TRANSPORT OF RADIOACTIVE MATERIALS BY ROAD CDG 2009

TRANSPORT OF RADIOACTIVE MATERIALS BY ROAD CDG 2009 – Practical Application Trevor Moseley University of Sheffield RSC –Radioactivity and the Law October 2009 YOUR LOGO HERE

Where our Regs come from l IAEA Basic Safety Standards – Equivalent to EU BSS l IAEA TS-R-1 , 2009 – Regulations for the Safe Transport of Radioactive Materials l ADR 2009 – European Agreement for International Carriage of Dangerous Goods l CDG 2009 (SI 2009 No. 1348) – Carriage of Dangerous Goods and use of Transportable Pressure Equipment Regulations YOUR LOGO HERE

Scope – what is excluded l The regulations do not apply to the transport of radioactive materials - – within the perimeter of an enclosed area – in the body of a person or animal – in instruments of war – in luminous watches and devices in the vehicle – in natural materials and ores – covered by a derogation YOUR LOGO HERE

Derogations - radioactives l Approved Derogations and Transitional Provisions – www. dft. gov. uk/426155/approvedderogations. pdf l Derogation for commercial products (domestic use) – Excludes up to 500 smoke detectors and 5 GTLDs l Derogation re carriage of FXs – For up to 10 packages with sum of TI <3 l Alternative to orange plates – Use of cab notice in vehicles <3. 5 tonnes carrying up to 10 packages with sum of TI <3 l Derogation re crossing of public roads – Permits transport between private premises separated by a public road with partial exemption from ADR requirements – i. e. DGSA, placarding, documentation, some driver training. YOUR LOGO HERE

EXEMPTION LIMITS Nuclide Activity conc Bq/g Activity Limit Bq H-3 1 x 106 1 GBq C-14 1 x 104 10 MBq P-32 1 x 103 100 k. Bq P-33 S-35 1 x 105 100 MBq I-125 1 x 103 1 MBq Co-60 1 x 101 100 k. Bq Cs-137 1 x 101 10 k. Bq YOUR LOGO HERE

CLASSIFICATION OF EXCEPTED PACKAGES See ADR 2. 2. 7. 2 l UN 2910 - limited quantity of material l UN 2908 - empty packaging l UN 2909 - articles made from nat U or dep U, or nat Th. l UN 2911 - instruments and articles YOUR LOGO HERE

Excepted Package – limited quantity of materials Nuclide H-3 C-14 P-32 P-33 S-35 I-125 Co-60 Cs-137 Ordinary Solid Liquids 40 GBq 3 GBq 0. 5 GBq 1 GBq 3 GBq 0. 4 GBq 0. 6 GBq 4 GBq 300 MBq 50 MBq 100 MBq 300 MBq 40 MBq 60 MBq See Table 2. 2. 7. 2. 4. 1. 2 of ADR NB surface dose-rate < 5 u. Sv/h. YOUR LOGO HERE

Excepted Package Requirements l l l Exempt from: security provisions, vehicle placarding, radioactive warning labels, instructions in writing, need for a DGSA. No restriction on loading/unloading in a public place. Provisions re training, radiation protection programme & QA programme should be proportionate to the risk. YOUR LOGO HERE

Main Provisions for Excepted Packages l l l Detailed in ADR 1. 7. 1. 5 and covered in Ch 5 on consignment procedures Mixed packing allowed see ADR 5. 1. 4 Markings should be visible, legible and permanent – resistant to the elements Mark on UN number and consignor or consignee details Mark weight if > 50 kg Mark orientation arrows for liquids – n/a if <120 ml and packed with absorbent material l l Mark as radioactive on internal surface Has to withstand routine transport conditions YOUR LOGO HERE

Basic Design Requirements for Routine Transport l Full details can be found in 6. 4. 2 of ADR – – Easily and safely transported and securely stowed External surfaces can be easily decontaminated Prevent collection and retention of water Withstand reasonable amount of movement in back of a van (routine transport) – Contents should be compatible with packaging – Withstand normal range of temps and pressures » NB additional requirements for air transport – Take note of any other dangerous properties » Other dangerous properties take precedence YOUR LOGO HERE

Transport Documents for Excepted Packages l Only require provisions of ADR 5. 4. 1. 1. 1 – a) UN Number – g) name and address of consignor – h) name and address of consignee l However would recommend a signed ‘shipper’s declaration’ e. g. – ‘I hereby declare that the contents of this consignment are fully and accurately described by proper shipping name, and are classified, packed, marked and labelled, and are in all respects in proper condition for transport by road according to the applicable international governmental regulations’ YOUR LOGO HERE

Example excepted package Screw top or tight fitting lid giving a good seal Absorbent material at least twice the volume in the tubes Screw-topped tubes taped with radioactive tape Packing of polystyrene or tissues etc Sample tubes containing excepted amounts of radioactivity Strong plastic or metal tub YOUR LOGO HERE

GE Healthcare –excepted package YOUR LOGO HERE

Air Transport – excepted package Radioactive Material, Excepted Package This package contains radioactive material, excepted package and is in all respects in compliance with the applicable international and national governmental regulations. UN _______ The information for this package need not appear on the Notification to Captain (NOTOC) YOUR LOGO HERE

Perkin. Elmer – excepted package YOUR LOGO HERE

Type A, IP, LSA & SCO (see ADR Table 2. 2. 7. 2. 1. 1) l UN 2915 RADIOACTIVE MATERIAL, TYPE A PACKAGE, non special form, non fissile or fissile excepted l UN 3332 RADIOACTIVE MATERIAL, TYPE A PACKAGE, SPECIAL FORM, non fissile or fissile excepted l UN 2912 l UN 2913 RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY, (LSA-I), non fissile or fissile excepted RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECTS, (SCO-I or SCO-II), non fissile or fissile excepted YOUR LOGO HERE

Type A Package Limits Nuclide Special Form –A 1 Other Form – A 2 H-3 C-14 P-32 P-33 S-35 I-125 Co-60 Cs-137 Am-241 40 TBq 0. 5 TBq 40 TBq 20 TBq 0. 4 TBq 2 TBq 10 TBq 40 TBq 3 TBq 0. 5 TBq 1 TBq 3 TBq 0. 4 TBq 0. 6 TBq 1 GBq See: ADR 2. 2. 7. 2. 4. 4 & Table 2. 2. 7. 2. 2. 1 YOUR LOGO HERE

LSA – low specific activity l LSA-I-iv – Other radioactive material, activity distributed throughout, av up to 30 x exempt conc values. LSA-1 ADR 2. 2. 7. 2. 3. 1. 2 a(iv) Nuclide Activity in 10 kg of waste H-3 300 GBq C-14 3 GBq S-35 30 GBq P-32 300 MBq I-125 300 MBq YOUR LOGO HERE

SCO – surface contaminated objects (ADR 2. 2. 7. 2. 3. 2) l SCO-I – Non-fixed contamination » <4 Bq/cm 2 (b, g & low toxicity alphas) » <0. 4 Bq/cm 2 (other alphas) – Fixed contamination » <4 x 104 Bq/cm 2 (b, g & low toxicity alphas) » <4 x 103 Bq/cm 2 (other alphas) l SCO-II – Non-fixed contamination » <400 Bq/cm 2 (b, g & low toxicity alphas) » <40 Bq/cm 2 (other alphas) – Fixed contamination » <8 x 105 Bq/cm 2 (b, g & low toxicity alphas) » <8 x 104 Bq/cm 2 (other alphas) YOUR LOGO HERE

IP packaging of waste (ADR 6. 4. 5) l Type IP-1 – Should be designed to contain radioactive contents under routine transport conditions l Type IP-2 & IP-3 – Protect against loss or dispersal and loss of shielding under normal conditions of transport l Shipping waste under exclusive use – LSA-I or SCO-I use IP-1 container – LSA-II or SCO-II use IP-2 container l NB can ship waste in excepted packages YOUR LOGO HERE

Waste transported as excepted packages Lockable lid Bagged labelled waste 240 L wheelie bin Bin identifier Transport label YOUR LOGO HERE

IP and Type A (ADR 6. 4. 5 – 6. 4. 7) l IP-1 – Minimum external dimension of 10 cm l IP-2 – As above + withstand dropping tests and stacking tests l IP-3 & Type A (no liquids) – As above + security seal, securely closed containment system, temperature and pressure resistance, design in accordance with approved standards etc. l Type A (liquids) – As above + more stringent drop test and penetration test + minimum 2 levels of containment – Absorbent material, 2 x volume of liquid contents YOUR LOGO HERE

Testing of Packages TYPE B Comp authority approval. Performance tests TYPE A IP-2, IP-3 Self certificated + performance tests Withstand accidents during transport Normal transport EXCEPTED IP-1 Self certificated (no tests) Routine EXEMPT Not applicable (no tests) Routine HAZARD HIGH HAZARD LOW YOUR LOGO HERE

Tests for Normal Transport l Water spray test – 5 cm rain in an hour l Free drop test – Height dependent on mass, testing possible weak points l l Stacking test – over 24 hours Penetration test – metal rod 3. 2 cm diameter weighing 6 kg See ADR 6. 4. 15 & 6. 4. 16 for full details YOUR LOGO HERE

Transport Documents for Type A packages etc Consignment Cert for CLASS 7 Radioactive Material The Carriage of Dangerous Goods etc Regulations SI 2009 No. 1348 From Consignor Name & Address + contact & tel no. To Consignee Name & Address Description of Consignment: UN No. & Shipping Name + any subsidiary risks Maximum dose-rate at surface of container in u. Sv/h Radionuclide Physical & Chemical Form Activity in MBq (or GBq etc) Package Type: Excepted / Type A / IP-I etc Category: n/a (excepted) I-WHITE, II-YELLOW, III-YELLOW Transport Index: n/a (excepted and I-WHITE) Contamination Checks: <4 Bq/cm 2 (b, g, U & Th); <0. 4 Bq/cm 2 (other alphas) Shippers Declaration Sign, Print Name, Date See ADR 5. 4. 1 & 5. 4. 1. 2. 5 for full details YOUR LOGO HERE

Transport Index TI Max dose-rate at surface Category 0 5 u. Sv/h I-WHITE 0 -1 500 u. Sv/h II-YELLOW 1 -10 2 m. Sv/h III-YELLOW >10 * 10 m. Sv/h III-YELLOW * Transported under exclusive use. Determination of TI: - dose-rate at 1 m in u. Sv/h ÷ 10 (mrem/h) YOUR LOGO HERE

Example Type A package Push fit lids should be taped and screw fit lids should be taped and the seal initialled when despatching a package to another establishment Packing Snap-top plastic tub or taped lead pot as appropriate (marked radioactive) Absorbent material 2 x volume in vial Vial containing stock solution Foam pad Strong plastic or metal tub Minimum outer dimension of 10 cm YOUR LOGO HERE

Training For All - ADR 1. 3 l l l General awareness training Function specific training Radiation hazard awareness Safe handling and emergency response Training to be documented and details kept by employer and employee YOUR LOGO HERE

Level of Training for Drivers l Transport of excepted packages – ADR 1. 3 + basic need to know training with record kept by employer and employee l Transport of excepted packages and up to 10 Type A (sum of TI<3) – Certificated training by employer covering duties under HASAW Act, CDG 2009 and hazard awareness etc l Transport of higher activities and quantities – 2 day City & Guilds course for VTC valid for 5 years YOUR LOGO HERE

Need to Know – ADR (8. 1) ADR Requirement Excepted Type A basic Consignment cert Emergency instructions n/a As in 5. 4. 3 Photo ID cards for crew n/a Applies Drivers training certificate in cab n/a Applies (but see Placarding of vehicle n/a applies FXs – dry powder minimum requirement (ignoring 2 kg 4 kg Wheel chock, 2 warning signs, eye-wash n/a Applies For crew – hi-vis vest, torch, gloves, goggles n/a Applies Transport documents derogation) Ch 8. 5 S 12) YOUR LOGO HERE

Need to Know – ADR (8. 3 & 8. 4) ADR Requirement Excepted Type A Carriage of passengers prohibited n/a Applies (except for White-I) Training in use of FXs n/a applies n/a Applies only if there are subsidiary risks applies Engine shutdown during loading etc n/a applies Compulsory use of parking brake n/a applies n/a if locked applies Prohibition on opening packages Portable lighting apparatus prohibited Prohibition on smoking Supervision of vehicles YOUR LOGO HERE

QUALITY ASSURANCE ADR 1. 7. 3 l l QA Programme to a standard acceptable to competent authority (Df. T) Certification that design specification has been fully implemented – See European Package Design Safety Reports Guide Issue 1 (June 2008) l Packaging designed for repeat use is inspected, repaired and maintained in good condition YOUR LOGO HERE

QUALITY ASSURANCE l IAEA SAFETY SERIES No. 113 (1994) – Quality Assurance for the Safe Transport of Radioactive Material l IAEA SAFETY GUIDE TS-G-1. 4 (2008) – The Management System for the Safe Transport of Radioactive Material. » Management system includes: quality control of products, quality assurance and quality management. YOUR LOGO HERE

QUALITY ASSURANCE l l l l Policy Statement Nature and Scope of Activities Organisational Structure Document Control/Records Instrument and Test Control Procedure Control Staffing and Training Audits YOUR LOGO HERE

ENFORCEMENT by HSE AUDITS by Df. T l Df. T or their agents will – – Monitor design, manufacture & testing of packages – Audit QA programmes of consignors & carriers – Witness transport operations – Starting to look at some small user operations l HSE now responsible for enforcement – Provide useful information in online guidance to ADR and the Carriage Regulations – see » http: //www. hse. gov. uk/cdg/manual/index. htm YOUR LOGO HERE

RAM TRANSPORT in the future. l DFT trying to make things simpler l ADR and IAEA recommendations getting closer together l More collaboration within EU l Less frequent issuing of regulations Trevor Moseley: t. j. moseley@shef. ac. uk YOUR LOGO HERE