1. The International Regulatory Setting for Safe Class 7 Transport
April 8, 2013 – WNA Singapore Meeting
The International Regulatory Setting
for Safe Class 7 Transport
Paul Gray
Nordion Inc.
Chairman, ISSPA

2. Comprehensive Regulatory framework for Transport Safety
The implementation of IAEA Regs into the Model and Modal Regulations
(190)
Class 7
All modes
All 9 Classes
All modes
Air
Mail
Sea
(192)
(159)
Land transport Road, Rail and Inland Waterway
Regional: MERCOSUR/MERCOSUL (4) ADR (47), RID (45), ADN (17) 2

3. 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)
Orange Book produced by UN committee of Experts based in Geneva.

4. Input from MS / Development of International Regulations
Recommendation
Expert of TDG/GHS
UN Orange Book
Model regulation
IMO-IMDG
ICAO-TI
IATA-DGR
UNECE-ADR, AND, RID
IAEA
SSR 6
TRANSSC
Mandatory for Safety
Minimum requirement for facilitation (?)
Revised 26/Sep/2012. (From the point of view input from MS)
IMO and ICAO etc. has two or more sources, not only from UNOB changes but also from MS proposal.
As a results the regulation could be different from the original Transport of radioactive material, for instance, segregation from foodstuff.
Need a cooperation among the input groups of each Member State.
Revised 17/Oct/2012. Change the picture of ADR.
MS with accession, ratification, etc to Convention
Transport Industry (?)
Mainly package design approval regulator / some transport regulator
Sea Transport Regulator
Air Transport Regulator

5. 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)
TS-G-1.5 (Compliance Assurance
2009
Set up in 1961; the most applied of all the IAEA’s regulations – even more so than the BSS.
Two-year review and revision cycle; this was done a few years ago to bring regs into line with the timetable of the committee of experts (Orange Book)
Stress the hierachy of requirements and guides.
Note that TS-G-1.1 is 2008 and refers to previous edition.
A new edition is under way.
TS-R-1to become SSR6

6. 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 includes the requirements of TS-R-1 (2005 edition) and security provisions (and the recommendations) of 15th edition of UN Model Regulations.

7. 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.

8. 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
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)

9. 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.
Protect
Throughout this 45 year period the objectives of the Regulations have remained pretty much as they are today. Those objectives are to protect persons, property and the environment from the effects of ionising radiation during the transport of radioactive material. This protection is achieved by:
• Containment of the radioactive contents.
• Control of external radiation levels.
• Prevention of criticality.
• Prevention of damage caused by heat.
It is of note that there is no mention of protection of the radioactive contents from a security threat in these objectives.

10. 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.

11. “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 + =
PACKAGING
PACKAGE
RADIOACTIVE
CONTENTS
Overpack shall mean an enclosure used by a single consignor to contain one or more packages and to form one unit for convenience of handling and stowage during transport.
Key Points:
IAEA definitions and any related requirements and testing procedures must not be confused with terminology developed for operational or other regulatory requirements such as storage or handling of radioactive materials or wastes.
A PACKAGE is defined (TS-R-1 §230 ) as a PACKAGING with its RADIOACTIVE CONTENTS as presented for transport.
There are 8 basic PACKAGE types defined in TS-R-1 §230 There are only simple requirements relating to the PACKAGING component of the PACKAGES in the transport regulations (§606 - §616 TS-R-1).
However, the transport regulations have a comprehensive graded series of requirements and tests for all PACKAGES (SECTIONS VI and VII of TS-R-1).
The Type B(U), B(M) and Type C packages are tested to withstand extremely severe accidents without loss of contents. They are Competent Authority approved and normally licensed to carry a large RADIOACTIVE CONTENT.
The other PACKAGE types listed in § 230 are only tested to withstand routine and normal conditions of transport (§106 TS-R-1).
Consequently their RADIOACTIVE CONTENTS are limited so that any losses under accident conditions will present no significant hazard to workers or the general public.

12. 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

13. 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
Other would be by “special arrangement”
Key Points:
Explain that the package types, including unpackaged materials, addressed in this slide are discussed, in order, in this module.
Briefly state the following:
- Unpackaged materials are applicable to solids which qualify as LSA-I materials or SCO-I
- Excepted packages are limited to a very restrictive activity, usually associated with limited quantities
- Industrial packages are designed and tested to carry qualified, e.g., LSA materials and SCO, radioactive contents
- Type A packages are restricted to carry contents up to a maximum of A1 or A2.
- Type B(U) and B(M) packages are generally for contents with activities >A1 or >A2.
- Type C packages are for transport of high content activity by air
- UF6 packages are unique only to UF6 materials
- Fissile material packages are specifically designed for the fissile material content and may include IPs, Type A, Type B, Type C and UF6 packages.
Objective(s):
None
References:
Module 7
Exercises:
None at this point

14. Graded approach to transport:
Routine conditions – incident free
Normal conditions – minor mishaps
Accident conditions
Key Points:
Objective(s):
Obj 2 and 4
References:
TS-R-1, ¶106
Exercises:
TBD
Type B Package
Excepted Package
Type A Package

15. 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
Key Points:
Detailed discussion on design and testing of packages should be addressed in Module 8, “Package Requirements & Test Procedures.” At this time, simply recite the information on the slide and add minimal information as deemed appropriate.
Objective(s):
Obj. 3 and 4
References:
TS-R-1, ¶ 620
Exercises:
None

16. 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
Type B packages need to be able to meet all the excepted and Type A package criteria, as well as much tougher restrictions.
Take several years to qualify and cost around $1 dollars to manufacture
Radiolytic decomposition and gas generation
Temperature and pressure effects

17. 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.

18. 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

19. 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 more responsibility of the carrier

20. 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

21. Correct Categorization of Packages
Security people hate labels!

22. Correct Labelling (on the package) and Placarding (on the vehicle)

23. RAM Transport: Inspection Before Departure, in Transit, and on Arrival
contamination checks
4 Bq/cm² βγ
Dose rate measurement should be much lower than this for excepted packages.
The non-fixed contamination on the external surfaces of an excepted package shall be kept as low as practicable and, under routine conditions of transport, shall not exceed:
4 Bq/cm2 for beta and gamma emitters and
low toxicity alpha emitters
(b) Bq/cm2 for all other alpha emitters
These limits apply when averaged over any 300 cm2 of the surface