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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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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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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)


Category 1 – Examples

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

Canadian Nuclear Safety Commission 6

Teletherapy medical treatment 555 TBq cobalt-60

Gammacell 3000 – Blood irradiator 110 TBq cesium-137

Category 1 – Examples (Cont’d.)



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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



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


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


Example of Transport of Category 1 – Pool-Type Irradiator

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Example of Transport of Category 2 and 3 – Industrial Use

Well logging

Industrial radiography 11


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


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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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


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


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


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


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

https://www.google.ca/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwimjdO04bnNAhUCLB4KHSVHBnMQjRwIBw&url=https%3A%2F%2Fwww.wins.org%2Findex.php%3Farticle_id%3D62&psig=AFQjCNFvCn3W6RSG3rO9NIWrHVfq6LrMzA&ust=1466620536647433


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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http://intranet.cnsc-ccsn.gc.ca/eng/operational_activities/about_rob_tsb/technical_support_branch/security_safeguards/Pages/NuclearSecurityIntelligence.aspx


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.


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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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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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


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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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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