CNSC Presentation to the Federal Agency for Nuclear Control · CNSC Presentation to the Federal...

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February 19, 2016

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CNSC Presentation to the Federal Agency for Nuclear Control

Canadian Experience in the Development and Implementation of Regulatory Requirements for the Security of Radioactive Sources Raphael Duguay, Security Advisor Nuclear Security Division Directorate of Security and Safeguards

Canadian Nuclear Safety Commission 2

Outline

• Who we are • Enabling regulatory framework • Context and application • Development process • Overview of security requirements • Challenges faced • Lessons learned • CNSC safety/security interfaces

Canadian Nuclear Safety Commission


• Mission • to regulate the use of nuclear energy and materials to protect

health, safety, security and the environment, and to implement Canada’s international commitments on the peaceful use of nuclear energy; and to disseminate objective scientific, technical and regulatory information to the public

• Mandate • to regulate the production, possession, use and transport of

nuclear substances

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Enabling Regulatory Framework

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• Nuclear regulation is a federal responsibility

• Nuclear Safety and Control Act came into force in 2000 and provides modern framework for the regulation of Canada’s nuclear sector

• The NSCA establishes the Canadian Nuclear Safety Commission (CNSC) as the Competent Authority

• Provides the CNSC with the powers to issue licences, make regulations, and conduct compliance and enforcement activities


Enabling Regulatory Framework (cont’d)

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*Includes any national or international standards referenced in Licences or Licence Conditions Handbooks

Act

Regulations

Licences and Licence Conditions Handbooks, Certificates, Orders

Regulatory Documents *

Guidance

Elements of the Regulatory Framework

Enabling Legislation

Guidance

Requirements

*Includes any national or international standards referenced in Licences or Licence Conditions Handbooks

Act

Regulations

Licences and Licence Conditions Handbooks, Certificates, Orders

Regulatory Documents *

Guidance

Elements of the Regulatory Framework

Enabling Legislation

Guidance

Requirements



Nuclear Safety and Control Act •Gives authority to the CNSC to establish regulations respecting measures to ensure the maintenance of national security…in the production, use, possession, packaging, transport, storage and disposal of nuclear substances

•Gives authority to the CNSC to issue licences for possession, transfer, import, export, use or abandonment of nuclear substances

•Gives authority to the CNSC to designate inspectors, to verify compliance with the act, regulations, or conditions of a lic

ence, and to

perform enforcement actions

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•General Nuclear Safety and Control Regulations, subsection 12(1)

Every licensee shall: (c) Take all reasonable precautions to … maintain the security of nuclear facilities and of nuclear substances

(g) Implement measures for alerting the licensee to the illegal use or removal of a nuclear substance

(h) Implement measures for alerting the licensee to acts of sabotage or attempted sabotage anywhere at the site of licensed activity

(j) Instruct the workers on the physical security program at the site of the licensed activity and on their obligations under that program

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Enabling Regulatory Framework (cont’d.)

Licence condition 2490 The licensee shall implement the security measures for sealed sources as set out in REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources

Other security provisions for nuclear facilities

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REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources

Sets out the minimum security measures to prevent the loss, sabotage, illegal use, illegal possession or illegal removal of sealed sources

Provides information and guidance on how to meet required security measures

Combined performance-based and prescriptive approach

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Public consultation in early 2012 Published in May 2013 Transition periods:

Category 1, 2 – effective May 31, 2015 Category 3, 4, 5 – effective May 31, 2018

Extensive licensee outreach and engagement Onsite compliance promotion/verification of security requirements conducted from May 2013 onwards Goal of ensuring high-risk licensees in compliance by May 2015

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The Canadian Context

Domestically ~ 250 category 1 and 2 high-risk radioactive source licensees in Canada (approx. 500 inspectable locations) These high-risk radioactive sources are used in a wide variety of applications such as: • oil well logging • industrial radiography • medical application and research

(teletherapy, high-dose-rate brachytherapy, blood irradiation, gamma knives)

• industrial irradiators

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Risk Categories of Radioactive Sealed Sources

EXTREMELY DANGEROUS

VERY DANGEROUS

DANGEROUS

UNLIKELY TO BE DANGEROUS

VERY UNLIKELY TO BE DANGEROUS

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Application

Security measures for sealed sources: • Applicable to transport by road and to storage within

Canada • Applicable to Category 1, 2 and 3 radioactive sealed

sources • Applicable to aggregate quantities • Does not apply to radioactive sources within military or

defence programs • Provides guidance for Category 4 and 5 radioactive

sealed sources

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Category 1 – Examples

Pool-type irradiator Up to 37,000 TBq of cobalt-60

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Category 1 – Examples (cont’d)

Teletherapy medical treatment 555 TBq cobalt-60

Gammacell 3000 – Blood irradiator 110 TBq cesium-137

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Industrial radiography exposure devices 5.5 TBq Iridium-192 Category 2

High-dose-rate brachytherapy device Medical treatment device 370 GBq iridium-192

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Logging source within transport container 600 GBq americium-241/beryllium

Industrial fixed gauge used in industrial process control 370 GBq cesium-137

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Category 4 and 5 – Examples

Portable gauges used in construction 370 MBq cesium-137 with 1480 MBq americium-241/beryllium Category 4

Electron Capture Detector 1400 MBq nickel-63 Category 5

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Development Process for Security Measures

1. Benchmarking with other Canadian regulators

2. Benchmarking with other countries 3. Review of IAEA recommendations and

guidance documents 4. Internal CNSC review 5. Security awareness to inspectors and

stakeholders 6. Public consultation - outreach 7. Presentation to the Commission and

approval 19


Technical Security Measures

Technical security measures include requirements and specific guidance for

Access control Detection of unauthorized access Locking hardware and key control Physical barriers Alarm response protocol Inspection, maintenance and testing of security-related equipment Security officers (if they are employed by the licensee)

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Technical Security Measures Category 1, 2 & 3 Sources

Implement a minimum of two physical barriers

Implement effective access control measures to ensure that only authorized persons have access

Implement an effective means to detect and assess unauthorized access and unauthorized removal (e.g., monitored alarm system)

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Technical Security Measures Category 1, 2 & 3 Sources (cont’d)

Implement an acceptable response protocol in case of a security alarm or incident

Implement regular testing and maintenance of security systems and devices (alarm sensors), minimum every six months

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Requirements for Administrative Security Measures - Category 1, 2 & 3 Sources

Administrative security measures include requirements and specific guidance for:

a site security plan a security awareness program personnel trustworthiness and reliability checks protection of prescribed and/or sensitive information inventory control of radioactive sources

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Administrative Security Measures

Implement a site (facility) security plan for each licensed site

Implement security awareness training for employees

Implement background verification for employees with unescorted access to sealed sources (e.g., criminal record name check)

Maintain an up-to-date list of personnel authorized for unescorted access

Source: 123rf

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Administrative Security Measures Category 1, 2 & 3 Sources

Implement measures/procedures to protect prescribed information and/or sensitive security-related information (ex: information related to security arrangements, equipment, systems and procedures).

Implement inventory control

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Requirement for Security during Transport Category 1, 2 & 3 Sources

Security measures during transport includes instructions and specific requirements for:

Vehicle security Security measures for sealed sources during transport Transport security plan

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Security Measures during Transport Category 1, 2 & 3 Sources

Use packages/containers that are robust enough to prevent unauthorized access

Implement a vehicle disabling device to prevent unauthorized removal

Install an effective intrusion detection system or an equivalent means to detect unauthorized access including regular testing and maintenance of the security system or device

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Security Measures during Transport Category 1, 2 & 3 Sources (cont’d)

Implement background verifications for employees with unescorted access (e.g., criminal record name check) for drivers

Licensees must ensure that commercial carriers meet CNSC transportation security measures

Implement an acceptable response protocol in case of a security alarm or incident while in transport mode

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Security Measures during Transport Category 1, 2 & 3 Sources (cont’d)

Specific transport security plan for category 1 sources Generic transport security plan for category 2 sources Includes describing proposed security measures, monitoring, routing, etc.

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Category 4 and 5 Prudent Management Practices

Physical barrier / intrusion detection system / access control

Source should be protected against unauthorized access and removal

Security of storage Should be stored in a secure container or location

Response protocol Source should be protected against unauthorized access and removal

Maintenance and testing Maintenance and testing must be conducted at least every six months, and written records should be maintained

Facility security plan Prudent management practice

Personal trustworthiness or background checks

Reference, education and employment verification and criminal records name check (prudent management practice)

Information security All prescribed information must be protected and be shared on a need to know basis

Security awareness program All authorized users, including staff who transport radioactive sources, must receive security awareness training on a regular basis

Vehicle security Source should be protected against unauthorized access and removal

Transportation security plan

Source should be protected against unauthorized access and removal

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Effective Implementation of Security Measures: Challenges

Responsibility functions

Potential for duplication

Cost

Public access - hospitals and universities

Remote locations

Safety and security interface

Sustainability

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Inspection tools and procedures did not exist to perform combined safety/security inspections

Defining roles and responsibilities for Inspectors and security specialists

Development of expectations for new requirements

Licensees not familiar with new inspection methodologies and requirements

Development of training for inspectors

Operational Challenges Faced


Effective Implementation of Security Measures: What Worked

Stakeholder engagement (public and industry)

Performance-based compliance activities

Cost-effective solutions

Security culture development through awareness promotion, training and guidance

Enhancing safety and security interfaces

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Changes that were needed:

Revision of inspection procedures to include security verifications

Creation of a Protocol between Inspectors and security specialists to define responsibilities

Creation of a working group

Delivery of significant promotional outreach

Additional security training for Inspectors to be provided as part of qualification program

Drafting of new inspection worksheets to be used for security requirements

What works at the operational level


Safety / Security Interfaces

Inspectors verify both safety and security regulatory requirements while onsite at defined frequencies • more frequent basic security verifications

• more effective use of resources

Communication protocol approved at the high level

Clear roles and responsibilities defined and approved

Internal working group on RSS

Integration of security in the training and qualification of inspectors

Shared tools to facilitate communication

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Safety / Security Interfaces (cont’d)

Technical support provided by security specialists (NSD)

• Continue review of licensee security measures (security plans)

• Perform an initial verification to inspect the implementation of a high-risk licensee’s security program

• Perform inspections of a licensee upon request by DNSR, DNCFR or DPRR

• Serve as a technical specialist available for inspectors to consult

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Ongoing Implementation

• Publication in French and English • Media release and public notice • Outreach activities with inspectors and

stakeholders • Security awareness during annual

workshops • Closer coordination with licensees

(Industry) • Implementation strategy – licence condition

– timing • Sharing of best practices (domestically and

internationally)

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Conclusion

Further to the requirements and obligations set forth in the NSCA and its regulations, this regulatory document provides a clear and consistent set of comprehensive requirements regarding security measures for sealed sources The incorporation of REGDOC-2.12.3 in the various affected licences also serves to align CNSC regulations with the International Atomic Energy Agency’s Code of Conduct and Nuclear Security Series documents

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