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)

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/G
HS
IMO-IMDG

ICAO-TI

Recommendation
UN Orange
Book
Model
regulation
IATA-DGR UNECE-ADR, AND, RID

IAEA
SSR 6
TRANSSC

Mandatory for Safety

MS with accession,
ratification, etc to
SeaConvention Air

Transpo
rt
Regulat

Transpo
rt
Regulat

Minimum requirement for facilitation

(?)

Transport
Industry (?)

Mainly
package
design
approval
regulator /
some transport

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.
6

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 IATAs current
DGR (Updated every two years)
8

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 IP1, 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 -40C to
+70C
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 tiedown

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/cm