cnsc oversight of counterfeit, fraudulent and suspect · pdf filecnsc oversight of...

nuclearsafety.gc.ca

CNSC Oversight of Counterfeit, Fraudulent and Suspect Items

Chantal Gélinas Hosted by the IAEA Bratislava, Slovakia January 19–22, 2016 e-Doc: 4898218

All stations are CANDU* design

In service or returned to service Safe storage state

In service within design life

Canadian Nuclear Power Reactor Fleet

In service 1983 Safe Shutdown since Dec. 2012 In service

1983/ 2012 Mwe 635

1 2

3 4

In service 1993

Mwe 881

In service 1993

Mwe 881

In service 1992

Mwe 881

In service 1990

Mwe 881

A2 A4 A3 A1

B5 B8 B6 B7

In service 1971 Safe

storage state

In service 1971/2003 Mwe 515

In service 1972 Safe

storage state


In service 1983

Mwe 516

In service 1986

Mwe 516

In service 1984

Mwe 516

In service 1985

Mwe 516

In

M

A2 A4 A3 A1

B5 B8 B6 B7





service 1985 we 882

In service 1987

Mwe 882

In service 1984

Mwe 882

In service 1986

Mwe 882

Bruce Nuclear Generating Station, Ontario

Darlington Nuclear Generating Station,

Ontario

Pickering Nuclear Generating Station, Ontario

Gentilly-2 Nuclear Facility, Quebec

Point Lepreau Generating Station, NB

* CANDU (Canada Deuterium-Dranium) is a pressurized heavy water reactor (PHWR) type that uses heavy water for moderator and coolant, and natural uranium for fuel

2

Canadian Regulatory Framework (1)

3

Act

Regulations

Licences

Regulatory documents, codes and standards

Canadian nuclear facilities regulations • Class IA: nuclear power plants (NPPs) • Class IB small reactors particle accelerators uranium fuel fabrication facilities nuclear processing facilities nuclear waste disposal facilities

• Class II prescribed equipment nuclear facilities of prescribed equipment

• Uranium mines and mills

The CNSC is the leading nuclear regulator in setting reporting requirements for NPPs on the detection of counterfeit,

fraudulent and suspect items (CFSI)

4

• Canadian nuclear facilities regulations An application for a licence in respect of a … nuclear facility …shall contain the following information… the proposed quality assurance program for the activity to be licensed

• A licensee’s quality assurance (QA) and management system

(MS) program shall be in compliance with the regulatory document or standard specified in their licence conditions handbook

• CNSC oversight of a licensee’s QA / MS provides assurance to the Commission that management and support processes are adequately implemented across all safety and control areas


Licensees’ QA programs • Licensees shall be in compliance with the CSA standard CSA N286,

Management system requirements for nuclear facilities

• This standard contains elements and requirements for preventing CFSI such as sharing of experiences audit programs purchasing requirements and supplier acceptability requirements receipt and inspection of items commissioning and testing surveillance and monitoring training program disposal of non-confirming items

5


• Canadian NPPs responsible for preventing, detecting and reporting on the

discovery of CFSI to regulator

• The CNSC ensures NPPs have measures in place for preventing,

detecting and reporting on the discovery of CFSI

issued regulatory document REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants in May 2014:

“The licensee shall report on the discovery of counterfeit, fraudulent or suspect items during the conduct of licensed activities”

6


7


Preventing and reporting CFSI

Nuclear facilities QA requirements

Event reporting

requirements

CFSI reporting

requirements

Nuclear power plants

Fuel cycle facilities

Uranium mines and mills

Recent Cases of CFSI: Canadian NPPs

8

Licensees’ investigations CFSI description

2015

Nuclear class valves: two inches and smaller • CFSI not detected and installed in the plant • non-conforming valve material: material properties did not meet

ASME boiler and pressure vessel requirements

2014 Pressure gauge • CFSI detected during the receiving inspection • gauge did not match description on certificate

International Guidance for Preventing CFSI

9

1990 EPRI NP-6629: Guidelines for the Procurement and Receipt of Items for Nuclear Power Plants (Appendix C: Identifying Substandard/Fraudulent Items)

2000 IAEA TECDOC-1169: Managing suspect and counterfeit items in the nuclear industry (document revised in 2016)

2009 EPRI Plant Support Engineering: Counterfeit and Fraudulent Items • Mitigating the Increasing Risk (issued in 2009, revised in 2014) • A Self-Assessment Checklist (issued in 2010)

2011 NEA/CNRA Report R(2011)9: Operating Experience Report: Counterfeit, Suspect and Fraudulent Items

2013 NEA/CNRA Report R(2012)7: Regulatory oversight of non-conforming, counterfeit, fraudulent and suspect items

Addressing CFSI: Canadian NPPs (1)

Licensees’ QA programs • A licensee’s QA program shall be in compliance with the requirements of

the CSA N286 standard

• NPPs ensure their program elements adequately address CFSI by implementing audit programs that ensure the use of only audited, qualified and reputable

suppliers

introducing CFSI awareness training programs for their personnel

checking for CFSI at the receipt of a item, before and after installation, and via periodic inspection and surveillance testing during operation

including contractual requirements for suppliers and sub-suppliers to prevent, detect and dispose of CFSI

disposing of non-conforming items so that CFSI are not reintroduced in the supply chain

10


11

Members of CANDU Owners Group (COG) • COG is a non-profit corporation, formed in 1984 by CANDU owning utilities

• All CANDU operators in the world are members of COG

• COG provides a platform for preventing and detecting CFSI

sharing operating experiences (COG partnerships and affiliations)

World Association of Nuclear Operators (WANO) and COG share operating experience, industry best practices and station performance information

COG is an EPRI member on behalf of its affiliated members

Supplier audit program CANDU Procurement Audit Committee (CANPAC) Program formed in 2002 for auditing supplier quality programs


Supplier audit programs • Licensees conduct supplier audits and use the services of CANPAC and

Nuclear Procurement Issues Committee (NUPIC) for assessing suppliers’ quality programs

• Licensees are members of CANPAC and NUPIC

CANPAC is a COG program

NUPIC members include all domestic U.S. nuclear utilities and several international members including Canada

• Use criteria specifically addressing suppliers’ processes for preventing and detecting CFSI

• Audit checklists include the verification of CFSI for suppliers and sub-suppliers

12


Suppliers’ QA programs •Licensees’ audit checklists contain specific requirements for preventing CFSI and other requirements mainly from the CSA Z299 series of standards

CSA Z299 was used worldwide as a recommended quality assurance standard for items

it has not been updated since 1986 and is not longer supported by the CSA Group

•Licensees’ audit checklists include requirements for sub-suppliers

•The CNSC verifies CFSI control in the licensees’ audit checklists

13


CSA N299 series • Licensees, suppliers and CNSC staff are working with the CSA Group

for the issuance of the CSA N299 series of standards (target date: Q3 2016)

describes the QA program requirements for the supply of items and services for NPPs

contains specific requirements addressing CFSI

applies to suppliers and sub-suppliers when specified by the customer

• CSA N299 series is triggered by an NPP adhering to a management system based on CSA N286 standard and applies to suppliers and sub-suppliers

14


Reporting events and CFSI • To the CNSC:

in accordance with regulatory document REGDOC-3.1.1

• Through partnerships and affiliations:

COG and CANPAC

NUPIC

EPRI

• Through international reporting systems

15

Oversight of Licensees’ Supply Chains

16

OEM

Sub- suppliers

Distributors

NPPs’ supply chain

processes • licensees • CANPAC • NUPIC • CNSC indirect

oversight

• original equipment manufacturer (OEM)

• CANDU Industry Audit Committee (CANIAC)

• Nuclear Industry Assessment Committee (NIAC)

• licensees • CANPAC • NUPIC • CNSC indirect

oversight

• CNSC direct oversight

CANIAC & NIAC: • groups formed to share auditing services among members • membership to suppliers with quality programs • CANIAC to be implemented • NIAC formed in 1994 in USA

Canadian NPPs’ supply chains

CNSC Oversight of CFSI (1)

CNSC oversight of NPPs’ supply chains

•Inspect licensees’ supply chain processes including supplier audit and qualification processes done by their third-party auditors (i.e., CANPAC and NUPIC)

•Participate as observer at CANPAC and NUPIC meetings and during audits of licensees’ suppliers

•Contribute to the development of the industry standards (such as the CSA N286 and CSA N299 series)

17

18

CNSC

Suppliers

audit audit

Audit report

Audit checklist

Audit procedure

Supply chain

process

Receiving inspection

Internal event

reports

Licensees

CNSC direct oversight CNSC indirect oversight

Audit report

CFSI guidance

and training

CANPAC/NUPIC

Sub-suppliers audit CANIAC/NIAC +



19

National and international activities

• Commission meetings: technical briefings on CFSI

• Participate in industry meetings and workshops: COG/OCI

• Participate in NEA/WGOE, WGIP and CFSI Task Group

• Participate in NEA/MDEP-VICWG and exchange CFSI information

• Contribute to the upcoming edition IAEA-TECDOC-1169, Managing suspect and counterfeit items in the nuclear industry

Next Steps

20

CNSC plans to consolidate regulatory requirements and guidance on CFSI

• Document the CFSI regulatory framework

• Describe the management system requirements applicable to CFSI

• Describe CFSI expectations

• Highlight CFSI threats

cnsc oversight of counterfeit, fraudulent and suspect · pdf filecnsc oversight of...

Documents