CNSC Presentation to the Federal Agency for Nuclear Control

Transcription

1 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 February 19, 2016 e-docs # nuclearsafety.gc.ca

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 2

3 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 3

4 Enabling Regulatory Framework 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 4

5 Enabling Regulatory Framework (cont d) Elements of the Regulatory Framework Enabling Legislation Act Regulations Requirements Licences and Licence Conditions Handbooks, Certificates, Orders Regulatory Documents * Guidance Guidance *Includes any national or international standards referenced in Licences or Licence Conditions Handbooks 5

6 Enabling Regulatory Framework (cont d) 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 licence, and to perform enforcement actions 6

7 Enabling Regulatory Framework (cont d) 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 7

8 Enabling Regulatory Framework (cont d.) Licence condition 2490 The licensee shall implement the security measures for sealed sources as set out in REGDOC , Security of Nuclear Substances: Sealed Sources Other security provisions for nuclear facilities 8

9 Enabling Regulatory Framework (cont d) REGDOC , 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 9

10 Enabling Regulatory Framework (cont d) 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

11 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 11

12 Risk Categories of Radioactive Sealed Sources EXTREMELY DANGEROUS VERY DANGEROUS DANGEROUS UNLIKELY TO BE DANGEROUS VERY UNLIKELY TO BE DANGEROUS 12

13 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 13

14 Category 1 Examples Pool-type irradiator Up to 37,000 TBq of cobalt-60 14

15 Category 1 Examples (cont d) Teletherapy medical treatment 555 TBq cobalt-60 Gammacell 3000 Blood irradiator 110 TBq cesium

16 Category 2 Examples Industrial radiography exposure devices 5.5 TBq Iridium-192 Category 2 High-dose-rate brachytherapy device Medical treatment device 370 GBq iridium

17 Category 3 Examples Logging source within transport container 600 GBq americium-241/beryllium Industrial fixed gauge used in industrial process control 370 GBq cesium

18 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 18

19 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

20 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) 20

21 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) 21

22 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 22

23 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 23

24 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 24

25 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 25

26 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 26

27 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 27

28 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 28

29 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. 29

30 Category 4 and 5 Prudent Management Practices Physical barrier / intrusion detection system / access control Security of storage Response protocol Maintenance and testing Facility security plan Personal trustworthiness or background checks Information security Security awareness program Vehicle security Transportation security plan Source should be protected against unauthorized access and removal Should be stored in a secure container or location Source should be protected against unauthorized access and removal Maintenance and testing must be conducted at least every six months, and written records should be maintained Prudent management practice Reference, education and employment verification and criminal records name check (prudent management practice) All prescribed information must be protected and be shared on a need to know basis All authorized users, including staff who transport radioactive sources, must receive security awareness training on a regular basis Source should be protected against unauthorized access and removal Source should be protected against unauthorized access and removal 30

31 Effective Implementation of Security Measures: Challenges Responsibility functions Potential for duplication Cost Public access - hospitals and universities Remote locations Safety and security interface Sustainability 31

32 Operational Challenges Faced 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 32

33 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 33

34 What works at the operational level 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 34

35 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 35

36 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 36

37 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) 37

38 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 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 38

39 nuclearsafety.gc.ca facebook.com/canadiannuclearsafetycommission youtube.ca/cnscccsn CNSC Copyright 2015