Security of Radioactive Sources: Training and Inspection ... · Security of Radioactive Sources:...
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Security of Radioactive Sources: Training and Inspection Program
Fifth Regional Review Meeting on Radioactive Source Security, Malaysia
Raphael Duguay Security Advisor and Inspector, M.Sc., PSP Nuclear Security Division Directorate of Security and Safeguards Canadian Nuclear Safety Commission
Canadian Nuclear Safety Commission
Outline
Who we are
The Canadian context
CNSC practices for radioactive sources
Application of REGDOC-2.12.3
Challenges and lessons learned during implementation phase
What works at the strategic and operational levels
Safety and security interfaces
Inspection Program
Training of inspectors and ongoing efforts
Conclusion
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Canadian Nuclear Safety Commission
Canadian Nuclear Safety Commission
Mission to regulate the use of nuclear energy and materials to protect health, safety, security and the environment; 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
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Canadian Nuclear Safety Commission
The Canadian Context
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Canada is one of the world’s largest suppliers of radioactive sealed sources used in various beneficial applications globally Domestically, there are approx. 261 Category 1 and 2 high-risk radioactive source licensees in Canada (approx. 500 inspectable locations)
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Category 1 – Examples
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Pool-type irradiator Up to 37,000 TBq of cobalt-60
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Teletherapy medical treatment 555 TBq cobalt-60
Gammacell 3000 – Blood irradiator 110 TBq cesium-137
Category 1 – Examples (Cont’d.)
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Category 2 – Examples
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Industrial radiography exposure devices 5.5 TBq Iridium-192
High-dose-rate brachytherapy device Medical treatment device 370 GBq iridium-192
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Category 3 – Examples
Industrial fixed gauge used in industrial process control 370 GBq cesium-137
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Logging source within transport container 600 GBq americium-241/beryllium
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Category 4 and 5 – Examples
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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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Example of Transport of Category 1 – Pool-Type Irradiator
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Canadian Nuclear Safety Commission
Example of Transport of Category 2 and 3 – Industrial Use
Well logging
Industrial radiography 11
Canadian Nuclear Safety Commission
Effective national legislative framework
Independent national regulatory body
Regulatory system for authorizations
National Sealed Source Registry and Sealed Source Tracking System for high-risk sources
Effective import/export controls
Enhanced regulatory oversight program for orphan sources and financial guarantees
Adequately trained and qualified competent authorities
Regulatory security requirements and guidance for high-risk sources in storage and while they are in transport
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Radioactive Source Security: Canadian Practices
Canadian Nuclear Safety Commission
Application of REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources
Applicable to transport by road and to storage within Canada
Applicable to Category 1, 2 and 3 radioactive sealed sources
Provides guidance for Category 4 and 5 radioactive sealed sources
Applicable to aggregate quantities
Does not apply to radioactive sources within military or defence programs
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Canadian Nuclear Safety Commission
Security Requirements Based on Risk Categories and Graded Approach
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EXTREMELY DANGEROUS
VERY DANGEROUS
DANGEROUS
UNLIKELY TO BE DANGEROUS
VERY UNLIKELY TO BE DANGEROUS
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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 and guidance for new requirements
Licensees not familiar with new inspection methodologies and security requirements
Development of training for inspectors
Challenges and Lessons learned During the Implementation Phase
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What Works at the Strategic Level
Stakeholder engagement (public and industry)
Compliance activities (both performance and prescriptive approaches)
Finding cost-effective solutions using a risk-based approach
Security culture development through awareness, promotion, training and guidance
Enhancing safety and security interfaces for sustainability
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Changes that were needed:
Creation of a communication protocol between divisions
Defining clear roles and responsibilities for safety and security specialists
Creation of an RSS working group
Delivery of significant promotional outreach
Revision of inspection procedures to include security
Drafting of new inspection worksheets for security requirements
Additional security training for inspectors to be provided as part of the qualification program
What Works at the Operational Level
Canadian Nuclear Safety Commission
Safety/Security Interfaces
Inspectors verify both safety and security requirements
more frequent basic security verifications more effective use of resources “eyes and ears” in the field
Internal working group on RSS to address potential safety/security issues and coordinate inspection activities
Integration of security in the training and qualification of inspectors
Shared tools to facilitate communication
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Source: WINS
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Safety/Security Interfaces (cont’d.)
Technical support provided by security specialists (NSD) Continue review of licensee security measures (security plans, transport 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
Establish inspection program following a risk-based approach
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Training of Safety Inspectors
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Needs analysis performed with learning specialists
Systematic approach to training evaluation
Audience targeted
Incorporated into baseline training requirements for affected work groups/inspectors.
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How the Training Was Received by the Safety Inspectors
Very positive feedback and good reception
Provided in classroom setting; evaluation by test (80% mark), which is tracked in our Learning Management System
Individual safety inspectors invited to participate in security inspections as observers (job shadowing opportunities); these opportunities help increase:
safety/security interfaces
communications
relationships between fellow inspectors
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Canadian Nuclear Safety Commission
How This New Approach Helps Enhance Safety/Security Interfaces for RSS
Increases security awareness for CNSC staff
Increases our organizational security culture
Improved procedures and processes to assess compliance and handle confidential information on the field
Improved tracking tools for the site security plan, TSP, security inspections and security findings
Internal Working Group helps to build robust and effective bridges between safety (RP, Transport, Licensing) and security experts
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Canadian Nuclear Safety Commission
How Did the Practice of Safety Inspectors Performing Field Inspections (for Security) Go? (Practices in the Field?)
Security is part of routine inspections for cat. 1/2; as a result, more security inspections have been done
Security part of annual public report
More visibility on security; enhanced transparency for the public
High compliance rate for security in medical, industrial, research, academic and research sector
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What Were/Are the Challenges Faced by the Regulator and Licensees Since the Training?
Additional guidance on trustworthiness and reliability for both users and safety inspectors
Identification of aggregate quantities (cat. 3/4) sites; licensees that are borderline and need guidance
Challenges of sharing threat information with licensees and industry
Outreach program with law enforcement agencies to increase awareness on radioactive sources in licensees’ local regions, and to demonstrate how to respond effectively
In Canada, a CRNC is very limited so we are looking at different options; it may change to fingerprinting to have faster and more accurate results on individual record data 24
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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 good practices (domestically and internationally)
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Canadian Nuclear Safety Commission
Conclusions
Specific regulatory requirements has served to clarify expectations at all levels
Use of safety inspectors has:
enhanced overall compliance visibility broadened number of inspections provided data for trending and analysis established the basis for future resource and activity planning
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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