April 8, 2013 – WNA Singapore Meeting
The International Regulatory Setting
for Safe Class 7 Transport
Paul Gray
Nordion Inc.
Chairman, ISSPA
Comprehensive Regulatory framework
for Transport Safety
The implementation of IAEA Regs into
the Model and Modal Regulations
Class 7
All modes
(190)
All 9 Classes
All modes
Air
Mail
(192)
Sea
(159)
Land transport
Road, Rail and
Inland Waterway
Regional: MERCOSUR/MERCOSUL (4)
ADR (47), RID (45), ADN (17)
2
Strict (and complex!) Regulatory Framework
IAEA issues specific regulations for
RAM transport (SSR 6)
These are incorporated into the UN
“Orange Book”, a set of transport
regulations for all Dangerous
Goods (Classes 1- 9)
Contents of Orange Book are
interpreted into the modal
regulations for each mode of
transport: road, rail, air, sea,
inland waterways e.g. the
(mandatory) IMDG Code
Regulations must be implemented in
national laws, (often with slight
variations)
Input from MS / Development of International Regulations
Expert of
TDG/GHS
IMO-IMDG
Recommendation
UN Orange Book
Model
regulation
ICAO-TI
IATA-DGR UNECE-ADR, AND, RID
IAEA
SSR 6
TRANSSC
Mandatory for Safety
MS with accession,
ratification, etc to
Convention
Sea
Transport
Regulator
Air
Transport
Regulator
Minimum requirement for facilitation
(?)
Transport
Industry (?)
Mainly package
design approval
regulator / some
transport regulator
Transport Safety Regulations (SSR-6)
TS-G-1.1 (Advisory Material)
2008
TS-G-1.2 (Emergency Response)
2002
TS-G-1.3 (RP Programmes)
2007
TS-G-1.4 (Management System)
2008
TS-G-1.5 (Compliance Assurance
2009
TS-R-1to become SSR6
Sea Transport
United Nations Convention on the Law of the Sea (UNCLOS) (adopted in 1982)
Safety Of Life At Sea Convention (SOLAS)
• SOLAS Convention 1974, entered into force on 25 May 1980
• Carriage of Dangerous Goods in packaged form (by sea) shall be in compliance
the relevant provisions of the IMDG Code (Reg. 3 of Part A of Chapter VII of
SOLAS Convention)
International Maritime Dangerous Goods (IMDG) Code
• Mandatory for the 159 contracting parties to SOLAS Convention
• Amendment 34-08 includes the requirements of TS-R-1 (2005 edition) and
security provisions (and the recommendations) of 15th edition of UN Model
Regulations.
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Sea Transport (continued)
Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level
Radioactive Wastes in Flasks on board Ships (INF Code)
• Mandatory since 2001 through Reg. 15 in Part D of Chapter VII of SOLAS Convention
• Ship carrying INF cargo complies with the INF Code requirements
International Ship and Port Facility Security (ISPS) Code
• Chapter XI-2 of SOLAS Convention
• Security provisions, not specifically on security of dangerous goods
Convention for the Suppression of Unlawful Acts against the Safety of Marine
Navigation (SUA)
• The 2005 Protocol to the 1988 SUA Convention expanded the scope to include
provisions on nuclear material.
• Adopted in October 2005, entered into force on 28 July 2010.
7
Air Transport
Chicago Convention
• On International Civil Aviation, Binding instrument (1947)
• Annex 18 = international standards and recommended practices for the safe
transport of dangerous goods by air
Technical Instructions of ICAO
• Mandatory for the 190 contracting parties to Chicago Convention
• 2011-2012 edition of the Technical Instructions of ICAO include TS-R-1 (2009
edition) and security provisions (and the recommendations) of 16th edition of
UN Model Regulations
Dangerous Goods Regulations of IATA
• Not mandatory
• In practice, airlines continue to require compliance with IATA’s current DGR
(Updated every two years)
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Basic Safety Concepts – SSR-6
Goal is to protect persons, property and the
environment through:
• Containment of the radioactive contents.
• Control of external radiation levels.
• Prevention of criticality.
• Prevention of damage caused by heat.
Basic Safety Concepts (continued)
“Safety in Depth” principle prescribed for transport of RAM:
package performance, compliance with requirements,
emergency response
Where necessary, multiple barriers are engineered
between the material and the environment
IAEA performs audits to verify implementation in
volunteer member States. Such TranSAS missions in
Panama, Brazil, Turkey, United Kingdom, France,
Japan have shown high levels of excellence.
“Packaging” and “Package” are Terms of
vital importance in SSR-6
Package - The packaging with its radioactive contents as
presented for transport
Packaging - The assembly of components necessary to
enclose the radioactive contents completely
+
RADIOACTIVE
CONTENTS
=
PACKAGING
PACKAGE
Why Regularly Review Regulations?
Need to review technical basis
Shipment of large objects from decommissioning
Extreme hot and extreme cold increasing in frequency
Resources such as copper
Digital image recording
Cultural diversity
Package Options for
Transporting Radioactive Material
According to the activity, physical state and fissile nature of the
radioactive material, several types of package are prescribed by IAEA
regulations:
Unpackaged
Excepted packages
Industrial packages Types IP-1,
IP-2, IP-3
Type A packages
Type B packages
Type C packages
Other
Graded Approach
Graded approach to transport:
• Routine conditions – incident free
• Normal conditions – minor mishaps
• Accident conditions
Excepted Package
Type A Package
Type B Package
Type A Packages Have Design and
Performance Testing Criteria
Design Requirements
•
•
•
•
•
•
•
•
•
•
excepted package requirements
minimum external dimensions
tamper proof / security seal
Withstand temperatures -40°C to
+70°C
recognized design standards
positive closing devices
containment system considerations
environmental pressure differentials
radiation shielding considerations
physical state of contents
Type B Packaging Functions
These are to:
- Remove heat
- Protect against impact
- Seal the container
- Provide gamma shielding
- Neutron shielding
- Hold the assemblies in place
- Help with handling and tie-down
Testing – Normal Conditions
Package tests for normal conditions:
Water Spray: simulates the effect of rain at the rate of 5 cm / hour for an hour
Stacking: simulates a compressive load equivalent to five times its own weight
Free Drop: simulates minor mishandling by being dropped from 1.2 m
Penetration: Simulates the penetration effect of a 6 kg steel bar dropped from 1 m, or
from loading hooks or forklifts.
Testing – Accident Conditions
Type B and Type C packages are designed to withstand severe accident
conditions.
Type B package tests for accident conditions:
Mechanical: A drop of 9 m onto an inflexible surface and a drop of 1 m
onto a steel pin
Thermal: Immersion for 30 minutes
in a 800 C fire
Water: Immersion at 15 m underwater
for 8 hours
Segregation, CSI, and TI
Class 7 packages must be segregated from other packages,
from other dangerous goods, from undeveloped films,
from passengers etc.
Transport Index (TI) is used to mitigate radiation
exposure and keep dose rates within allowable regulatory
limits; it appears on a label affixed to the package or container
Criticality Safety Index (CSI) is used to prevent any unsafe
accumulation of fissile packages. It appears on a label affixed
to the package (or the container).
Segregation in ICAO Technical Instructions
Provides minimum
segregation distance
guidelines
• Based on sums of TI and
distances / locations of
inner passenger cabin
floors and flight decks
• Based on duration of
flight
Correct Categorization of Packages
Correct Labelling (on the package) and
Placarding (on the vehicle)
RAM Transport: Inspection Before Departure,
in Transit, and on Arrival
contamination
checks
4 Bq/cm² βγ