Presentation on theme: "The International Regulatory Setting for Safe Class 7 Transport"— Presentation transcript:
1The International Regulatory Setting for Safe Class 7 Transport April 8, 2013 – WNA Singapore MeetingThe International Regulatory Settingfor Safe Class 7 TransportPaul GrayNordion Inc.Chairman, ISSPA
2Comprehensive Regulatory framework for Transport Safety The implementation of IAEA Regs into the Model and Modal Regulations(190)Class 7All modesAll 9 ClassesAll modesAirMailSea(192)(159)Land transport Road, Rail and Inland WaterwayRegional: MERCOSUR/MERCOSUL (4) ADR (47), RID (45), ADN (17)2
3Strict (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 CodeRegulations must be implemented in national laws, (often with slight variations)Orange Book produced by UN committee of Experts based in Geneva.
4Input from MS / Development of International Regulations RecommendationExpert of TDG/GHSUN Orange BookModel regulationIMO-IMDGICAO-TIIATA-DGRUNECE-ADR, AND, RIDIAEASSR 6TRANSSCMandatory for SafetyMinimum 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 ConventionTransport Industry (?)Mainly package design approval regulator / some transport regulatorSea Transport RegulatorAir Transport Regulator
5Transport Safety Regulations (SSR-6) TS-G-1.1 (Advisory Material)2008TS-G-1.2 (Emergency Response)2002TS-G-1.3 (RP Programmes)2007TS-G-1.4 (Management System)TS-G-1.5 (Compliance Assurance2009Set 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
6Sea TransportUnited 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 1980Carriage 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) CodeMandatory for the 159 contracting parties to SOLAS ConventionAmendment includes the requirements of TS-R-1 (2005 edition) and security provisions (and the recommendations) of 15th edition of UN Model Regulations.
7Sea 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 ConventionShip carrying INF cargo complies with the INF Code requirementsInternational Ship and Port Facility Security (ISPS) CodeChapter XI-2 of SOLAS ConventionSecurity provisions, not specifically on security of dangerous goodsConvention 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.
8Air 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 airTechnical Instructions of ICAOMandatory for the 190 contracting parties to Chicago Conventionedition of the Technical Instructions of ICAO include TS-R-1 (2009 edition) and security provisions (and the recommendations) of 16th edition of UN Model RegulationsDangerous Goods Regulations of IATANot mandatoryIn practice, airlines continue to require compliance with IATA’s current DGR (Updated every two years)
9Basic 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.ProtectThroughout 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.
10Basic Safety Concepts (continued) “Safety in Depth” principle prescribed for transport of RAM:package performance, compliance with requirements,emergency responseWhere necessary, multiple barriers are engineeredbetween the material and the environmentIAEA performs audits to verify implementation involunteer member States. Such TranSAS missions inPanama, 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 transportPackaging - The assembly of components necessary to enclose the radioactive contents completely+=PACKAGINGPACKAGERADIOACTIVECONTENTSOverpack 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.
12Why 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
13Package 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:UnpackagedExcepted packagesIndustrial packages Types IP-1, IP-2, IP-3Type A packagesType B packagesType C packagesOtherOther 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):NoneReferences:Module 7Exercises:None at this point
14Graded approach to transport: Routine conditions – incident freeNormal conditions – minor mishapsAccident conditionsKey Points:Objective(s):Obj 2 and 4References:TS-R-1, ¶106Exercises:TBDType B PackageExcepted PackageType A Package
15Type A Packages Have Design and Performance Testing Criteria Design Requirementsexcepted package requirementsminimum external dimensionstamper proof / security sealWithstand temperatures -40°C to+70°Crecognized design standardspositive closing devicescontainment system considerationsenvironmental pressure differentialsradiation shielding considerationsphysical state of contentsKey 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 4References:TS-R-1, ¶ 620Exercises:None
16Type B Packaging Functions These are to:- Remove heatProtect against impactSeal the containerProvide gamma shieldingNeutron shieldingHold the assemblies in placeHelp with handling and tie-downType 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 manufactureRadiolytic decomposition and gas generationTemperature and pressure effects
17Testing – Normal Conditions Package tests for normal conditions:Water Spray: simulates the effect of rain at the rate of 5 cm / hour for an hourStacking: simulates a compressive load equivalent to five times its own weightFree Drop: simulates minor mishandling by being dropped from 1.2 mPenetration: Simulates the penetration effect of a 6 kg steel bar dropped from 1 m, or from loading hooks or forklifts.
18Testing – 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 pinThermal: Immersion for 30 minutesin a 800 C fireWater: Immersion at 15 m underwaterfor 8 hours
19Segregation, CSI, and TIClass 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 radiationexposure and keep dose rates within allowable regulatory limits; it appears on a label affixed to the package or containerCriticality 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
20Segregation in ICAO Technical Instructions Provides minimum segregation distance guidelinesBased on sums of TI and distances / locations of inner passenger cabin floors and flight decksBased on duration of flight
21Correct Categorization of Packages Security people hate labels!
22Correct Labelling (on the package) and Placarding (on the vehicle)
23RAM Transport: Inspection Before Departure, in Transit, and on Arrival contamination checks4 Bq/cm² βγDose 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 andlow toxicity alpha emitters(b) Bq/cm2 for all other alpha emittersThese limits apply when averaged over any 300 cm2 of the surface