Nancy Capadona International Atomic Energy Agency, Austria

1. Session Title: Regulatory and Institutional Issues: IAEA Regulations from Past to Future Presentation Title: Ensuring Safe Transport of Radioactive Materials: Implementation of the 2012 IAEA Transport Regulations (SSR-6) Nancy Capadona International Atomic Energy Agency, Austria

2. Ensuring Safe Transport of Radioactive Materials: Implementation of the 2012 IAEA Transport Regulations (SSR-6) Nancy CapadonaDepartment of Nuclear Safety and Security International Atomic Energy Agency Ahmad Al-Khatibeh Department of Nuclear Safety and Security International Atomic Energy Agency Christopher S. BajwaDepartment of Nuclear Safety and Security International Atomic Energy Agency

3. Overview • Background • The Transport Safety Standards • The Regulations Today • Changes to SSR 6 • The Review/Revision Cycle • Regulatory Stability • Harmonization • Conclusions • Questions?

4. Background • Where did the transport regulations come from? • The Preparatory Commission of the International Atomic Energy Agency, in 1957, stated that the: “Agency might obtain information on the work which has been done in, and consider the formulation of regulations governing, (i) the transport of radioactive materials, (ii) the transport of radioactive waste to burial grounds, …” • Transport was considered to be important from the very beginning of the Agency!

5. The Transport Safety Standards • SSR-6 (TS-R-1) Regulations for the Safe Transport of Radioactive Material • SSG-26 (TS-G-1.1) Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material • TS-G-1.2 Planning and Preparing for Emergency Response to Transport Accidents Involving Radioactive Material • TS-G-1.3 Radiation Protection Programmes for the Transport of Radioactive Material • TS-G-1.4 The Management System for the Safe Transport of Radioactive Material • TS-G-1.5 Compliance Assurance for the Safe Transport of Radioactive Material • TS-G-1.6 Schedules of Provisions of the IAEA Regulations for the Safe Transport of Radioactive Material

6. The Regulations Today • Specific Safety Requirements No. SSR-6 • SSR-6 (2012 Edition) • Advisory Material to the regulations issued as SSG-26 • Approved 2012, to be published 2013 (?) • TS-G-1.2 Under revision, Step 5 of SPESS • TS-G-1.3 Published 2007 • TS-G-1.4 Published 2008 • TS-G-1.5 Published 2009 • TS-G-1.6 Under revision, Step 10 of SPESS

7. Changes in SSR-6 • The 2012 Edition of the IAEA Regulations has changes in the following areas: • Definitions, • Fissile material exceptions, • Package shipment requirements, • Documentation, and • Editorial Corrections • A table describing the changes from the 2009 to 2012 editions of the Transport Regulations is available at the IAEA website. • http://www-ns.iaea.org/tech-areas/radiation-safety/transport.asp

8. Definitions • A number of definitions in SSR-6 were modified or adjusted including those for: • Fissile nuclides and fissile material • Freight container • Design • Exclusive use • Management System (para. 228) was added to replace Quality Assurance (para. 232, in 2009 Edition)

9. Regarding Fissile Material • Material excluded from the definition of fissile • Para. 222 (a), (b), (c) and (d) • Fissile exceptions • Para. 417 (a) - (f), and transported subject to the requirements of para. 570 • Packages containing fissile material, but excepted from the requirements 676-686 • Meeting the requirements of para. 674(d) and one of the provisions of para. 674(a)–(c) • Meeting the requirements of para. 675 • Fissile material • Meets requirements of paras 676-686

10. Paragraph 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. 570.

11. Paragraph 606 Establish the conditions for exception under 417(f) • 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 paragraph 673(a) • (b) The conditions consistent with the assessment provisions stated in paragraphs 684(b) and 685(b) for packages; • (c) The cconditions specified in para. 683(a), if transported by air.

12. Paragraph 570 • Fissile material exceptions • Fissile material meeting one of the provisions (a)-(f) of para. 417 shall meet the following requirements: • Only one of the provisions (a)-(f) of para. 417 is allowed per consignment. • Only one approved fissile material (para 417(f)) in packages is allowed per consignment unless multiple materials are authorized in the certificate of approval. • Fissile material in packages (para 417 (c)) shall be transported in a consignment with no more than 45 g of fissile nuclides. • Fissile material in packages (para 417(d)) shall be transported in a consignment with no more than 15 g of fissile nuclides. • Unpackaged or packaged fissile material (para. 417(e)) shall be transported under exclusive use on a conveyance with no more than 45 g of fissile nuclides.

13. Paragraph 674 Packages can be transported as any other fissile package (not fissile exception) – CSI label and fissile UN number label but CA approval not required • Packages NOT tested for normal conditions (NCT) • CSI = 50 x 5 x Fissile Mass ÷ Appropriate U value from Table 13 or 280g Pu • Maximum CSI = 10 • Packages supporting NCT & 30cm minimum dimension • CSI = 50 x 2 x Fissile Mass ÷ Appropriate U value from Table 13 or 280g Pu • Maximum CSI = 10 • Packages supporting NCT & 10cm minimum dimension • CSI = 50 x 2 x Fissile Mass ÷ U(100%) value from Table 13 or 280g Pu • Maximum 15g per package

14. Package shipment requirements • Confirmation of design conformity with the regulations prior to first shipment (Paragraph 501) • Each shipment of a package must have the contents verified by the shipper before shipment (Paragraph 502)

15. Documentation • Clarifications in Paragraphs 584 -588 • Appropriate documentation for a consignment must be received by a carrier before they accept the consignment for transport • Documents shall be retained by the carrier for three months

16. Editorial • Editorial Changes were made as needed to: • Clarify text • Correct grammatical and usage errors • Improve readability of the regulations • Modify Paragraph numbers as needed

17. The Review/Revision Cycle • SSR-6 is currently under a review cycle • Review cycle began December 2012 • Comments from Member States and other interested bodies were received in May 2013 • Comments have been dispositioned and a recommendation will be made to TRANSSC 27 • TRANSSC 27 (November 2013) will decide on whether to initiate a Revision cycle • Decision to Revise: New Edition of SSR-6 expected • Decision not to Revise: A new Review Cycle would be initiated in 20XX

18. Revision Process: CSS to BOG Approval Option 2 Option 1 Submission of final draft to CSS Submission of final draft to CSS 23/06-04/08/2015 27/06-11/07/2016 CSS Comment on Final Draft CSS Comment on Final Draft 04/08-29/09/2015 11/07-03/10/2016 CSS Endorses Final Draft for Publication CSS Endorses Final Draft for Publication 03-24/10/2016 29/09-20/10/2015 Director General Approves Final Draft for Publication Director General Approves Final Draft for Publication 29/09/2015-12/01/2016 24/10/2016-16/01/2017 Board of Governors Approves Final Text for Publication 12/01-08/03/2016 16/01-13/03/2017

19. Changes to the Regulations • Changes must focus on Safety • Changes must have clear safety impact • Cost to implement is a consideration • Safety benefit of the change should be weighed against cost of implementation • Regulations should be changed when it is needed, but ONLY if needed

20. Stability of the Regulations • A period of up to 4 years could elapse between publication of revised editions of the regulations • Current safety record and demonstrated maturity of the current regulations make a case for reducing frequency of review • Longer periods of time between revisions would potentially enable Member States to more easily establish the current edition of the transport regulations in their national regulations

21. Harmonization All 9 Dangerous Goods Classes - All modes Class 7 - All modes Road, Rail and Inland Waterway Air Sea

22. Harmonization, continued. • Harmonization occurs between the IAEA and other UN organizations for the Model and Modal regulations • Harmonization between Member States is also a challenge • Some Denials of shipment can be traced to differences in national regulations, between countries and also within a given country • Packages designed, fabricated, and prepared in accordance with IAEA transport standards should be acceptable for transport to, from, or through any Member State

23. Conclusions • 50+ years of safety • Stability of Regulations • Extend review cycle? • Changes based on safety • Could Transport Regulations be further Risk Informed? • Harmonization • Between IAEA and UN Regulations • Between Model and Modal Regulations • Between Member States • Within a given Member State

24. Questions ? Thank you Nancy Capadona N.Capadona@iaea.org Christopher Bajwa C.Bajwa@iaea.org