Preliminary review of comments from MS on SSR-6 17 – 20 June 2013 Agenda Item 4.4.2 Transport Safety Standards Committee Jorge López Vietri

Objective The presentation pointed out a preliminary review of comments from Member States and International Organizations on 2012 Edition of SSR-6 Regulations submitted for the 2013 Review Cycle It is aimed at identification of ISSUES ISSUE: problem identified in SSR-6, justification of the issue PROPOSAL: recommended change to address an issue

Comments MS and Intl Organization TOTAL: 63 MS: 40 IO: 23 Canada comments received after deadline: 7 (security)

Issues submitted by MS and IO (*) Identified issues Issue Issues submitted by MS and IO (*) (1) Identification mark, UN number, marking, placarding and documentation IR/1, IR/2, IR/3, E/1, F/16, F/19, ICAO/1, WNTI/5, WNTI/6, WNTI/7, WNTI/8, WNTI/10 (2) Fissile material requirements S/1, F/11, F/16, F/19, WNTI/4, WNTI/7, WNTI/10 (3) LSA material and SCO D/2, D/3, D/4, F/2, F/5, F/20, WNTI/8, WNTI/9, WNTI/11 (4) Test and design requirements D/4, F/8, F/9, F/11, F/12, F/13, F/14, F/20, WNTI/11 (5) Harmonization B/1, F/4, WNTI/1, WNTI/9, WNTI/13 (6) A1 and A2 values J/1, F/17, WNTI/3 (7) Restructuration of the Regulations S/2 (8) Large components CDN/1 (9) Emergency response F/1 (10) Dual purpose cask CH/1 (11) Editorial D/1, B/2, F/6, F/10, ICAO/2 (12) Various not otherwise considered LI/1, D/6, F/15, F/18, F/21, BR/1, WNTI/2, WNTI/12, WNTI/14, WNTI/15 (13) Advisory Material only D/5, F/3, F/7, WNTI/16, WNTI/17, WNTI/18, WNTI/19, WNTI/20, WNTI/21 (*) Identical: F/20 & WNTI/11 issues (3)-(4); F/21 & WNTI/14 issue (12) Similar: F/19 & WNTI/7 issues (1)-(2)

Identified issues (cont.) Issues submitted by MS and IO (1) Identification mark, UN number, marking, placarding and documentation IR/1, IR/2, IR/3, E/1, F/16, F/19, ICAO/1, WNTI/5, WNTI/6, WNTI/7, WNTI/8, WNTI/10 (2) Fissile material requirements S/1, F/11, F/16, F/19, WNTI/4, WNTI/7, WNTI/10 (3) LSA material and SCO D/2, D/3, D/4, F/2, F/5, F/20, WNTI/8, WNTI/9, WNTI/11 (4) Test and design requirements D/4, F/8, F/9, F/11, F/12, F/13, F/14, F/20, WNTI/11 (5) Harmonization B/1, F/4, WNTI/1, WNTI/9, WNTI/13 (6) A1 and A2 values J/1, F/17, WNTI/3 (7) Restructuration of the Regulations S/2 (8) Large components CDN/1 (9) Emergency response F/1 (10) Dual purpose cask CH/1 (11) Editorial D/1, B/2, F/6, F/10, ICAO/2 (12) Various not otherwise considered LI/1, D/6, F/15, F/18, F/21, BR/1, WNTI/2, WNTI/12, WNTI/14, WNTI/15 (13) Advisory Material only D/5, F/3, F/7, WNTI/16, WNTI/17, WNTI/18, WNTI/19, WNTI/20, WNTI/21 21%; 19% Bold – red: issue without proposed text – Need additional work Italics – red: compare proposals to take a decision – Need add work

Issue (1) – Identification mark, UN Number, marking, placarding and documentation Packaging unloaded, Radiation Level ext. surface > 5 Sv/h Confusion for involved stakeholders (including competent authorities) Type B(U) or Type B(M) returned empty (depleted uranium shielding): can not be UN2908, may be declared as: (i) LSA-I in IP-1; marks, docs?; (ii) Type B(U) / B(M) it is dangerous goods; marks and transport documents? Establish correct package identification & transport docs Corresponding to radioactive material contents no to the Type of Package design Certificate of Approval for B(U)F with two contents: B(U)F, UN 3328, and AF, UN3327; marks, UN Number, documentation? On going issue: ambiguous situations for classification of mixing material in the same package: (a) Special Form RAM UN 3332 with Non-Special Form RAM UN2915; or (b) LSA UN 2912 with UN3321; or (c) LSA UN3321 with SCO 2913 Type B(U) package containing equal or less than 1 A1 or 1 A2; marks, docs? IR/1, IR/2, IR/3, E/1, F/16, F/19, ICAO/1, WNTI/5, WNTI/6, WNTI/7, WNTI/8, WNTI/10

Issue (2) – Fissile material requirements Delete “confinement system” definition in § 209 introduced as a new concept in the 1996 Edition of the Regulations. It can be removed from all application paras in the Regulations without any negative impact. Water reflection of the package was required and water inside the package had to be considered Include a requirement for a water-reflected “containment system” to be subcritical in § 681 and § 682 (packages in isolation). This proposal necessitates a modification of the definition in § 213 Necessary: subcriticality with water reflection of the containment system with its contents and subcriticality with water reflection of the package In § 680 (b) (i) should require also the absence of interaction between “the plug” and “other components of the package” for UF6 only & up to 5% enrichment in U-235 E.g., applicable to package designs containing UF6, 30B cylinders; Plug has the same function of the valve S/1, F/11, F/16, F/19, WNTI/4, WNTI/7, WNTI/10

Issue (2) – Fissile material requirements (cont.) Allow a CSI value on the label in Fig. 5 SSR-6 (No. 7E, UN Recommendations) greater than or equal to the CSI stated in the certificates of approval applicable in the various countries concerned by the consignment For international transports, as regards the CSI: inconsistency between § 530 and § 541 Separate current § 417 “Fissile material” in two different paras: one for FISSILE and one “for fissile-excepted”. Para. 417 currently refers to both FISSILE and fissile-excepted material. Confusion: most of the time, reference to that para. is made only for fissile- excepted criteria S/1, F/11, F/16, F/19, WNTI/4, WNTI/7, WNTI/10

Issue (3) – LSA material and SCO Para. 408 “Low specific activity material” (LSA) and para. 412 “Surface contaminated object” (SCO): delete reference to paras do not relate to LSA Material or SCO classification Delete text related to Leaching Test for LSA-III material in paras 409 (c) (ii), 601 and 701 (a), and headings above paras 601 and 703. Justification of the assumptions of this test and its relevance with respect to transport safety has often been questioned. Various interpretations and implementations of this test for classification as LSA-III (radioactive waste) Limits of heterogeneity of LSA material are not clearly stated in SSR-6, but its consequences might be far beyond the radiation protection goals for human life and health in transport accident. Paras 226 and 409 (definition & LSA-III group) should be reviewed respect the influence of temperatures and vibrations in routine conditions on the activity leaching rate D/2, D/3, D/4, F/2, F/5, F/20, WNTI/8, WNTI/9, WNTI/11

Issue (3) – LSA material and SCO (cont.) Current “Surface contaminated object” definition, § 241: clarify that the contamination should be “distributed on its internal or external surface” In § 628 “Alternative requirements for Type IP-2 and Type IP-3”: it should be open the possibility to carry solid material in other tanks as already allowed for portable tanks in § 627. Idem as in UN Model and Modal regulations (ADR, RID), tanks are designed to carry gases, liquids and solids. SSR-6 Regulations should not restrict the use of other tanks to liquids and gases solely Explanation of Proposals: WNTI/8 in issue (1), WNTI/9 in issue (5) and WNTI/11 in issue (4) D/2, D/3, D/4, F/2, F/5, F/20, WNTI/8, WNTI/9, WNTI/11

Issue (4) Test and design requirements Include new provisions applied for Type B(M) packages when a mechanical cooling energized system is needed to ensure that package temperatures do not exceed the maximum allowable temperatures for the package components under the ambient conditions, 38°C + solar insolation. Document its efficiency Allow more than a 20% increase in the maximum radiation level in normal conditions of transport in some situations: exclusive use, certain radiation levels, compliance with objectives of individual annual dose limits, etc. Applied for Type B(U), Type B(M) or Type C package which does not satisfy the requirement of § 648 (b) “test for normal conditions”; it is required multilateral approval Extend the crush test to Type B(U)/Type B(M) packages (less than 500 kg) with contents > 1000 A2 and packages containing fissile material whose apparent density exceeds 1 (instead of ≤ 1000 kg/m3) D/4, F/8, F/9, F/11, F/12, F/13, F/14, F/20, WNTI/11

Issue (4) Test and design requirements (cont.) Increase the duration of: (i) 15 m water immersion test § 729, 8 hours; (ii) 0,9 m water leakage test for fissile material package § 733, 8 hours; and (iii) 200 m enhanced water immersion test § 730, 1 hour. Consistency with the complementary safety approach adopted after the Fukushima accident Provide an assessment of package temperatures when special stowage provisions are necessary to ensure the safe dissipation of heat from the package, e.g., packages with significant heat load within a confined cargo space Documented evidence: a thermal analysis should be attached to the application for approval of a Type B(U) and Type C package design for specific transport conditions D/4, F/8, F/9, F/11, F/12, F/13, F/14, F/20, WNTI/11

Issue (5) Harmonization To include the definitions of other stakeholders as “packer” (ADR, RID) and “loader” to current of “carrier”, “consignor” and “consignee” To separate the definition of “consignor” into “consignor” and “shipper”. One consignor and one or more shippers. Clarify definition of “consignor” because can be applied to different stakeholders. Confusion in ADR, RID The terminology of “radiation level” (SSR-6 and transport related docs) with “equivalent dose rate” universally used in other docs The Internal Pressure of a package transported by air that must withstand without loss or dispersal of it contents between SSR-6, UN Model and ICAO regulations (95 kPa in SSR-6; 75 kPa for liquids in Packing Group III of Class 3 or Division 6.1). It is proposed a gradual system for packages do not require approval: Excepted, Industrial and Type A The definition of “Freight containers – small, large”. In UN Model and Modal regulations “large freight containers” are those that conform to the definition of the International Convention for Safety Containers (CSC) B/1, F/4, WNTI/1, WNTI/9, WNTI/13

Issue (6) A1 and A2 values Proposal: organize a research group with radiation protection experts to assess in detail the following: Determine A1 and A2 and exempted values based in agreed calculation methods Take account of the new tool developed by the Health Protection Agency (HPA) and the Report presented in TRANSSC 24 Establish agreed methods in processes where ambiguity is identified in deriving A1 or A2 values and treatment of progeny in current Q-system. They can be incorporated in the program “SEAL” Review the transport specific scenario and transportation time to derive exemption values for transport Determine nuclides to be listed in Table 2 Use of basic radioactive values for decay chain Determine A1 / A2 and exemption values considering the ICRP publication which includes new dose conversion factors Revise appendices of Advisory Material to maintain clear record of the calculation process, or included in a TECDOC or the Technical Basis Document (TBD) J/1, F/17, WNTI/3

Issue (7) Restructuration of the Regulations SSR-6 2012 Edition SSR-6 20xx Edition Definition of Radioactive Material § 236 & associated § 402-407 together with exemption values in Tables 2 and 3 To be moved to § 106 under SCOPE in Section I, together with appropriate references to a new Annex Paras 402-407 together with A1 and A2 values in Tables 2 and 3 are needed for other purposes Move that paras together with A1 and A2 values in Tables 2 and 3 to a new Annex in SSR-6 To clean up Section IV To move “Material and package design requirements” to Section VI and the UN number assignment to Section V Multiple changes Harmonization with other regulations for transport of other dangerous goods S/2

Issue (7) Restructuration of the Regulations (cont.) SSR-6 2012 Edition SSR-6 20xx Edition Proposed Structure Sections: I Introduction; II Definition; III General provisions Sections: I Introduction; II Definition; III General provisions Section VI Requirement for radioactive material and for packagings and packages Section IV Materials, packagings and packages Section VII Test procedures, slightly expanded with more on calculation methods Section V Demonstration of compliance Section VIII Approval and administrative requirements Section VI Approval and administrative requirements Part of Section IV Activity limits and classification and Part of Section V Requirements and controls for transport Section VII Pre-shipment requirements and controls Part of Section V Requirements and controls for transport Section VIII Requirements and controls during transport S/2

Issue (8) Large Components Inclusion of a new “Large object” (LO) definition to cover the transport of large radioactive components such as equipment from decommissioning activities of nuclear facilities, categorized as surface contaminated object in a SCO-III new group Large object: a solid object which is contaminated with radioactive material and because of its size must be transported unpackaged Other modifications: (i) proper shipping name to include the SCO-III group in UN 2913, Table 1; (ii) new § 413 (c) to define the requirements to be complied by SCO-III; (iii) corresponding requirement to Section V “Requirements and controls for transport”, title of Table 7 Multiplication Factors for the transport of SCO-III both packaged and unpackaged, and Section VIII “Approval and administrative requirements” CDN/1

Issue (9) Emergency response Clear state in the “Objective” § 104 that emergency response planning and preparedness directly contribute to safety and protection goals Make mandatory the emergency plans to be used by the consignors and carriers in § 304 and to state that those plans will have to be consistent with the national emergency response plans prepared by governments and competent authorities Benefit: it is more efficient the emergency response in case of transport accident from consignors, carriers and other involved organizations. It seems to be a lack in the transport safety policy This proposal is derived from the lessons learned of the Fukushima accident F/1

Issue (10) Dual purpose cask It seems necessary to introduce a new package design that consider the safe transport of packages after short and long term storage A joint TRANSSC / WASSC Working Group established in 2011 developed the “Guidance for preparation of a safety case for a dual purpose cask containing spent fuel”, and recommended these committees to make changes to existing Safety Requirements and Guides relevant to licensing and use of transport and storage casks for spent fuel Proposed solution: introduces the Dual Purpose Cask (DPC) package in SSR-6 based on the results of that working group. Requirements for ageing demonstrations and for tracing of regulatory changes are ensured for DPC packages Expected benefit: safe transport of spent fuel packages after short and long term storage, establishing an international safety level due to international standards CH/1

Issue (11) Editorial Para. 417 “Fissile material”, 2nd sentence, replace “meets” with “meet” Para. 620 “Additional requirements for packages transported by air”, replace “containment” with “containment system”; consistency with § 621 Para. 431 “Classification as Type B(U), Type B(M) or Type C package”, replace “package” with “package design” Paras 659 (i) and (ii) “Requirement for Type B(U) packages”, align text with the one of § 659 (b) Para. 502 “Requirements before each shipment” is formed in the negative, it should be revised for the sake of clarity “… the package does not contain: … (a) … design; or” D/1, B/2, F/6, F/10, ICAO/2

Issue (12) Various not otherwise considered Delete TI limits for “seagoing vessel” in Table 10 as they were necessary when CSI did not exist. In Tables 10 & 11 for seagoing vessel the term “freight containers” should be supplemented with “closed containers” Recommend to UNECE to conduct a study to confirm or refute that UF6 subsidiary risk is toxicity (Class 8); appropriate packaging for small samples Specify the A/D value of the package on the transport documents. This allow to enhance security for contents covered by “Code of Conduct” in case of A/D exceeds 10 activity values Exclusion of Tanks and Intermediate Bulk Containers (IBC) from the requirements of § 509 and § 514 related to the level of non-fixed contamination, except from that requirement in inner surfaces of large freight containers used as packagings Introduce transitional arrangements in Section VIII covering possible evolutions in the requirements for UN packagings, IBCs, tanks and ISO freight containers used as IP-2 and IP-3 LI/1, D/6, F/15, F/18, F/21, BR/1, WNTI/2, WNTI/12, WNTI/14, WNTI/15

Issue (12) Various not otherwise considered (cont.) Issue: operational or administrative impact experienced in the preparation of land-air shipments of RAM with short half-life, e.g.: 18Fluorine (110 min) High difference between TI values measured at dispatch by vehicle and at dispatch by aircraft. Number of packages allowed in aircraft becomes smaller due to the sum of TI per conveyance Enlarge the definition in § 217 of “conveyance” to “cargo compartments” of an aircraft. Linked to the definition of “exclusive use shipment”. Consider the size of current cargo aircraft equivalent to a hold in a vessel Clarify the definition of “consignments of instruments and articles” Issue: simplification of a potentially complex regulatory approvals process can free up both industry and regulators to focus on more worthy areas in terms of safety significance (compliance assurance). It is discussed the regulatory framework for validations and suggests examples where the development of working practices and processes could be enhanced LI/1, D/6, F/15, F/18, F/21, BR/1, WNTI/2, WNTI/12, WNTI/14, WNTI/15

Issue (13) Advisory Material input only Proposals submitted are related to the following: Streamline TS-G-1.1 including text that could be into two categories: (i) Explanatory text of SSR-6 includes the technical basis for the SSR-6 and could be easily removed to the Technical Basis Document (TBD) to preserve history; and (ii) Advisory Material for SSR-6 leaving in TS-G-1.1 (a) Paras related to Classification of Excepted and Type A packages, and additional requirements for empty packagings can be moved to TBD; (b) Some paras of Section IV, V and VI should be deleted and, if relevant, be moved to TBD; (c) Some paras related to “Activity limits and material restrictions”, “Fissile material” should be moved from TS-G-1.1 to TBD (d) Some paras in Section V related to “Marking, labelling and placarding” Note: in issues (1) to (12) are also included proposals related to suggested changes to the Advisory Material D/5, F/3, F/7, WNTI/16, WNTI/17, WNTI/18, WNTI/19, WNTI/20, WNTI/21

Issue (13) Advisory Material input only (cont.) Proposals submitted are related to the following (cont.): Advice on measurement of radiation level considering background of places Clarify Maximum Normal Operating Pressure (MNOP) to take into account the production of radiolysis and thermolysis phenomena Clarify that contents and internal elements of package are wedged prior to shipment, and are in position or to cause maximum damage to containment system in drop I (§ 727 (a)) and impact test (§ 737) Expand text in para. 681.1 “Assessment of an individual package in isolation” to clarify the definition of “containment system” (§ 209), including examples Add text to paras 634.1-634.4 “Requirements for packages containing UF6” for to cylinders constructed before 1st edition of ISO 7195 (1993) about the behavior during fire test: can be solved by the H(M) approval procedure D/5, F/3, F/7, WNTI/16, WNTI/17, WNTI/18, WNTI/19, WNTI/20, WNTI/21

Conclusions and recommendations IAEA should motivate submission of comments for next review cycles Each proposal will be carefully analyzed: in few cases would be considered as “Minor change”, issue (11), and in many cases as “Detail change” or “Major change”, issues (1)-(10), (12) and (13) Ratio considered Fraction Estimated % MS Submitted Comments (SC) vs Total IAEA MS 11 / 155 7 MS & IO (SC) vs MS & IO take part of TRANSSC 13 / 40 32 Total MS (SC) vs Usual MS take part of TRANSSC 11 / 32 34 Total IO (SC) vs Usual IO take part of TRANSSC 2 / 8 25 Southern MS (SC) vs Northern MS (SC) 1 / 10 10

Conclusions and recommendations (cont.) For this and following review cycles TRANSSC should review carefully comments with the intention of not to go backward to concepts included in previous editions of IAEA Regulations E.g., a complex issue during review cycles seems to be Fissile Material. In the framework of current global circumstances, when TRANSSC will analyze the inclusion of a change in the new 20xx Edition of SSR-6 it is highly recommended to consider if such change would produce a negative impact pondering associated economic and social factors

Thank you for your atention!