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B.S.MANJUNATH BHABHA ATOMIC RESEARCH CENTRE MUMBAI – 400085, INDIA
TRANSSC-37, IAEA, VIENNA, NOVEMBER 26-30, 2018 AGENDA ITEM – New Concept of ON-LINE USER’S MANUALS for EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS B.S.MANJUNATH BHABHA ATOMIC RESEARCH CENTRE MUMBAI – , INDIA
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85% 17 MILLION GLOBALLY PACKAGES TRANSPORTED /YEAR = 20 MILLION
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS GLOBALLY PACKAGES TRANSPORTED /YEAR = 20 MILLION (Ref: 15, 2018) 10% 2 MILLION 5% 1 MILLION FUEL RELATED PACKAGES NON-FUEL TYPE-B PACKAGES 85% 17 MILLION For Medicine, Agriculture, Research, Manufacturing, Non-Destructive Testing and in the Exploration of minerals TRANSPORTED BY: LARGE INSTITUTIONS WITH EXPERTISE & RESOURCES NON-FUEL RELATED PACKAGES (NON-FISSILE AND FISSILE EXCEPTED) TRANSPORTED BY: SMALL/ MEDIUM INSTITUTIONS WITH LIMITED EXPERTISE & RESOURCES BETTER REGULATORY COMPLIANCE BY ’COMPACT, COMPREHENSIVE & PRECISE’ REGULATIONS
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ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS IAEA DOCUMENTS RELATED TO ‘TRANSPORTATION OF RADIOACTIVE MATERIALS’ MAIN DOCUMENTS 1. Regulatory Requirements, 2018 (SSR-6) 2. Schedules for SSR-6, 2015 (SSG-33) 3. Advisory for SSR-6, 2014 (SSG-26) 4. Compliance Assurance, 2009 (TS-G-1.5) Documents integrated with Compliance Assurance, 2009 5.Radiation Protection (TS-G-1.3) 6.Emergency Response (TS-G-1.2) 7.Management Systems (TS-G-1.4) Documents yet to be integrated with Compliance Assurance, 2009 8. Guide for Security, 26-G 9. Physical Protection, 27-G 10. Other publications like Guidance for Import/Export, Postal…
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STRUCTURE OF PROPOSED MANUALS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS STRUCTURE OF PROPOSED MANUALS Each Manual is Specific to ONE UN SHIPMENT NUMBER OF SSG-33 Adopting the ‘Sequence of Paragraph numbers mentioned in SSG-33 for the specific UN SHIPMENT NUMBER, Manual compiles applicable requirements/ guidance from SSR-6 and SSG-26 Any other Paragraphs not mentioned in SSG-3 but referred by ‘compiled paragraphs’ are also appended immediately to ensure continuity of the subject. Ensure ‘Integrity of Paragraphs’, so that referred IAEA docs need not be referred again Also compile all Annexures, Appendices and References to the specific UN Shipment Number. This completes ‘gathering all relevant information’ specific to the UN Number in Manual’ Compile ‘perceived’ Applicable information of the Specific UN Number from Radiation Protection, Emergency Response & Management Systems
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS STRUCTURE OF PROPOSED MANUALS For facilitating the Approval from Competent Authorities, The Manual presents the gathered information in the sequence specified by Compliance Assurance
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Proposed to be an ‘ON-LINE INFORMATION TOOL OF IAEA’
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS ADVANTAGES OF ON-LINE MANUALS SPECIFIC TO EACH UN SHIPMENT NUMBER Proposed to be an ‘ON-LINE INFORMATION TOOL OF IAEA’ ‘Stand Alone Document’ for each UN Shipment Number: 26 Nos Comprehensive, Precise and Compact for Most Common Shipments (85% Shipments) or no need to refer 10 IAEA Documents Harmonizes the Regulatory Standards/Documents published at different times, ‘to improve Interpretation’ Uniform implementation across the World IAEA can communicate to users any other latest information regarding ‘Any UN shipment number’ ‘No Modifications/ Changes in Text and Paragraph numbers’ of referred IAEA Standards. Can be prepared by only 3 of 14 Steps (or in TWO months) by a small IAEA Team.
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SPECIFIC TO A UN SHIPMENT NUMBER
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS ADVANTAGES OF ON-LINE MANUALS SPECIFIC TO A UN SHIPMENT NUMBER 14th Step (1 Month) STD-1 12th Step (4 Month) STD-3 10th Step (6 Month) STD-2 9th Step ‘Manuals are Real Time IAEA Tools’, to communicate revised Regulations/information
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Experience gained/ Observations made
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Experience gained/ Observations made SAMPLE ONLINE USER’S MANUAL FOR ‘SHIPMENTS UNDER UN NO: 3332’ RADIOACTIVE MATERIAL, TYPE A PACKAGE SPECIAL FORM, non-fissile or fissile-excepted Different types of Nucleonic gauge sources Low activity sources used in intracavitary brachytherapy 3. Low activity sources used in interstitial brachytherapy 4. Calibration sources: Cs-137 of activities 1 TBq and 0.1 TBq 5. Calibration sources: Co-60 of activities 50 GBq and 0.5 GBq 6. Calibration source: Sr-90 of activity 0.4 GBq or more 7. Am-Be well logging sources
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Experience gained/ Observations made: Considerations made for preparing ‘Sample Manual of UN NO: 3332’ for ‘Most Common Transportations’ Radioactive materials are Non-Fissile or Fissile Excepted & Solid No Surface Contamination Always meets Type A requirements Supplementary to Sample Manual for less frequent shipments like: When Radioactive Materials are Fissile Excepted, in Liquid or Gas Form and An Exempt Material/ Consignment When Packages, Overpacks, freight containers and Conveyances have Surface Contamination When Packages are transported as Special Arrangement Exclusive Use and by Postal arrangements
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Experience gained/ Observations made: Procedure followed during Preparation of Manual specific to UN:3332 Notations adopted to integrate paragraphs of referred Standards/ Documents in Manual For Regulations, SSR : #C (Mentioned at the beginning of Paragraph in Manual) Notations for Other Standards/ Documents (Mentioned at the end of Paragraph in Manual) (b) For Advisory Material, SSG-26 : #A (c) For Schedules, SSG-33 : #S (d) For Compliance Assurance : #CA (e) For Radiation Protection : #RP (f) For Emergency Response : #ER (g) For Management Systems : #MS
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Experience gained/ Observations made: Typical Page of Sample Manual It is the consignor’s responsibility to comply with the requirements of marking, labelling and placarding. ( S#) C# 545. Except as otherwise provided in these Regulations, no person may offer radioactive material for transport unless it is properly marked, labelled, placarded, described and certified on a transport document, and otherwise in a condition for transport as required by these Regulations. ( S#) The consignor should take appropriate actions according to its management system to ensure that compliance with the requirements can be demonstrated. This does not mean that actions such as placarding the vehicle have to be carried out by the consignor (A# 545.1).
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Experience gained/ Observations made: ‘A portion from a Page’ of Compliance Assurance, as included in Manual ANNEX-CA CA# Compliance Assurance for the Safe Transport of Radioactive Material, Safety Guide No. TS-G-1.5, 2009 42. Proposed route : C# 108, C# 554, C# 576, C# 837, C# ANNEX I (c) 43. Type of conveyance : C# 524, C# 546(l), C# 554, C# 566, C# Table 10, C# 607, C# 837(e) 44. Operational controls : C# 837(g) during shipment 45. Storage in transit : C# 106, C# 562, C# 563, C# 564, C# 565, C# 566 46. Stowing, handling and : lifting 47. Radiation protection : C# 802(d), C# 576(a) programme for IAEA TS-G-1.3, 2007 (RPP) special use vessels RP# Annex I, II, III, VIII, IX, X and XI
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Experience gained/ Observations made: Preliminary quantification of the ‘Effort Saved’ by referring to Manual Total Pages in Sample Manual : 197 (Not considering other shipments under UN:3332, Font sizes, Page Width, Line Spacing, etc Estimated number of pages for ‘Other Conditions : 100 and Fissile-Excepted Shipments’ Total Number of Pages from Seven IAEA Documents, : 1211 referred by Manual (Without editorials, forewords, Contributors, Bibliography and Index) Less number of Pages referred by Users, : 1211 – 297 by adopting this Manual = 914 Pages Pages in Manual is expected to increase by another 50 pages, when requirements from Standards published after 2009 are also included
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PROPOSED FUTURE ACTIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS PROPOSED FUTURE ACTIONS 1. IAEA is required to Develop a Software for ‘DETERMINATION OF THE UN SHIPMENT NUMBER’ which shall subsequently link the ‘User to Applicable Manuals’ Typical Inputs for Software of ‘Non-Fissile Shipments’ are: Radio-Isotope: Single/ Mixture 8. Package Detail: If, empty Total Activity Activity: Packaged/ Unpackaged Physical Form: Solid/Liquid/Gas Article/ Instrument Special Form : Yes/No If Surface Contamination Mass of Radioactive Material a. Fixed/ Non-fixed Mode of Transport b. Surface Area: Conveyance Details Fissile Materials need more exhaustive Inputs 2. Explore including in applicable Manuals: ‘Typical Package Configurations with Specifications’ which can meet all compiled requirements
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Suggestions for Compact, Comprehensive & Widely Adoptable Manuals Each UN Shipment Number may have A MAIN MANUAL (b) A SUPPLEMENTARY MANUAL and (c) A FISSILE RELATED ADDITIONAL MANUAL a. Main Manual for the ‘Most Prevalent Conditions of Transport’ b. Fissile related Manual for ‘Fissile Excepted and Fissile Materials’ c. Supplementary Manual for ‘Conditions Excluded in both above Manuals’ like Liquids and Gases, Contaminated, Damaged and Leaking sources/Packages/Conveyances and for any other extra-ordinary situations ‘Segregating’ the requirements of Emergency Response, Security, Management Systems and Radiation Protection for packages other than Type-B, Type-C & Fissile-Excepted/Fissile packages, Greatly Simplifies Documents and Procedures for Demonstration of Regulatory Compliance for a Majority of Shipments.
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Some of the Manuals on ‘Radioactive Material Transportation’ Manual of Training Course series no. 1 “Safe Transport of Radioactive Material”, Fourth Edition, IAEA, 2006 Reactor Concepts Manual for “Transportation of Radioactive Material” by USNRC Technical Training Center “Radioactive Material Transportation Practices Manual” for Use with DOE O 460.2A, 2008 HazMat Team Emergency Response “Manual for Class 7 Transport Emergencies”, Canadian Nuclear Safety Commission, July 2009 Radioactive Materials Packaging and Transportation, “Basic Primer. Office of Science”, USDOE, 2009 “Radioactive Materials Packaging and Transportation”, DOE/Oak Ridge Office, 2013 Radiation Safety Manual 2016, Chapter 7-Transportation of Radioactive Material, Environmental Health and Safety Office
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Requirement of ‘AN ASSESSMENT MANUAL FOR COMPETENT AUTHORITIES’ as discussed in an IAEA international conference titled “Safety of Transport of Radioactive Material” , in Vienna during 7–11 July 2003 After Technical Session-2 on Invited Paper “Experience with TranSAS, A key to compliance assurance” by L. BAEKELANDT, Federal Agency for Nuclear Control, Brussels, Belgium, following discussions occurred: E.W.BRACH (USA): …the TranSAS team suggested that “the Radioactive Material Transport Division should prepare and implement a technical instruction document, i.e. An “assessment manual” that provides guidance for the review and approval of applications for package design, special form and low dispersible radioactive materials, special arrangements, shipments, and radiation protection programmes.” ….. I was wondering whether the IAEA’s Secretariat has considered preparing one.
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Requirement of ‘AN ASSESSMENT MANUAL’ FOR COMPETENT AUTHORITIES as discussed in an IAEA international conference titled “Safety of Transport of Radioactive Material” , in Vienna, 7–11 July 2003 G.J. DICKE (IAEA): As emphasized at Transport Safety Standards Committee (TRANSSC) meetings, there is a need for quite a few manuals in the radioactive material transport area. Unfortunately, the resources made available for work in this area through the IAEA budget are limited. At recent meetings, TRANSSC has discussed the possibility of IAEA Member States doing more to help the Secretariat with the preparation of manuals. From the good practices identified during TranSAS missions, it is clear that much relevant expertise exists in Member States. Note: Proceedings of Transport Safety Standards Committee (TRANSSC) meetings held in 2003 are not available on-line
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Requirement of ‘AN ASSESSMENT MANUAL’ FOR COMPETENT AUTHORITIES as discussed in an IAEA international conference titled “Safety of Transport of Radioactive Material” , in Vienna, 7–11 July 2003 R.B.POPE (IAEA): The suggestion regarding the preparation and implementation of an “assessment manual” resulted from the fact that the TranSAS team had established that the Radioactive Materials Transport Division had been working on such a document for some time. Like Mr. Brach, I believe that the “assessment manual”, when finalized, could benefit competent authorities throughout the world. As indicated by Mr. Dicke, because the IAEA’s Secretariat is operating under severe resource constraints, it would like to make available what some competent authorities already have available in this area to the competent authorities of the other IAEA Member States so as to assist them in their work.
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FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Requirement of ‘AN ASSESSMENT MANUAL’ FOR COMPETENT AUTHORITIES as discussed in an IAEA international conference titled “Safety of Transport of Radioactive Material” , in Vienna, 7–11 July 2003 C. PECOVER (United Kingdom): That is clearly a matter that TRANSSC should focus on. “SUMMARY BY THE CHAIRPERSON” One of the five noteworthy points emerged from the Discussion after Technical Session-2: A suggestion made during the UK TranSAS mission prompted a request for the IAEA Secretariat to consider developing an “assessors manual” for competent authorities, to assist in harmonizing the interpretation of regulatory requirements.
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Words of The Director General, IAEA
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Words of The Director General, IAEA as mentioned in forewords of IAEA Publications “Standards are only effective, if they are properly applied in practice” AKNOWLEDGEMENTS Mr. PAUL HINRICHSEN For encouraging to make this presentation and DR. A.N. NANDAKUMAR For Guidance during Preparation of Sample Manual
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Summary of Presentation
ON-LINE USER’S MANUAL FOR EFFECTIVE APPLICATION OF IAEA TRANSPORT REGULATIONS Summary of Presentation Online Manuals can be an ‘Effective Tool’ in implementing Regulations for Most Common Shipments to communicate ‘Latest, Precise and Comprehensive Requirements’ to Specific Users. Manuals can be used to ‘Harmonize the IAEA Documents’ which are published in different time-scales. The ‘Compliance Assurance’ shall include requirements from IAEA Standards published after 2009. The ‘Sample Manual’ highlighted the ‘Effort saved by Users’ and suggested ‘Developing a Software to Determine the UN Shipment Numbers and other Applicable Manuals’. The Online Manuals could facilitate ‘Application of Standards in Practice’ as desired by DG, IAEA and the observation of an IAEA Conference in 2003.
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Thanks for Your Attention
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