Managing Safety, Security, and Safeguards Risks

chne.unm.edu

Managing Safety, Security, and Safeguards Risks

University of New Mexico

March 21, 2013

Martha Williams

1


Safety, security, safeguards

• The problem: Addressing safety, security and safeguards as three separate and

independent facility functions

• The reality: Safety, security and safeguards are inherently interwoven

Security needs safeguards information to resolve questions of loss or theft of

nuclear material

Safety needs safeguards information concerning nuclear material location and

quantities

Safeguards (material control and accounting ) needs security to provide control

access to rooms where material is located, vetting of personnel, etc

• Each discipline has its own specialized functions and information

3SDB, University of New Mexico, March 2013

2


Safety, security, safeguards

• Locating safety, security and safeguards in different organizations is not the

problem; the problem is poor communication and lack of cooperation

• Effective safety, security and safeguards require communication and

cooperation

• Cooperation can be constrained by organizational boundaries.

• Both regulatory agencies and facilities can be more effective if improvements

are made to communication between safety, security and safeguards.

Note: Measures taken for Safeguards are based primarily on nuclear material

accounting and control. Sometimes the words “Safeguardsand “nuclear

material accounting and control” are used interchangeably; however they are

not equivalent. Nuclear material accounting and control extends beyond

Safeguards reporting. It can and does provide information that is essential to

safety and security.

3SDB, • University of New Mexico, March 2013

3


NRC

model

MC&A

Safeguards

DOE

model

Safety

Security

IAEA

model

Ideal model

3SDB, University of New Mexico, March 2013

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Safety, security, safeguards

Safety - Measures taken to ensure that nuclear material is not used in a way that

causes hurt or injury to persons

• IAEA Safety Glossary: The achievement of proper operating conditions, prevention of accidents

or mitigation of accident consequences, resulting in protection of workers, the public and the

environment from undue radiation hazards.

Security - Measures taken to ensure that nuclear material and facilities are

protected

• INFCIRC/225, Nuclear Security Recommendations on Physical Protection of Nuclear Material

and Nuclear Facilities: “The overall objective of a State’s nuclear security regime is to protect

persons, property, society, and the environment from malicious acts involving nuclear material

and other radioactive material.”

Safeguards - Measures taken to protect the public by preventing the spread of

nuclear weapons

• Article III.A.5 of the Statute of the International Atomic Energy Agency, approved Oct 1956:

“…establish and administer safeguards designed to ensure that special fissionable and other

materials, services, equipment, facilities, and information made available by the Agency or at its

request or under its supervision or control are not used in such a way as to further any military

purpose”.

3SDB, University of New Mexico, March 2013

5


Safety, security, safeguards

To add to the confusion:

• The U.S. Nuclear Regulatory Commission has a committee named the

“Advisory Committee on Reactor Safeguards” that has the following

responsibilities: “Reviews and advises the Commission with regard to the

licensing and operation of production and utilization facilities and related

safety issues, the adequacy of proposed reactor safety standards, technical

and policy issues related to the licensing of evolutionary and passive plant

designs, and other matters referred to it by the Commission. Upon request,

reviews and advises with regard to the hazards of the Department of Energy

(DOE) nuclear activities and facilities and provides technical advice to the

DOE Nuclear Facilities Safety Board. On its own initiative, may conduct

reviews of specific safety-related items. Submits a report to the Commission

commenting on the NRC Safety Research Program.”

• Some languages have only one word for safety and security

3SDB, University of New Mexico, March 2013

6


Safety, security, safeguards

• Communication and cooperation are essential to ensuring safety,

security and safeguards (and thereby protecting the public health and

safety)

• Should be supported through the organizational structure

• Communication and cooperation can be facilitated by an effective

regulatory framework

• The regulatory authority looks at all three disciplines as part of the

licensing (and inspection) process

‣ For the U.S. NRC, a license or certificate authorizing a facility to possess

nuclear material and operate a domestic nuclear facility is contingent

on establishing and maintaining effective safety, security, and

safeguards programs.

3SDB, University of New Mexico, March 2013

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Partial Solution

• Having facility safety, security and safeguards managers report to the

same upper level manager can improve communication and

cooperation

• A “licensing” manager can fill this role

• All three disciplines are subject to licensing requirements established

by the regulatory authority

• The facility safety, security and safeguards managers should be separate

from operations

• Combining safety, security, and safeguards would be cumbersome and

not desirable, but the three must work together to be effective.

3SDB, University of New Mexico, March 2013

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Communication

Material

Accounting

Operations

• Some facilities schedule weekly

or even daily meetings to

discuss facility activities and

problems that may (or may not)

have implications for the three

disciplines

Physical

Protection

Safety

Material

Control

• All facility functions

represented: safeguards, safety,

security, operations, human

resources, etc,

3SDB, University of New Mexico, March 2013

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Safety

Security

Radiation portal

monitor

Access control

OVERLAPS

3SDB, University of New Mexico, March 2013

Safeguards

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Safety

• Classification of areas

based on radiation risk

• Minimization of

exposure

• Worker dose

monitoring

• Health monitoring for

radiation workers

• Warning sings on

radioactive materials

• Proving the reliability

• Design of

material handling

equipment

• Emergency

preparedness

• Materials accounting

• Access control

• Standard work

procedures

• Quality control

• Confidentiality

• Protecting people

• Preventing danger to

realize

Security

• Background checks on

workers

• Information security

• Proving the reliability

• Secrecy

• Physical

protection

• Technical

surveillance

• NDA

• Protecting

from people

• Environmental sampling

• Declarations

• Proving the reliability

Antero Kuusi, Nordic Society 7-8 October 2008

Safeguards

SÄTEILYTURVAKESKUS • STRÅLSÄKERHETSCENTRALEN

RADIATION AND NUCLEAR SAFETY AUTHORITY, FINLAND


S-S-S Problem – Example 1

• A fuel manufacturing facility

processed scrap and waste in an

incinerator. A maximum allowable

quantity was set as part of the safety

design basis, which assumed that the

quantity of nuclear material buildup

in the incinerator was known.

• Criticality control staff did not keep

records of accumulation of nuclear

material buildup in the incinerator.

• Nuclear material accounting and

control (i.e. Safeguards) staff kept

records of the incinerator buildup, but

did not know that it was factored into

the safety design basis or that

criticality control staff needed this

information

• A criticality accident was avoided when

Safeguards staff casually mentioned the

buildup to Safety staff.

• Enabling and encouraging

communication between safety and

safeguards staff members should have

been a requirement.

3SDB, University of New Mexico, March 2013

12


S-S-S Problem – Example 2

• In 2005 leaked radioactive waste was

discovered at the THORP spent fuel

reprocessing plant at Sellafield.

Safeguards staff had noted a change

in measurements, which were

indicative of a possible leak, and

attempted to convince management

that a problem existed, but were

ignored.

• The leak may have started nine

months before it was discovered.

Safeguards warnings went back at

least six months.

• Better communication and

cooperation between safeguards,

safety and operations might have

led to earlier discovery of the leak.

3SDB, University of New Mexico, March 2013

13


S-S-S Problem – Example 3

• A physical inventory taking may

reveal that an item is missing or that

an ID exceeds limits.

• A missing item may pose a safety

risk. It may be a criticality risk if it is

in an unapproved location.

• In response to a missing item or an

excessive ID, security will always be

called on to demonstrate that the

missing material could not have left

the site. Security and safeguards will

share responsibility for the

investigation.

• Establishing a roadmap for

communication and cooperation

before a problem is identified can

lead to faster and more effective

resolution of the problem.

3SDB, University of New Mexico, March 2013

14


Safeguards and Security

Why is material accounting & control important to security?

• Physical measures can be taken to protect against theft, but physical

protection measures cannot resolve allegations or questions of theft.

• The question “Has an item been stolen?” can only be answered by an

accounting system with complete and up-to-date records of the

facility’s nuclear material.

• Effective control over nuclear material is essential for mitigating the

risk of theft or unauthorized removal.

• Accounting records of nuclear material locations and quantities are

necessary for resolving questions of theft.

3SDB, University of New Mexico, March 2013

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Safeguards and Security

• 2004 - UN Security Council Resolution 1540 recognized the

importance of nuclear material accounting and control to

effective nuclear security

• “Develop and maintain appropriate effective physical protection

measures as well as measures to account for and secure nuclear

materials in production, use, storage or transport.”

• 2010 - Nuclear Security Summit Work Plan

• Recognized “the importance of nuclear material accountancy in

support of nuclear security.”

• 2012 - Communiqué from the Seoul Nuclear Summit

• “We encourage all States to enhance their physical protection of and

accounting system for nuclear materials….”

• Response: Increased cooperation between the IAEA Department

of Safeguards and the Department of Nuclear Security

3SDB, University of New Mexico, March 2013

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