April 8, 2013 – WNA Singapore Meeting

The International Regulatory SettingThe International Regulatory Setting for Safe Class 7 Transport for Safe Class 7 Transport

Paul GrayNordion Inc.Chairman, ISSPA

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Comprehensive Regulatory framework

for Transport Safety

Land transportRoad, Rail and Inland Waterway

Air

Sea

All 9 ClassesAll modes

Class 7All modes

The implementation of IAEA Regs into the Model and Modal Regulations

Regional: MERCOSUR/MERCOSUL (4)ADR (47), RID (45), ADN (17)

Mail

(159)

(190)

(192)

Strict (and complex!) Regulatory FrameworkStrict (and complex!) Regulatory Framework

IAEA issues specific regulations for IAEA issues specific regulations for RAM transport (SSR 6)RAM transport (SSR 6)

These are incorporated into the UN These are incorporated into the UN “Orange Book”, a set of transport “Orange Book”, a set of transport regulations for all Dangerous regulations for all Dangerous Goods (Classes 1- 9)Goods (Classes 1- 9)

Contents of Orange Book are Contents of Orange Book are interpreted into the modal interpreted into the modal regulations for each mode of regulations for each mode of transport: road, rail, air, sea, transport: road, rail, air, sea, inland waterways e.g. the inland waterways e.g. the (mandatory) IMDG Code (mandatory) IMDG Code

Regulations must be implemented in Regulations must be implemented in national laws, (often with slight national laws, (often with slight variations)variations)

UN Orange BookModel regulation

IAEASSR 6

ICAO-TI

Mandatory for Safety

Recommendation

Air Transport Regulator

Transport Industry (?)

Mainly package design approval regulator / some

transport regulator

IMO-IMDG

Minimum requirement for facilitation (?)

UNECE-ADR, AND, RID

MS with accession, ratification, etc to

Convention

Sea Transport Regulator

Expert of TDG/GHS

TRANSSC

IATA-DGR

Input from MS / Development of International Regulations

Transport Safety Regulations (SSR-6)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

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Sea TransportSea Transport

United Nations Convention on the Law of the Sea (UNCLOS) (adopted in 1982)United Nations Convention on the Law of the Sea (UNCLOS) (adopted in 1982)Safety Of Life At Sea Convention (SOLAS)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) CodeInternational 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)Sea Transport (continued)Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on board Ships (INF Code)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 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 Convention for the Suppression of Unlawful Acts against the Safety of Marine Navigation (SUA)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.

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Air TransportAir TransportChicago ConventionChicago 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 ICAOTechnical 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 Dangerous Goods Regulations of IATAof IATA• Not mandatory• In practice, airlines continue to require compliance with IATA’s current DGR

(Updated every two years)

BasicBasic Safety Concepts – SSR-6Safety Concepts – SSR-6Goal 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) Basic Safety Concepts (continued)

““Safety in Depth” principle prescribed for transport of RAM: Safety in Depth” principle prescribed for transport of RAM: package performance, compliance with requirements, package performance, compliance with requirements, emergency responseemergency response

Where necessary, multiple barriers are engineeredWhere necessary, multiple barriers are engineeredbetween the material and the environmentbetween the material and the environment

IAEA performs audits to verify implementation inIAEA performs audits to verify implementation involunteer member States. Such TranSAS missions involunteer member States. Such TranSAS missions inPanama, Brazil, Turkey, United Kingdom, France, Panama, Brazil, Turkey, United Kingdom, France, Japan have shown high levels of excellence.Japan have shown high levels of excellence.

““Packaging” and “Package” are Terms of Packaging” and “Package” are Terms of vital importancevital importance in SSR-6 in SSR-6

Package - Package - The The packagingpackaging with its with its radioactive contentsradioactive contents as as presented for transportpresented for transport

Packaging - Packaging - The assembly of components necessary to The assembly of components necessary to enclose the enclose the radioactive contentsradioactive contents completely completely

+ =

PACKAGING PACKAGE

RADIOACTIVECONTENTS

Why Regularly Review Regulations?Why Regularly Review Regulations?

Need to review technical basisNeed to review technical basisShipment of large objects from decommissioningShipment of large objects from decommissioningExtreme hot and extreme cold increasing in frequencyExtreme hot and extreme cold increasing in frequencyResources such as copperResources such as copperDigital image recordingDigital image recordingCultural diversityCultural diversity

Package Options for Package Options for Transporting Radioactive MaterialTransporting Radioactive Material

Unpackaged Unpackaged Excepted packagesExcepted packagesIndustrial packages Types IP-1, Industrial packages Types IP-1,

IP-2, IP-3IP-2, IP-3Type A packagesType A packagesType B packagesType B packagesType C packagesType C packagesOtherOther

According to the activity, physical state and fissile nature of the radioactive material, several types of package are prescribed by IAEA regulations:

Graded ApproachGraded Approach

Graded approach to transport: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 Type A Packages Have Design and Performance Testing CriteriaPerformance Testing Criteria

Design RequirementsDesign 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 Type B Packaging Functions

These are to:These are to:- - Remove heat Remove heat - Protect against impactProtect against impact- Seal the containerSeal the container- Provide gamma shieldingProvide gamma shielding- Neutron shieldingNeutron shielding- Hold the assemblies in placeHold the assemblies in place- Help with handling and tie-downHelp with handling and tie-down

Testing – Normal ConditionsTesting – Normal Conditions

Package tests for normal conditions:Package tests for normal conditions:Water Spray: Water Spray: simulates the effect of rain at the rate of 5 cm / hour for an hoursimulates the effect of rain at the rate of 5 cm / hour for an hourStacking: Stacking: simulates a compressive load equivalent to five times its own weightsimulates a compressive load equivalent to five times its own weightFree Drop: Free Drop: simulates minor mishandling by being dropped from 1.2 msimulates minor mishandling by being dropped from 1.2 m Penetration: Penetration: Simulates the penetration effect of a 6 kg steel bar dropped from 1 m, or Simulates the penetration effect of a 6 kg steel bar dropped from 1 m, or

from loading hooks or forklifts.from loading hooks or forklifts.

Testing – Accident ConditionsTesting – Accident Conditions

Type B and Type C packages are designed to withstand severe accident Type B and Type C packages are designed to withstand severe accident conditions.conditions.

Type B package tests for accident conditions:Type B package tests for accident conditions:

Mechanical: Mechanical: A drop of 9 m onto an inflexible surface and a drop of 1 m A drop of 9 m onto an inflexible surface and a drop of 1 m onto a steel pinonto a steel pin

Thermal: Thermal: Immersion for 30 minutesImmersion for 30 minutes in a 800 C firein a 800 C fireWater: Water: Immersion at 15 m underwater Immersion at 15 m underwater for 8 hoursfor 8 hours

Segregation, CSI, and TISegregation, CSI, and TI

Class 7 packages must be segregated from other packages,Class 7 packages must be segregated from other packages,from other dangerous goods, from undeveloped films,from other dangerous goods, from undeveloped films,from passengers etc. from passengers etc.

Transport Index (TI) is used to mitigate radiationTransport Index (TI) is used to mitigate radiationexposure and keep dose rates within allowable regulatory exposure and keep dose rates within allowable regulatory limits; it appears on a label affixed to the package or limits; it appears on a label affixed to the package or container container

Criticality Safety Index (CSI) is used to prevent any unsafe Criticality Safety Index (CSI) is used to prevent any unsafe accumulation of fissile packages. It appears on a label affixed accumulation of fissile packages. It appears on a label affixed to the package (or the container).to the package (or the container).

Segregation in ICAO Technical InstructionsSegregation in ICAO Technical Instructions

Provides minimum Provides minimum segregation distance segregation distance guidelinesguidelines• Based on sums of TI and

distances / locations of inner passenger cabin floors and flight decks

• Based on duration of flight

Correct Categorization of PackagesCorrect Categorization of Packages

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

contamination checks4 Bq/cm² βγ

RAM Transport: Inspection Before Departure, RAM Transport: Inspection Before Departure, in Transit, and on Arrivalin Transit, and on Arrival