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

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

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.

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

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

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.

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.

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)

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.

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 + = 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.

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 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

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

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

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

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 more responsibility of the carrier

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 Security people hate labels!

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 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) 0.4 Bq/cm2 for all other alpha emitters These limits apply when averaged over any 300 cm2 of the surface