STANDARD OPERATING PROCEDURE (SOP)

Transcription

1 . STANDARD OPERATING PROCEDURE (SOP) SUPPORTING DATA TO THE SOP: RADIOACTIVE MATERIALS TRANSPORT STATUTORY FRAMEWORK Whereas the rules and procedures for using sources of ionising radiation are mostly straightforward and intuitive, having been written for the non-specialist, by contrast understanding the transport of radionuclides is a minefield of meaning, nuance and cross reference complex complicated by the need to address international legislation in the form of: (i) the IAEA Regulations for the Safe Transport of Radioactive Material SSR-6 (2012), (ii) the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR), which is updated annually, and, (iii) the UK Corrigendum. Moreover, the responsibility for compliance with all transport legislation is delegated to the national Competent Authority, in the UK, the Office for Nuclear Regulation. The ONR takes a proactive role in compliance and inspection. DANGEROUS GOODS SAFETY ADVISER (DGSA) AND RADIATION PROTECTION ADVISER The University (Central Campus and Dalton Cumbria Facility) has appointed Simon Jakes of Public Health England (PHE) as it s DGSA for Class 7 Radioactive Materials along with Julian Dunderdale as the RPA contact. THIS DOCUMENT This SOP supports associated SOPs and Consignment Notes by guiding the reader through the various UN transport categories, providing guidance on how to determine maximum activity limits Author(s) Version Issue date Review date Ian Haslam (RSU) / /2020 Information governance doc ref: SOP transport technical addendum.docx

2 and how to interpret basic data. The appendices include the relevant extracts from SSR CLASSIFYING PACKAGES FOR CARRIAGE BY ROAD Table 1 UN number UN numbers and proper shipping names (ref. Table 1 SSR ), derivations of classification and explanations Proper shipping name - and description Excepted Packages UN2909 UN2910 UN2911 RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - ARTICLES MANUFACTURED FROM NATURAL URANIUM OR DEPLETED URANIUM OR NATURAL THORIUM RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - LIMITED QUANTITY OF MATERIAL RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - INSTRUMENTS OR ARTICLES Low specific activity material (to be transported in a Type IP-1 package) UN2912 RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), non-fissile or fissile-excepted Type-A package UN2915 RADIOACTIVE MATERIAL, TYPE A PACKAGE, non-special form, non-fissile or fissile excepted Notes (i) The PROPER SHIPPING NAME is restricted to that part shown in CAPITAL LETTERS. (ii) fissile-excepted means material excepted under paragraph 417 of IAEA SS-R (Appendix I) (iii) LSA-1 includes uranium and thorium naturally containing ores, unirradiated compounds and mixtures, and also radioactive material where the A 2 value is unlimited. (ref. paragraph 409(a) SSR : Appendix I) HOWEVER - in practical terms, only EXEMP, EXCEPTED or the occasional TYPE-A package may be carried by University staff, LSA-1 may not. EXPLANATION: under the ADR drivers are required to received validated training delivered and certificated by a competent organisation (approved by the Office for Nuclear Regulation; ONR) in order to be able to transport any other than EXCEPTED packages (EXEMPT and the occasional TYPE A): Condition S5, page 565 of the ADR 2015, gives exemption from paragraph 8.2.1, which relates to driver training. (iv) UN2909 is defined in Appendix I paragraph 426 (below). Further self-explanatory extracts from SSR relating to general training are reproduced in Appendix III.

3 DETERMINING ACTIVITY LIMITS FOR EXEMPT AND EXCEPTED PACKAGES Table 2 A values and EXEMPT limits Radionuclide A1 A2 Activity concentration limit for EXEMPT material Activity limit for an EXEMPT consignment TBq TBq Bq/g Bq H-3 4 x x x x 10 9 C-14 4 x x x x 10 7 P-32 5 x x x x 10 8 P-33 4 x x x x 10 6 Cl-36 1 x x x x 10 6 Ca-45 4 x x x x 10 7 Co-57 1 x x x x 10 6 Co-60 4 x x x x 10 5 Cr-51 3 x x x x 10 7 Mn-54 1 x x x x 10 6 Fe-55 4 x x x x 10 6 Ni-63 4 x x x x 10 8 Zn-65 2 x x x x 10 6 Cu-67 1 x x x x 10 6 Kr-85 1 x x x x 10 4 Sr-90 3 x x x x 10 4 Tc-99 4 x x x x 10 7 Tc-99m 1 x x x x 10 7 Cd x x x x 10 6 I x x x x 10 6 Cs x x x x 10 4 Gd x x x x 10 7 Ir x x x x 10 4 Po x x x x 10 4 Pu x x x x 10 4 Pu x x x x 10 5 Np x x x x 10 3 Np x x x x 10 7 Am x x x x 10 4 Th - natural Unlimited Unlimited 1 x x 10 3 U - natural Unlimited Unlimited 1 x x 10 3

4 U - depleted Unlimited Unlimited 1 x x 10 3 Definition of unlimited This definition is not straightforward and difficult to interpret. The University s DGSA has determined that paragraph 409(a) provides the definition by defining LSA-1 as material where the material is (ii) Natural uranium, depleted uranium, natural thorium or their compounds or mixtures, that are unirradiated and in solid or liquid form [and] (iii) Radioactive material for which the A2 value is unlimited. This means if the material is Unlimited then it shall be consigned as LSA-1, for which a material limit does not apply. However, such materials may be shipped as UN2909 providing the uranium / thorium is appropriately sheathed in metal or in rigid containment. LSA-1 consignments may not be transported by University staff, whereas EXCEPTED packages may be. Table 3 EXEMPT quantities of natural uranium and thorium and also depleted uranium Radionuclide Concentration Consignment limit Mass limit Bq mg -1 Bq mg Th - natural 8 1 x U - natural 26 1 x U - depleted 15 1 x Note The definition of radioactive material as it pertains to transport is given in paragraph 236 of SSR , and states that both the limits specified in columns 4 AND 5 of Table 2 (above) must be exceeded for the material to be radioactive, i.e. if the consignment limit is less than specified in this table then the consignment is EXEMPT. The SOP on the transfer, transport and use of uranium and thorium samples goes into greater detail on the consignment of small quantities of materials and using the data presented in Table 3 to determine EXEMPT package limits. Note these data refer to compounds where the radionuclide is in secular equilibrium with their daughters. Table 4 Activity limits for EXCEPTED packages (ref. Table 4 SSR ) Physical state of contents Instrument or article Material Item limits Package limits Package limits Solids 10-2 A 2 A A 2 Liquids 10-2 A A A 2 EXCEPTED package limits for a range of radionuclides can be determined easily by multiplying the A2 value for the radionuclide in column 3 of Table 2 by the solid / liquid multiplier in column 4 of

5 Table 4. For example, the package limit for Fe-55 in solid form is TBq x 10-3 = 0.04 TBq (40 GBq). NON DELIVERY OF RADIOACTIVE PACKAGES It is essential that when consigning packages care is given to ensuring that: (i) the package is properly categorised and consigned with the correct UN number and proper shipping name and labels, (ii) has the correct consignment note or transport note (EXEMPT packages), (iii) an ONR declaration form has been completed, and, (iv) the package is expected by the recipient, is received and confirmation of receipt is given. Even when couriers are used responsibility for delivery lies with the consignor, meaning that the consignor has to arrange for the (immediate) recovery of the consignment. (v) Undelivered consignments must be notified to the Office for Nuclear Regulation by virtue of the following paragraph in SSR : ONR transport incident hotline (documents may be ed to class7@onr.gov.uk). 583 Where a consignment is undeliverable it shall be placed in a safe location and the appropriate competent authority shall be informed as soon as possible and a request made to the competent authority (ONR) for instructions on further action (SSR ).

6 APPENDIX I: VERBATIM EXTRACTS FROM IAEA SSR Paragraph 417 ACTIVITY LIMITS AND CLASSIFICATION: FISSILE MATERIAL 417. Fissile material and packages containing fissile material shall be classified under the relevant entry as FISSILE, in accordance with Table 1 unless excepted by one of the provisions of subparagraphs (a) (f) of this paragraph and transported subject to the requirements of para All provisions apply only to material in packages that meets the requirements of para. 636, unless unpackaged material is specifically allowed in the provision: (a) Uranium enriched in uranium-235 to a maximum of 1% by mass, and with a total plutonium and uranium-233 content not exceeding 1% of the mass of uranium-235, provided that the fissile nuclides are distributed essentially homogeneously throughout the material. In addition, if uranium- 235 is present in metallic, oxide or carbide forms, it shall not form a lattice arrangement. (b) Liquid solutions of uranyl nitrate enriched in uranium-235 to a maximum of 2% by mass, with a total plutonium and uranium-233 content not exceeding 0.002% of the mass of uranium, and with a minimum nitrogen to uranium atomic ratio (N/U) of 2. (c) Uranium with a maximum uranium enrichment of 5% by mass of uranium- 235 provided: (i) There is no more than 3.5 g of uranium-235 per package. (ii) The total plutonium and uranium-233 content does not exceed 1% of the mass of uranium-235 per package. (iii) Transport of the package is subject to the consignment limit provided in para. 570(c). (d) Fissile nuclides with a total mass not greater than 2.0 g per package, provided the package is transported subject to the consignment limit provided in para. 570(d). (e) Fissile nuclides with a total mass not greater than 45 g, either packaged or unpackaged, subject to the limits provided in para. 570(e). (f) A fissile material that meets the requirements of paras 570(b), 606 and 802. Paragraph 426 CLASSIFICATION OF PACKAGES 426. Articles manufactured of natural uranium, depleted uranium or natural thorium and articles in which the sole radioactive material is unirradiated natural uranium, unirradiated depleted uranium or unirradiated natural thorium may be classified under UN 2909, RADIOACTIVE MATERIAL, EXCEPTED PACKAGE ARTICLES MANUFACTURED FROM NATURAL URANIUM or DEPLETED URANIUM or NATURAL THORIUM, provided that the outer surface of the uranium or thorium is enclosed in an inactive sheath made of metal or some other substantial material. Paragraph 570 REQUIREMENTS AND CONTROLS FOR TRANSPORT 570. Fissile material meeting one of the provisions (a) (f) of para. 417 shall meet the following

7 requirements: (a) Only one of the provisions (a) (f) of para. 417 is allowed per consignment. (b) Only one approved fissile material in packages classified in accordance with para. 417(f) is allowed per consignment unless multiple materials are authorized in the certificate of approval. (c) Fissile material in packages classified in accordance with para. 417(c) shall be transported in a consignment with no more than 45 g of fissile nuclides. (d) Fissile material in packages classified in accordance with para. 417(d) shall be transported in a consignment with no more than 15 g of fissile nuclides. (e) Unpackaged or packaged fissile material classified in accordance with para. 417(e) shall be transported under exclusive use on a conveyance with no more than 45 g of fissile nuclides. Paragraphs 606 and 802 REQUIREMENTS FOR MATERIAL EXCEPTED FROM FISSILE CLASSIFICATION 606. A fissile material excepted from classification as FISSILE under para. 417(f) shall be subcritical without the need for accumulation control under the following conditions: (a) The conditions of para. 673(a); (b) The conditions consistent with the assessment provisions stated in paras 684(b) and 685(b) for packages; (c) The conditions specified in para. 683(a), if transported by air. APPROVAL AND ADMINISTRATIVE REQUIREMENTS: GENERAL 802. Competent authority approval shall be required for the following: (a) Designs for: (i) Special form radioactive material (see paras 803, 804 and 823); (ii) Low dispersible radioactive material see paras 803 and 804); (iii) Fissile material excepted under para. 417(f) (see paras 805 and 806); (iv) Packages containing 0.1 kg or more of uranium hexafluoride (see para. 807); (v) Packages containing fissile material, unless excepted by para. 417, 674 or 675 (see paras and 820); (vi) Type B (U) packages and Type B (M) packages (see paras and 820); (vii) Type C packages (see paras ). (b) Special arrangements (see paras ). (c) Certain shipments (see paras ). (d) Radiation protection programme for special use vessels (see para. 576(a)). (e) Calculation of radionuclide values that are not listed in Table 2 (see para. 403(a)). (f) Calculation of alternative activity limits for an exempt consignment of instruments or articles (see para. 403(b)). The certificates of approval for the package design and the shipment may be combined into a

8 single certificate. Paragraph 636 REQUIREMENTS FOR TYPE A PACKAGES 636. The smallest overall external dimension of the package shall not be less than 10 cm. APPENDIX II: TRAINING Paragraph 311 Workers 311. Workers shall receive appropriate training concerning radiation protection, including the precautions to be observed in order to restrict their occupational exposure and the exposure of other persons who might be affected by their actions. Paragraph 312 Persons engaged in transport 312. Persons engaged in the transport of radioactive material shall receive training in the contents of these Regulations commensurate with their responsibilities. Paragraph 313 Persons engaged in classifying, packing, etc Individuals such as those who classify radioactive material; pack radioactive material; mark and label radioactive material; prepare transport documents for radioactive material; offer or accept radioactive material for transport; carry or handle radioactive material in transport; mark or placard or load or unload packages of radioactive material into or from transport vehicles, bulk packagings or freight containers; or are otherwise directly involved in the transport of radioactive material as determined by the competent authority; shall receive the following training: General awareness training (a) General awareness/familiarization training: (i) Each person shall receive training designed to provide familiarity with the general provisions of these Regulations. (ii) Such training shall include a description of the categories of radioactive material; labelling, marking, placarding and packaging and segregation requirements; a description of the purpose and content of the radioactive material transport document; and a description of available emergency response documents. (b) Function specific training: Each person shall receive detailed training concerning specific radioactive material transport requirements that are applicable to the function that person performs; (c) Safety training: Commensurate with the risk of exposure in the event of a release and the functions performed, each person shall receive training on: (i) Methods and procedures for accident avoidance, such as proper use of package handling

9 equipment and appropriate methods of stowage of radioactive material. (ii) Available emergency response information and how to use it. (iii) General dangers presented by the various categories of radioactive material and how to prevent exposure to those hazards, including, if appropriate, the use of personal protective clothing and equipment. (iv) Immediate procedures to be followed in the event of an unintentional release of radioactive material, including any emergency response procedures for which the person is responsible and personal protection procedures to be followed. All drivers and other persons engaged in transport shall be issued with a Certificate (card) of competence by RSU. APPENDIX III: FURTHER NOTES ON TRANSPORTING LSA-1 Transport index (TI) Regulation on calculating the TI for LSA-1 is found in SSR para For most radionuclides the TI is the maximum dose rate at 1m in msv/h x 100. For chemical concentrates of thorium take the maximum dose rate at 1m in msv/h x 0.3, for chemical concentrates of uranium sum the dose rate at 1m in msv/h x Round the TI up to first decimal point (e.g = 1.2), but for Tis less than 0.05 use 0. Categories LSA-1 in a IP-1 is shipped using a I-WHITE label. For a TI 0 (or <0.05) and a surface dose rate of <0.005 msv/h use I-WHITE [For a TI <1 and a surface dose rate < dr <0.5 msv/h use II-YELLOW] Labelling for packages other than excepted Enter onto the surface of the package: consignor & consignee name, address and contact details the UN number and proper shipping name TYPE IP-1 Tyre IP-1 packages must always be legibly marked with TYPE IP-1 on the outside of the packaging.

10 APPENDIX IV: THE TRANSPORT OF EXCEPTED PACKAGES BY AIR Information for the captain The pilot of an airplane has the final decision on whether a package is carried and it is the pilot s final and unquestioned decision. To aid the process of decision making on the transport of EXCEPTED packages by agents and handlers, and to by-pass the need to bring the radioactive contents to the captain s attention the following label must be placed in a visible position on the package and filled in legibly; the red / white bordered label confirms that the package has been correctly packed, marked and consigned in accordance with relevant regulations.