Safety Standards Series: Title · Web view2020-05-22 · For complex packages this may involve several big drawings, necessary for modelling and assessing the package for calculations

DS493 – Step 11 - Format and Content of the Package Design Safety Report (PDSR) for the Transport of Radioactive Material

COMMENTS BY REVIEWERReviewer: P. Malesys, R. Noering, D. Ito, B. Desnoyers, W. S. Edwards Page 1 of 56Country/Organization:　WNTI Date:　22 May 2020

RESOLUTION

Comment No.

Para/Line No.

Proposed new text Reason Accepted Accepted, but modified as follows

Rejected Reason for modification/rejection

WNTI-1 General The document has been significantly edited and modified since the document that was made available to TRANSSC 39 and the document that was prepared during the Consultancy Meeting in January 2020. The document is now of a significantly higher quality. That said, these modifications have induced in some instances typos, different wordings for the same idea in the different appendices (whilst during the Consultancy Meetings a significant effort was dedicated to the harmonization throughout the appendices, considering that different wordings might be interpreted as different intent or different meanings), difficulties in understanding new wordings, or even changes in the meaning. The goal of most of the following editorial comments is, for the sake of clarity, to correct these unexpected and unintentional secondary impacts following the improvement of the document.

WNTI-2 1.9 1.9. The objective of this Safety Guide is to provide recommendations on the preparation of a PDSR to demonstrate compliance of a design of a package design for the transport of radioactive material with the Transport Regulations.

Editorial – Use of a consistent wording throughout the document.

WNTI-3 2.1. 2.1. The person or organization that is responsible for the design of the package is known as the package designer. The package designer may rely on documentation provided by the packaging manufacturer or others for the design and associated approval of the packaging used (e.g. manufacturers of packagings, tanks approved for transport of dangerous goods, ISO freight containers). In that case, the package designer is the person or organization that takes the responsibility for

Clarification about the definition of the package designer.

1

the complete package design, which includes defining the contents allowed in the packaging to constitute a package. The package designer should also issue the PDSR. For each package design there should be only one package designer, which should also issue the PDSR.

WNTI-4 2.3 − Package Ooperations; Editorial – Use of a consistent style throughout the items in 2.3.

WNTI-5 2.7 2.7. (…). For complex packages this may involve several big drawings, necessary for modelling and assessing the package for calculations relating to mechanical strength, heat transfer, dose rates and criticality., and are often called "design drawings". For simple packages, (…).

Editorial.

WNTI-6 2.8 In accordance with paras. 809 and 812 of the Transport Regulations a reproducible illustration not larger than 21 cm × 30 cm, showing the make-up of the package is requested to be part of the application for approval of a Type B(U), Type B(M) and Type C package designs.

Clarification about the reasons for and the scope of this requirement.

WNTI-7 Appendix I1.6 (a)

(a) The package design that is being evaluated should be uniquely identified by precisely indicating a schematic drawing of the packaging (see item 1.3. of the PDSR), (…).

Consistency with item 1.3 in Table 1.

WNTI-8 Appendix ITABLE 1TABLE OF CONTENTS OF THE PDSR

The contents of the PDSR, Part 1 and Part 2, should be listed here, as needed, including the revision number of each individual document included in the PDSR.

According to the resolution table, WNTI/24 was accepted as modified.

WNTI-9 Appendix I (b) UN number of the package, if as applicable; According to the resolution table,

2

TABLE 11.1 (b) Note

The same sentence should be added for the other types of packages, in the other appendices. There are other instances where several UN Numbers could potentially be assigned to a packaging and its different contents. For instance, four UN Numbers (UN 2915, UN 3327, UN 3332 and UN 3333) might be assigned to a Type A package.

J/40 was accepted as modified

WNTI-10

Appendix ITABLE 11.1 (c)

(c) Modes of transport for which the package is designed and any operational restrictions associated with the mode of transport;

Editorial – Consistency with the wording used in Appendices II, III and IV.

WNTI-11

Appendix ITABLE 11.1 (d)

(d) Reference to the applicable regulations for the specific package design, including the edition of the IAEA Transport Regulations for the Safe Transport of Radioactive Material to which the package design is referring.

Editorial – Consistency with the wording used throughout the document.

WNTI-12

Appendix ITABLE 11.2

A detailed description of the permitted contents of the package design should be provided by stating, at a minimum, the following information, as applicable: (…)

Editorial – A comma is needed after “stating”.

WNTI-13

Appendix ITABLE 11.2.

(a) The general nature of contents (e.g. articles, instruments, metallurgical specimens, internal contamination of the package);(b) The nuclides and/or nuclide composition, including daughter radionuclides;(cb) The physical and chemical state of the contents;(c) The nuclides and/or nuclide composition, including daughter radionuclides;(d) The type and characteristics of the radiation

The order should be consistent with the order which is used in Appendix II. The order in Appendix II (and that it is proposed to use in Appendix I) seems better as the general information about the contents is grouped together, and then the information about the nuclides and radiation follows.

3

emitted by the contents of the package;(…)

WNTI-14

Appendix ITABLE 11.2 (e)

(e) The lLimitations on activity, mass and activity concentrations, and heterogeneities in the distribution of the nuclides. Compliance with the activity limits for excepted packages in accordance with tTable 4, (…) of the Transport Regulations, as applicable, is required;

Editorial.– Same presentation as the other items in 1.2. This is also consistent with the presentation in Appendix IV.– Use of capital letter for the first letter of “Table” as in the Transport Regulations.

WNTI-15

Appendix ITABLE 11.2. (j)

(j b bis) The A1/A2 values of the radionuclides to be carried in the package. The A1/A2 values for radionuclides that are not listed in tTable 2 of the Transport Regulations determined in accordance with paras 403 – 407 of the Transport Regulations and may be subject to multilateral approval in accordance with para. 403 of the Transport Regulations.

(j) should be better located after the current (b) about the nuclides to be transported, as the subject of (j) is directly related to the nuclides to be transported. This is consistent with what is done in Appendix III.

Correction of typos.

Use of capital letter for the first letter of “Table” as in the Transport Regulations.

WNTI-16

Appendix ITABLE 12.1

If the package is to be transported by air, the structural analysis of the containment system should take into account ambient temperatures and pressures that are likely to be encountered in routine conditions of transport as well as the specific temperature and pressure requirements for air transport.

In particular, aAttention should be paid to ensure that any nuts, bolts and other retention devices keep their safety functions during routine conditions of transport even after repeated use.

The second sentence is also applicable for carriage by other modes of transport. It shall not be gathered in a single paragraph with the first sentence which is only applicable for air transport.

Similarly, the last sentence is (still more) general, and should be in a separate paragraph.

4

Further recommendations are provided in paras 607.1 - 621.3 of SSG-26 (Rev. 1) [2].

WNTI-17

Appendix I TABLE 12.2Third paragraph

The dose rate analysis should take into account the appropriate recommendations of the International Commission on Radiation Protection most recent (ICRP) recommendations on nuclear decay data for dosimetric calculations (e.g. see Ref. [9]).

[9] INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION, Nuclear Decay Data for Dosimetric Calculations, ICRP Publication 107, Ann. ICRP 38, Elsevier (2008).

Alternative proposal

The dose rate analysis should take into account the appropriate recommendations of the International Commission on Radiation Protection most recent (ICRP) recommendations on nuclear decay data for dosimetric calculations (e.g. see Ref. [9] and Ref [9 bis]).

[9] INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION, The 2007 Recommendations of the International Commission on Radiological Protection, ICRP Publication 103, Ann. ICRP 37, Elsevier (2007).

[9 bis] INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION, Nuclear Decay Data for Dosimetric Calculations, ICRP Publication 107, Ann. ICRP 38, Elsevier (2008).

It is proposed to come back to the text that was available in the draft that was submitted to TRANSSC 39. This text was more general, and it does not seem appropriate to focus only on nuclear decay data for dosimetric calculations (included in ICRP Publications 107). For instance, ICRP Publication 103 “The 2007 Recommendations of the International Commission on Radiation Protection” is also very important as it includes the recommended values for the radiation weighting factors.

5

WNTI-18

Appendix I TABLE 12.2Fourth paragraph

In accordance with para. 516.5 and 523.6 of SSG-26 (Rev. 1) [2], the maximum dose rate should be determined taking into account potential amplifying phenomena, such as internal movement of the contents, or, in the case of packages containing liquids, change in the state of the contents, including segregation and precipitation of the radionuclides.

Para. 523 of the Transport Regulations and – subsequently – para. 523.6 of SSG-26 (Rev.1) are not applicable to excepted packages.

WNTI-19

Appendix IIII.2

II.2 In accordance with para. 801 of the Transport Regulations, Type IP-1, Type IP-2 and Type IP-3 packages require a PDSR. (…)

Consistency with I.2 in Appendix I.

WNTI-20

Appendix IIII.6 (c)

(c) Except for a Type IP-2 and a Type IP-3 package meeting the alternative requirements in one of the paras 626 to 630, the The safety demonstration of an Type IP-2 or a Type IP-3 package design is required to be accomplished in accordance with para. 701 of the Transport Regulations by any of the following methods or by a combination thereof: (…).

Para. 701 requirements do not apply to Type IP-2 and Type IP-3 package designs meeting the alternative requirements in one of the paras 626 to 630.

Editorial.

WNTI-21

Appendix IIII.6 (d)

(d) (…). Other hazards (e.g. corrosion, combustion, pyrophoricity or other chemical reactions, radiolysis, phase changes) should be analysed, as necessary, if they that may have a consequential effect on the safety functions of the package should be analysed. This may concern corrosion, combustion, pyrophoricity or other chemical reactions, radiolysis, phase changes.

Editorial – Use of the same wording as in Appendices III and VI.

WNTI-22

Appendix II TABLE 2TABLE OF CONTENTS OF THE

The contents of the PDSR, Part 1 and Part 2, should be listed here, as needed, including the revision number of each individual document included in the PDSR.

According to the resolution table, WNTI/32 was accepted as modified.

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PDSR

WNTI-23

Appendix II TABLE 21.1. (d)

(d) For package tTypes IP-2 and Type IP-3 packages, packaging and/or package design identification and restrictions in packaging serial number(s), if applicable;

Editorial – Wording used in the Transport Regulations.

WNTI-24

Appendix II TABLE 21.1. (f)

(f) Reference to applicable regulations for the specific package design, including the edition of the IAEA Transport Regulations to which the package design is referring.


WNTI-25

Appendix II TABLE 21.2. (e)

(e) The lLimitations on activity, mass and activity concentrations, and heterogeneities in the distribution of the nuclides. The contents should be classified appropriately in one of the categories of LSA material or SCO, as appropriate, in accordance with paras 409 and 413 of the Transport Regulations. Limitations in specific activity (Bq/g) and surface contamination (Bq/cm2) may be required. Conveyance activity limits in accordance with tTable 6 of the Transport Regulations should also be taken into account to limit the activity of a single package, if applicable;

Editorial.- Consistency with the other items of item 1.2.- Wording that is used in the Transport Regulations.- Use of capital letter for the first letter of “Table” as in the Transport Regulations.- Note that there appears to be an extra space before the section number – “_(e)”

WNTI-26

Appendix II TABLE 21.2. (g)

(g) (…). Additional information on the design requirements for dangerous goods in accordance with the subsidiary hazard can be found in Ref. [3], Chapter 3.3 Special Provision 172;

Clarification. It is proposed to use the same wording as in Appendices III and IV.

WNTI-27

Appendix II TABLE 21.2. (h)

(h) (…). Safety relevant limits for non-radioactive materials (e.g. materials subject to radiolysis) should be stated, for example limits in terms of material composition, density, form, location within the package, restrictions of relative quantities of materials.

- Consistency with the conclusion of the Consultancy Meeting in January 2020: WNTI/34 was accepted (radiolysis is not considered as a significant issue for industrial packages).

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- Editorial

WNTI-28

Appendix IITABLE 21.2. (i)

(i c bis) The A1/A2 values of the radionuclides to be carried in the package. The A1/A2 values for radionuclides that are not listed in tTable 2 of the Transport Regulations determined in accordance with paras 403 – 407 of the Transport Regulations and may be subject to multilateral approval in accordance with para. 403 of the Transport Regulations.

(i) should be better located after the current (c) about the nuclides to be transported, as the subject of (i) is directly related to the nuclides to be transported. This is consistent with what is done in Appendix III.


Use of capital letter for the first letter of “Table” as in the Transport Regulations.

WNTI-29

Appendix IITABLE 21.3 (c)

(c) A list of all packaging components important to safety and their materials. For Type IP-2 and Type IP-3 packages, the material specifications of the packaging components should also be included);

Editorial.

WNTI-30

Appendix II TABLE 21.3

To be included after (d):(d bis) In the case of packages meeting the alternative requirements stated in one of the paras 626 to 630 of the Transport Regulations, the appropriate regulatory or standardized designation of the package, portable tank, tank, freight container or IBC.

The case of "alternative Type IP-2 or Type IP-3", as allowed by paras 626 to 630, should be considered, with the information required for the package, portable tank, tank, freight container or IBC.

WNTI-31

Appendix IITABLE 21.4. (d)

(d) Analysis of the influence of the ageing of packaging and contents on the design assumptions for demonstration of compliance with the regulations including the technical analyses in Part 2 of the PDSR. In this analysis , considering the specified intended use conditions, ageing mechanisms and operational

Clarification. The wording that is proposed is the wording used in Appendix IV.

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measures should also be considered.

WNTI-32

Appendix II TABLE 22.1 (a)

(a) (…). The components of the containment system. This is required fFor Type IP-1 packages, this is required only when transported by air (see paras 619 to 621 of the Transport Regulations);

Clarification (need to clarify to what “only” applies).

WNTI-33

Appendix II TABLE 22.1 (d)

(d) The lifting attachments (see paras 608 and 609 of the Transport Regulations).

Editorial

WNTI-34

Appendix II TABLE 22.1 After (e)

If the package is to be transported by air (paras 619 to 621 of the Transport Regulations), the structural analysis of the containment system should take into account ambient temperatures and pressures that are likely to be encountered in routine conditions of transport as well as the specific temperature and pressure requirements for air transport. In addition, attention should be paid to ensure that any nuts, bolts and other retention devices keep their safety functions during routine conditions of transport even after repeated use. Further recommendations are provided in paras 621.2, and 621.3 and 613.1 of SSG-26 (Rev. 1) [2].

Attention should be paid to ensure that any nuts, bolts and other retention devices keep their safety functions during routine conditions of transport even after repeated use. Further recommendations are provided in para. 613.1 of SSG-26 (Rev. 1) [2].


The information about recommendations provided in SSG-26 should be distributed in the appropriate paragraphs.

WNTI-35

Appendix II TABLE 22.1

When performing the structural analysis for industrial packages, except for a Type IP-2 or a Type IP-3 package meeting the alternative requirements in one of the paras 626 to 630,

The information in (1), (2) and (3) is not applicable to Type IP-2 and Type IP-3 package designs meeting the alternative requirements in one

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the following points should be considered: of the paras 626 to 630.

WNTI-36

Appendix II TABLE 22.1 (1) (iv)

(iv) The strength of lid bolts should be verified for all the drop orientations recommended in para. 722.6 of SSG-26 (Rev. 1) [2];

All drop orientations are not required in normal conditions of transport according to para. 722.6 of SSG-26 (Rev.1).

WNTI-37

Appendix II TABLE 22.1 (1) (vi)

(vi) The condition of the containment system should be determined to demonstrate compliance with the requirements of item 2.23 of the PDSR for the temperature range likely to be encountered during routine conditions of transport;

The relevant paragraph is 2.3 “Containment analysis”. See also the draft that was submitted to TRANSSC 39.

WNTI-38

Appendix II TABLE 22.1 (1) (vii)

(vii) Phenomena such as radiolysis, (and subsequent internal pressure elevation, internal inflammation or explosion), physical changes and chemical reactions should be considered when analysing the maximum pressure.

Clarification and consistency with the text which was constantly agreed in the previous drafts of the document.

WNTI-39

Appendix II TABLE 22.1 (2) (i)

(i) The package orientations should be determined in accordance with para. paras 722.4 and 722.6 of SSG-26 (Rev. 1) [2],. The orientations should which maximize the loading of the package (such as stress, strain, acceleration and deformation) with consideration of the different package components (e.g. cask body, lid system, impact limiter, etc.) and of the protection objectives (containment and shielding)should be determined;

Para. 722.6 of SSG-26 (Rev.1) is also important to select the orientations for normal conditions of transport.

An extra space should be added between “(Rev. 1) and “[2]”.

The sentence is unclear, as there are twice “should be determined” (at the beginning and at the end of the sentence). It is proposed to have two sentences, and this would assure consistency with the wording in Appendix III.

WNTI-40

Appendix II TABLE 2

(iii) The results of the drop test with reduced scale models should be tested to guarantee that

Clarification. The current sentence is difficult to understand. See also

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2.1 (2) (iii) they are covering and/or are should be transferable to the original design;

the draft text that was submitted to TRANSSC 39 and that was clearer.

WNTI-41

Appendix II TABLE 22.1 (2)Last paragraph

(v) The experimental mechanical tests should be conducted and reported in accordance with the management system. (…).

All the items in 2.1 (1), (2) and (3) are numbered (see also Appendix III).

WNTI-42

Appendix II TABLE 22.1 (3) (iii)

(iii) If uncertainties exist regarding important input parameters (e.g. material laws), conservative design calculations including the possible range of material properties should be performed;

Editorial – Clarification and simplification.

WNTI-43

Appendix II TABLE 22.4Third bullet point

- The dose rate analysis should take into account the appropriate recommendations of the International Commission on Radiation Protection most recent (ICRP) recommendations on nuclear decay data for dosimetric calculations (e.g. see Ref. [9]).



- The dose rate analysis should take into account the appropriate recommendations of the International Commission on Radiation Protection most recent (ICRP) recommendations on nuclear decay data for dosimetric calculations (e.g. see Ref. [9] and Ref [9 bis]).


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WNTI-44

Appendix II TABLE 22.4Fourth bullet point

- In accordance with para.s 624.4 and 523.6 and 624.4 of SSG-26 (Rev. 1) [2], the maximum dose rate and the dose rate increase ratio for normal conditions of transport should be determined, taking into account potential amplifying phenomena such as internal movement of the contents (…).

Editorial. The paragraphs should be ordered in the same order as the subjects that are considered later in the sentence (para. 523.6 is about the maximum dose rate and para. 624.4 is about the dose rate increase ratio).

WNTI-45

Appendix II TABLE 22.43rd bullet point from the end

- Dose rate analysis should be based on tThe maximum radioactive contents of the package design, which should could be defined by various methods and parameters, such as nuclide specific activities and source terms for gamma and neutron emitters. (…).

Editorial – Simplification of the wording to avoid duplication of the 2nd bullet point in 2.4.

WNTI-46

Appendix III III.1bis In accordance with para. 801 of the Transport Regulations, Type A packages require a PDSR. III. 2 (…).

Consistency with I.2 in Appendix I and II.2 in Appendix II.

WNTI- Appendix IIIIII.5

The bullet points should be numbered (a), (b), Editorial – Consistency with the

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47 (c) (d) and (e). presentation used throughout the document.

WNTI-48

Appendix IIIIII.5 (b)

(b) (…). The acceptance criteria should be specified by the designer and should be derived from the criteria established by the regulatory body and from other applicable standards developed to meet the regulatory requirements. (…).

It seems that a piece of the sentence is missing. The wording that is proposed is the wording used in Appendix II (II.6(b)).

WNTI-49

Appendix IIITABLE 31.1 (f)

(f) Reference to the applicable regulations for the specific package design, including the edition of the IAEA Transport Regulations for the Safe Transport of Radioactive Material to which the package design is referring.


WNTI-50

Appendix IIITABLE 31.2 (c)

(c) (…). The A1/A2 values for radionuclides that are not listed in tTable 2 of the Transport Regulations (…).

Editorial – Use of capital letter for the first letter of “Table” as in the Transport Regulations.

WNTI-51

Appendix III TABLE 31.2. (f)

(f) The lLimitations on activity, mass and activity concentrations, and heterogeneities in the distribution of the nuclides. (…).

Editorial – Same presentation as the other items in 1.2. This is also consistent with the presentation in Appendix IV.

WNTI-52

Appendix III TABLE 31.2. (i)

(i) (…). Additional information on the design requirements for dangerous goods in accordance with the subsidiary hazard can be found in Ref. [3], Chapter 3.3 Special Provision 172;

Editorial.

WNTI-53

Appendix IIITABLE 31.2.

(a) The general nature of contents (e.g. irradiated fuel, metallurgical specimens, radiographic source);(b) The physical and chemical state (additional design specifications are applicable to liquid and gas contents), geometric shape, arrangement, irradiation

The order should be consistent with the order which is used in Appendix II. The order in Appendix II (and that it is proposed to use in Appendix III) seems better as the general information about the contents comes together, and then

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parameters, material specifications;(bc) The nuclides and/or nuclide composition, including daughter radionuclides;(cd) The A1/A2 values of the radionuclides to be carried in the package. The A1/A2 values for radionuclides that are not listed in table 2 of the Transport Regulations are required to be determined in accordance with paras 403 – 407 of the Transport Regulations and may be subject to multilateral approval in accordance with para. 403 of the Transport Regulations.(d) The physical and chemical state (additional design specifications are applicable to liquid and gas contents), geometric shape, arrangement, irradiation parameters, material specifications;(e) The type and characteristics of the radiation emitted (…).

the information about the nuclides and radiation comes also together.

Correction of a typo.

WNTI-54

Appendix IIITABLE 31.3.

(…)(c) A list of all packaging components important to safety and their materials, including the material specifications of the packaging components;(d) The maximum normal operating pressure (particularly in case of air transport).;

The packaging design should include a description of the following:

(e) A description of tThe packaging body, lid (…), internal arrangements, and components for lifting and tie-down;(f) A description of tThe packaging components of the containment system (…);(g) A description of tThe packaging components required for shielding;(h) A description of tThe protection against

(c) – Clarification. The wording that is proposed is the wording used in Appendix II.

The intermediate sentence between (d) and (e) is not needed (see also Appendix IV).

(e) to (j) – Clarification (transition between the introductory sentence and the items in (e) to (j)).

(e) – Editorial (comma after “internal arrangements”) (see also Appendix IV).

(k) – Simplification and consistency with Appendix IV. It is proposed to use the same general wording as in

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corrosion;(i) A description of tThe protection against contamination;(j) A description of tThe shock limiting components;(k) Testing specifications and controls before first use to transport radioactive material. and acceptance tests to This ensures compliance of the fabrication to the design and allows acceptance of the specimen before its first use. In accordance with See also para. 501 (a) of the Transport Regulations, if the design pressure of the containment system exceeds 35 kPa, a procedure for testing the integrity of the containment system under that pressure should also be included.

Note - For radioactive material having other dangerous properties, see 4.1.9.1.5 of Ref. [3]. With the exception of packages containing 0.1 kg or more of uranium hexafluoride, tThe packing instruction as specified in Ref. [3] (or in the applicable regulations for the carriage of dangerous goods) appropriate to the other dangerous properties of the radioactive material should be complied with, with the exception of packages containing 0.1 kg or more of uranium hexafluoride.

Appendix IV.

Note – Use of similar wording as in Appendix II.

WNTI-55

Appendix IIITABLE 31.4. (d)

(d) Analysis of the influence of the ageing of packaging and contents on the design assumptions for demonstration of compliance with the regulations including the technical analyses in Part 2 of the PDSR. In this analysis , considering the specified intended use conditions, ageing mechanisms and operational measures should also be considered.

Clarification and consistency with Appendix IV. The wording that is proposed here is the wording used in Appendix IV which seems clearer.

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WNTI-56

Appendix IIITABLE 31.6

(a) Assembling of the packaging components, including demonstration of compliance with para. 637 of the Transport Regulations;(b) Loading and unloading of the package contents;(a c) Testing and controls before each shipment. The methods used for operational controls and tests, in particular those required in accordance with paras 502, 503 (a), 508, 523, 526, 527 and 528 of the Transport Regulations, should be detailed;(b d) Handling and tie down. Specifications on bolt torqueing, number of transport cycles (to be used in fatigue analysis) for each mode of transport should be included, if applicable;(c) Loading and unloading of the package contents;(d) Assembling of the packaging components, including demonstration of compliance with para. 637 of the Transport Regulations;(…).

Consistency – Change of the order of the items (a) to (d), to have the same ordrer as in Appendices I and II (and the order in Appendices I and II seems more logical, as it follows the practical order of the operations).

Editorial.

WNTI-57

Appendix IIITABLE 31.7Last bullet point

⎯ If written procedures with details of the package maintenance are avoiailable, then reference should be made to these procedures.

Editorial – Correction of typo.

WNTI-58


A reproducible illustration should be provided showing the make-up of the package, including shock absorbers and packaging inserts internal arrangements, if applicable.

Clarification – During the Consultancy Meeting in January 2020, WNTI comments about the changes from “packaging inserts” to “internal arrangements” were accepted (the wording “internal arrangements” is easier to understand than “inserts”). See also 1.3. (e) in Appendix III where the wording “internal arrangements” is used.

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WNTI-59

Appendix IIITABLE 32.1(d)


Editorial

WNTI-60






WNTI-61

Appendix III TABLE 32.1 (1)

(1) General considerations:1) (i) The mechanical properties of the materials considered in the safety demonstration should be representative for of the range of mechanical properties of the package components and for considering temperatures likely to be encountered during routine conditions of transport (see para. 616 639 of the Transport Regulations);(i) (ii) (…)

- Editorial – The paragraph starting with “The mechanical properties” should be numbered (i) (it is the first sub-bullet of “(1) General considerations”. And the following items (currently (i) to (vi)) should be renumbered (ii) to (vii).- Consistency with the wording in Appendix II and IV.- Para. 616 in the Transport Regulations is applicable to all types of packages. Para. 639 is dedicated

17

to Type A packages.

WNTI-62

Appendix III TABLE 32.1 (1) (iii)



WNTI-63

Appendix III TABLE 32.1 (1) (v)

(vi) The condition of the containment system should be determined to demonstrate compliance with the specifications in item 12.3. of the PDSR for the temperature range likely to be encountered during routine conditions of transport;

The relevant paragraph is 2.3 “Containment analysis”. See also the European Technical Guide on Package Design Safety Reports for the Transport of Radioactive Material”).

WNTI-64

Appendix III TABLE 32.1 (1) (vi)

(vii) Phenomena such as radiolysis, (and subsequent internal pressure elevation, internal inflammation or explosion), physical changes and chemical reactions should be considered when analysing the maximum pressure.

Clarification and consistency with the text which was constantly agreed in the previous drafts of the document.

WNTI-65

Appendix III TABLE 32.1 (2) (i)

(i) The package orientations should be determined in accordance with para. paras 722.4 and 722.6 of SSG-26 (Rev. 1) [2]. (…)


WNTI-66

Appendix III TABLE 32.1 (2) (i)

(i) (…). The orientations should be such that maximize the loading of the package (…).

Editorial. Clarification.

WNTI-67


(iii) The results of the drop test with reduced scale models should be tested to guarantee that they are covering and/or are should be transferable to the original design;

Clarification. The current sentence is difficult to understand. See also the draft text that was submitted to TRANSSC 39 and that was clearer.

WNTI-68


(iii) If uncertainties exist regarding important input parameters (e.g. material laws), conservative design calculations including the


18

possible range of material properties should be performed;

WNTI-69

Appendix III TABLE 32.1 (3) (iv)

(iv) Data used (e.g. material laws, boundary conditions, load assumptions) and calculation results are to should be documented comprehensibly.

Editorial. “Should” is a better word in a guidance document. The wording that is proposed here is the wording that is used in Appendix II.

WNTI-70

Appendix III TABLE 32.4Second bullet point

- The dose rate analysis should be based on assuming the maximum radioactive content of the package or such a content for a tType A package (…).

Editorial – Use of capital letter for the first letter of “Type” as in the Transport Regulations.

WNTI-71

Appendix III TABLE 32.4Third bullet point






19



WNTI-72

Appendix III TABLE 32.4Fourth bullet point

In accordance with para.s 523.6 and 624.4 of SSG-26 (Rev. 1) [2], the maximum dose rate and the dose rate increase ratio for normal conditions of transport should be determined,

Para. 523.6 of SSG-26 (Rev. 1) is relevant for the maximum dose rate (and para. 624.4 of SSG-26 (Rev. 1 is relevant only for the dose rate increase ratio). See also the text in Appendix II.

WNTI-73

Appendix III TABLE 32.46th bullet point from the end

- Dose rate analysis should be based on tThe maximum radioactive contents of the package design, which should could be defined by various methods and parameters, such as nuclide specific activities and source terms for gamma and neutron emitters. (…).

Editorial – Simplification of the wording to avoid duplication of the 2nd bullet point in 2.4.

WNTI-74

Appendix IVIV.1

IV.1 This appendix provides specific recommendations on the information that should be included in Parts 1 and 2 of the PDSR for Type B(U), Type B(M) and Type C packages. Further recommendations on Type B(U), Type B(M) and Type C packages are provided in SSG-26 (Rev. 1) [2].

Editorial. Consistency with the wording used in Appendix I, Appendix II and Appendix III.

WNTI-75

Appendix IVIV.5

The bullet points should be numbered (a), (b), (c) (d) and (e).

Editorial – Consistency with the presentation used throughout the

20

document.

WNTI-76

Appendix IVIV.5 (b)

(b) The acceptance criteria for the technical analyses and the package design assumptions relating to geometry or performance characteristics should be defined and justified when necessary. The acceptance criteria should be specified by the designer and should be derived from the criteria established by the regulatory body and from other applicable standards developed to meet the regulatory requirements. The design assumptions refer to the design specification provided in items 1.2. and 1.3. of the PDSR or to other assumptions derived from the design specifications and used in the technical analyses. All mechanical, thermal and shielding characteristics of each component of the package and acceptance criteria used in technical analyses should be defined. The design assumptions should take into account ageing mechanisms, as necessary. Additional recommendations are provided in paras 613A.1 to 613A.4 of SSG-26 (Rev. 1) [2].

Editorial. Clarification. Use of similar wording as in Appendix II and Appendix III.

WNTI-77

Appendix IVIV.5 (c)

(c) The safety demonstration of a Type B(U), Type B(M) or Type C package design is required to be accomplished in accordance with para. 701 of the Transport Regulations by any of the following methods or by a combination thereof: (…).

Editorial. Use of similar wording as in Appendix II and Appendix III.

WNTI-78

Appendix IVIV.5 (d)

(d) (…). Other hazards should be analysed, if they that may have a consequential effect on the safety functions of the package should be analysed. This may concern corrosion, combustion, pyrophoricity or other chemical reactions, radiolysis, phase changes.

Editorial – Use of the same wording as in Appendices III and VI.

21

WNTI-79

Appendix IVTABLE 41.1 (f)

(f) Reference to the applicable regulations for the specific package design, including, if necessary, the edition of the IAEA Transport Regulations for the Safe Transport of Radioactive Material to which the package design is referring.

Editorial – Consistency with the wording used in the Appendices I to III and throughout the document.

WNTI-80

Appendix IVTABLE 41.2.

(a) The general nature of contents (e.g. irradiated fuel, metallurgical specimens, radiographic source);(b) The nuclides and/or nuclide composition, including daughter radionuclides;(cb) The physical and chemical state, geometric shape, arrangement, irradiation parameters (if applicable, the maximum burnup and minimum cooling time), moisture content, material specifications;(c) The nuclides and/or nuclide composition, including daughter radionuclides;(d) The type and characteristics of the radiation emitted by the contents of the package; (…)

General comment - The order should be consistent with the order which is used in Appendix II. The order in Appendix II (and that it is proposed to use in Appendix IV) seems better as the general information about the contents comes together, and then the information about the nuclides and radiation comes also together.

(d) – Editorial (semi-colon at the end of (d)).

WNTI-81

Appendix IVTABLE 41.2.

(…).The properties of materials (…) should be given for a range of temperature reachable during such a test.

The description may include the total numbers of A1 or A2 in the contents.

There are additional design requirements depending on the activity (e.g. see para. 660 of the Transport Regulations).

Compliance with the activity limits for Type B(U) and Type B(M) packages, if transported by air, in accordance with para. 433 of the Transport Regulations should be considered.

Part of the text should be moved in (e) as the information provided are relevant to the subject of (e). See also the draft that was provide before TRANSSC 39.

22

A detailed description of the permitted contents of the package design should be provided by stating, at a minimum, the following information, as applicable:(…)(e) The limitations in on activity, mass and concentrations, heterogeneities in the distribution of the nuclides;

The description may include the total numbers of A1 or A2 in the contents.

There are additional design requirements depending on the activity (e.g. see para. 660 of the Transport Regulations).

Compliance with the activity limits for Type B(U) and Type B(M) packages, if transported by air, in accordance with para. 433 of the Transport Regulations should be considered.

(f) (…)

WNTI-82

Appendix IVTABLE 41.2. (g)

(g) The lLimitations in the heat generation rate of the contents;

Editorial – Same presentation as the other items in 1.2.

WNTI-83

Appendix IVTABLE 41.2. (i)

(i) Other dangerous properties (subsidiary hazards) of the contents. In accordance with para. 618 of the Transport Regulations, any other dangerous properties (subsidiary hazards) of the contents of the package are required to be taken into account in the packing package design to be in compliance with the relevant transport regulations for dangerous goods. Additional information on the design

Editorial- Use of the same wording as in Appendix III.- Corrections of typos.

23

requirements for dangerous goods in accordance with the subsidiary hazard can be found in Ref. [3], Chapter 3.3 Special Provision 172);

WNTI-84

Appendix IVTABLE 41.2. (k)

(k b bis) The A1/A2 values of a the radionuclides to be carried in the package. The A1/A2 values for radionuclides that are not listed in Table 2 of the Transport Regulations determined in accordance with paras 403 – 407 of the Transport Regulations and may be subject to multilateral approval in accordance with para. 403 of the Transport Regulations.

(k) should be better located after the current (b) about the nuclides to be transported, as the subject of (k) is directly related to the nuclides to be transported.


WNTI-85

Appendix IVTABLE 41.3

(c) A list of packaging components important to safety and their materials, including the specifications and methods of manufacture of the components, specifications for material procurement, welding, other special processes, non-destructive evaluation examination and testing. (…);(d) The maximum normal operating pressure.(e) A description of tThe packaging body, lid (closure mechanism and tamper-indicating features) and internal arrangements, and components for lifting and tie-down;(f) A description of tThe packaging components of the containment system (including the definition of the containment boundary). This may be supported by special form radioactive material, if applicable (see also item 1.2. (f) of the PDSR);(g) A description of tThe packaging components required for shielding;(h) A description of tThe packaging components for thermal protection;(i) A description of tThe packaging components for heat dissipation;

(c) – Correction of a typo.

(e) to (l) – Clarification (transition between the introductory sentence and the items in (e) to (j)).

24

(j) A description of tThe protection against corrosion;(k) A description of tThe protection against contamination;(l) A description of tThe shock absorbing components;(m) (…).

WNTI-86


Depending on the package design, the information relating to the ageing considerations, expected in this section of the PDSR, can also be provided by the package designer directly in the table mentioned in item 1.6. For packagings used once for a single transport and not intended for shipment after storage, this section should be left blank.(…).

The first and second sentences should be merged in a single paragraph, as they cover similar topics. See also Appendix II and Appendix III. See also the text drafted during the Consultancy Meeting which was held in January 2020.

WNTI-87

Appendix IVTABLE 41.6Last paragraph

Annex I provides a matrix indicating tThe applicable paragraphs of the Transport Regulations for Type B(U), Type B(M) and Type C packages are provided in a matrix in Annex I.

Editorial. Use of the same wording as in Appendix I, Appendix II, Appendix III and Appendix V.

WNTI-88


The minimum specifications for the following activities should be fully defined, as applicable:

(a) Assembling of the packaging components, including demonstration of compliance with the requirements established in para. 637 of the Transport Regulations;

(b) Loading and unloading of the package contents;

(ac) Testing and controls before each shipment: (…)(v) For leak tightness testing, qualified methods

- Editorial – Clarification and simplification.

- Consistency – Change of the order of the items (a) to (d), to have the same order as in Appendices I and II (and the order in Appendices I and II seems more logical, as it follows the practical order of the operations).

- (v) – Item 2.3 “Containment analysis” is more relevant (and this is consistent with the table of

25

should be implemented (see item 12.3. of the PDSR). (…).

(bd) Handling and tie down. Specifications on bolt torqueing, number of transport cycles (to be used in fatigue analysis) for each mode of transport should be included, if applicable;

(c) Loading and unloading of the package contents;

(d) Assembling of the packaging components, including demonstration of compliance with the requirements established in para. 637 of the Transport Regulations);

(…)

resolutions: J/133 was accepted)

- (d) (current) – Editorial (no need for a bracket at the end of (d))

WNTI-89

Appendix IVTABLE 41.8 (f)

(f) Structural and pressure tests (including tie-down and handling attachments) and pressure tests;

Clarification: the text between brackets is about the structural tests (and not about the pressure tests).

WNTI-90


Items (c) to (j) should be numbered (a) to (h). The list (c) to (j) is not the continuity of items (a) and (b) at the beginning of the section 1.8.

WNTI-91


(…).

The management system should include the descriptions of the actions to be performed (…).

For all components important to safety, the PDSR should define the parameters (…).

Editorial.

WNTI-92


A reproducible illustration should be provided showing the make-up of the package, including shock absorbers, devices for thermal protection and packaging inserts internal arrangements,

Clarification – During the Consultancy Meeting in January 2020, WNTI comments about the changes from “packaging inserts” to

26

if applicable.

The illustration should indicate at least the overall outside dimensions and the mass of the package when empty and when loaded.

“internal arrangements” were accepted (the wording “internal arrangements” is easier to understand than “inserts”). See also 1.3. (e) in Appendix IV where the wording “internal arrangements” is used.

Editorial: consistency with the wording used in Appendix III.

WNTI-93

Appendix IVTABLE 42.1 (d)


Editorial

WNTI-94






WNTI-95

Appendix IV TABLE 4

(ii) The impacts on the package behaviour due to variations in the shock absorbing properties

Clarification (what should be “a range of moisture conditions?).

27

2.1 (1) (ii) of the shock absorber material (e.g. wood, polymers, plaster, concrete) should be analysed for the temperature range from -40°C (or another specified temperature for Type B(M) packages as agreed by the competent authority) to the maximum temperature in normal conditions of transport, and for a the range of moisture conditions that is likely to be encountered during transport;

WNTI-96

Appendix IV TABLE 42.1 (1) (iv)



WNTI-97

Appendix IV TABLE 42.1 (1) (viii)

(viii) The condition of the containment system should be determined to demonstrate compliance with the specifications in item 12.3. of the PDSR for the temperature range concerned, i.e. from -40°C (or another specified temperature for Type B(M) packages as agreed by the competent authority) to the maximum temperature in accident conditions of transport;

The relevant paragraph is 2.3 “Containment analysis”. See also the European Technical Guide on Package Design Safety Reports for the Transport of Radioactive Material”).

WNTI-98

Appendix IV TABLE 42.1 (1) (x)

(x) The effect of the thermal test on the mechanical behaviour of the package should be assessed considered, taking into account, for example, (e.g. thermal stresses and strains, thermo-mechanical interactions between package components and interactions of the package components with the contents);

Clarification. See also the text of the draft that was presented to TRANSSC 39 and the text in Appendix V.

WNTI-99

Appendix IV TABLE 42.1 (2) (i)

(i) The package orientations should be determined in accordance with paras 722.4, 722.6 and 727.5 of SSG-26 (Rev. 1) [2]. The orientations should be such that maximize the loading of the package (…).



28

WNTI-100

Appendix IV TABLE 42.1 (2) (ii)

(ii) For reduced scale models, geometry and material properties similar to the original design, or conservative geometry and material properties, should be used;

Editorial. Clarification by improving the punctuation. Consistency with Appendix II and Appendix III.

WNTI-101

Appendix IV TABLE 42.1 (2) (iii)

(iii) The results of the drop test with reduced scale models should be assessed to ensure that they are covering and/or are should be transferable to the original design;


WNTI-102

Appendix IV TABLE 42.1 (2)Last paragraph



WNTI-103

Appendix IV TABLE 42.1 (3) (iii)



WNTI-104

Appendix IV TABLE 42.1 (3) (iv)


Editorial - “Should” is a better word in a guidance document. The wording that is proposed here is the wording that is used in Appendix II.

WNTI-105

Appendix IV TABLE 42.2Third paragraph

The following considerations remarks should be taken into account for the thermal analysis:(…)

Editorial. Simplification. The wording that is proposed here is the wording which is used in Appendix V and Appendix VI and which was used in the draft submitted to TRANSSC 39.

WNTI-106

Appendix IV TABLE 42.2

(…):- The effects of insolation on a period of 12 hours in accordance with para. 657 of the

Editorial. It is better to have the text about the “protective systems” just after the first bullet point after the

29

Third paragraph

Transport Regulations. Averaging of the results of insolation on 24 hours should not be accepted;- The solar insolation before and after the thermal test as defined in para. 728 of the Transport Regulations;- The presence of protective systems liable to oppose heat dissipation in normal conditions of transport. Protective systems to be considered include, as applicable, tarpaulins, canopies, additional screens and outer packaging (e.g. containers, boxes);- The solar insolation before and after the thermal test as defined in para. 728 of the Transport Regulations;- (…)

effect of insolation, as both items are related to normal conditions of transport.

WNTI-107

Appendix IV TABLE 42.2Third paragraph

- The presence of protective systems liable to oppose heat dissipation in normal conditions of transport. Protective systems to be considered include, as applicable, tarpaulins, canopies, additional screens and outer packaging (e.g. containers, boxes);

During the meeting of the TRANSSC Technical Experts Group dedicated to Package Performance and Assessment (TTEG-PPA) that met during last TRANSSC 39, the issue of the “protective systems” was discussed extensively. It was recognized that there are many different ways to consider these “protective systems”, and that it is common that these “protective systems” are not considered in the PDSR (and might be considered in other documents).

The conclusions of the TTEG-PPA were as follows:“TTEG DECISION: A working group for harmonization of assessment/authorization for transport in confined areas will be

30

founded to accomplish the identified task. The working group is called WG CONFINED-AREAS. The working group is composed of WNTI, D, F and UK.

WG CONFINED AREAS ACTION: The WG will develop a proposal for the amendment of the PDSR guide related to confined areas. In addition, the WG will identify relevant information for confined areas, which are necessary to be provided in approvals.”

Consequently, it seems premature to have such guidance in this document for the time being.

WNTI-108

Appendix IV TABLE 42.2Third paragraph8th bullet points

⎯ The profile of heat power based on the burnup distribution in irradiated fuels considered in the thermal analysis;

Editorial: simplification.

WNTI-109

Appendix IV TABLE 42.2Last bullet point

⎯ Demonstration that the spare volume in the gasket grooves allows for gasket thermal expansion in the conditions specified in paras. 654 and 655 653 of the Transport Regulations and accident conditions of transport, unless appropriate justification is provided.

Para. 653 of the Transport Regulations is more appropriate. It should be noticed that paras 654 and 655 do not consider solar insolation.

WNTI-110

Appendix IV TABLE 42.3Second bullet

⎯ The analysis of the state of the irradiated fuel assemblies in accident conditions of transport (risk of cracking or rupture of the fuel rod at their ends) should have been included

Editorial – Consistency with the wording used in the bullet point just before.

31

point. assessed in item 2.1 of the PDSR for safety demonstration, if necessary;

WNTI-111

Appendix IV TABLE 42.3Penultimate bullet point

⎯ The long-term behaviour of gasket material should be considered (see item. 1.75. of the PDSR);

Item 1.7 “Package operations” is not relevant for the purpose of this bullet point. Item 1.5 “Ageing management” is more appropriate (and that is what was agreed during the Consultancy Meeting in December 2018).

WNTI-112

Appendix IV TABLE 42.41st bullet point

⎯ The dose rates (…) should be assessed to demonstrate compliance with the requirements established in of the Transport Regulations.

Editorial: consistency with the wording used in Appendix I, Appendix II and Appendix III.

WNTI-113

Appendix IV TABLE 42.4Second bullet point

⎯ The dose rate analysis should be based on assuming the maximum radioactive content of the package or such a content for a Type B(U), Type B(M) or Type C package that would create the maximum dose rate at the surface of the package and at specific distances from the surface of the package as defined in the Transport Regulations. ⎯ The dose rate analysis should take into account the most recent ICRP recommendations on nuclear decay data for dosimetric calculations (e.g. see Ref [9]).

Editorial – The second sentence should be a separate bullet point (third bullet point) as it covers a different topic. This wording should also assure consistency with the Appendices I, II and III).

WNTI-114

Appendix IV TABLE 42.4


[9] INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION, Nuclear

It is proposed to come back to the text that was available in the draft that was submitted to TRANSSC 39. This text was more general, and it does not seem appropriate to focus only on nuclear decay data for dosimetric calculations (included in ICRP Publications 107). For instance, ICRP Publication 103 “The 2007 Recommendations of the

32

Decay Data for Dosimetric Calculations, ICRP Publication 107, Ann. ICRP 38, Elsevier (2008).





International Commission on Radiation Protection” is also very important as it includes the recommended values for the radiation weighting factors.

WNTI-115

Appendix IV TABLE 42.47th bullet point from the end

- Dose rate analysis should be based on tThe maximum radioactive contents of the package design, which should could be defined by various methods and parameters, such as nuclide specific activities, and source terms for gamma and neutron emitters. (…).

Editorial – Simplification of the wording to avoid duplication of the 2nd bullet point in 2.4.– Use of a similar wording as in Appendix II and Appendix III.

WNTI-116

Appendix IV TABLE 42.4Bullet

- Proof that the sources are maintained secure in their storage positions for drop test sequence conditions in their storage positions (e.g., in an irradiator) should be provided in the

Editorial: clarification and consistency with wording used in Appendix III.

33

point before the last bullet point

structural analysis, if applicable.

WNTI-117

Appendix IV TABLE 42.4Last bullet point

⎯ For the materials providing radiation shielding, local melting or combustion during the thermal test should be considered, as determined by the thermal analysis, and the thermal dose rate analysis should take into account the effects of penetration or deformation of components by the bar in the mechanical test.

According to the table of resolutions, J/155 was accepted.

WNTI-118

Appendix IV TABLE 42.6Second bullet point

⎯ When the radiolysis phenomenon limits the maximum safe duration of transport, any specified limit for the duration of transport should necessarily integrate margins for incidents and emergency response operations;

The word “necessarily” is for a requirement and is not appropriate in a guide (and is in contradiction with the word “should” which is for a recommendation).

WNTI-119

Appendix V FIG. 2

Editorial: the abbreviations “CA” and “CSI” should be defined.

WNTI-120

Appendix V FIG. 24th line from the topLast column

Package design specified in a CA fissile “F” certificate (802(a)(v)) (including or Sspecial Aarrangements)

“Special Arrangements” are approved shipments (and not approved fissile package design).

WNTI-121

Appendix V FIG. 2Last line Second box from the right

The text in this box should be aligned with the text in the other boxes of the last line.

Editorial.

WNTI-122

Appendix V V.4.Second

⎯ Group No 2: Transport with exception (…) The colon after “Group No 2” should not be underlined.

34

bullet point

WNTI-123

Appendix V V.5.

V.5. The same package design may be assigned to different groups for different consignments. (…)

Clarification.

WNTI-124

Appendix V V.8. (b)

(b) (…). The acceptance criteria should be specified by the designer and should be derived (…). The design assumptions refer to the design specification provided in items 1.2. and 1.3. of the PDSR and or to other assumptions derived from the design specifications and used in the technical analyses. All mechanical and thermal characteristics of each component of the package and acceptance criteria used in technical analyses should be defined. The design assumptions should take into account ageing mechanisms, as necessary. (see also Additional recommendations are provided in paras 613A.1 to 613A.4 of SSG-26 (Rev. 1) [2]).

Editorial. Clarification. Use of similar wording as in Appendix II, Appendix III and Appendix IV.

WNTI-125

Appendix V V.8.

(c) The safety demonstration of a package design for fissile material is required to be accomplished in accordance with para. 701 (…):

This part of the text should be numbered (c) (as, for instance, in Appendix IV). It should be noted, that later in V.8., there is an item (d).

Editorial: use of similar wording as in Appendix II and Appendix III.

WNTI-126

Appendix V V.8. (i)

(i) (…) the competent authority should be notified of the programme in advance of the testing and the competent authority should be allowed to witness the testing. (…)

Editorial. The wording that is proposed here is the wording that is used in Appendix IV.

35

WNTI-127

Appendix V V.8. (iii)

(iii) (…) If computer codes are used for the safety analysis, then additional information should be included in order to justify that the code is verified and validated in its field of use.

Editorial. Simplification. The wording that is proposed here is the wording that is used in Appendix II, Appendix III and Appendix IV.

WNTI-128

Appendix V V.8. (d)

(d) (…) Other hazards that may have a consequential effect on the safety functions of the package should be analysed. (…).

Editorial. Use of the same wording as in Appendix II, Appendix III and Appendix IV.

WNTI-129

Appendix V V.9.

V.9. (…)⎯ Part 2:

- Shielding analysis- Other analyses.

“Shielding analysis” is not needed for packages containing fissile material (and is not included in Part 2 of Table 5.

WNTI-130

Appendix V TABLE 51.1.

Group No 2:

When one of the provisions of subparagraphs (a) to (f) of para. 417 of the Transport Regulations applies to the package, then a reference to the provision should be added. Especially, when para. 417 (f) applies, multilateral approval is required for the package fissile material.

Para. 417 (f) of the Transport Regulations applies to fissile material, not to a package. The multilateral approval is required for the fissile material, not for the package. See also para. 802 (a) (iii) in the Transport Regulations.

WNTI-131

Appendix V TABLE 51.1.

Group No 4:The following administrative information should be added, when necessary:(a) Colloquial name of the package, if applicable;(b) A certificate of approval of the package design for fissile material issued by the competent authority Type of package.

Clarification (what is required in (b) is not clear) and use of a similar wording as the wording that is used in Appendix I, Appendix II, Appendix III and Appendix IV.

WNTI-132

Appendix V TABLE 51.2.Group No 4(a)

(a) Mass of fissile nuclides and enrichment of the contents, if applicable. A description of quantities of nuclides not defined as fissile, but able to sustain chain reaction should also be

Editorial. A verb is missing in the second sentence. See also See also the text in the draft that was submitted to TRANSSC 39.

36

included (e.g. if certain actinides could be present in sufficient quantity or concentration to increase the neutron multiplication factor, their concentrations and/or quantities should be defined).

WNTI-133

Appendix V TABLE 51.2.Last paragraph

This last paragraph should be indented and aligned with the text in (c)

Criticality safety can be very sensitive to the presence and geometrical arrangement of fissile material (e.g. possibility and size of lattice arrangements), moderators (e.g. water, graphite, beryllium, and other light elements) and reflectors. This should be taken into account in the description of the permitted and not permitted contents.

This last paragraph is directly related to the information in (c), not to all the information in 1.2. See also the text in the draft that was submitted to TRANSSC 39.

WNTI-134

Appendix V TABLE 51.3.Group No 3(d)

(d) Testing specifications and controls before first use to transport radioactive material,. including acceptance tests to This ensures compliance of the fabrication to the design and allows acceptance of the specimen before its first use. See also para. 501 of the Transport Regulations.

Editorial. Consistency with the wording used in Appendix IV. It is proposed to use the same general wording as in Appendix IV, as it is more accurate.

WNTI-135

Appendix V TABLE 51.3.Group No 4(a) and (b)

(a) The overall dimensions, the maximum mass of the package, when fully loaded, and the mass of the empty packaginge (additional configurations may be included, depending on the operation conditions);(b) A list of packaging components important to safety and their materials, including their specifications and methods of manufacture of the components, specifications for material procurement, welding, other special processes, non-destructive evaluation examination and testing;. The properties of materials of


37

components that are expected to maintain their safety function under the thermal test, should be given for a range of temperature reachable during such a test;

WNTI-136

Appendix V TABLE 51.3.Group No 4(j)

(j) Testing specifications and controls before first use to transport radioactive material. (acceptance tests to This ensures compliance of the fabrication to the design and allows acceptance of the specimen before its first use). See also para. 501 of the Transport Regulations.

Editorial. Consistency with the wording used in Appendix IV (and also in above Group No 3 (d)). It is proposed to use the same general wording as in Appendix IV, as it is more accurate.

WNTI-137

Appendix VTABLE 51.4

Depending on the package design, the information relating to the ageing considerations, expected in this section of the PDSR, can also be provided by the package designer directly in the table mentioned in item 1.6. For packagings used once for a single transport and not intended for shipment after storage, this section should be left blank.(…).

The first and second sentences should be merged in a single paragraph, as they cover similar topics. See also Appendix II and Appendix III. See also the text drafted during the Consultancy Meeting which was held in January 2020.

WNTI-138

Appendix VTABLE 51.4. (d)

(d) Analysis of the influence of the ageing of packaging and contents on the design assumptions for demonstration of compliance with the regulations including the technical analyses in Part 2 of the PDSR. In this analysis , considering the specified intended use conditions, ageing mechanisms and operational measures should also be considered.


WNTI-139

Appendix VTABLE 51.5.

(…)Group No 4: This section should describe tThe main design principles and performance characteristics of the package design to meet the criticality safety requirements of the Transport Regulations should be described in

Clarification and consistency with Appendix IV. The wording that is proposed here is the wording used in Appendix IV.

Editorial.

38

this section.(…)This section should enable the package designer will help to ensure that the package design and the various parts of the safety demonstration are compatible with one another.

(…). The state of the parts of the confinement system under normal and accident conditions should be derived from the design and the behaviour of the package under the test conditions,. oOtherwise conservative assumptions should be taken, and their conservatism should be demonstrated.(…).

WNTI-140

Appendix VTABLE 51.7.Group No 3

Group No 3:⎯ Specifications for assembling of the packaging components, (including compliance with the requirements established in para. 637 of the Transport Regulations.

Editorial: correction of a typo.

WNTI-141

Appendix VTABLE 51.7.Group No 4(i)

(i) The methods used for operational controls and tests,. iIn particular those required in paras 502 and 503 of the Transport Regulations, should be detailed;

Editorial: correction of a typo.

WNTI-142

Appendix VTABLE 51.7.Group No 4(iii)

(iii) For leak tightness testing, qualified methods should be implemented (see item 12.3. of the PDSR). (…).

Item 2.3 “Containment analysis” is more relevant. According to the table of resolution, WNTI/60 was accepted.

WNTI-143

Appendix VTABLE 51.7.Last bullet point

- Specifications for the (vi) aAssembling of the packaging components, including compliance with the requirements established in para. 637 of the Transport Regulations.

This item should be an additional item to those listed in (i) to (v) (as it is the case in the other appendices).

39

WNTI-144

Appendix VTABLE 51.8 (d)

(d) Structural and pressure tests (including internal enclosures, tie-down and handling attachments) and pressure tests;

Clarification: the text between brackets is about the structural tests (and not about the pressure tests).

WNTI-145

Appendix VTABLE 51.8 (e)

(e) Component and material tests, including tests for (screws, bolts, welds, neutron absorbers, basket, etc.).

Editorial. Consistency with the wording used in Appendix IV.

WNTI-146


No additional information is needed for Groups No. 2_and No.3.

Group No.4: Additional information about the For packages that are to be used for shipment after storage, the PDSR should include a gap analysis programme describing a systematic procedure for a periodic evaluation of changes of regulations, changes in technical knowledge should be provided, if necessary and changes of the state of the package design during storage (see also paras 613A.5, 809.3 and 809.4 of SSG-26 (Rev. 1) [2]).

Editorial: the underline sign “_” between “No 2” and “and No 3” should be deleted.

Group No 4: consistency with the wording used in Appendix IV; the wording used in Appendix IV seems to be more accurate.

WNTI-147


No additional information is needed for Groups No. 2_and No.3.

Group No 4: The management system should include cover the following information activities, if necessary:(…)

The management system should include the descriptions of tThe actions to be performed to check the compliance with the PDSR of the operational documents with the PDSR relating to package operation (e.g. manufacture, operation or maintenance manual) and the management of deviations detected in the

Editorial: the underline sign “_” between “No 2” and “and No 3” should be deleted.

Group No 4: consistency with the wording used in Appendix IV; the wording used in Appendix IV seems to be more accurate.

40

framework of any transport activity should be described in the management system.

For all components important to safety, this section of the PDSR should define the parameters to be guaranteed to assure compliance with the package design, and thereby safety, and the level of controls during manufacturing and maintenance.

WNTI-148


(…).Group No 3: A reproducible illustration should be provided showing the make-up of the package, including shock absorbers and packaging inserts internal arrangements, if applicable.

The illustration should indicate at least the overall outside dimensions and the masses for of the package when empty and when loaded conditions.

Group No 4: A reproducible illustration should be provided showing the make-up of the package, including shock absorbers, devices for thermal protection and packaging inserts internal arrangements, if applicable.


Clarification – During the Consultancy Meeting in January 2020, WNTI comments about the changes from “packaging inserts” to “internal arrangements” were accepted (the wording “internal arrangements” is easier to understand than “inserts”). See also 1.3. (b) for Group No 3 and 1.3. (d) for Group No 4, in Appendix IV, where the wording “internal arrangements” is used.


WNTI-149

Appendix V TABLE 52.1.3rd paragraph

The additional structural analysis results of the assessment of the mechanical behaviour (including, as applicable, analysis of thermal stresses, fatigue, brittle fracture and creep) for routine, normal and accident conditions of

Editorial. Clarification. Consistency with the wording used in Appendix II, Appendix III and Appendix IV.

41

transport should cover:

WNTI-150

Appendix V TABLE 52.14th paragraph

See also the remarks in item. 1.35. of the PDSR.

Item 1.3 “Specification of the packaging” is not relevant for the purpose of this bullet point. Item 1.5 “Package performance characteristics” is more appropriate (and that is what was agreed during the Consultancy Meeting in December 2018).

WNTI-151

Appendix V TABLE 52.1 (1) (i)

(i) (…) for the ambient temperature range of -40°C to +38°C or another temperature range specified by the competent authority (…)

Editorial: a space is needed between “+38°C” and “or another temperature range”.

WNTI-152

Appendix V TABLE 52.1 (1) (iv)



WNTI-153

Appendix V TABLE 52.1 (2) (i)

(i) The package orientations should be determined in accordance with paras 722.4, 722.6 and 727.5 of SSG-26 (Rev. 1) [2]. (…)


WNTI-154

Appendix V TABLE 52.1 (1) (ii)

(ii) The impacts on the package behaviour due to variations in the shock absorbing properties of the shock absorber material (e.g. wood, polymers, plaster, concrete) should be analysed for the ambient temperature range of -40°C to +38°C, or another temperature range specified by the competent authority in accordance with para. 679 of the Transport Regulations, or and for the range of moisture conditions that is likely to be encountered during transport;

Clarification (what is expected for “moisture”?).

WNTI-155

Appendix V TABLE 52.1 (1) (viii)

(viii) The condition of the confinement system should be determined to demonstrate compliance with the specification of packaging

Clarification and consistency with the wording used in Appendix IV.

42

presented in item 1.3. 2.4. of the PDSR for an ambient temperature range from -40°C to +38°C or another temperature range specified by the competent authority in accordance with para. 679 of the Transport Regulations;

Item 1.3 “Specification of the packaging” is not relevant for the purpose of this bullet point. Item 2.4 “Criticality analysis” is more appropriate (and that is what was agreed during the Consultancy Meeting in December 2018).

WNTI-156

Appendix V TABLE 52.1 (2) (ii)

(ii) For reduced scale models, similar or conservative geometry and material properties similar to the original design, or conservative geometry and material properties, should are to be used as with the original design.

Clarification. The current sentence is difficult to understand. The wording that is proposed here is the wording that is used in Appendix II and Appendix III.

WNTI-157

Appendix V TABLE 52.1 (2) (iii)



WNTI-158

Appendix V TABLE 52.1 (2) (iv)5th bullet point

⎯ The scaling of tightening torques (…) in an exact geometrical and physical scaling of the containment system and of the confinement system components;

For packages containing fissile material, the confinement system is as important as the containment system.

WNTI-159


⎯ For In case of reduced scale model drop testing with significant deformations of impact limiters, the original package performance should be carefully justified.

(v) The experimental mechanical tests should be conducted and reported in accordance with the management system. (…)

- Editorial. The wording that is proposed here is the same wording as in Appendix IV.

- All the items in 2.1 (1), (2) and (3) are numbered (see also Appendix III).

WNTI-160

Appendix V TABLE 52.1 (3)

(3) Considerations for calculations:

(i) (…);

(ii) Validated computer codes should be used. It

(ii) The same wording as in Appendix II, Appendix III and Appendix IV should be used, as it is more precise and provide more information.

43

should be justified that iInput parameters (e.g. material laws, characteristic values, boundary conditions) should describe sufficiently and precisely the real technical and/or physical problems and the use of these parameters should be justified;



(iii) Editorial – Clarification and simplification.

(iv) Editorial - “Should” is a better word in a guidance document. The wording that is proposed here is the wording that is used in Appendix II.

WNTI-161

Appendix V TABLE 52.2 3rd bullet point

- The justification for simplifying the assumptions (e.g. absence of trunnions) used for calculation in under normal and accident conditions of transport;

Editorial – Consistency with the wording used in Appendix IV.

WNTI-162

Appendix V TABLE 52.2Third paragraph8th bullet points

⎯ The profile of heat power based on the burnup distribution in irradiated fuels considered in the thermal analysis;

Editorial: simplification.

WNTI-163

Appendix V TABLE 52.5

2.5. 2.4. CRITICALITY SAFETY ANALYSIS Editorial – The paragraph just before is numbered 2.3.

WNTI-164

Appendix V TABLE 52.5 (New 2.4)First

The general considerations for all technical analyses should be taken into account when performing the criticality safety analysis.

Editorial – Such introductory wording is not used in the other similar items, and is redundant with

44

paragraph the introductory sentence in V.8.

WNTI-165

Appendix V TABLE 52.5 (New 2.4)(b) (i) and (ii)

(i) (…). The testing conditions defined in para. 680 (a) of the Transport Regulations should be taken into account;(ii) For packages to be transported by air, subcriticality of the isolated package should be assessed under conditions consistent with Type C package tests, assuming reflection by at least 20 cm of water but no water in-leakage. (…)

(i) Clarification.

(ii) Clarification. This is also the wording used in para. 683 (a) of the Transport Regulations.

WNTI-166

Appendix VI VI.2. and VI.3.

VI.2. The recommendations provided in this appendix apply in addition to those items belonging to the package type defined by the radioactive properties of the contents, see Appendices II to IV.VI.32. Further recommendations are available provided in SSG-26 (Rev. 1) [2].VI.3. The recommendations provided in this appendix apply in addition to those items belonging to the package type defined by the radioactive properties of the contents, see Appendices II to IV.

Editorial – The items should be ordered as in the other appendices. The wording should be the same as in the other appendices.

WNTI-167

Appendix VI VI.6. a) to e)

The items a) to e) should be numbered (a) to (e).

Editorial – Consistency of numbering format throughout the document.

WNTI-168

Appendix VI VI.6. (a)

(a) The package design that is being evaluated should be uniquely identified by precisely indicateding by mentioning the drawing (…).

Editorial – Some words are missing in this sentence to make it understandable. It is proposed to use the same wording as in the other appendices.

WNTI-169

Appendix VI VI.6. (b)

(b) (…). The acceptance criteria should be specified by the designer and should be derived (…). The design assumptions refer to the design specification provided in items 1.2.

Editorial. Clarification. Use of similar wording as in Appendix II, Appendix III and Appendix IV.

45

and 1.3. of the PDSR and to other assumptions derived from the design specifications and used in the technical analyses. All mechanical and thermal characteristics of each component of the package and acceptance criteria used in technical analyses should be defined. The design assumptions should take into account ageing mechanisms, as necessary. Additional recommendations are provided in paras 613A.5 613A.6 of SSG-26 (Rev. 1) [2].

Correction of typo. Para. 613A.5 of SSG-26 (Rev. 1) is not relevant in this context, as it is about ageing management programme (and not precisely about ageing mechanisms). It is not quoted in the other appendices. Conversely, para. 613A.6 of SSG-26 (Rev. 1) is dedicated to UF6 and should be quoted here.

WNTI-170

Appendix VI VI.6. (c)

(c) The safety demonstration of a package design containing 0.1 kg or more of uranium hexafluoride is required to be accomplished in accordance with para. 701 (…):

Editorial – Use of similar wording as in Appendix II and Appendix III..

WNTI-171

Appendix VI VI.6. (c) (i)

(i) (…)When a programme for physical testing of prototypes or models of appropriate scale is implemented for a specific package design to be approved by the competent authority, the competent authority should be notified of the programme before in advance of the testing and should be allowed to witness the testing. (…).

Editorial. The wording that is proposed here is the wording that is used in Appendix IV.

WNTI-172

Appendix VI VI.6. (c) (iii)

(…)The methods or standards used in each analysis specified in paras items 2.1 to 2.3 of this appendix the PDSR should include a description of the analysis technique used, the limitations and accuracy of this technique and the demonstration of the correct application of the technique for the analysis of the package design.

Clarification. The wording that it is proposed here is the wording that is used in Appendix II, Appendix III, Appendix IV and Appendix V.

WNTI-173

Appendix VI VI.6. (c) (iii)Last paragraph

If computer codes are used for the safety analysis, then additional information should be

The recommendations included in the end of this paragraph are not

46

included in the PDSR to justify that the code is verified and validated in its field of use. The justification for the applicability of these codes should include a statement of possible sources of errors and/or uncertainties relative to the effects of the operating platform (computer) used and of modelling assumptions and simplifications as well as of any other parameter influencing the calculated results. This may include sensitivity analysis.

included in Appendix IV for Type B(U), Type B(M) and Type C packages, nor in Appendix V for packages containing fissile nuclides. It should not be included in Appendix VI for packages containing 0.1 kg or more of uranium hexafluoride.

WNTI-174

Appendix VI VI.6. (d)

(d) (…) Other hazards that may have a consequential effect on the safety functions of the package should be analysed. (…).

Editorial. Use of the same wording as in Appendix II, Appendix III and Appendix IV.

WNTI-175

Appendix VI TABLE 61.3. (a)

(a) A list of packaging components important to safety and their materials, including their specifications and methods of manufacture of the components, specifications for material procurement, welding, other special processes, non-destructive evaluation examination and testing;. The properties of materials of components that are expected to maintain their safety function under the thermal test, should be given for a range of temperature reachable during such a test;


WNTI-176

Appendix VI TABLE 61.3. (g)

(g) Testing specifications and controls before first use to transport uranium hexafluoride. This ensures compliance of the fabrication to the design and allows acceptance of the specimen before its first use. See also para. 501 of the Transport Regulations.

Editorial. Consistency with the wording used in Appendix IV. It is proposed to use the same wording as in Appendix IV, as it is more accurate.

WNTI-177

Appendix VITABLE 61.4

Depending on the package design, the information relating to the ageing considerations, expected in this section of the PDSR, can also be provided by the package

The first and second sentences should be merged in a single paragraph, as they cover similar topics. See also Appendix II and

47

designer directly in the table mentioned in item 1.6. For packagings used once for a single transport and not intended for shipment after storage, this section should be left blank.(…).

Appendix III. See also the text drafted during the Consultancy Meeting which was held in January 2020.

WNTI-178

Appendix VITABLE 61.4 (d)

(d) Analysis of the influence of the ageing of packaging and contents on the design assumptions for demonstration of compliance with the regulations including the technical analyses in Part 2 of the PDSR. in this analysis , considering the specified intended use conditions, ageing mechanisms and operational measures should also be considered.


WNTI-179

Appendix VITABLE 61.4 (d)Last paragraph

More recommendations are provided in para paras 613A.5 613A.6 of SSG-26 (Rev. 1) [2].

Correction of typo. Para. 613A.5 of SSG-26 (Rev. 1) is not relevant in this context, as it is about ageing management programme (and not precisely about ageing mechanisms). It is not quoted in the other appendices. Conversely, para. 613A.6 of SSG-26 (Rev. 1) is dedicated to UF6 and should be quoted here.

WNTI-180

Appendix VITABLE 61.51st paragraph

The following information should be added, when necessary:

Editorial – Such introductory wording is not used in the other similar items, and is redundant with the introductory sentence in V.8.

WNTI-181

Appendix VITABLE 61.5Last bullet point

This section should enable the package designer will help to ensure that the package design and the various parts of the safety demonstration are compatible with one another.

Clarification and consistency with Appendix IV. The wording that is proposed here is the wording used in Appendix IV.

WNTI-182


The applicable paragraphs of the Transport Regulations for packages containing 0.1 kg or

Editorial (there are two final periods at the end of sentence).

48

Last paragraph more of uranium hexafluoride are provided in a matrix in Annex I..

WNTI-183


Additional information about the For packages that are to be used for shipment after storage, the PDSR should include a gap analysis programme describing a systematic procedure for a periodic evaluation of changes of regulations, changes in technical knowledge should be provided, if necessary and changes of the state of the package design during storage (see also paras 613A.5, 809.3 and 809.4 of SSG-26 (Rev. 1) [2]).

Consistency with the wording used in Appendix IV; the wording used in Appendix IV seems to be more accurate.

WNTI-184


(…)The management system should include cover the following information activities, if necessary:(…)

The management system should include the descriptions of tThe actions to be performed to check the compliance with the PDSR of the operational documents with the PDSR relating to package operation (e.g. manufacture, operation or maintenance manual) and the management of deviations detected in the framework of any transport activity should be described in the management system.

For all components important to safety, this section of the PDSR should define the parameters to be guaranteed to assure compliance with the package design, and thereby safety, and the level of controls during manufacturing and maintenance.

Consistency with the wording used in Appendix IV; the wording used in Appendix IV seems to be more accurate.

WNTI-185

Appendix VITABLE 6

A reproducible illustration should be provided showing the make-up of the package, including

There is no “packaging inserts” (or “internal arrangements”) in UF6

49

1.11 shock absorbers, and devices for thermal protection and packaging inserts, if applicable.


cylinders. “Packaging inserts” is not a good example in Appendix VI.


WNTI-186

Appendix VITABLE 62.1 (b)

(b) Any other package components (e.g. shock absorbing components, packaging components that provide heat dissipation thermal protection) whose performance may have a consequential effect upon (a).

“packaging components that provide heat dissipation” is not a good example for packages containing uranium hexafluoride, as the heat load in such a package is negligible. It should be better to mention the “packaging components that provide thermal protection” (for the fire test)..

WNTI-187

Appendix VITABLE 62.1 (1) (ii)

(ii) The impacts on the package behaviour due to variations in the shock absorbing properties of the shock absorber material should be analysed considering the temperature range applicable to the type of package, or and the range of moisture conditions that is likely to be encountered during transport;

Clarification (what is expected for “moisture”?). Consistency with the wording that is proposed for Appendix IV and Appendix V.

WNTI-188

Appendix VITABLE 62.1 (1) (v)

(v) The condition of the containment system should be determined to demonstrate compliance with the specifications the packaging (see item 1.3. of the PDSR) within requirements established in paras 632 (a) and (b) of the Transport Regulations for the temperature range applicable to the type of package;

The item of the PDSR to be quoted should be 2.3 “Containment analysis” (see also the comment on Appendix IV, TABLE 4, 2.1 (1) (viii)) (and not 1.3 “Specification of the packaging”). But item 2.3 mentions that compliance with para. 632 has to be provided in item 2.1 “Structural analysis”, where – in the introductory sentence – the paras 632 (a) and (b) are quoted.

50

WNTI-189

Appendix VITABLE 62.1 (1) (vi)

(vi) The ability to withstand the maximum pressure during the thermal test (elevation of pressure of UF6) should be demonstrated.

This subject is covered by the third paragraph in 2.2 “Thermal analysis” “The demonstration of compliance should be limited to show compliance with para. 632 (c) of the Transport Regulations.”

WNTI-190

Appendix VI TABLE 62.1 (2) (i)

(i) The package orientations should be determined in accordance with para.s 722.4 and 722.6 of SSG-26 (Rev. 1) [2]. The orientations should be such that maximize the loading of the package (sin terms of stress, strain, acceleration and deformation) with consideration of the different package components (e.g. cask cylinder body, lid system, impact limiter) and of the protection objective (containment).

For package orientations, the following aspects tests should be considered:(…)




The examples have to be reworded to be adapted to the case of UF6

cylinders.

Editorial. Use of the same wording as in Appendix IV and Appendix V.

WNTI-191

Appendix VITABLE 62.1 (2) (ii)

(ii) For reduced scale models, similar or conservative geometry and material properties similar to the original design, or conservative geometry and material properties, should are to be used as with the original design.

Clarification. The current sentence is difficult to understand. The wording that is proposed here is the wording that is used in Appendix II and Appendix III.

WNTI-192

Appendix VI TABLE 62.1 (2) (iii)



WNTI-193


⎯ For In case of reduced scale model drop testing with significant deformations of impact limiters, the original package performance should be carefully justified.

- Editorial. The wording that is proposed here is the same wording as in Appendix IV.

51

WNTI-194

Appendix VI TABLE 62.1 (2)Last paragraph



WNTI-195

Appendix VI TABLE 62.1 (3)

(3) Considerations for calculations:

(i) (…);

(ii) Validated computer codes should be used. It should be justified that iInput parameters (e.g. material laws, characteristic values, boundary conditions) should describe sufficiently and precisely the real technical and/or physical problems and the use of these parameters should be justified;


(iv) (…)

(ii) The same wording as in Appendix II, Appendix III and Appendix IV should be used, as it is more precise and provide more information.

(iii) Editorial – Clarification and simplification.

WNTI-196

Appendix VI TABLE 62.2First paragraph

The general considerations for all technical analyses should be taken into account when performing the thermal analysis.

Editorial – Such introductory wording is not used in the other similar items, and is redundant with the introductory sentence in VI.6.

WNTI-197

Appendix VI TABLE 62.2Second paragraph

The temperatures of the package components should be assessed in accident conditions of transport (see para. 659 (b) 632 (c) of the Transport Regulations). (…).

For packages containing 0.1 kg or more of uranium hexafluoride, the relevant paragraph for the thermal test is para. 632 (c) of the Transport Regulations. Para. 659 (b) of the Transport Regulations is for Type

52

B(U) package designs.

WNTI-198

Appendix VI TABLE 62.3

Compliance with para.s 632 (a) and (b) of the Transport Regulations should be demonstrated in the structural analysis. Compliance with para. 632 (c) of the Transport Regulations should be demonstrated in the thermal analysis.

Consistency with the statements in the first paragraph of 2.1 “Structural analysis” and in the third paragraph of 2.2 “Thermal analysis”.

WNTI-199

REFERENCES [4] EUROPEAN ASSOCIATION OF COMPETENT AUTHORITIES, Package Design Safety Reports for the Transport of Radioactive Material, European PDSR Guide Issue 23 (September 2012 December 2014).

To take into account the latest edition.

WNTI-200

ANNEX IICanada

(…)ISO 12807 “Safe transport of radioactive materials - Leakage testing on packages”(…)ANSI N14.7, “Guidance for Packaging Type A - Quantities of Radioactive Materials”(…)

Editorial- ISO 12807 – Need for a space between “… radioactive materials-“ and “Leakage testing…”.- ANSI N14.7 – See the proposed new text (including the deletion of “-“ between “Type A” and “Quantities”.

WNTI-201

ANNEX IIFrance

(…)Vol. 1: Applications for package design and shipment approvals : legal context, required documentation, approval certificate template, applicant obligations, reference demonstration methods and parameters, experience feedback of assessment key issues) Demandes d’agréments et d’approbations d’expéditions – Vol. 2: Dossiers de sûreté des modèles de colis, guide européen European PDSR ( “Package Design Safety Reports”) – Vol.3: Conformity of package designs that do not require a certificate of approval Conformité des modèles de colis non soumis à agrément

Editorial. These documents are only available in French, with a French title. The French title should be kept here.

53

(…)

WNTI-202

ANNEX IIFrance

(…)ROARK’s Formulas for stress and strain; 7th edition, Warren C. YOUNG(…)

Editorial – Need for a space between “… strain:” and “7th edition…”.

WNTI-203

ANNEX IIGermany

(…)BAM-GGR 011 “Quality Assurance Measures of Packagings for Competent Authority Approved Package Designs for the Transport of Radioactive Material”BAM-GGR 012 “Leitlinie zur Berechnung der Deckelsysteme und Lastanschlagsysteme von Transportbehältern für radioaktive Stoffe“

BAM-GGR 011 “Quality Assurance Measures of Packagings for Competent Authority Approved Package Designs for the Transport of Radioactive Material”

BAM-GGR 012 “Guideline on the Assessment of the Lid Systems and Load Attachment Systems of Transport Packages for Radioactive Materials“

DIN 25415 part 1 “Radioactively contaminated surfaces - Method for testing and assessing the ease of decontamination” FKM Guideline “Fracture Mechanics Proof of Strength for Engineering Components”

DIN 25415 part 1 “Radioactively contaminated surfaces - Method for testing and assessing the ease of decontamination”

FKM Guideline “Fracture Mechanics Proof of Strength for Engineering Components”

Editorial- BAM-GGR 011 and BAM-GGR 012 should be two different items.- A translation of BAM-GGR 012 is available on BAM web site. The title of the document in English could be used here.

- DIN 25415 and FKM Guideline should be two different items.

See also the draft that was submitted to TRANSSC 39.

54

(…)

WNTI-204

CONTRIBUTORS TO DRAFTING AND REVIEW

(…)Gauthier, GF.(…)


WNTI-205

Appendices I to IV

Tables 1 to 4

APPENDIX I - 1.5 PACKAGE OPERATIONSAPPENDIX I - 1.6 MAINTENANCEAPPENDIX II - 1.6 PACKAGE OPERATIONSAPPENDIX II - 1.7 MAINTENANCEAPPENDIX III - 1.6 PACKAGE OPERATIONSAPPENDIX III- 1.7 MAINTENANCEAPPENDIX IV - 1.7 PACKAGE OPERATIONSAPPENDIX IV - 1.8 MAINTENANCE

The minimum specifications for the following activities should be fully defined, as applicable:

Editorial: simplification and clarification.

WNTI-206

Appendices I to V

Tables 1 to 5

APPENDIX I - 1.5 PACKAGE OPERATIONSAPPENDIX II - 1.6 PACKAGE OPERATIONSAPPENDIX III - 1.6 PACKAGE OPERATIONSAPPENDIX IV - 1.7 PACKAGE OPERATIONSAPPENDIX V - 1.7 PACKAGE OPERATIONS

Last sentenceIf written procedures with a detailed description of these activities are available, then reference should might be made to these procedures.

Clarification and consistency with the conclusions of the Consultancy Meeting held in January 2020 (Comments WNTI/30 and WNTI/37 were accepted as modified).

WNTI-207

Appendices I to V

Tables 1 to 5

APPENDIX I - 1.6 MAINTENANCEAPPENDIX II - 1.7 MAINTENANCEAPPENDIX III- 1.7 MAINTENANCEAPPENDIX IV - 1.8 MAINTENANCEAPPENDIX V - 1.8 MAINTENANCE

Last sentenceIf written procedures with details of the package maintenance activities are available, then reference to these procedures should

Clarification and consistency with the draft that was made available to TRANSSC 39 and not modified during the Consultancy Meeting in January 2020.

55

might be made.

WNTI-208

General (…) containment design analysis (…) Editorial – Simplification and clarification

WNTI-209

General The draft that was submitted to TRANSSC 39 included examples (for instance in the appendix about excepted packages, in the box about “Acceptance criteria and design assumptions”). It is regretful that these examples have been deleted in the current draft.

WNTI-210

Appendices I to VI1.3

For Appendix IV “Type B(U), Type B(M) and Type C packages”, for the items that are listed for 1.3 “Specification of the packaging the following order is proposed.

(1) Design drawings;(2) The overall dimensions, the maximum mass of the package;(3) A list of packaging components important to safety and their materials;(4) The maximum normal operating pressure.(5) A description of the packaging body, lid (closure mechanism and tamper-indicating features) and internal arrangements, and components for lifting and tie-down;(6) A description of the protection against corrosion;(7) A description of the protection against contamination;(8) A description of the packaging components for heat dissipation; (9) A description of the packaging components of the containment system (including the definition of the containment boundary);(10) A description of the packaging components required for shielding; (11) A description of the shock absorbing components; (12) A description of the packaging

The principle is to group the information in a logical order:- General information and description [(1) to (5)],- Description of general protections [(6) and (7)],- Description of the packaging components for the safety function that are described in para. 104 of the Transport Regulations [(8) to (10)],- Description of the components for the protection in accident conditions of transport [(11) and (12)],- Tests and controls before first use ((13)].

For the other types of packages the same order should be followed, just keeping the information that are not relevant (as identified currently in each appendix).

56

components for thermal protection;(13) Testing specifications and controls before first use to transport radioactive material.

57

Documents

Safety Standards Series: Title · Web view2020-05-22 · For complex packages this may involve several big drawings, necessary for modelling and assessing the package for calculations