1. 23 January 2017 Vienna, Austria
Regulations for the Safe Transport of Radioactive Material SSR-6 Module School for Drafting Regulations on Radiation Safety Module 2: Main Requirements on Emergency and Medical Exposure, Transport and Waste Safety
23 January 2017 Vienna, Austria
Christopher S. Bajwa
Transport Safety Unit
Regulatory Infrastructure and Transport Safety Section
Division of Radiation, Transport and Waste Safety Department of Nuclear Safety and Security
International Atomic Energy Agency

2. How does SSR 6 fit with GSR Part 1?
GSR Part 1 v SSR 6
How does SSR 6 fit with GSR Part 1?
GSR Part 1
SSR 6
To operate as an organisation
307 – Plus guidance in TS-G-1.5
To engage stakeholders
To establish and adopt regulations and guides
To regulate
To authorise facilities and activities
SSR 6 Section VIII
To inspect facilities and activities
306, 307 – Plus guidance in TS-G-1.5
To enforce

3. Contents Objective and scope Properties of radioactive material
Types of radioactive material
Safety systems and regulations
Implementing in Regulation
General use summary

4. Objective and scope

5. Exclusions
Radioactive material that is an integral part of the means of transport.
Radioactive material moved within an establishment that is subject to appropriate safety regulations in force in the establishment and where the movement does not involve public roads or railways.
Radioactive material implanted or incorporated into a person or live animal for diagnosis or treatment.
Radioactive material in or on a person who is to be transported for medical treatment because the person has been subject to accidental or deliberate intake of radioactive material or to contamination.

6. Exclusions
Radioactive material in consumer products that have received regulatory approval, following their sale to the end user.
Natural material and ores containing naturally occurring radionuclides, which may have been processed, provided the activity concentration of the material does not exceed 10 times the values specified in Table 2, or ...
Non-radioactive solid objects with radioactive substances present on any surface in quantities not in excess of the levels defined in Para. 214

7. Objective
The objective of these Regulations is to establish requirements that must be satisfied to ensure safety and to protect persons, property and the environment from the effects of radiation in the transport of radioactive material.

8. Objective This protection is achieved by requiring:
Containment of the radioactive contents;
Control of external radiation levels;
Prevention of criticality;
Prevention of damage caused by heat.

9. Scope
These Regulations apply to the transport of radioactive material by all modes on land, water, or in the air.
Transport comprises all operations and conditions associated with, and involved in, the movement of radioactive material; these include the design, manufacture, maintenance and repair of packaging, and the preparation, consigning, loading, carriage including in-transit storage, unloading and receipt at the final destination of loads of radioactive material and packages.

10. Scope
A graded approach is applied in specifying the performance standards in these Regulations, which are characterized in terms of three general severity levels:
Routine conditions of transport (incident free);
Normal conditions of transport (minor mishaps);
Accident conditions of transport.

11. Scope The requirements are satisfied:
by applying a graded approach to contents limits for packages and conveyances and to performance standards applied to package designs, depending upon the hazard of the radioactive contents.
by imposing conditions on the design and operation of packages and on the maintenance of packagings, including consideration of the nature of the radioactive contents.
by requiring administrative controls, including, where appropriate, approval by competent authorities.

12. Properties of radioactive material

13. A1 and A2 Hazard index For direct radiation in transport – A1
For radiotoxicity in transport – A2
Maximum exposure in any accident for workers and public around 50mSv
Most exposed person expected to have very small increase in risk of death over their lifetime, and
effectively no chance of acute death , even in the most severe accidents (from the radioactive material).

14. Fissile material Only applies to nuclear material
Once a “critical” amount of material is in one place a lethal amount of radiation is released
Exceptions for certain amounts and types of material – otherwise strict approval

15. Types of radioactive material

16. Transport categories of radioactive material
Low Specific Activity (LSA)
Surface Contaminated Object (SCO)
Special Form (SF) – sometimes SFRM
(consider also LDRM)
Uranium Hexafluoride
Fissile Material
Radioactive Material
LSA material
Low specific activity (LSA) material shall mean radioactive material which by its nature has a limited specific activity, or radioactive material for which limits of estimated average specific activity apply. External shielding materials surrounding the LSA material shall not be considered in determining the estimated average specific activity.
SCO material
Surface contaminated object (SCO) shall mean a solid object which is not itself radioactive but which has radioactive material distributed on its surfaces.
Special form radioactive material
…..either
an indispersible solid radioactive material or
a sealed capsule containing radioactive material
Fissile material
is the fissile nuclides uranium-233, uranium-235, plutonium-239, plutonium-241, or any material containing a combination of these radionuclides
Excepted from this definition are
natural uranium or depleted uranium which is unirradiated
natural uranium or depleted uranium which has been irradiated in thermal reactors only
Radioactive material
…..any material containing radionuclide where both the activity concentration and the total activity in the consignment exceed the values specified
material that is not radioactive material is not subject to regulatory control by requirements of TS-R-1

17. LSA and SCO
LSA
Radioactive Material dispersed in non-radioactive material
Low concentration limits hazard
Three categories
SCO
Radioactive Material in low concentrations on the surface of a non-radioactive object
Low surface concentration limits hazard
Two categories
Low Specific Activity Material - three categories of LSA
LSA-1 generally consists of unirradiated natural or depleted uranium and thorium compounds and processing ores, or material with unlimited A2 value (para 409(a))
LSA-II material includes material for which the average specific activity does not exceed 10-4 A2/g for solids and gases and 10-5 A2/g for liquids, and water with tritium up to 0.8 TBq/L (para 409(b))
LSA-III material consists of solids in which radioactive material is distributed throughout, relatively insoluble and a specific activity not exceeding 2x 10-3 A2/g (para 409(c))
Surface Contamination Object – two categories of SCO
Must be a solid object
SCO-I and SCO-II have specific limits for the maximum non-fixed contamination and fixed contamination, and combined non-fixed/fixed contamination on accessible surfaces . SCO –II allows fixed and non fixed contamination greater than SCO-I (para 413)

18. Special Form Radioactive Material
Material in a solid form that is difficult to disperse
Tested and certified against accident conditions (impact and fire)
Usually contained in non-radioactive metal sheath
NOTE – LDRM
Special Form Radioactive Material – material that is either an indispersible solid or in a sealed capsule, subject to testing and Competent Authority approval (para 415)
(A1 values apply to special form material)

19. Uranium Hexafluoride Has other hazardous properties
UN Class 6, with 8 and 7 subsidiary
Can produce HF when exposed to water

20. Fissile material
Has potential for critical mass to be formed – requires control of accumulation
Certain types safe because of low concentration or other reasons (often described as “fissile excepted”)

21. Radioactive Material Generally regulated based on quantity
Some exceptions related to very low quantities (empty packages, instruments or articles etc.)
Special form and fissile material can be a sub-category

22. Safety systems and regulations

23. UN number Classification process depends on: Uranium Hexafluoride?
Fissile?
Excepted Package?
LSA or SCO?
Type A Quantity?
Package certificate?

24. Safety system based on hazard
Graded approach, as hazard increases
Higher package standard
More controls during transport
More regulatory control before shipment
Graded approach aims to limit exposure to 50mSv in the event of an accident by:
Material specification
Packaging standards
Conveyance limitations
Administrative controls
Continuous review to ensure this is achieved

25. Package standard
Packages graded to limit possible exposure of workers and public
Unpackaged
Excepted Package
Industrial Package
Type A Package (designed to withstand normal rough handling)
Type B Package (designed to survive severe accident)
Type C Package (designed to survive severe air accident)
Excepted Packages
Least restrictive package (para 422)
Limited quantities of radioactive material that present a very low hazard (Table 4, p 51 SSR-6)
Package design requirements apply but no test requirements (paras 607 – 618)
Maximum surface dose rate = 5 µSv h-1 (para 516)
Industrial Packages (Type IP-1, Type IP-2 Type IP-3)
Maximum surface dose rate = 2 mSv h-1 (unless under Exclusive Use) [paras 527, 528]
Max TI = 10 (unless under Exclusive Use) [para 526]
Contents must be Low Specific Activity material (LSA-I, LSA-II or LSA-III) or Surface Contaminated Objects (SCO-I or SCO-II) [paras 226, 408, 241, 413]
Often in the form of drums, freight containers, etc.
Generally used to transport low specific activity materials in bulk quantities
Type A packages
Maximum TI = 10 (unless under Exclusive Use) [para 526]
Maximum activity = A1 (special form) otherwise A2
Type B Packages – Type B (U) and Type B(M)
Designed to survive severe accidents
Maximum surface dose rate = 2 mSv h-1 (unless under Exclusive Use)
Maximum TI = 10 (unless under Exclusive Use)
Maximum activity - Competent Authority Approved
Rigorous testing regime
Competent Authority Approval of design required

26. Package standard
Maximum exposure in any accident for workers and public around 50mSv
Most exposed person expected to have much less than a 1% increase in risk of death over their lifetime, and effectively no chance of acute death (within 60 days), even in the most severe accidents (from the radioactive material).

27. Controls during transport
Pre-shipment checks (graded approach)
Normal controls (excepted package has some different controls), examples
Contamination, labels, marks, placards, Transport Index, documentation, segregation etc.
Category I, II or III labels relates to the direct radiation hazard close to the package
Transport Index relates to the direct radiation hazard at a distance from the package
Special control – exclusive use – all aspects of shipment controlled from start to finish by a single consignor or consignee

28. Regulatory oversight Certain materials require pre approval
Certain packages require pre approval
Some approvals only needed in country of origin, others in all states of transit
Some shipments require notification of all transit states

29. Schedules (SSG-33)
Provides a breakdown of conditions by UN number

30. Schedules Example – Type A
SCHEDULE FOR UN 2915
RADIOACTIVE MATERIAL, TYPE A PACKAGE,
non-special form, non-fissile or fissile-excepted
Paragraph
number(s) of the
Regulations [1]
Subject
109, 507
Other dangerous properties of contents and transport with
other dangerous goods.
301–303
General provisions for radiation protection.
304, 305, 556(c)
Emergency response.
306
Quality assurance.
311–314
Training.
501(a)
Requirements before the first shipment.
502
Requirements before each shipment.
606–616
Design requirements for all packagings and packages.
617–619
Additional design requirements — air transport.
633
Design requirements for Type A packages, summary.
634–646
Additional design requirements for Type A packages.
647–648
Additional design requirements for packages containing
liquids.

31. Implementing in Regulation

32. General Requirements Paras Content Implementation 101–103 Background
Not often implemented
104–105
Objective
May be necessary as introduction
106–110
Scope
Exclusions and other properties (107, 110) important
111
Structure
201–249
SECTION II. DEFINITIONS
Always required
301–303
Radiation protection
301 and 303 may be implemented through RP legislation – but 302 is important
304–305
Emergency response
Interface with other legislation important
306
Management system
Normally implemented
307–308
Compliance assurance
Requirements on Competent Authority – may be impossible in some states
309
Non-compliance
Close links with BSS
310
Special arrangement
Required – overarching conditions
311–315
Training
Links to other legislation – 313 important

33. Choosing the UN number Paras Content Implementation 401
General provisions
Overarching requirement
402–407
Basic radionuclide values and how to calculate them
Required – to determine hazard
408–420
Classification of materials and packages
Required - how to assign a UN number
434
Special arrangement
Required - close link to 310 above

34. Controls during transport
Paras
Content
Implementation
501
Requirements before the first shipment
Required – who?
502–503
Requirements before each shipment
504–505
Transport of other goods
Required who; 505 release criteria for equipment (how do you control this)
506–507
Other dangerous goods and properties of contents
Links to other legislation
508–514
Requirements and controls for contamination and for leaking packages
508 is overarching – all paras required – who?
515–516
Requirements and controls for transport of excepted packages
Complex section – links to SSR 6 structure
517–522
Requirements and controls for transport of LSA material and SCO in industrial packages or unpackaged
All required – who?
523–524
Determination of transport index

35. Controls during transport
Paras
Content
Implementation
525
Determination of criticality safety index for consignments, freight containers and overpacks
All required – who?
526–528
Limits on transport index, criticality safety index and radiation levels for packages and overpacks
529
Categories
530–544
Marking, labelling and placarding
Required – see 545 for responsibility
545–561
Consignor’s responsibilities
545 is overarching requirement.
562–570
Transport and storage in transit
Stowage and storage – who?

36. Controls during transport
Paras
Content
Implementation
571–574
Additional requirements for road and rail
Depends on scope of legislation
575–576
Additional requirements for vessels
577–579
Additional requirements for air
580–581
Additional requirements for post
582
Customs operations
May not be appropriate in transport legislation – may be better in customs legislation
583
Undeliverable consignments
Difficult to specify in legislation
584–588
Retention and availability of transport documents by carriers
Required

37. Material and package requirements
Paras
Content
Implementation
601–605
Requirements for material classification
Material must meet these requirements in order to be classified as LSA-III, SFRM, LDRM
606
Requirements for material excepted from fissile classification
Material (from 417 f) must meet these requirements in order NOT to be classified as FISSILE
607–618
General requirements for all packagings and packages
Required – how do you control design
619–621
Additional requirements for packages transported by air
Depends on scope of legislation – except air transport often starts with a road journey
622–672
Requirements for each package type
Required
673–686
Requirements for packages containing fissile material
Specific criticality assessment requirements

38. Specification of tests/demonstrations
Paras
Content
Implementation
701–702
Demonstration of compliance
Overarching specification of how to carry out demonstrations
703
Leaching test for LSA-III material and low dispersible radioactive material
Links to 601 – 605
704–711
Tests for special form radioactive material
712
Tests for low dispersible radioactive material
713–737
Tests for packages
Links to 622 – 672

39. Approval by the CA Paras Content Implementation 801–802 General
Overarching requirements
803–816
Approval of materials and package designs
Required – sets a standard for applications
817–818
Approval of alternative activity limits for an exempt consignment of instruments or articles
Not often used, but required
819–823
Transitional arrangements
Links to IAEA publication process – may require careful editing
824
Notification and registration of serial numbers
Required
825–828
Approval of shipments
Overarching requirement and application standard
829–831
Approval of shipments under special arrangement
Special requirements
832–833
Competent authority identification marks
Required to be used – but may not need legislation
834–839
Contents of certificates of approval
May not be easy to implement – controls the content of the certificate issued
840
Validation of certificates
How to deal with foreign certificates - required

40. General use summary

41. Normal transport of radioactive material
Excepted packages make up most shipments – these are intended to be treated like general cargo packages
Type A packages carry the majority of the rest of the shipments – often medical shipments
It is unusual for normal transport operators to come across fissile material, uranium hexafluoride, special form, LSA or SCO
Industrial packages carry LSA and SCO – these tend to be large volume, heavy weight shipments
Fissile material normally has special security requirements and so normally has special carriers

42. Questions?
Thank you 50