CNSC Oversight of Counterfeit, Fraudulent and Suspect Items

CNSC Oversight of Counterfeit, Fraudulent and Suspect Items Chantal Gélinas Hosted by the IAEA Bratislava, Slovakia January 19 22, 2016 e-doc: 4898218 nuclearsafety.gc.ca

Canadian Nuclear Power Reactor Fleet All stations are CANDU* design within design life or returned to service Safe storage state Bruce Nuclear Generating Station, Ontario A1 A2 A3 A4 Darlington Nuclear Generating Station, Ontario 1 2 A1 Pickering Nuclear Generating Station, Ontario A2 A3 A4 Gentilly-2 Nuclear Facility, Quebec Point Lepreau Generating Station, NB 1977/2012 Mwe 750 B5 1977/2012 Mwe 750 B6 1978/2003 Mwe 750 B7 1979/2003 Mwe 750 B8 1992 Mwe 881 3 4 1990 Mwe 881 1971/2005 Mwe 515 B5 1971 Safe storage state B6 1972 Safe storage state B7 1971/2003 Mwe 515 B8 1983 Safe Shutdown since Dec. 2012 1983/ 2012 Mwe 635 1985 Mwe 882 1984 Mwe 882 1986 Mwe 882 1987 Mwe 882 1993 Mwe 881 1993 Mwe 881 1983 Mwe 516 1984 Mwe 516 1985 Mwe 516 1986 Mwe 516 * 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) 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 Act Regulations Licences Regulatory documents, codes and standards The CNSC is the leading nuclear regulator in setting reporting requirements for NPPs on the detection of counterfeit, fraudulent and suspect items (CFSI) 3

Canadian Regulatory Framework (2) 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 4

Canadian Regulatory Framework (3) 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 Regulatory Framework (4) 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

Canadian Regulatory Framework (5) Preventing and reporting CFSI Nuclear facilities Nuclear power plants QA requirements Event reporting requirements CFSI reporting requirements Fuel cycle facilities Uranium mines and mills 7

Recent Cases of CFSI: Canadian NPPs Licensees investigations 2015 2014 CFSI description 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 Pressure gauge CFSI detected during the receiving inspection gauge did not match description on certificate 8

International Guidance for Preventing CFSI 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 9

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

Addressing CFSI: Canadian NPPs (2) 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 11

Addressing CFSI: Canadian NPPs (3) 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 subsuppliers 12

Addressing CFSI: Canadian NPPs (4) 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

Addressing CFSI: Canadian NPPs (5) 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

Addressing CFSI: Canadian NPPs (6) 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 Canadian NPPs supply chains Sub- NPPs suppliers original equipment manufacturer (OEM) CANDU Industry Audit Committee (CANIAC) Nuclear Industry Assessment Committee (NIAC) OEM licensees CANPAC NUPIC CNSC indirect oversight Distributors licensees CANPAC NUPIC CNSC indirect oversight supply chain processes 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 16

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

CNSC Oversight of CFSI (2) CNSC direct oversight CNSC indirect oversight CNSC Audit report CANPAC/NUPIC Audit procedure Supply chain process Receiving inspection Audit checklist Audit report Licensees CFSI guidance and training Internal event reports audit Suppliers audit + CANIAC/NIAC audit Sub-suppliers 18

CNSC Oversight of CFSI (3) 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 19

Next Steps 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 20