. 49.
32

- The Committee note that even after nearly three decades of its existence, AERB is yet to 

formulate a nuclear and radiation safety policy for the Country in spite of a specific 

mandate in its Constitution Order of 1983.85

- The Committee are concerned to note that there is an acute shortage of Radiological 

Safety Officers, who are required to be designated for all radiation units in accordance 

with the provisions in Rule 22 of RPR, 2004 and Rule 13 of Safe Disposal of Radioactive 

Waste Rules, 1987...the Committee observe that effectiveness of safety procedures 

remains deeply compromised due to their acute shortage. The Committee are concerned 

to find that there was acute shortage of not only RSOs but also of trained manpower in 

general in AERB.86

- The Committee note with profound concern that off-site emergency exercises carried out 

highlighted inadequate emergency preparedness even for situations where the 

radiological effects of an emergency originating from NPP are likely to extend beyond 

the site and affect the people around.”

87

The Committee concluded its report with the following stinging remarks: 

In fact, the Committee's examination revealed inter-alia, diminished legal status of 

AERB which remained a mere subordinate authority lacking due autonomy of an 

empowered and independent regulator as existent in many other Countries; failure 

of AERB to develop safety policy, standards, codes and guides; weak consenting 

process and monitoring system resulting insubstantial number of radiation 

facilities units operating without valid licenses as evident by the non-registration 

of 91 per cent of medical x-ray facilities in the country which therefore, remained 

out of the ambit of the regulating control of AERB; absence of rules to prescribe 

fees for recovery of the cost of services for regulating and consenting process; 

failure to enforce safety provisions and compliance to frequency of regulatory 

inspections for both industrial radiography and radiotherapy units and shortfall of 

over 97 per cent inspection in case of diagnostic radiology facilities; absence of a 

detailed inventory of all radiation sources to ensure effective compliance of 

regulation for safe disposal of disused sources; inadequate emergency 

preparedness for nuclear and radiation facilities; absence of a legislative 

framework for decommissioning of Nuclear Power Plants; and total absence of 

peer review and appraisal service of IAEA.88

4.2.2 The Nuclear Safety Regulatory Authority (NSRA) Bill

As pointed out earlier, the Indian government is currently in the process of bringing about a new 

law to set up a more empowered nuclear regulatory authority in the country with far more 

 

85 Ibid., p. 50.

86 Ibid., p. 55.

87 Ibid., p. 56.

88 Ibid., pp. 57-8.
33

autonomy.89 But questions remain on how autonomous even the new body will be. The demand 

for making the regulatory body autonomous has been a long-standing one. In 1997, the Raja 

Ramanna Committee report had recommended that the Atomic Energy Act (1962) should be 

amended to enhance the effectiveness of the nuclear regulatory system in the country. Thereafter, 

in 2000, the government had directed the DAE to suggest the necessary amendments to the 1962 

Act. However, it was only after the Mayapuri radiation accident (New Delhi) in 2010 and the 

Fukushima disaster (Japan) of 2011 that the government became serious about taking a relook at 

the nuclear regulatory system in the country.

The above-mentioned Parliamentary standing committee also conveyed to the DAE that the 

proposed law in its current form may lack full autonomy and has recommended that “the DAE 

should seriously re-examine the provisions of the Bill and take necessary steps urgently so as to 

ensure that the nuclear regulator becomes an independent and credible body at par with similar 

regulators in other Countries.”90 Among other issues, the Bill also suffers from the fact that it is 

dependent on the government for funding and appointment of staff. Moreover, “The Council of 

Nuclear Safety to be established by the NSRA Bill — with the Prime Minister as the Chair and 

mostly government representatives as members — will be a very powerful body with the power 

to appoint the chairperson and members of the new regulatory body. This will diminish the 

powers of the regulator since it will be subordinate to the Council chaired by the Prime Minister. 

We will, as a result, end up having a government-controlled regulator all over again.” The NSRA 

Bill is explicit on the ability of the government to control the regulator: “the Central Government 

may, by notification, supersede the Authority for such period, not exceeding six months, as may 

be specified in the notification.”

91

The NSRA, at least in its current form, does not elaborate on which facilities would be put under 

the new authority – currently, the AERB can only oversee the civilian facilities. 92 If that 

continues under the new law, it is uncertain who will oversee the safety and security of the 

strategic facilities and programs. The Bill mentions that new regulatory bodies can be created to 

regulate the strategic programs (clause 25, Sub-clause (2) of the Bill). However, there has been 

no movement to do so as of now. The previous government has laid the NSRA Bill in the Indian 

Parliament to be legislated into law. However, now that the term of the 15thLok Sabha has ended, 

the Bill has lapsed. The new Lok Sabha and a new government will now have to restart the 

process all over again. After the Bill was introduced in the Parliament in 2011, the Parliamentary 

Standing Committee had given its recommendations on the Bill, some of which were 

incorporated by the DAE, but not all. Talking about the Bill, the Minister in the Prime Minister’s 

 

89 For a copy of the Bill see, 

http://www.prsindia.org/uploads/media/Nuclear%20Safety/Nuclear%20Safety%20Regulatory%20Authority%20Bill

%202011.pdf

90 “Activities of Atomic Energy Regulatory Board,” p. 48.

91 Happymon Jacob, “Regulating India’s nuclear estate,” The Hindu, August 29, 2014. Available at 

http://www.thehindu.com/opinion/lead/regulating-indias-nuclear-estate/article6360984.ece

92 A. Gopalakrishnan, “Transparency in Nuclear Safety Regulation,” February 02, 2012. Available at 

http://www.dnaindia.com/analysis/comment-transparency-in-nuclear-safety-regulation-1644896India
34

Office, Mr. Narayanaswamy had said in 2013 that "the government adopted majority of the 

recommendations given by the committee and it has now come to the Lok Sabha.”

93

This is not to argue that the NSRA Bill is not an improvement from the existing AERB. Indeed, 

there are significant differences between the two. For one, while the AERB was set up by a 

government order, the new regulator under NSRA will be established by an Act of the 

Parliament, making it more powerful. Moreover, while the AERB was bound to report to AEC 

and indirectly to the DAE, the new authority will not report to the AEC and will submit its report 

to the Parliament. However, the council of nuclear safety to be established by the Bill – chaired 

by the Prime Minister and comprised mostly of government representatives − will be a very 

powerful body, including the power to appoint the chairperson and members of the regulatory 

body. This is likely to diminish the powers of the regulator.94 Besides, “the Chairperson of the 

NSRA will be on the search committee for other members. This may affect the independence of 

other members.”95 According to the latest reports, the new government headed by Prime Minister 

Narendra Modi has already taken steps to legislate on the NSRA. 96

4.3 The Legal Framework

In India, nuclear security and nuclear safety have traditionally been considered as two sides of 

the same coin, and hence, the legislative framework and institutional architecture that were 

responsible for nuclear safety also catered to nuclear security considerations. The country’s 

legislative framework for nuclear matters flows from the 1962 Atomic Energy Act, passed by the 

Indian Parliament. As per the 1962 Act, the AEC is the sole authority in the country that deals 

with nuclear energy matters. The regulatory body, AERB, was not set up by the Atomic Energy 

Act of 1962, but by a gazette notification by the government of India in 1983. The AERB is 

responsible for both the safety and security aspects of nuclear facilities and material. Prior to the 

establishment of the AERB, self-regulation by each facility was the norm in the 1950s, and 

safety monitoring and surveillance was taken care of by the Health Physics Division and 

Directorate of Radiation Protection at the BARC in the 1960s.97 In 1972, the Safety Review 

Committee was set up in the DAE − the government department that deals with nuclear energy 

matters and reporting to the Prime Minister of the country.98

 

93 “Nuclear Safety Bill to be Taken up in Next Session: Minister,” www.zeenews.india.com, September 06, 2013. 

Available at http://zeenews.india.com/news/nation/nuclear-safety-bill-to-be-taken-up-in-next-sessionminister_874653.html

94 Happymon Jacob, “Regulating India’s Nuclear Estate,” The Hindu, August 29, 2014. 

95 “The Nuclear Safety Regulatory Authority Bill 2011: Highlights of the Bill.”. Available at 

http://www.prsindia.org/billtrack/the-nuclear-safety-regulatory-authority-bill-2011-1980/

96 Indrani Bagchi and Sanjay Dutta, “ Soon, a PM-led council for nuclear safety”, Times of India, October 18, 2014. 

Available at http://timesofindia.indiatimes.com/india/Soon-a-PM-led-council-for-nuclearsafety/articleshow/44863604.cms

97 R. Bhattacharya, “Nuclear Regulatory Framework in India,” November 2012. Available at 

http://www.abdan.org.br/download/encontro/india.pdf

98 Ibid.
35

Various rules were established under the 1962 Atomic Energy Act such as: 1) Atomic Energy 

(Working of Mines, Minerals and Handling of Prescribed Substance) Rules, 1984; 2) Atomic 

Energy (Safe Disposal of Radioactive Wastes) Rules, 1987; 3) Atomic Energy (Factories) Rules, 

1996; 4) Atomic Energy (Control of Irradiation of Food) Rules, 1996; and 5) Atomic Energy 

(Radiation Protection) Rules, 2004. The AERB is legally empowered to enforce these rules.99 In 

addition, the Manufacture, Storage and Import of Hazardous Chemical Rules (1989), under the 

Environmental Protection Act, 1986, also names “AERB as the authority to enforce directions 

and procedures as per Atomic Energy Act with respect to radioactive substances.” 100

Furthermore, India enacted The Weapons of Mass Destruction and Their Delivery Systems 

(Prohibition of Unlawful Activities) Act in 2005.

4.4 India and the Global Nuclear Security Regime

India has been an active participant in the global nuclear security regime. To start with, New 

Delhi is clearly committed to fighting terrorism in all its forms, and hence, it is party to “all the 

13 universal instruments accepted as benchmarks for a State's commitment to combat 

international terrorism,” including the International Convention for the Suppression of Acts of 

Nuclear Terrorism (ICSANT).101 India has ratified the Convention on the Physical Protection of 

Nuclear Material (CPPNM) as well as its 2005 Amendment. It has also expressed its support for 

the 5th revision of IAEA's INFCIRC/225. India adheres to the IAEA Code of Conduct on the 

Safety and Security of Radioactive Sources and the NSG guidelines on nuclear transfers.102 With 

regard to the safety review of India’s nuclear facilities, India has recently been more 

forthcoming, especially after the 2008 India-IAEA agreement. India’s civilian nuclear power 

plants were reviewed by the Operational Safety Review Team (OSART) of the IAEA and the 

World Association of Nuclear Operators (WANO). While the Indian nuclear reactors have been 

under WANO peer review for some time (NPCIL is a member of WANO), they were reviewed 

for the first time in 2012 by OSART.103 India has also now requested the Integrated Regulatory 

Review Service (IRRS), the Peer Review Mission of IAEA, to conduct a review of the nuclear 

power plants in India, which is likely to take place later this year or in early 2015.104 The IRRS 

peer review usually looks at both safety and security aspects.105 However, it is unclear whether 

 

99 Ibid.

100AERB, “The Rules.” Available at 

http://www.aerb.gov.in/AERBPortal/pages/English/Constitution/Rules_jsp.action

101 MEA, “Nuclear Security in India.” 

102 Ibid.

103“IAEA experts to begin review of nuclear plants in Rajasthan tomorrow,” The Times of India, October 29, 2012. 

Available at http://timesofindia.indiatimes.com/india/IAEA-experts-to-begin-review-of-nuclear-plants-in-Rajasthantomorrow/articleshow/17003100.cms

104 “Indian atomic energy regulator readying for IAEA review,” March 04, 2014. Available at 

http://www.dnaindia.com/india/report-indian-atomic-energy-regulator-readying-for-iaea-review-1966844

105 IAEA, “Integrated Regulatory Review Service.” Available at http://www-ns.iaea.org/reviews/rs-reviews.asp
36

the peer review will include security aspects in the Indian case. In addition, India has been 

cooperating with Interpol’s Radiological and Nuclear Terrorism Prevention Unit.106

India has clearly been steadfast in its adherence to the instruments and norms stipulated by the 

global nuclear security regime. India has not only adopted the UN Security Council Resolution 

1540 (as well as its extension Resolution 1977), but has taken measures to implement its 

recommendations. Regarding some of the other measures that makes India a part of the global 

nuclear security regime, an exhaustive report of the Ministry of External Affairs states that

“India participates in the IAEA's Illicit Trafficking Database (ITDB), which was 

established in 1995 and disseminates information on confirmed reports about illicit 

trafficking and other unauthorized activities and events involving nuclear radioactive 

materials to the States. Since 2007, India is a party to the Global Initiative to Combat 

Nuclear Terrorism and has participated in its working groups on nuclear detection, 

nuclear forensics and response and mitigation. India also cooperates with the Interpol's 

Radiological and Nuclear Terrorism Prevention Unit and the World Customs 

Organization on nuclear trafficking issues.”107

In fulfilling the promise made by India at the inaugural Nuclear Security Summit, it has 

established the ‘Global Centre for Nuclear Energy Partnership’ with a view to “help in capacity 

building, in association with the interested countries and the IAEA, involving technology, human 

resource development, education & training and giving a momentum to R&D in enlisted 

areas.”108 Established in 2010, the Centre currently has five schools, including one on Nuclear 

Security studies. India, as a “partner to the IAEA-US Regional Radiological Security Partnership 

(RRSP) has been organizing international training courses in India under the aegis of the 

IAEA.”109 India has also been hosting international conferences on nuclear security including 

one in November 2012, in collaboration with the United Nations Office of Disarmament Affairs. 

Moreover, “India has also conducted 9 regional training seminars on nuclear security in 

cooperation with the IAEA.”110 India is a participant in IAEA’s Illicit Trafficking Database 

(ITDB)111 and the Global Initiative to Combat Nuclear Terrorism (GICNT),112even though it is 

not a member of the ‘Megaports Initiative’ or the Proliferation Security Initiative (PSI). New 

Delhi has not ruled out joining the PSI and the Container Security Initiative (CSI). 

 

106 “Nuclear Security Summit National Progress Report India,”, Press Information Bureau, Government of India, 

March 27, 2012. Available at http://pib.nic.in/newsite/PrintRelease.aspx?relid=81755

107 MEA, “Nuclear Security in India.” 

108 “Global Centre for Nuclear Energy Partnership,” Government of India. Available at 

http://www.gcnep.gov.in/about/about.html

109 “National Progress Report: India,” Nuclear Security Summit, Seoul, March 26-27, 2012. Available at 

http://nuclearsecuritymatters.belfercenter.org/files/nuclearmatters/files/india_-_national_report.pdf

110 Ibid.

111 “India and the IAEA.” Embassy of India, Vienna. Available at http://www.indianembassy.at/pages.php?id=64

112 NTI, “Global Initiative to Combat Nuclear Terrorism.” Available at http://www.nti.org/treaties-andregimes/global-initiative-combat-nuclear-terrorism-gicnt/
37

India has also been attempting to adjust the country’s domestic laws to match the legal 

provisions, practices, and expectations of the international nuclear order. India passed the 

Chemical Weapons Convention Act in 2000 and subsequently amended it in 2010. The law was 

enacted “to give effect to the convention on the prohibition of the development, production, 

stockpiling and use of chemical weapons and on their destruction. India had signed the 

convention on January 14, 1993.”

113 The country enacted The Weapons of Mass Destruction and 

Their Delivery Systems (Prohibition of Unlawful Activities) Act in 2005114 “to fulfill India’s 

obligations under the United Nations Security Council Resolution 1540 of April 28, 2004.”115

Further, the Foreign Trade Development and Regulation (FTDR) Act No. 22 of 1992 (amended 

in 2010) provides the legal basis for India’s strategic trade control system. The FTDR 

“empowers the Directorate General of Foreign Trade (DGFT), situated within the Department of 

Commerce and Industry (DCI), to license the export and import of items on the Indian Tariff 

Classification (Harmonized System) or ITC (HS) list.” 116 This legal instrument was further 

strengthened with the passage of the Weapons of Mass Destruction (WMD) Act in 2005, which 

“authorizes the GOI to regulate the export, re-transfer, re-export, transit, and transshipment of 

any items related to the development, production, handling, operation, maintenance, storage, or 

dissemination of a WMD or missile delivery device. It also established a catch-all control that 

restricts exports of non-listed items destined for a WMD end-use, and it provided a rudimentary 

legal basis to regulate technology transfers.”117

4.5 The Physical Protection System (PPS)

India shares the global concerns on nuclear security and strives to follow a ‘cradle to grave’ 

principle of security for nuclear materials and associated facilities. Keeping in mind the 

allegation that India’s nuclear security and control measures are “average” and below those of 

Pakistan, the sections of this report delve into the physical security system in place in India’s 

nuclear installations. 

At the outset, the physical security system in India’s nuclear infrastructure has many dimensions: 

the nature of the nuclear programme itself – their unique closed fuel cycle, which is argued to be 

inherently secure; the technological dimension where India is known to have made many 

technological advances to respond to any such contingency if it ever arises; the human dimension 

where the country maintains an impeccable record; the facility-specific physical security systems 

 

113 “Lok Sabha passes chemical weapons, AIIMS bills,” Ndtv.com, August 30, 2012. Available at 

http://www.ndtv.com/article/india/lok-sabha-passes-chemical-weapons-aiims-bills-260977

114“The Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005,” 

MEA, Government of India. Available at http://www.mea.gov.in/Uploads/PublicationDocs/148_The-WeaponsMass-destruction-And-Delivery-Systems-Act-2005.pdf

115 R. Ramachandran, “A Bill and nuclear hopes,” Frontline, Vol. 22, Issue 12, Jun 04-17, 2005. Available at 

http://www.frontline.in/navigation/?type=static&page=flonnet&rdurl=fl2212/stories/20050617003102900.htm

116 “India’s Export Controls: Current Status and Possible Changes on the Horizon,” SECURUS Strategic Trade 

Solutions, 2011. Available at http://securustrade.com/Indias_Export_Controls_Article_July_2011_FINAL.pdf

117 Ibid.
38

that it has developed in and around its nuclear installations, India’s experience in managing 

terrorism given the regional security environment; and most importantly, the safe-keeping of its 

nuclear arsenals. 

The nuclear security architecture of India’s nuclear infrastructure is based mainly on five pillars:

1) National legal provisions in consonance with IAEA guidelines; 

2) Oversight agency (AERB) that stipulates the SOPs;

3) The security (and intelligence) agencies in charge of threat assessment and physical 

protection;

4) The human element (personnel) with the responsibility of oversight or observance; and

5) Surveillance and detection technology for detection, delay, and response approach.

As an oversight agency, the AERB has prescribed the technical basis to establish security levels 

– a graded approach of security118– for ensuring the safety of radioactive materials during all 

stages of their handling in its guidelines on “Security of Radioactive Sources in Radiation 

Facilities.”

119 In India’s case, safety and security aspects of radioactive/nuclear materials are 

intimately linked and many of the measures designed to address safety would also address 

security. Normally the physical protection system around Indian nuclear facilities is designed on 

the basis of their nuclear threat assessment,

120 taking into account the Design Basis Threat 

(DBT) and Beyond DBT (BDBT) to create a layered protective envelope – consisting of inbuilt 

reactor security, perimeter security, personnel reliability, material protection and accounting, 

transportation security, air and water front defense, emergency preparedness, legal provisions, 

and in extreme situations, military protection. 

 

118 The Graded Approach to Security is based on the vulnerability analysis for a specific source, facility, or activity 

such as transportation. Assessment is made of the level of risk involved. Depending on the degree or level of risk 

involved the security measures required to protect the source is determined. The higher the risk, the more capable 

security systems are required. Based on the security threat associated with radioactive sources, four security levels -

A, B, C and D have been defined. It must be emphasized that these security levels do not themselves lay down the 

security guidelines or measures.

119AERB, “Security of Radioactive Sources in Radiation Facilities,” Safety Guide No. AERB/RF-RS/SG-1. 

Available at http://www.aerb.gov.in/AERBPortal/pages/English/t/publications/CODESGUIDES/SG-RF-RS-01.pdf

120 Design basis threat assessment is normally done by government agencies such as Ministry of Home, Intelligence 

Bureau, Ministry of External Affairs, Law Enforcement Agencies, Cost Guards and Customs, Regulatory 

Authorities and other agencies with security related responsibilities.
39

Figure 5: The Security Envelope

Source: Sitakanta Mishra, “Contours of India’s Nuclear Safety,” Air Power, Apr-June 2011 (Adapted and updated).

4.5.1 Inbuilt Security

Indian nuclear plants are characterised by a high level of built-in safety-security features, which 

make them relatively less vulnerable to sabotage.121 According to Rajesh Basrur and Friedrich 

Steinhäusler,“[T]he large-volume, low-pressure, low-temperature moderator surrounding the 

pressure tubes keeps the risk of a fuel meltdown low. The steam generators are positioned well 

above the core, which promotes natural thermosyphoning (heat movement) in case shutdown 

cooling is lost. In addition, the CANDU plants are enclosed by heavy concrete walls, including a 

reactor vault of a minimum four feet thickness surrounding the nuclear core itself.”

122 Reactors 

like the Kaiga-1 and 2, Rajasthan-3 and 4, and Tarapur-3 and 4 are housed in double containment 

domes. The domes are made of “the microsilica-based high performance concrete;” they also

 

121 Rajesh M. Basrur and Friedrich Steinhäusler, “Nuclear and Radiological Terrorism Threats for India: Risk 

Potential and Countermeasures.” Available at http://jps.anl.gov/vol1_iss1/3-Threats_for_India.pdf, p.7.

122 Ibid.
40

have other added safety features like the automatic, “quick acting poison injection system to shut 

down the reactor in an emergency”.

123

The primary inner containment of the reactor is “designed to withstand the ‘design basis’

accidents” like postulated loss of coolant leading to reactor blackout; the secondary containment 

envelops the inner containment, and “the annulus between the two containment walls is 

maintained under vacuum, with a provision of continuous monitoring for any accidental release 

of radioactivity”.

124 For avoiding the accidents due to external missile such as aircraft impact, 

adequate care is taken to exclude this event with proper siting criteria and selecting a safe screen 

distance value (SDV). During site selection, if the site falls within SDV for different types of 

airfields, a “probabilistic study of aircraft crashing” on the installation (considering flight 

frequencies) are carried out. If this probability is not acceptably low, the site is considered 

unsuitable for establishing NPP.125 According to a study conducted by Mukesh Kukreja, et. al. of

the Reactor Safety Division, BARC, “on the damage evaluation of the 500 MWe PHWR’s 

containment for aircraft impact, concludes that such an event would cause only local 

deformation; the double containment is capable of absorbing the full impulsive load.”

126

India’s unique three-stage nuclear programme (based on the ‘closed fuel cycle’) is said to 

promote the security of nuclear materials. The ‘reprocess to reuse’ approach “avoids both the 

build-up of stockpiles, as well as the need to store large amounts of spent fuel in underground 

repositories that could turn into easy to access plutonium mines for malefactors in the future.”

127

In order to eliminate chances of terrorists’ access to high-level nuclear waste, India follows the 

vitrification method for nuclear waste management. In addition, India is also working on design 

and deployment of proliferation resistant reactor designs such as the Advanced Heavy Water 

Reactors (AHWRs), based on thorium and Low Enriched Uranium (LEU), which is associated 

with the high-energy gamma-emitter U-232, that makes access and use by unauthorised non-state 

actors difficult. Responding to the global concern for security of HEU in research reactors, “the 

enriched uranium based fuel in the APSARA nascent reactor has been placed in a “safeguarded 

facility.” At present no research reactor in India is operating with HEU.

 

123 Department of Atomic Energy, Nuclear India, Vol. 34, No.1-2, July-Aug 2000. Available at 

http://dae.nic.in/?q=node/171

124 Mukesh Kukreja, et al., “Damage Evaluation of 500 MWe Indian Pressurized Heavy Water Reactor Nuclear 

Containment for Air Craft Impact,” Proceedings of the 17th International Conference on Structural Mechanics in 

Reactor Technology (SMiRT 17) Prague, Czech Republic, August 17–22, 2003, p. 1; also see, B.N. Rao et al, 

“Reliability analysis of 500 MWe PHWR Inner Containment Using High-Dimensional Model Representation”, 

International Journal of Pressure Vessels and Piping, vol. 87, 2010, pp. 230-238.

125 Roshan A.D., Shylamoni P., and Sourav Acharya, Monograph on Siting of Nuclear Power Plants, AERB, Civil 

& Structural Engineering Division. Available at http://www.aerb.gov.in/t/sj/Siting.pdf, p. 13.

126

 Kukreja, “Damage Evaluation of 500 MWe Indian Pressurized Heavy Reactor Nuclear Containment for Air 

Craft Impact.” 

127 MEA, “Nuclear Security in India.”
41

4.5.2 Perimeter Security

Each nuclear facility is designed with three concentric circles of security zones, known as the 

perimeter security system (Fig. 6). Though this is designed more for efficient emergency 

response and relief operations, it simultaneously enhances plant security. The inner most circle 

(O-A) is the plant station area. The second circle (O-B) is the Exclusion Zone from the inner 

fence of the plant area and is directly under the control of the plant administration, with two rings 

of security deployed with sophisticated surveillance systems and allowing no public habitation.

The Sterilized Zone (B-C) is where the growth of population is limited by administrative control. 

The outermost circle is the Emergency Planning Zone, where constant monitoring is undertaken 

for security and emergency planning purposes. (The expanse of these zones varies from facility 

to facility.) Close surveillance is conducted over transportation networks, means of 

communication, etc.

Figure 6: Perimeter Security Zoning System

Source: http://www.aerb.gov.in/AERBPortal/pages/English/t/publications/CODESGUIDES/SG-O-06.PDF, p. 29.

4.5.3 Physical Protection

The AERB, as the regulator responsible for safety as well as security, prescribes safety-security 

guidelines to be followed by Indian plants in accordance with IAEA guidelines. An Advisory 

Group of Experts help in reviewing the implementation of these guidelines. It has also been 

recently entrusted with the responsibility to ensure that a licensee takes adequate measures 

towards security.128

 

128 SS Bajaj, “Regulatory Practices for Nuclear Power Plants in India” Sadhan, Vol. 38, Part 5, October 2013. 

Available at http://www.ias.ac.in/sadhana/Pdf2013Oct/13.pdf, pp. 1044-45.
42

As far as physical protection is concerned, all nuclear facilities in India are secured by a physical 

protection system (PPS) aiming to restrict easy access to sensitive areas. Every facility is 

surrounded by two fences – inner and outer – having a double-layer security structure. In order to 

prevent inadvertent or unauthorised access to radioactive sources or the facility, many technical 

measures are used. These are comprised of state-of-the-art hardware, security devices, and 

electronic security systems such as fences, walls, rooms/vaults, cages, transport packaging, locks 

and interlocks for doors with alarm systems, intrusion-resistant source-holding devices, 

surveillance cameras, etc.

129 For more sensitive parts of the facility, “a variety of surveillance, 

detection, delay, response and access control measures are in place in a graded manner over four 

layers.”130 Normally, access control is maintained over personnel by verifying identity cards. 

BARC has invented a ‘Phonetic Number System’ with many novel mathematical features, 

permitting unique identification of people with only six digits, called the Phonetic Code.131 This 

System of Phonetic Identification was accepted by the Ministry of Home Affairs, Government of 

India, in 1986, to check infiltration across the border into India from Pakistan. The ‘Need to 

Know’ principle was adopted for information security relating to source location, specific 

security plans and measures, source utilization plans, date and time of source transfer, etc. The 

Global Centre for Nuclear Energy Partnership (GCNEP) and BARC provide a training course for 

concerned authorities regarding requirements, design, and evaluation of PPS.132

The Central Industrial Security Force (CISF), a paramilitary force, is in charge of providing 

security to nuclear facilities in the country. Each nuclear facility is guided by a CISF team 

headed by a Commandant. At many sites, the CISF team is supplemented by a Special Task 

Force. A Departmental Committee headed by an Inspector General of Police (IGP) at the 

Secretariat oversees the physical security at the sites. The CISF has developed the necessary 

ability to deploy specially-trained First Responders in case of a nuclear emergency. Four 

companies of the CISF with specialised training are deployed in four locations across the 

country: the Ghaziabad unit caters to Delhi and other northern areas; the Ranchi unit for the 

eastern areas; Kota unit for the western; and Chennai unit for the southern part.

However, the CISF is not in charge of all nuclear related installations in the country. For 

example, the Heavy Water Plant in Baroda is guarded by departmental security personnel with 

armed police support under the command of Deputy Commissioner of Police, Special Branch, 

Baroda City. The Heavy Water Plant in Hazira is co-located with the Krishak Bharati 

Cooperative Ltd. (KRIBHCO) fertilizer plant and its security is taken care of by KRIBHCO 

security personnel, in addition to armed police personnel from the State Police. And, the Institute 

 

129 AERB, “Security of Radioactive Sources in Radiation Facilities,” AERB Safety Guide, AERB/RF-RS/SG-1. 

Available at http://www.aerb.gov.in/AERBPortal/pages/English/t/publications/CODESGUIDES/SG-RF-RS-01.pdf

130 MEA, “Nuclear Security in India.” 

131 D.N. Srivastava, “Hi-Tech Computerized Security Management,” Vol. 34, No.3-4, Sep-Oct 2000, Department of 

Atomic Energy, Government of India. Available at http://dae.nic.in/?q=node/172

132 “National Training Course on Physical Protection of Nuclear Material and Nuclear Facilities,” 18 to 22 February, 

2013 Mumbai, Available at http://www.gcnep.gov.in/programs/details/NTC-PPofNMNF-Report.pdf
43

of Plasma Research (IPR) at Gandhi Nagar employs private security personnel.

133 Due to the 

dispersed and individualized approach to handling security at various nuclear facilities, it would 

be prudent, therefore, to suggest a unified or centralised security arrangement in all nuclear 

related installations for better coordination and security planning and implementation. 

Besides this, DAE installations and its residential colonies continue to remain potential targets of 

outfits and elements inimical to the interests of India. Anonymous letters threatening bomb blasts

at KKNPP and kidnapping of senior officials have been received many times.134 Reportedly, the 

26/11 Mumbai terror attacks planner, David Coleman Headley, surveyed the BARC complex for 

a possible terror strike.135 At least 25 intrusions have been reported in two years and this is the

result of “a lack of unified command and control, as security is handled by both AEC and 

CISF.”136

Moreover, the National Disaster Relief Force (NDRF) is trained to deal with nuclear disasters, if 

not security. Recent newspaper reports indicate, however, that the agency is not yet fully ready to 

deal with nuclear disasters. A recent Indian Express story had this to say:

In theory, there’s back-up in place already. A nuclear emergency should set off 

what’s called a level 3 response – involving the country’s defence, paramilitary, 

police, and government agencies all the way from the Centre to the taluka. The 

National Disaster Management Agency had prepared a structured document, 

providing precise directions on rescue, decontamination, and evacuation, to be 

administered in real-time by control rooms at the Ministry of Home Affairs in 

New Delhi and in the states. The reality is that Maharashtra doesn’t have a set of 

operating procedures in place, which would govern all organisations in a crisis.137

The SOPs of three agencies the Indian Express accessed showed overlaps, while the one at the 

state level had not been updated since 2005. 

4.5.4 Personnel Reliability

India’s nuclear establishment follows a personnel reliability program designed with several lines 

of inquiry. Generally, a background check of the employee is conducted to verify his identity, 

credit history, criminal history, reputation, and character. A series of psychological and medical 

screenings are used to evaluate the mental health and stability of the individual, taking into 

consideration aspects such as depression, schizophrenia, epilepsy, high/low blood pressure, and 

 

133 Rajya Sabha, Unstarred Question No. 2175, “Security at Units of Atomic Energy,” answered on December 13, 

2012. Available at http://dae.nic.in/writereaddata/rsus2175.pdf

134 Lok Sabha Unstarred Question No. 2626, “Security Threat to Kudankulam Power Plan,” March 13, 2013. 

Available at http://www.dae.nic.in/writereaddata/parl/bud2013/lsus2626.pdf

135 Shoaib Ahmed, “Mumbai: BARC Security Breached 25 Times in Two Years,” IBN Live, March 28, 2012.

136 Ibid.

137 Smita Nair, “Nuclear disaster: Control rooms with no bosses, hotline turned cold,” Indian Express, October 21, 

2014. Available at http://indianexpress.com/article/india/india-others/nuclear-disaster-control-rooms-with-nobosses-htline-turned-cold/99/
44

other disorders. To motivate and ensure a fair working environment, the employees “are 

provided with excellent living conditions and career opportunities. The Scientific and Technical 

promotions in the Department are governed by the Merit Promotion Scheme and are not vacancy 

based. Compulsory health care facilities are provided covering all disciplines including mental 

help, social welfare services counseling and psychiatry. This covers both employees and their 

families. Cultural and recreational activities are also conducted regularly.”138

Additionally, a detailed interview to verify background information and elucidate other potential 

concerns is conducted at the time of employment, or when any sensitive task is being assigned. 

With an appropriate Human Resource Development (HRD) program,

139 periodic reviews of job 

performance, co-worker interaction, after work activities, etc., are monitored. The AERB has 

developed a “formal code of professional ethical values” for all employees to adhere to.140 In 

order to ensure all activities in nuclear and radiation facilities in India are conducted in 

compliance with the Atomic energy Act of 1962, the officials shall be guided by the principle to:

(1) to maintain a high level of professional competence; (2) maintain high level of honesty and 

integrity, and be principled and consistent in application of regulations. All employees of the 

AERB have to accept a “statement of responsibility” to uphold the highest standards of 

professional conduct in the performance of professional duties.141

Similarly, the NPCIL, which operates the nuclear power plants in the country, has mandated a 

“Code of Ethics & Conduct” requiring “commitment for ethical professional conduct from every 

director and senior employee.”

142 The code, formulated in the form of statements of personal 

commitment, bestows responsibilities on concerned personnel for the design, construction,

operation, and maintenance of nuclear power projects. Also, the code asks to maintain 

confidentiality of information, strive to achieve the highest quality, mutual trust, and 

transparency and, avoid conflict of personal interest with the interest of the company at large. 

The other public sector undertaking, Bharatiya Nabhikiya Vidyut Nigam Ltd. (BHAVINI), has 

its own code of business conduct and ethics for board members and senior management.143 More 

importantly, it has framed a Fraud Prevention Policy “to provide a system for 

prevention/detection/reporting of any fraud that is detected or suspected and fair dealing of 

matters on the subject.”144

The NPCIL has also instituted a Vigilance Directorate with the objective “to eliminate or 

minimize factors which provide opportunity for corruption or malpractices through in-depth 

 

138 Lok Sabha, Question No. 6416, “Suicide Among Scientists,” May 05, 2010. Available at 

http://dae.nic.in/writereaddata/lsus050510.pdf.

139 NPCIL, “21st Annual Report 2007-08.” Available at http://www.npcil.nic.in/pdf/annual_report07_08.pdf, p. 07.

140 AERB, “Code of Ethics.” Available at http://www.aerb.gov.in/t/publications/ethics.pdf

141 Ibid, p. 5.

142 NPCIL, “Code of Ethics and Conduct.” Available at http://www.npcil.nic.in/main/CodeofEthics.aspx

143 BHAVINI, “Code of Business Conduct and Ethics for Board Members and Senior Management.” Available at 

http://www.bhavini.nic.in/attachments/Code%20of%20Business%20Conduct%20&%20Ethics.PDF

144 BHAVINI, “Risk Management – Fraud Prevention Policy.” Available at 

http://www.bhavini.nic.in/attachments/Risk%20management%20and%20Fraud%20Prevention%20Policy.pdf
45

examination ... regular inspection and surprise visits,” ensuring prompt observance of proper 

conduct and ethics relating to integrity.

145 According to the corporation, it maintains surveillance 

on employees who have access to sensitive parts of the plants and performs regular and surprise 

inspections to detect possible misconduct.146

However, occasional incidents of malpractice in different departments of the establishment are 

reported. In November 2009, some employees of a maintenance unit of the Kaiga plant were 

treated “for increased level of tritium after they drank water from a cooler in the operating 

area”.

147 In a clarification then, India's Minister for Science and Technology, Prithviraj Chavan, 

said an insider at the plant is suspected of spiking the cooler with “heavy water.”

148 In addition, 

questions have been raised in the Parliament regarding suicides and mysterious deaths of 

personnel.

149 Sekhar Basu, Director of BARC, argues that “The number of deaths due to suicide 

is less than 100 (69 to be precise) over a period of 20 years and over 60,000 employees work at 

DAE.150 The official view is that the reasons for suicides are general; none of these unnatural 

deaths are connected to radiation exposure, working conditions, or official activities. Rather, 

safety and security measures to prevent casualties are in place at all nuclear power plants, and 

employees are provided with “excellent living conditions and career opportunities;” compulsory 

health care facilities are provided including social welfare services, mental help, counseling,

psychiatry, etc.

151

4.5.5 Material Protection Control & Accounting

India has devised a comprehensive material protection control and accounting programme 

comprised of three basic elements: (1) the legislative and regulatory framework; (2) an integrated 

physical protection programme for facilities and materials; and (3) a comprehensive “Nuclear 

Material Accounting and Control System” (NUMAC).152 While all facilities are covered by a 

multi-layered security system, facility-specific NUMAC arrangements are in place under an 

 

145 “Vigilance,” Nuclear Power Corporation Of India Limited. Available at 

http://www.npcil.nic.in/main/Vigilance.aspx

146 “Director’s Report,” Annual Report 2004-2005, Nuclear Power Corporation of India Ltd, p. 17.

147 “Union Minister Confirms Nuclear Sabotage”, The Times of India, November 29, 2009.

148 “Water Cooler at Indian Nuclear Plant Contaminated,” Voice of America, November 29, 2009. Available at 

http://www.voanews.com/english/news/Water-Cooler-at-Indian-Nuclear-Plant-Contaminated-78087742.html

149 Lok Sabha Unstarred Question No. 3362, “Deaths of Scientists in BARC,” 12 February 2014. Available at 

http://dae.nic.in/writereaddata/parl/budget2014/lsus3362.pdf; Lok Sabha Unstarred Question No. 324, 23 February 

2011, Available at http://dae.nic.in/writereaddata/324_lsus230211.pdf.

150 Pradipti Jayaram, “Counting Suicides in India’s Nuclear Family,” 

http://www.thehindubusinessonline.com/features/counting-suicides-in-indias-nuclear-family/article6497513.ece, 

October 13, 2014.

151 Lok Sabha Unstarred Question No. 6416, “Suicide Among Scientists,” May 05, 2010. Available at 

http://dae.nic.in/writereaddata/lsus050510.pdf.

152 Based on K. Raghuraman, from DAE, presentation in an international workshop on “Protection, Control, and 

Accounting of Nuclear Materials: International Challenges and National Programs” at the National Academy of 

Sciences, Washington, DC. Christopher Eldridge, “Domestic MPC&A Program,” in Protection Control and 

Accounting of Nuclear Materials, National Academy of Sciences, Washington, DC. Available at 

http://books.nap.edu/openbook.php?record_id=11343&page=39, pp. 39-40.
46

Officer in Charge to oversee each facility. The Inventory Information and Control and Data 

Management Section and a control laboratory compile and preserve the information. The 

activities of all NUMAC facilities are coordinated through a central NUMAC group at the DAE. 

At the top, the Senior Coordination Committee reviews NUMAC reports to initiate actions, if 

needed. The responsibility of NUMAC is to identify nuclear material by type, nature, and 

amount; to implement accounting and control mechanisms; to ensure measurement capabilities 

and statistical analysis of reported data as efficient; to oversee auditing practices and implement 

inspection and verification practices; and to ensure the compliance of constructive 

measurements, periodic inspection, verification and auditing, and documentation of inventory 

changes and discrepancies thereof.153

A Nuclear Control & Planning Wing (NC&PW) was created in the DAE in 2013 to take “the 

lead on international cooperation on nuclear security” by integrating DAE’s safeguards, export 

controls, and nuclear security related activities.154

4.5.6 Transportation Security

The AERB has stipulated a Safety Guide on security of radioactive material during transport 

(AERB/NRF-TS/SG-10) that prescribes the requirements for ensuring safety in the movement of 

radioactive material through public domain. 155 This guide specifies rules, regulations, and 

standard procedures to be followed in packaging and shipment, and protective measures to be 

arranged during the process of transportation. Security levels are specified for different materials 

(Category I to 5), depending upon their degree of fissile characteristics and danger involved. This 

includes, amongst others, prior approval for the shipment, special vehicle, security locks, 

appropriate training of personnel involved, additional security and escort by armed guards, 

secure communication support, an on-line tracking system, etc.156

4.5.7 Air and Water Front Defense

Within a month after the 9/11 terror attacks in the US, New Delhi promulgated no-fly zone 

restrictions around nuclear power plants. Reportedly, the flights over BARC were also banned 

because there were fears that planes flown by countries hostile towards India could perhaps crash 

into the reactors in suicide missions.157 Requisition for additional anti-aircraft guns was made for 

deployment to the Narora Atomic Power Plant in Rajasthan and for two atomic power plants in 

 

153 Ibid, p. 40.

154 “National Progress Report 2014: India.” Available at 

https://www.nss2014.com/sites/default/files/documents/india.pdf

155 “Security of Radioactive Material During Transport,” AERB Safety Guide No. AERB/NRF-TS/SG-10, AERB, 

January 2008. Available at http://www.aerb.gov.in/T/PUBLICATIONS/CODESGUIDES/sg-10.pdf

156 Ibid, pp. 13-16.

157 Srinivas Laxman, ChinmayiShalya, “Ban Flight of Civilian Planes over BARC: Experts,” The Times of India, 

December 04, 2008.
47

southern India.158 However, no information is available on whether these facilities are adequately 

protected by anti-aircraft defenses.

Taking no chances with its security following the Mumbai terror attacks (November 26, 2011),

security arrangements around India’s key nuclear installations are given a second thought. As a 

step in this direction, the Director General of Civil Aviation (DGCA) has “declared a no-fly zone 

around the Kalpakkam nuclear plant” in Tamil Nadu,

159 BARC and Tarapur Atomic Power 

Station in Mumbai.160

In an April 27, 2011 meeting chaired by the then CISF Director-General N.R. Das and attended 

by top officials of 14 atomic energy plants, the DAE and CISF reviewed the security 

arrangements of major nuclear power plants, considering constant threat to India’s sensitive 

installations.161 In the meeting it was decided to strengthen the water front security of all nuclear 

installations and fortify these areas with the help of additional security personnel and deployment 

of security devices. To meet the threat that may arise from the waterfront, the Indian Coast 

Guard deploys additional boats off the coast of Bombay to guard BARC.

4.5.8 Security of Radiological Materials

Arguably, physical protection at the sites where radiological sources, materials, devices, and 

instruments are used (e.g., hospitals, research facilities, oil and gas exploration industry, road 

construction industry, and steel manufacture) “is rather lax, at best comparable to the protection 

provided at a jeweler shop (i.e., not a real logistical problem for a trained team of 

adversaries.)”

162 Even in a highly industrialized country like the US, with “cradle-to-grave” 

supervision of radioactive material, on average based on 1999 estimates, every year control is 

lost over about 200 such sources.163 It can be assumed that the situation is, at best, similar, or 

even worse, in India.

In April 2010, the Cobalt-60 used in the irradiator of the Chemistry Department of Delhi 

University landed in New Delhi’s Mayapuri scrap market, resulting in a radiation leak and death 

of one person.164 The scrap market was not equipped with radiation detection devices and the

scrap workers had no radiation-related awareness. Even the authorities in charge of the 

 

158 "Indian Atomic Energy Body Wants ‘No Fly Zones’ Over Nuke Facilities," Deutsche Presse-Agentur, February 

5, 2002, in Lexis-Nexis Academic Universe, February 13, 2005. Available at http://www.lexis-nexis.com

159 “India Declares Kalpakkam Nuclear Plant No-Fly Zone,” December 17, 2008. Available at 

http://www.brahmand.com/news/India-declares-Kalpakkam-nuclear-plant-no-fly-zone/821/1/12.html Vinay Kumar, 

“Kalpakkam Nuclear Plant No-Fly Zone,” The Hindu, December 17, 2008.

160 Srinivas Laxman and Chinmayi Shalya, “Ban Flight of Civilian Planes over BARC: Experts”, The Times of 

India, December 04, 2008.

161 “DAE, CISF Review Security of Nuclear Power Plants,”, The Times of India, April 30, 2011.

162 Basrur and Steinhausler, “Nuclear and Radiological Terrorism Threats for India: Risk Potential and 

Countermeasures,” p.5.

163 Greta J. Dicus, “USA Perspectives - Safety and Security of Radioactive Sources,”

IAEA Bulletin, Vol. 41, No. 3, 1999, pp. 22-27.

164 “Biggest radiation crisis in 4 years may shut DU labs,” Hindustan Times, April 30, 2010.
48

laboratory were unaware of the radiological material inside the unused irradiator. The AERB had 

no inventory of radioactive materials sourced from abroad prior to its own existence. Before the 

AERB was set up in 1983, the Directorate of Radiation Protection (DRP) was responsible for the 

radiation protection program, including radiation surveillance in hospitals, industries, and 

research institutes. It suggests that the coordination between the DRP and AERB was absent 

after the former was established. 165 Another such incident of a lackadaisical act was the 

misplacement of a power source containing Pu-238, an alpha emitter in sealed conditions 

installed at Nanda Devi (Indian side of Himalayas), which could not be traced in spite of several 

attempts. 166 So, several gaps seem to exist at each level, starting from the suppliers’ 

responsibility to the users’ obligation, from monitoring of movement of materials to waste 

disposal, and finally, lack of public awareness. 

Smuggling of radioactive materials in and around India is often reported. According to a report 

in 2001, uranium smuggled from Jaduguda mines was confiscated from smugglers in Balurghat

in northern West Bengal, which was “planned to be smuggled across the Bangladeshi border”.

167

Five people were arrested in Meghalaya for allegedly trying to smuggle uranium on September 

10, 2008.168 More threatening instances have been reported:

 “Uranium 235 weapons-grade material recovered from criminals in Tamil Nadu in 1998;

 The theft of more than 8 kg of natural uranium from the Indira Gandhi Centre for Atomic 

Research (IGCAR) in Chennai (later seized by the Central Bureau of Investigation in 

1999);

 The recovery of 26 kg of uranium from illicit traffickers in Hyderabad in 2000; a gamma 

radiography camera containing Iridium 192 stolen during transportation” in Assam in 

July 2002;169

 An industrial ionising radiation-gauging device containing about 9.25 GBq Cs-137 

source, used in a coal washery, “was found to be missing from the premises on 

November 16, 2006”;

170

 Seizure of around 4 kg of low-quality uranium after the Bihar police arrested a group of 

smugglers from the Nepal border in 2008;171 and 

 

165 Sitakanta Mishra, “Radiation Safety: How Prepared Are We?,” National Defence & Aerospace Power, Centre 

for Air Power Studies, New Delhi, No. 25/10, May 15, 2010.

166 Lok Sabha Unstarred Question No: 2194, “Missing of Nuclear Device,” March 10, 2010. Available at 

http://dae.nic.in/writereaddata/lsus100310.pdf.

167 Andrew Prosser, “Nuclear Trafficking Routes: Dangerous Trends in South Asia,” Centre for Defence 

Information, November 24, 2004. Available at http://www.cdi.org/PDFs/TraffickingSmuggling.pdf, p. 9.

168 “Five arrested for alleged ‘uranium’ smuggling, say police,” September 11, 2008. Available at 

http://www.spacewar.com/reports/Five_arrested_for_alleged_uranium_smuggling_say_police_999.html

169 Rajeswari Pillai Rajagopalan, et al., “Chemical, Biological and Radiological Materials: An Analysis of Security 

Risks and Terrorist Threats to India,” 2012. Available at 

http://www.observerindia.com/cms/export/orfonline/documents/ORF-RUSI.pdf; Jennifer Cole, “An Explosion of 

Demand”, CBRNe WORLD, August 2012,

170 “Safety Surveillance of Radiation Facilities.” Available at

http://www.aerb.gov.in/AERBPortal/pages/English/t/annrpt/2006/chapter3.pdf, p. 29.
49

 15 disused Cobalt-60 isotopes stolen from the SAIL Durgapur plant in January 2011.172

Though the authenticity of these reports can be questioned, chances of such incidents are hardly 

surprising given the location of South Asia, situated between two well-established drug 

trafficking routes – the Golden Crescent and Golden Triangle. These incidents indicate that 

“while elaborate security structures have been put in place to prevent radioactive material falling 

into the hands of malicious actors, thus far it has not proved to be completely foolproof.”173

Increasing incidents of smuggling uranium ore in the Nepal-Bihar-Jharkhand-West Bengal 

conduit have been reported that raise the issue of security of uranium mining. The information 

regarding the security arrangement in uranium mines and mining activities is not publicly 

available. Moreover, smuggling of monazite sands (a beach sand mineral containing thorium) 

from the beaches in the states of Tamil Nadu, Kerala, and Orissa are reported. Even though DAE 

has not given license to any private entity except the state-run Indian Rare Earth Ltd. (IREL) to

produce, process, and export monazite, a mining cartel led by a Tirunelveli firm has allegedly 

mined and quietly exported the material.

174 Another report reveals that around 2.1 million tonnes 

of monazite, equivalent to 195,300 tonnes of thorium at 9.3 per cent recovery, has disappeared 

from the shores of India.175 In an answer to the question on mining of monazite in the Lok Sabha, 

the Minister of State for Personnel, Public Grievances & Pensions and Prime Minister’s Office,

Shri V. Narayansamy replied that minerals like ilmenite, rutile, leucoxene, garnet, sillimanite,

and zircon are free of monazite and delisted from the prescribed substances list (DAE 

notification vide ref. S.O.61(E) dated January 20, 2006), hence for the handling of these minerals 

licensed from DAE under the Atomic Energy (Working of the Mines, Minerals and Handling of 

Prescribed Substance) Act (AEC), 1984 is not required. Therefore, private companies are 

allowed to separate and export these materials from beach sands. However, license under the 

AEC is still required for the handling / export of monazite and Thorium, which are prescribed 

substances. This Department has not given any licenses for the export of beach sand as such.176

Conscious of the threat, Indian authorities have made attempts to address the existing loopholes 

through a number of policies and technological solutions. To ensure Mayapuri-type incidents are 

not repeated, the University Grant Commission (UGC), the national body that manages higher

education in India, has issued comprehensive guidelines on the usage of radioactive material by 

 

171 India Police Seize 8 lbs of Uranium from Smugglers” February 19, 2008. Available at 

http://www.reuters.com/article/worldNews/idUSB65928720080219?feedType=RSS&feedName=worldNews.

172 “15 Disused Cobalt-60 Isotopes Stolen from SAIL in Jan”, The Economic Times, March 14, 2011.

173 Rajagopalan, “Chemical, Biological and Radiological Materials: An Analysis of Security Risks and Terrorist 

Threats to India,” p. 15.

174 “How India Lost Thorium as Govt Bungled.” Available at http://freepressjournal.in/how-india-lost-thorium-asgovt-bungled/ October 05, 2012.

175 Bikram Lamba, “The Great Thorium Robbery,” Cnn.com, September 09, 2012. Available at 

http://ireport.cnn.com/docs/DOC-839177.

176 Lok Sabha Question No 1531, “Mining of Monazite,” Suresh Kodikunnil, November 30, 2011.
50

universities and colleges across the country 177 Also, BARC has prepared a comprehensive 

inventory of all the radioactive materials imported, used, and disposed in the country.

India’s ministry of shipping has ordered the installation of Radiation Monitor Portals in all major 

ports in the country.178 Monitoring devices have been installed in the major seaports of the 

Jawaharlal Nehru Port Trust (JNPT, Navi Mumbai), Mumbai Port, Kandla, Goa, New 

Mangalore, Cochin, Tuticorin, Ennore, Chennai, Visakhapatnam, Paradip, and Kolkata. At 

present, only the JNPT is Container Security Initiative (CSI) compliant and equipped with 

“automated container screening and information exchange” provisions to intercept the movement 

of radioactive materials.

179 This study is of the view that India should consider equipping its 

other major seaports with technology similar to CSI arrangements.

Mobile Radiation Detection Systems (MRDS), as part of the preparedness to handle radiological 

emergencies, have been initiated in major Indian cities. In 2011, the Union Home Ministry 

sanctioned setting up nearly 1,000 MRDS in 50 Indian cities for detecting radiation.180

Indian scientists have indigenously developed two types of radiation detection systems using 

plastic scintillators – a portal monitor for pedestrians and a camouflaged Limb/Pole monitor.181

These have been calibrated and installed at a few facilities to detect orphan sources and 

unauthorized movement or illicit trafficking of radioactive materials. At the major transit points,

border crossings, and airports, radiation monitoring devices have been installed to monitor the 

unauthorized movement of radioactive materials.182 Devices have been positioned in 14 major 

airports, including Delhi, Mumbai, Chennai, Kolkata, and Amritsar. In a phased manner, the 

remaining airports will be covered. Similarly, in the first phase, devices have been installed at 13 

integrated border check-posts including the check posts at Wagah-Attari and on either side of the 

India-Nepal border. The police and border security forces have been given the necessary training 

to identify and take action if such an event is noticed. In 2004, India’s Border Security Force 

(BSF) formed a battalion with special skills in countering nuclear, biological, and chemical 

threats. With the aim to tackle danger arising out of the possibility of terrorists using WMDs, 

“the DRDO has developed a mobile truck mounted laboratory to screen troops in the field from 

the after effects of radiation and initiate remedial measures. The chamber, termed as Mobile 

 

177 University Grants Commission, “UGC Guidelines for Universities, Research Institutes and Colleges for 

Procurement, Storage, Usage and Disposal of Radioactive and other Hazardous Material/ Chemicals,” January 2011. 

Available at http://www.ugc.ac.in/oldpdf/xiplanpdf/disposalofradioactiv.pdf

178 “India to Install Radiation Monitors for Steel Scrap Import at All Major Port,” December 16, 2011. Available at 

http://www.steelguru.com/indian_news/India_to_install_radiation_monitors_for_steel_scrap_import_at_all_major_p

ort/241105.html

179 Gurpreet S Khurana, “India and the Container Security Initiative”, IDSA COMMENT, July 17, 2007.

180 Vishwa Mohan, “50 Cities to Get Mobile Kit to Trace Radiation,”The Times of India, October 07, 2011.

181 Harikumar M, Vaishali M Thakur, Amit Kumar Verma, Krishnamachari G., D. N Sharma, “Detection of 

Unauthorized Movement of Radioactive Sources in the Public Domain for Regaining Control on Orphan Sources -

Systems and Feasibility,” IAEA. Available at http://www.unece.org/fileadmin/DAM/trans/radiation/docs/India.pdf

182 Y. Mallikarjun, “Seaports, Airports to Get Radiation Detection Equipment,” The Hindu, May 04, 2012.
51

Whole Body Counter (MWBC) will do away with the necessity and the logistic impediment of 

evacuating soldiers from operational areas to rear echelons.”183

4.5.9 Information & Cyber Security

The extensive use of information technology in various systems has given rise to concerns of 

potential attacks on these systems. It is alleged that India currently has neither a strong cyber 

law, nor effective cyber security capabilities. Many times in the past, government websites and 

emails have been hacked. According to media reports a few years ago, computers at the Rare 

Materials Plant (RMP), Rattehalli, were possibly infected by malware.184 The authors could not 

find any information on India’s cyber security strategy for its nuclear infrastructure. Situated in 

an unstable neighborhood with non-state actors, India’s nuclear infrastructure is vulnerable to 

cyber espionage or sabotage. 

One may wonder if the Indian technocrats are prepared to mitigate a Stuxnet-type threat to its 

nuclear installations with robust protection. The National Critical Information Infrastructure 

Protection Centre National Technical Research Organisation (NTRO) has prescribed Guidelines 

for Protection of National Critical Information Infrastructure to take all necessary measures to 

facilitate protection of Critical Information Infrastructure (CII) from unauthorized access, 

modification, use, disclosure, disruption, incapacitation, or destruction.185 Also, the Computer 

Information and Security Advisory Group (CISAG) is in charge of periodic oversight of

information systems. It has put in place plans and guidelines to counter cyber-attacks and 

mitigate any adverse effects. Specific guidelines are under preparation to deal with network 

related risks to control and instrumentation systems used in various installations.186

4.5.10 Nuclear Forensics

In a bid to tackle smuggling and illegal transportation of nuclear materials, the Directorate of 

Forensic Science Laboratories (DFSL), Bangalore, has drawn up a comprehensive plan and 

proposed establishment of a national nuclear forensic science centre. The plan is expected to take 

off by 2018-19, but the proposal is still pending with the state government.187 As one of the 

objectives of the GCNEP is to enhance nuclear safeguards through various advanced systems

(including nuclear forensics), it may coordinate and expedite the DFSL plan.

 

183 “DRDO Develops Mobile Lab to Screen Troops in Nuclear Scenario”. Available at http://www.tribuneindia.com, 

January 06, 2015.

184 S. Raghotham, “Cyber Attack on Key N-Facility in Mysore?”The Asian Age, November 02, 2011. 

185 NTRO, “Guidelines for Protection of National Critical Information Infrastructure,” Version 1.0, June 2013. 

Available at http://www.ficciweb.info/conf-cell/Guidelines.pdf,

186 MEA, “Nuclear Security in India.”

187 “Dirty Bomb: Forensic Lab to Take Lead in Fighting Nuclear Terrorism,” March 06, 2011. Available at 

http://www.dnaindia.com/bangalore/report-dirty-bomb-forensic-lab-to-take-lead-in-fighting-nuclear-terrorism1516166
52

4.5.11 Security of Strategic Assets

There is virtually no open information available on the steps India takes to prioritize security of 

its strategic assets, including nuclear weapons, components, or strategic facilities. It is believed 

that India’s nuclear weapons are in a disassembled and dispersed state. It is important to 

acknowledge the fact that India adheres to a second-strike nuclear posture that relies on secrecy,

and therefore has to keep internal safety and security measures away from scrutiny, mainly to 

ensure survivability of its arsenal. The Strategic Forces Command (SFC) has administrative 

control of the nuclear forces. The Strategic Armament Safety Authority (SASA) that functions 

directly under the Nuclear Command Authority (NCA) is responsible for all matters relating to 

the safety and security of India’s nuclear and delivery assets at all locations.188 It is believed that 

the physical security of warheads and components is provided by a specialized force drawn from 

the Indian Army. 

After the Indo-US civil nuclear deal, India separated its civil nuclear facilities from facilities that 

are associated with its strategic programme. As of 2014, 20 nuclear facilities and 12 reactors are 

on the civilian list. Though a comprehensive physical security architecture of the civilian 

facilities is in place (as discussed above), nothing is known about the physical security 

arrangement for the strategic nuclear plants except the 2014 MEA document stating that

“Separate institutions and operating procedures exist for nuclear security at India’s strategic 

facilities.”189

For instance, since 2000 BARC has not been under the regulatory supervision of the AERB. This 

is a significant move since BARC houses much of India’s strategic nuclear program, including 

the Dhruva reactor. As of now, only the civilian nuclear reactors in the country are under the 

regulatory supervision of the AERB, and the strategic facilities are managed by internal safety 

committee structures constituted by the facility director. 

Collaboratively, while the CISF is responsible for the physical security of the civilian nuclear 

installations in the country, the NUMAC cell within the DAE ensures that there is a proper 

nuclear material accounting and control system in the country. This implies that nuclear security 

in India is the responsibility of different organizations: physical security is with the CISF or the 

local police; material accounting (which has security implications) is of the responsibility of the 

DAE; and the review of security practices is handled by the AERB. Indeed, when it comes to 

physical security, there is more than the CISF that is involved.

 

188 Shyam Saran, “India’s Nuclear Weapons Not for National Pride,” May 09, 2013. Available at 

http://ris.org.in/images/RIS_images/pdf/tribune-9may%202013.pdf

189 MEA, “Nuclear Security in India.”
53

5. NUCLEAR SECURITY CULTURE IN INDIA: AN EVALUATION

In India, nuclear security has traditionally been subsumed within the broader nuclear safety 

framework. The various legal and institutional frameworks in the country were instituted,

keeping the safety considerations in mind. Given the intertwined nature of safety and security, 

one would have expected more transparency within the country’s nuclear security infrastructure 

since a healthy safety culture, by definition, demands a certain amount of transparency. However, 

transparency regarding nuclear security, or even safety for that matter, in the country’s nuclear 

establishment is hardly visible. There are a number of reasons for the lack of transparency in 

India’s nuclear establishment. The country’s distinctive nuclear past, including many years of 

isolation, and a mix of civilian and strategic nuclear programs, have given rise to heightened 

levels of caution within the country’s nuclear establishment. Additionally, given that India’s 

nuclear programme was under sanctions and isolated by the international community after the 

1974 PNE, there was a culture of extreme secrecy within the establishment, ensuring that the 

nature of the country’s nuclear programme was not disclosed to outsiders. 

Secrecy can be both positive and negative as far as nuclear security is concerned. While a certain 

amount of secrecy and sense of threat will contribute to enhancing security measures in nuclear 

installations, it is also possible that extreme secrecy will reduce accountability and internal 

checks and balances. However, there is a new-found belief in India that it is no longer an isolated 

state in the global nuclear order and that it is, therefore, important that it participate in global 

norms and rules. For instance, IAEA has been invited by India to conduct a peer review of the

Indian nuclear safety regulatory system, which is slated to take place in early 2015.190 There is 

also a great sense of urgency among the Indian political leadership on nuclear security matters. 

This is evident from the participation of the Prime Minister and the External Affairs Minister in 

the Nuclear Security Summits and their statements indicating the seriousness with which India 

approaches nuclear security matters. The then Prime Minister, Dr. Manmohan Singh, stated at 

the 2010 NSS that “Nuclear security is one of the foremost challenges we face today.” Likewise, 

the then External Affairs Minister declared in the Hague Summit that “India fully shares the 

continuing global concern on possible breaches of nuclear security.”

191 India has been actively 

implementing the various undertakings that it made at the various NSS, such as not using HEU 

in research reactors and establishing the GCNEP. 

In short, it would be appropriate to argue that India’s nuclear security approach is based on the 

foundation and belief that “credible threat exists and that nuclear security is important.” In our 

considered opinion, we believe that India needs to further strengthen its institutional, legal, and 

physical infrastructure relating to nuclear security, in order to ensure that its nuclear 

 

190 “IAEA Review of Indian Nuke Plants Latest by Early 2015,” March 04, 2014. Available at 

http://m.outlookindia.com/items.aspx/?artid=831294

191 “Khurshid: Nuclear Terrorism Serious Threat to Global Peace”, Indian Express, March 26, 2014. Available at 

http://indianexpress.com/article/india/india-others/khurshid-nuclear-terrorism-serious-threat-to-global-peace/
54

establishment is secure. We also believe that the country does have the institutional and physical 

basis that can be further enhanced and strengthened. 

5.1 Absence of an Overarching Security Apparatus

One of the issues that should be taken seriously by the government of India regarding nuclear 

security is the absence of an overarching security apparatus to safeguard the country’s nuclear 

security installations. For instance, as mentioned earlier, the physical security of nuclear 

installations is provided by a mix of multiple organisations such as the CISF, the local police,

and sometimes even with private security organisations. On the other hand, material accounting 

is done by the DAE, and the review of security practices is the responsibility of the AERB. Note 

that this is the situation on the civilian side alone. Thus, there are multiple organisations in 

charge of the various aspects of nuclear security in the country, resulting in non-uniform nuclear 

security culture, norms, and standard operating procedures. 

5.2 Regulatory Autonomy

It may be noted that there was no regulatory mechanism prior to 1983 when the AERB was 

established through a gazette notification by the government of India. Prior to 1983, the security 

and safety regulation was carried out by an internally constituted committee in each facility. Not 

much has changed since 1983. 

The AERB’s regulatory powers are limited, as it is not a truly autonomous institution. The Public 

Accounts Committee of the Parliament of India in its 19th report pointed out that “the legal status 

of the AERB continues to be that of an authority subordinate to the Central Government, with 

powers delegated to it by the latter.”192 It is the government of India that appoints the head of the 

regulatory body and provides the necessary funding. Moreover, the head of the AERB reports to 

the Chairperson of the Atomic Energy Commission, who is also the Secretary in the Department 

of Atomic Energy, which creates the situation of the regulator reporting to the promoter of 

nuclear projects. This is a potential conflict-of-interest and has implications for the extent and 

quality of oversight by the regulatory authority. The new Bill under consideration of the Indian 

Parliament, the NSRA, also, in its current shape and form, does not provide for a truly 

autonomous regulator. 

The Bill was presented to the previous Lok Sabha in September 2011 and was subsequently 

referred to a Department-Related Parliamentary Standing Committee on Science & Technology, 

Environment & Forests in the same month. The Committee gave its report in March 2012 and, 

according to reports,

193 the government (DAE) adopted most of the suggestions and sent it back 

to the Parliament. The Bill is currently lapsed and is likely that the new government will 

 

192 Public Accounts Committee 2013-2014, “Activities of Atomic Energy Regulatory Board,” December 2013. 

Available at http://164.100.47.134/lsscommittee/Public%20Accounts/15_Public_Accounts_90.pdf, p. 4.

193 “Nuclear Safety Bill to be Taken up in Next Session: Minister,” September 06, 2013. Available at 

http://zeenews.india.com/news/nation/nuclear-safety-bill-to-be-taken-up-in-next-session-minister_874653.html
55

reintroduce the Bill in the newly formed Lok Sabha (it has not yet been introduced in the Rajya 

Sabha). 

The Committee in its report194 asked the government to ensure that the regulatory authority is 

made more autonomous. The PAC also made the same recommendation to the government: “The 

department of atomic energy should seriously re-examine provisions of the Bill and take 

necessary steps to ensure the nuclear regulator becomes independent and credible and at par with 

regulators in other nations.”

195

Analysts have also critiqued the various provisions of the Bill. For instance, Suvrat Raju and MV 

Ramana have argued that the clause “the decision of the central government whether a question 

is one of policy or not shall be final” is problematic since “if a pesky Authority questions, say, 

the decision to import an untested nuclear reactor, the government can silence it simply by 

declaring that the matter is one of ‘policy.’ This clause profoundly undermines the independence 

of the Authority.”196 According the Raju and Ramana, the appointment process is also faulty −

“Another structural problem with the proposed NSRA is that all its members will be “appointed 

by the central government on the recommendations of the search committees.” However, these 

committees will be constituted by the “Council of Nuclear Safety,” which will comprise seven 

Union Ministers, the Secretary of the DAE, and the Cabinet Secretary. So, in effect, the 

government will have complete control over the appointment process, and can use it to appoint 

pliant technocrats.”197

5.2.1 Program Confusions

There are reactors that are connected to the grid and produce electricity, yet are marked 

“strategic.” The difference between these reactors and those that are “civilian” is the length of 

irradiation; but confusion remains regarding the status of the spent fuel generated out of these 

reactors. Yet, it is conceivable that there could be two sets of standards and different 

organizations involved in managing safety and security of each, simply because of this semantic 

(or perhaps operational) difference. This could seem problematic in the public eye from a 

consistency and regulatory point of view.198

 

194 Department-related Parliamentary Standing Committee on Science & Technology, 

Environment & Forests, “Two Hundred and Twenty First Report on the Nuclear Safety Regulatory Authority Bill, 

2011,” March 06, 2012. Available at 

http://www.prsindia.org/uploads/media/Nuclear%20Safety/NSRA%20Bill%202011_%20Standing%20Com%20Rep

ort.pdf

195 Ibid, p. 48.

196 Suvrat Raju and MV Ramana, “It’s Better to be Safe than Sorry,” Hindustan Times, February 05, 2014. Available 

at http://www.hindustantimes.com/comment/analysis/it-s-better-to-be-safe-than-sorry/article1-1180454.aspx

197 Ibid.

198 Inputs via email from Toby Dalton, Deputy Director, Nuclear Policy Program, Carnegie Endowment for 

International Peace, Washington D.C. July, 2014.
56

5.2.2 Conceptual Tensions

There are conceptual tensions at every level of nuclear security: between safety and security;

between physical protection and material protection and accounting; between the use of 

technology and manpower; and between counter-intelligence and “need to know” system.199

Such tensions need to be addressed to achieve a certain level of balance that would be acceptable 

for India. The accountability system in the country needs to be based on how these tensions are 

resolved. We’ve seen in failures in the US where internal accountability was lacking.200

Besides ensuring the security of nuclear materials and facilities spread throughout the country, 

the other major challenge that India needs to wake up to is the security of radioactive materials, 

sources, and devices. This is an enormous challenge given the number of facilities and amount of 

material and devices to be secured. Currently, the government is only beginning the task of 

putting in place proper accounting of these facilities and materials. There have been a number of 

past incidents involving radiological material, including one involving the University of Delhi

(Mayapuri scrap market incident in 2010). Both the CAG and the PAC reports have raised 

concerns about these incidents. Given the fact that there have been accidents in the past 

involving radioactive material, New Delhi should create national level structures to bring the 

radioactive material under proper regulatory and security mechanisms. 

There are also other such related concerns linked (directly or indirectly) to nuclear or 

radiological security in India. For instance, as previously noted, there have been a number of 

reports on the smuggling of radioactive material, hacking of websites of sensitive nuclear-related 

institutions in the past leading to fears about India’s ability to withstand a cyber-attack directed 

against its nuclear facilities, instances of misconduct and malpractices in nuclear facilities,201 and 

mysterious and unnatural deaths of nuclear scientists. Related concerns are the physical security 

of residential colonies attached to the nuclear facilities, and the security of thorium and uranium 

mining sites. There can often be conceptual tensions between issues of safety and security with 

implications for the everyday management of nuclear security. Therefore, there is a need to 

maintain a well-thought out balance between these two, sometimes competing, but equally 

important issues. 

Finally, it is worth recalling the words of Kiyoshi Kurokawa, the Chairman of the Fukushima 

Nuclear Accident Independent Investigation Commission, on the Fukushima nuclear accident: 

“What must be admitted — very painfully — is that this was a disaster ‘Made in Japan.’ Its 

fundamental causes are to be found in the ingrained conventions of Japanese culture: our 

reflexive obedience; our reluctance to question authority; our devotion to ‘sticking with the 

program’; our groupism; and our insularity ... nuclear power became an unstoppable force, 

 

199 Ibid. 

200 Ibid.

201 “Sabotage in Kaiga: Tritium Added to Drinking Water,” Economic Times, November 30, 2009. Available at 

http://articles.economictimes.indiatimes.com/2009-11-30/news/28471895_1_tritium-drinking-water-contamination
57

immune to scrutiny by civil society. Its regulation was entrusted to the same government 

bureaucracy responsible for its promotion.” 202 Anyone familiar with the Indian nuclear 

establishment will see that much of what Kurokawa says about the Japanese nuclear safety 

culture could also be applicable in the case of India’s nuclear safety/security culture. There is an 

urgent need for the government to look closely at how much these characteristics are prevalent in 

India’s case and seek ways for them to be addressed. 

 

202 Kiyoshi Kurokawa, “The National Diet of Japan Fukushima Nuclear Accident Independent Investigation 

Commission,” 2012. Available at http://ieer.org/wp/wpcontent/uploads/2012/07/Fukushima_NAIIC_report_lo_res3.pdf
58

6. RECOMMENDATIONS FOR ENHANCING NUCLEAR SECURITY 

GOVERNANCE, INSTITUTIONS, INSTRUMENTS, AND CULTURE

This study has identified a number of areas where we believe much needs to be done in order to 

improve the nuclear security culture and architecture in India. Based on our findings, we put 

forward the following suggestions for debate and consideration by the government of India and 

the International community. 

6.1 Recommendations for India

Transparency

 Demonstrate more confidence and clarity in the essential elements of the 

country’s nuclear security practices. 

 Make transparency a key feature of the country’s nuclear security culture. 

 Develop a comprehensive white paper on security and safety measures.

Enhance the Autonomy of the Regulatory Body

 Ensure complete autonomy of the regulatory body from the promoting agency.

 Include scientists, civilian auditors, environmentalists, etc. into the regulatory 

oversight body.

 Constitute a bi-partisan body to select the members of the regulatory body.

Strengthen National Nuclear Safety-Security Culture

 Reexamine organizational issues identified in the Fukushima accident 

investigation, including “reflexive obedience, reluctance to question authority, 

devotion to ‘sticking with the program’, and vested interest, groupism, and 

insularity.”

203

 Set up a high-level committee to explore how prevailing trends in India’s nuclear 

security system can be addressed.

New Areas to Consider 

 Create unified security command/structure/requirements for the civilian nuclear

installations.

 Create a special division within the CISF, or even a new specialized nuclear 

security force, to address nuclear security.

 

203 Ibid. 
59

 Create an agency to oversee and regulate strategic nuclear facilities.

o Consider the strategic importance of declaring thorium-bearing areas and 

monazite sands as exclusive zones and providing them oversight and 

adequate security.

 Enhance the security of radiological materials, devices, and facilities.

 Equip major Indian seaports with technology similar to CSI.

6.2 Recommendations for the International Community

 Help mainstream India in the global nuclear order.

 Invite India to observe nuclear security training, practices, simulation exercises, 

etc. in other nuclear states and vice versa.

 Pursue India’s entry into the export control organizations.

 India and the NSS process should consider convening Regional Nuclear Security 

Summits.
60

7. NEXT STEPS

This section identifies some of the short-term, intermediate-term, and long-term steps that we 

think could be taken by the Indian government in order to strengthen the safety and security of 

India’s civilian nuclear facilities and material. 

Short-term (1-2 years)

 Introduce theoretical and practical aspects of nuclear security in university courses on 

arms control/disarmament, nuclear strategy, nuclear energy, etc.

 Conduct a comparative study on the nuclear security structures of various countries and 

determine what aspects are applicable in Indian conditions.

 Initiate debates in the country on the NSRA legislation through mass media.

Intermediate-term (2-5 years)

 Hold a regional preparatory workshop (formal or informal) in South Asia to explore the 

possibility of holding a Regional Nuclear Security Summit.

 Prepare a draft action plan, based on the practices and experiences of other countries, for 

securing radiological facilities in India. Necessary training may be given to the personnel 

in key radiological facilities in the country on nuclear security. 

Long-term (ongoing)

 Promote interface and collaboration among universities, think tanks, and nuclear 

establishment in India to discuss and deliberate on nuclear security matters.

 Promote collaborative research on nuclear security between Indian and international think 

tanks and Universities.
61

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ABOUT THE AUTHORS

Dr. Sitakanta Mishra is a Research Fellow at the Centre for Air Power Studies in New Delhi 

(India), and the Associate Editor of Indian Foreign Affairs Journal (New Delhi), published by 

The Association of Indian Diplomats. Dr. Mishra has also worked with the Indian Pugwash for 

several years. He was a Visiting Research Scholar at Sandia National Laboratories in

Albuquerque, New Mexico during September-December 2013.

Dr. Mishra has authored three books: The Challenge of Nuclear Terror (2008), and Cruise 

Missiles: Evolution, Proliferation and Future (2011), and Parmanu Politics: Indian Political 

Parties and Nuclear Weapons (2015). He has many other national and international publications 

related to South Asian affairs, nuclear energy, nuclear safety-security, missiles, Indian foreign 

policy, and also involved in Indo-Pak track-two dialogue.

Dr. Happymon Jacob is Assistant Professor of Diplomacy and Disarmament at the School of 

International Studies at Jawaharlal Nehru University (JNU), New Delhi. Prior to joining JNU in 

2008, he held teaching positions at the University of Jammu in Jammu & Kashmir and the Jamia

Millia Islamia University in New Delhi; and research positions at the Centre for Air Power 

Studies, Delhi Policy Group and Observer Research Foundation, all based in New Delhi. He has 

been organising and/or participating in some of the most influential India-Pakistan track-two 

dialogues: ‘Chaophraya Dialogue’; ‘Pugwash India-Pakistan Dialogue’; and the ‘Ottawa 

Dialogue on India-Pakistan Nuclear Relations.’ Dr. Jacob is the author/editor of eight books. 

Jacob’s latest work is Does India Think Strategically? Institutions, Strategic Culture and 

Security Polices, Manohar Publications, New Delhi, 2014.
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