Transport Regulations (SSR-6 and SSG-26) 2015 Review Cycle

Transcription

1 Transport Regulations (SSR-6 and SSG-26) 2015 Review Cycle Reviewer: Page... of... Country/Organization: Date: [1] Comment No [2] SSR-6/SSG-26 Para/Line No. 220 Table 1 COMMENTS BY REVIEWER [3] Identified problem/proposed new text Design shall mean the description of LSA IV material under para. 409(d), the description of fissile material excepted under para. 417(f), special form radioactive material, low dispersible radioactive material, package or packaging that enables such an item to be fully identified. The description may include specifications, engineering drawings, reports demonstrating compliance with regulatory requirements, and other relevant documentation. Two additional entries: UN #### RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-IV), non-fissile or fissile-excepted b UN #### RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-IV), FISSILE [4] Reason/Description This change proposes a new provision to facilitate the cost effective and safe transport of bulk quantities of back end materials. The existing regulations for classification as LSA-II or LSA-III material provides a cost effective and safe means for the transport of qualifying materials. Materials that do not qualify must be transported in Type B(U/M) packaging. This results in a significant step increase in both cost and approval requirements. [5] Accepted [6] Accepted, but modified as follows RESOLUTION [7] Rejected [8] Reason for modification/rejection

2 Table 5 Table 6 601bis LSA material shall be in one of threefour groups: (a) [No change] (b) [No change] (c) [No change] (d) LSA-IV: LSA material that meets the requirements of paras 601bis and 802. A single package of noncombustible solid LSA-II, or LSA- III or LSA-IV material, if carried by air, shall not contain an activity greater than 3000A 2. One additional entry: Radioactive Contents: LSA-IV Exclusive Use: Type IP-2 Not under Exclusive Use: Type IP-3 Amendments to two entries: LSA-II, and LSA-III and LSA-IV non-combustible solids LSA-II, and LSA-III and LSA-IV combustible solids and all liquids and gases Requirements for LSA-IV material LSA-IV material shall not give rise to a significant inhalation or ingestion radiation hazard without the need for There is great diversity in the properties of back end materials such that specification of a single safety criterion or limited number of criteria that cover all international needs is not a realistic goal. Back end transport predominately takes place within a member state. It is therefore proposed that a provision is introduced for multilateral approval of suitable material designs that permits transport of the material in an Industrial Package. This proposal is analogous to para 417(f) for fissile excepted material designs. Thus this proposal is to introduce a new provision for multilateral approval of a material design as LSA-IV material, subject to demonstration that the material does not give

3 8 Croft Associat es SSR-6/ Para 617 accumulation control under the following conditions: (a) The condition of the material if it had been subjected to the tests specified in paras (b) The condition of the material if it had been subjected to the tests specified in paras followed by whichever of the following is the more limiting: (i) The tests specified in para. 727(b) and either para. 727(c) for packages having a mass not greater than 500 kg and an overall density not greater than 1000 kg/m 3 based on the external dimensions or para. 727(a) for all other packages, followed by the test specified in para. 728; or (ii) The test specified in para (c) The condition of the material if it had been subjected to the tests consistent with the Type C package tests specified in para. 734, if transported by air. This paragraph should either be deleted or some re-classification established, possibly moved into the Design Requirements for Type B(U) Packages and removed from general design rise to a significant inhalation or ingestion radiation hazard. Paragraph 617 imposes unrealistic

4 requirements for all packagings and packages. requirements on Type A/IP user requirements and Safeguarding sampling type contents. We need to address the requirement to ship unknown or unclassifiable contents such as decommissioning waste or retrieved obsolete sources. Most waste type contents are unknown, but assessed by user/consigners as very low risk. Most retrieved sources, which originally had special form certification, can only be assessed by the retrieval organization. At a design level, this requirement is probably unachievable for Type A and IP packaging and at an operational level this paragraph has a major and very significant impact.

5 9 10 SSR SSG Where the chemical or physical form, isotopic composition, mass or concentration, moderation ratio or density, or geometric configuration is not known, the assessments of paras shall be performed assuming that each parameter that is not known has the value that gives the maximum credible neutron multiplication consistent with the known conditions and parameters in these assessments Values of unknown or uncertain parameters should be appropriately selected to produce the maximum credible neutron multiplication factor for the assessments, as described in paras In practice, this requirement may be met by covering the effect of these uncertainties by a suitable allowance in the acceptance criteria. Mixtures whose contents Only applicable to Type B design assessments where the contents are known and can migrate or provide a point source scenario. However some realistic way needs to be found to enable wastes and other difficult to define materials to be shipped in Type B packages and the design requirements of the regulations need to be flexible to enable this. Particularly for radioactive waste the wording without this change leads to overly onerous application with no real safety benefit. This leads to unduly restricted fissile loadings that in turn will lead to increased numbers of shipments. To be consistent with 676. Also isotopics for changed to isotopic content of for clarity.

6 are not well defined are often generated as by-products of production operations, for example, contaminated work clothes, gloves or tools, residues of chemical analyses and operations, floor sweepings, etc., and as direct products from waste processing operations. It is important to determine the combination of parameters that produce the maximum credible neutron multiplication. Thus, the criticality safety assessment must both identify the unknown parameters and explain the interrelationship of the parameters and their effects on neutron multiplication. The range of maximum credible values possible (based on available information and consistent with the nature of the material involved) should be determined for each parameter, and the neutron multiplication factor for any possible credible combination of parameter values should be shown to satisfy the acceptance criteria. This principle should also be applied to the irradiation characteristics used to determine the isotopics content of for irradiated nuclear fuel.

7 12 804bis Competent authority approval shall be required for the following: (a) Designs for: (i) to (iii) [No change] (iiibis) LSA material under para. 409(d) (see paras 804bis and 804bisbis). (iv) to (vii) [No change] (b) to (f) [No change] The certificates of approval for the package design and the shipment may be combined into a single certificate bisbis APPROVAL OF LSA MATERIAL The design for a LSA material under para. 409(d) shall require multilateral approval. An application for approval shall include: (a) A detailed description of the LSA-IV material; particular reference shall be made to both physical and chemical states. (b) A statement of the tests that have been carried out and their results, or evidence based on calculative methods, to show that the material is capable of meeting the requirements specified in para. 601bis. (c) A specification of the applicable management system

8 832 as required in para (d) A statement of specific actions to be taken prior to shipment. The competent authority shall establish a certificate of approval stating that the approved material meets the requirements for LSA-IV material in accordance with para. 601bis and shall attribute to that design an identification mark. Each certificate of approval issued by a competent authority shall be assigned an identification mark. The mark shall be of the following generalized type: VRI/Number/Type Code (a) to (b) [No change] (c) The following type codes shall be used in the order listed to indicate the types of certificate of approval issued: AF Type A package design for fissile material B(U) Type B(U) package design (B(U)F if for fissile material) B(M) Type B(M) package design (B(M)F if for fissile material)

9 C Type C package design (CF if for fissile material) IF Industrial package design for fissile material S Special form radioactive material LD Low dispersible radioactive material LSA LSA-IV material complying with the requirements of para. 409(d) FE Fissile material complying with the requirements of para. 606 T Shipment X Special arrangement AL Alternative activity limits for an exempt consignment of instruments or articles In the case of package designs for non-fissile or fissile-excepted uranium hexafluoride, where none of the above codes apply, the following type codes shall be used: H(U) Unilateral approval H(M) Multilateral approval. (d) [No change]

10 Certificates of approval for LSA-IV material and material excepted from fissile classification Each certificate of approval issued by a competent authority for LSA-IV material or material excepted from classification as FISSILE shall include the following information: (a) Type of certificate; (b) The competent authority identification mark; (c) The issue date and an expiry date; (d) List of applicable national and international regulations, including the edition of the IAEA Regulations for the Safe Transport of Radioactive Material under which the exception is approved; (e) A description of the LSA-IV material or fissile excepted material; (f) Limiting specifications for the LSA-IV material or fissile excepted material; (g) A specification of the applicable management system, as required in para. 306; (h) Reference to information provided by the applicant relating to specific actions to be taken

11 prior to shipment; (i) If deemed appropriate by the competent authority, reference to the identity of the applicant; (j) Signature and identification of the certifying official; (k) Reference to documentation that demonstrates compliance with para. 601bis for LSA-IV material or with para. 606 for fissile excepted material.