TRANSPORT SAFETY AND REGULATORY REQUIREMENTS FOR LICENCING LAND

TRANSPORT SAFETY AND REGULATORY REQUIREMENTS FOR LICENCING LAND TRANSPORT OF CLASS 7 DANGEROUS

GOODS

By

Muhammad, BELLO GUSAU

Department of Authorization and Enforcement

OutlineObjectives Introduction Legal BasisTransport Safety Regulatory Requirements Recommendations

Objectives

Upon completion of this presentation, we should be able to:

Understand the basic approaches to transport safety

Safety is a mirror image of security

Recognize that transport safety measures established by application of the IAEA/NNRA Transport Regulations complement any measures that will be put in place for security during transport

Understand the regulatory requirements for licensing land transport of Radioactive Material (RM)

IntroductionUnited Nation Dangerous Goods (DGs) Classification A united Nations (UN) sub-committee of Experts classifies DGs into

NINE CLASESS. And this is the basis for dangerous goods transport regulations world wide.

Radioactive Material is classified in class 7 The other classes includes; Class 1-Explosives Class 2-Gases Class 3-Flammable Liquids Class 4-Flammable Solids Class 5- Oxidizing Substance and Organic Peroxides Class 6-Toxic and Infectious Substance Class 8-Corrosive Substances Class 9-Miscellaneous DGs and Environmentally Hazardous

Substances

Introduction cont.

Radioactive Material are widely use in every day life in a wide range of activities. According to IAEA, 10 million package shipments of RM take place each year. In Nigeria, we do not produce radioactive material, therefore, RM need to be imported and transported from the port of entry to the various facilities.

Introduction Cont.Transport comprises all operations and

conditions associated with and involved in the movement of radioactive materials; these includes the designing, loading, manufacturing, maintaining and repairing of packaging, and the preparation, consigning, loading, carriage including in–transit storage, unloading and receipt at the final destination of loads of radioactive materials and packages.

Movement could be by road or rail

Introduction cont.For the purpose of this presentation IAEA/NNRA Regulations for the Safe Transport of Radioactive Material, and Regulatory Requirements for licensing land transport of Radioactive Material will be discussed

Legal Basis for Regulating Safety of Transport of Radioactive Material

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Since 1959, the IAEA has had the mandate for the drafting of recommendations on the transport of radioactive substances

The IAEA Director General was authorized to:– promulgate the Regulations for the Safe

Transport of Radioactive Material, and– recommend to the Governments of Member

States that the Regulations be used in formulating national regulations

Regulations for the Safe Transport of Radioactive Material

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The result of this mandate has been the issuing of the IAEA Regulations for the Safe Transport of Radioactive Material

The latest edition of this set of recommendations was issued in 2005

It is the basis for binding regulations at the international modal level and at the individual State level

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The International Regulation of the Transport of all Dangerous Goods

UN Economic and Social Council

IAEA(Vienna) ICAO IMO UPU UNECE

UN Committee of Experts(Geneva)

Regulations for the SafeTransport of Radioactive

Material (Class 7)

Recommendations forthe Transport

of Dangerous Goods(Classes 1-6 & 8-9)

Regional/European Road, Rail and Inland Waterway Transport

Agreements

South AmericanMERCOSUR/MERCOSUL

NationalRegulations

Safe Transport of Radioactive Guidance Material

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The IAEA Transport Regulations are supplemented by various guidance documents including

• a set of advisory material (TS-G-1.1), and

• a guide on planning and preparingfor emergency response to transport accidents (TS-G-1.2)

• A guide on radiation protection(TS-G-1.3)

Legal Basis cont.

Detailed requirements

Practice specific requirements or guidance

Principal requirements Legislation(Nuclear Safety and Radiation Protection Act of 1995)

Nigerian Transportation of RS Regulations 2006

Codes of practice(Regulatory

Requirements)

Legal Basis Cont.Section 4-(1) Charged Nigerian Nuclear Regulatory

Authority (NNRA) with the responsibility for nuclear safety and radiological protection regulation in Nigeria

Section 6(a) Empowers the NNRA to categorize and licence activities involving exposure to ionizing radiation, in particular, the possession, production, processing, manufacture, purchase, sale, import, export, handling, use, transformation, transfer, trading, assignment, Transport, Storage and disposal of any radioactive material, nuclear material, radioactive waste and any apparatus emitting ionizing radiation.

Legal Basis cont.

Section 40(1)-The Act shall apply to the transportation of radioactive materials or waste by

land, water or air40 (2)-In addition to the provisions of this act, the

general regulations for the transportation of dangerous goods by land, water and air, including the regulation on goods having hazardous characteristics shall apply to the transportation of radioactive material by land, water and air

Nigerian Transportation of Radioactive Sources Regulations, 2006

Legal Basis cont.40 (3) Radioactive materials or waste stored in

transit shall be stored and handled in accordance with the regulations laid down in the code of practice

Nigerian Safety and Security of Radioactive Sources Regulations, 2006

41-A consignor, carrier and consignee of radioactive materials shall have a valid licence from the Authority well in advance and prior to the delivery, transport and receipt of any such materials

Transport Safety

Safety ObjectivesPreparatory Activities for

Achieving Safe Transport of Radioactive Materials

Concept of Packaging

Safety Objective of the IAEA Transport Regulations

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The objective of the IAEA/NNRA Transport Regulations is “to protect persons, property and the environment from the effects of radiation during the transport of radioactive material. This protection is achieved by requiring:(a) containment of the radioactive contents;(b) control of external radiation levels;(c) prevention of criticality; and(d) prevention of damage caused by heat.”

Achieving the Safety Objective of the IAEA Transport Regulations

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The objectives of the Regulations are achieved

First, 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.

Second, by imposing requirements on the design and operation of packages and on the maintenance of packaging, including a consideration of the nature of the radioactive contents.

Third, by requiring administrative controls including, where appropriate, approval by competent authorities.

Preparatory Activities for Achieving Safe Transport of Radioactive Material

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Safety is first achieved by:providing accurate and useful information

about radioactive contents to be transportedproper selection of a package for the materialproper preparation of the package for transport

Safety is then achieved through proper controls and communication during all phases of transport

Controls and Communications are Key to both Safety and Security

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All packages of radioactive material are subject to a regime of control and communication for safety purposes

The application of these controls and communications is all part of:Preparing the package for dispatchTransporting the package from consignor to

consigneeThe application of this regime assists in an

operator providing a proper security system

Package Requirements for Transport of Radioactive Material

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Package = packaging with its radioactive contents

i.e Package= Packaging + Radioactive Material

There are 7 types of packages specified for radioactive materials

Packages containing fissile material or uranium hexafluoride are subject to additional requirements

Types of Packages used for Transport of Radioactive Material

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Excepted package for very small quantities

Industrial packages, Types IP-1, IP-2 and IP-3 for low specific activity materials and surface

contaminated objects Type A package

limited to quantities less than A1 or A2 as applicable Type B(U) and Type B(M) packages

may contain large quantities, accident resistant Type C package

for air transport of large quantities, severe accident resistant

Examples of Packages used for Transport of Radioactive Material

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Excepted package Industrial packages, Types IP-1, IP-2 and IP-3 Type A package (containing less than

A1 or A2 as applicable) Type B(U) and Type B(M) packages Type C package

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The Control of PackagesImportant Controls for Hazard Management Radiation dose rate limits Contamination limits Activity limits Use of exclusive use shipments Separation & segregation Package Preparation

Transport Index (TI)Criticality Safety Index (CSI) ?Satisfying limits on TI, CSI and radiation levelsCategorizing package

Transport Index (TI) Provides Control for Radiation Exposure in Transport

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The TI is a single number assigned to a package to provide control over radiation exposure

The TI is included on each packages radioactive label

II-Yellow and III-Yellow

Labels

TI is an Important Control for Radiation Exposure in Transport

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The TI is used to establish:Content limits on packages, overpacks,

tanks, or freight containersNecessity of exclusive use shipmentsSegregation requirements during storage

or transitMixing restrictions during transport or

storage under special arrangementsLimiting the number of packages in freight

container or conveyance

Determiningthe Appropriate Category

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The category of packages determines the labelThree factors determine the

category:Surface radiation level

Transport Index

Whether shipments are made under special arrangement

Categories of Packages and Overpacks TS-R-1, Table VII (TS-R-1)

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Transport Index Maximum radiation level at any point on external

surface

Category

0a Not more than 0.005 mSv/h I-WHITE

More than 0 but notmore than 10

More than 0.005 mSv/h but not more than 0.5 mSv/h

II-YELLOW

More than 10 More than 2 mSv/h butnot more than 10 mSv/h

III-YELLOWb

TABLE VII. CATEGORIES OF PACKAGES AND OVERPACKS

a If the measured TI is not greater than 0.05, the value quoted my be zero in accordance with para. 526(c).b Shall also be transported under exclusive use.

Regulatory Requirements

Administrative Requirements Facility/Equipment Radiation Protection Program (RPP) Training and Personnel Accredited Service

Administrative Requirements

Completion and submission of NNRA Authorization Application Form

Provision of a certified copies of Memorandum and Article of Association, Certificate of Incorporation with CAC and Particulars of First Directors (Form C02 & C05)

Payment of applicable authorization feesAccreditation Certificate for LT of RM N2,000,000 p.a.Accreditation Certificate for FW of RM N1,000,000 p.a.Registration of Vehicle to T RM N500,000 p.a per V

Administrative Requirements Cont.

Security arrangement for source movement from one point to the next.

Letter from Police Anti-Bomb Squad to escort the sources consignment from port to base

Vehicle’s particulars

FacilityThe dedicated vehicle for transportation of RM

shall meet the following minimum requirements:Provisions shall be made to secure packages

or over packs so that their positions within the vehicle remain fixed during transportation

Vehicle must be equipped with an enclosure which, during conditions of transport, prevents the access of unauthorized persons to the interior of the enclosure

Radiation levels shall not exceed 2mSv/hr at any point on vehicle, and 0.1mSv/hr at 1m from the surface of the containers

M/R EquipmentPersonnel Monitoring EquipmentRadiation Monitoring EquipmentEmergency response equipment

Radiation Protection Program (RPP)

RPP covers Organizational structure Personnel monitoring Workplace monitoring Local rules and Supervision Emergency Procedure Health Surveillance

Training and Personnel

Evidence of having staff that are trained in radiation protection in the handling of radioactive sources

Evidence of designation of a Radiation Safety officer (RSO) indicating his job description and authority to stop unsafe operation

Copies of CVs, academic and professional qualifications of classified workers and their appointment letters

Accredited Service

Contractual Service agreement with NNRA accredited Dosimetry Service Provider (DSP)

Service agreement with an NNRA accredited Radiation Safety Adviser (RSA) ?

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SummaryThis presentation has not addressed the

proper selection, design and testing of packages and placarding

Proper preparation of a package for transport is essential to safety of workers, the public and the environment

Requirements imposed for safety as provided in TS-R-1 also provide a sound method for assisting in communicating for security purposes– safety requirements and security measures

generally complement each other

Recommendations

The Authority may wish to:

i. Review the operational areas of RSA in line with requirements of the NiBIRR

ii. Review and Update the regulatory requirements for all practices involving the use of ionizing radiation sources in Nigeria

iii. Put as part of the conditions of accreditation certification for Land Transport of RM, that the Licensee of Land Transport of RM shall not practice Freight Forwarding unless if he/she is accredited for both. And vice versa

Thank you all for listening