May 14, 2021

ROSTECHNADZOR REPORTS ON NUCLEAR SECURITY FOR 2020

On March 23, 2021, Rostechnadzor, the Russian regulator of nuclear safety and security in the civil nuclear industry, published the reports on its activity in 2020 including the results of oversight over nuclear materials control, accounting, and physical protection (MPC&A).

The new report provides the data for the 2020 reporting period that could be used to identify trends in nuclear security and what impact Rostechnadzor's activity made over the past year. The results of MPC&A oversight of nuclear material (NM), radioactive source (RS), and radioactive waste (RW) for 2017–2020 are provided in Table 1.
According to the Rostechnadzor 2020 report, there were no cases of NM loss or unauthorized use, as well as no cases of theft or unauthorized use of RS and RW at sites under oversight. No adversary actions against NM, RS, and RW, and associated facilities were committed. At the same time, 3 anomalies in accounting for NM were detected and investigated, 15 unaccounted RS were found, including 11 orphaned RS, 16 RS were lost, and accounting data for two RS were inaccurate.

For 2020, Rostechnadzor imposed 16 fines for violations of mandatory MPC&A requirements for a total amount of 1,17 million Rubles (USD $15.681). For 2019, Rostechnadzor imposed 40 fines for violations of mandatory MPC&A requirements for a total amount of 4.23 million Rubles (USD $58.800). For 2018, 39 fines were imposed for a total amount of 3.935 million Rubles (USD $54.700).

A list of typical violations identified during the oversight of materials control and accounting (MC&A) and physical protection (PP) of NM, RS, and RW is provided in Table 2. The table compares results of Rostechnadzor oversight activity in 2017, 2018, 2019, and 2020.

Table 2 provides evidence of trends in MPC&A violations. Categories of violations (MPC&A elements affected by the violations) mostly remain the same over four years (2017-2020). However, the number of violations within a specific category and details of violations vary. Rostechnadzor qualifies most MPC&A violations as those of medium severity. Only the violations related to access control points equipment (access control points equipment not fully ensuring the authorized access of people and vehicles and the prevention of unauthorized movement of prohibited items) are considered to be of high severity. Below is an overview of trends in specific violations, as well as Rostechnadzor efforts aimed at eliminating and preventing the violations.

Violations of requirements to control and accounting for nuclear material
Following violations in control and accounting for NM substantially decreased compared to 2019:

– Violations in maintaining accounting records;
– Lack of measures that prevent movement of NM into and outside material balance areas bypassing key measurement points;
– Lack of inspections of installed seals.

At the same time, there are violations that remained frequent in 2020. Examples of such violations are:

– Lack of site regulation assigning personnel responsible for MC&A in site material balance areas (MBAs);
– The use of seals that do not comply with national standards;
– Violation of requirements to the physical inventory, including validation of the actual presence of accountable items, timely submission of inventory reports, as well as verification of consistency between accounting records and inventory listing;
– Violation of requirements to establishing and documenting MBAs at sites;
– Violations of requirements for sites document to define deadlines for conducting MC&A measurements, requirements to calibration of measurement equipment;

Also, several new frequent violations emerged in 2020 compared to 2019:
– Lack of approved measurement methods for MC&A measurements;
– Violation of requirements to training and testing MC&A personnel;
– Violation of requirement for site regulations to define the scope of confirmation measurements conducted during nuclear material transfers and deadlines for conducting the measurements.

Violations of requirements to control and accounting for radioactive substances and radioactive waste
Most violations that Rostechnadzor qualified as typical in 2019 remained typical in 2020 as well. Examples of violations are:
– Lack of site MC&A policies and instructions;
– Violations in maintaining accounting and reporting documents, as well as submitting them to state accounting system;
– Violations of requirements to sealing program;
– Violation of physical inventory procedures and deficiencies in the procedures;
– Lack of personal licenses that chief MC&A personnel should receive from Rostechnadzor and violation of requirements to MC&A personnel training and testing;
– Deficiencies in measurement program.

Violations related to non-conduct of physical inventories decreased compared to 2019, however violations associate with deficiencies in physical inventories procedures and compliance with these procedures remain typical.

Violations of PP requirements at Nuclear Sites
The following type of violations in PP at nuclear sites substantially decreased compared to 2019:
– Access control points equipment not fully ensuring the authorized access of people and vehicles and the prevention of unauthorized movement of prohibited items, such as NM, RS, explosives, and metal objects;
– Violations of requirements to vulnerability assessment of nuclear sites and evaluation of PP system effectiveness. At the same time there were violations repeating in 2019 that remained frequent in 2020 as well. Examples of such violations are:
– Shortage of PP equipment in the secure areas (protected and internal) or installation of PP equipment in a way precluding it from performing its intended task;
– Absence or a need for revision of certain organizational documents (regulations, plans, instructions)

Also, a new frequent violation emerged in 2020 compared to 2019:
– Categorization of PP objects, rooms, and buildings at the nuclear site being inconsistent with regulations.

Finally, some of the violations present in 2017-2018 but absent in 2019 re-appeared:
– Violations of regulatory requirements in training and admission for work with equipment for PP personnel, as well as knowledge assessments of work and safety instructions;
– Non-compliance with technical regulations as this relates to planning maintenance and operation of PP equipment, as well to the conduct of operability tests and monitoring equipment maintenance and repair.

Violations of Mandatory PP Requirements at Sites Handling Radioactive Substances and Waste
Most violations that Rostechnadzor qualified as typical in 2019 remained typical in 2020 as well. Examples of violations are:
– Some organizational documents related to PP of the site are missing or require revision;
– Adversary Model is not developed or not approved in accordance with the established procedure;
– Required level of PP at the site is not defined based on the categorization of used RS or level of PP does not meet requirements;
– Violations related to PP personnel not taking training on time.

Also, a new frequent violation emerged in 2020 compared to 2019:
– Operators did not designate personnel and/or alternate personnel responsible for PP.

The main causes of the violations remain the same over the last four years
Rostechnadzor analyzed the most common violations and identified the following main causes of MPC&A violations in 2020:
– Insufficient monitoring over compliance with mandatory MPC&A requirements by the site administration;
– Insufficient level of qualifications and training of personnel;
– Ineffective and insufficient procedures for holding tenders for the modernization of PP systems at the facilities;
– The same main causes of MPC&A violations were identified by Rostechnadzor 2017, 2018, and 2019 Annual Reports.

Rostechnadzor efforts on elimination and prevention of violations include the development of MPC&A regulations and recommendations
In 2020, Rostechnadzor issued a new revision of the key regulation governing MC&A of all civil NM in Russia Federal Norms and Rules NP-030-19 "Basic Rules of Accounting and Control of Nuclear Materials" (also known by its Russian acronym, OPUK). You can find additional information on the document in the Russian Nuclear Security Update from March 2020.

In addition, Rostechnadzor issued voluntary recommendations for operators showing possible ways of compliance with MPC&A requirements:
– RB-162-20 "Recommendations on Implementation of PP Requirements for Nuclear Facilities and Nuclear Material Storage Facilities under Design and Construction";
– RB-095-20 "Recommendations on the Use of Seals and Surveillance Equipment for Control and Accounting of Radioactive Sources and Radioactive Waste";
– RB-165-20 "Recommendations on Investigation and Accounting for Anomalies and Violations in the Control and Accounting of Radioactive Sources and Radioactive Waste.

In 2021, as a part of preventive measures, Rostechnadzor plans to keep developing the MPC&A guidelines, publish all the relevant MPC&A guidelines on its website, inform nuclear sites and organizations engaged in the use of nuclear energy on typical MPC&A violations and their causes, and implement its violations prevention program for 2020-2022. The same preventive measures were also present in the 2019 report.
The background information and other Russian Nuclear Security Update reviews of the results of Rostechnadzor nuclear security related activities in 2017–2020 could be found here:
– "Rostechnadzor Reports on Nuclear Security in First Nine Months of 2018", January 2019 Issue http://russiannuclearsecurity.com/january2019issue#rec94741795
– "Rostechnadzor Reports on Nuclear Security for First Quarter of 2019", July 2019 Issue http://russiannuclearsecurity.com/july2019issue#rec118732430
– "Rostechnadzor Reports on Nuclear Security For 2019", May-June 2020 Issue http://russiannuclearsecurity.com/may-june2020issue#rec207791500

Sources:
1. Rostechnadzor draft Order "Report on Law Enforcement Practice of Oversight Activities of the Federal Environmental, Industrial, and Nuclear Regulatory Authority in Implementation of the Federal State Oversight in the Field of Nuclear Energy, Including Issues of Federal State Construction Oversight at Nuclear Facilities, for 2020", March 23, 2021
2. May-June 2020 Issue of the Russian Nuclear Security Update http://russiannuclearsecurity.com/may-june2020issue
3. January 2019 Issue of the Russian Nuclear Security Update http://russiannuclearsecurity.com/january2019issue
4. July 2019 Issue of the Russian Nuclear Security Update http://russiannuclearsecurity.com/july2019issue