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nuclearsafety.gc.ca
February 19, 2016
e-Docs # 4916771
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
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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Canadian Nuclear Safety Commission
Enabling Regulatory Framework
4
• 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
Canadian Nuclear Safety Commission
Enabling Regulatory Framework (cont’d)
5
*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
Canadian Nuclear Safety Commission
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 lic
ence, and to
perform enforcement actions
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Canadian Nuclear Safety Commission
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
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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
Enabling Regulatory Framework (cont’d)
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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Canadian Nuclear Safety Commission
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 2015
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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
Risk Categories of Radioactive Sealed Sources
EXTREMELY DANGEROUS
VERY DANGEROUS
DANGEROUS
UNLIKELY TO BE DANGEROUS
VERY UNLIKELY TO BE DANGEROUS
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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
Category 1 – Examples
Pool-type irradiator Up to 37,000 TBq of cobalt-60
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Canadian Nuclear Safety Commission
Category 1 – Examples (cont’d)
Teletherapy medical treatment 555 TBq cobalt-60
Gammacell 3000 – Blood irradiator 110 TBq cesium-137
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Canadian Nuclear Safety Commission
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-192
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Canadian Nuclear Safety Commission
Category 3 – Examples
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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
Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission 32
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
Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission 34
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
Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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Canadian Nuclear Safety Commission
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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