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TRANSPORT OF RADIOACTIVE MATERIALS

BY ROADCDG 2009 – Practical Application

Trevor Moseley

University of Sheffield

RSC –Radioactivity and the Law

October 2009

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Where our Regs come from

IAEA Basic Safety Standards– Equivalent to EU BSS

IAEA TS-R-1 , 2009– Regulations for the Safe Transport of

Radioactive Materials

ADR 2009– European Agreement for International

Carriage of Dangerous Goods

CDG 2009 (SI 2009 No.1348)– Carriage of Dangerous Goods and use of

Transportable Pressure Equipment Regulations

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Scope – what is excluded

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

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Derogations - radioactives Approved Derogations and Transitional Provisions

– www.dft.gov.uk/426155/approvedderogations.pdf Derogation for commercial products (domestic

use)– Excludes up to 500 smoke detectors and 5 GTLDs

Derogation re carriage of FXs– For up to 10 packages with sum of TI <3

Alternative to orange plates– Use of cab notice in vehicles <3.5 tonnes carrying up

to 10 packages with sum of TI <3 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.

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EXEMPTION LIMITS

Nuclide Activity conc Bq/g

Activity Limit Bq

H-3 1x106 1 GBq

C-14 1x104 10 MBq

P-32 1x103 100 kBq

P-33 1x105 100 MBq

S-35 1x105 100 MBq

I-125 1x103 1 MBq

Co-60 1x101 100 kBq

Cs-137 1x101 10 kBq

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CLASSIFICATION OFEXCEPTED PACKAGES

See ADR 2.2.7.2

UN 2910 - limited quantity of material

UN 2908 - empty packaging

UN 2909 - articles made from nat U or dep U, or nat Th.

UN 2911 - instruments and articles

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Excepted Package – limited quantity of

materials

Nuclide Ordinary Solid

Liquids

H-3 40 GBq 4 GBqC-14 3 GBq 300 MBqP-32 0.5 GBq 50 MBqP-33 1 GBq 100 MBqS-35 3 GBq 300 MBqI-125 3 GBq 300 MBqCo-60 0.4 GBq 40 MBqCs-137 0.6 GBq 60 MBq

See Table 2.2.7.2.4.1.2 of ADRNB surface dose-rate < 5uSv/h.

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Excepted Package Requirements

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.

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Main Provisions for Excepted Packages

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 > 50kg Mark orientation arrows for liquids

– n/a if <120ml and packed with absorbent material Mark as radioactive on internal surface Has to withstand routine transport conditions

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Basic Design Requirements

for Routine Transport

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

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Transport Documents for Excepted Packages

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

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’

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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

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GE Healthcare –excepted package

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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)

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PerkinElmer – excepted package

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Type A, IP, LSA & SCO (see ADR Table

2.2.7.2.1.1)

UN 2915 RADIOACTIVE MATERIAL, TYPE A PACKAGE, non special form, non

fissile or fissile excepted

UN 3332 RADIOACTIVE MATERIAL, TYPE A PACKAGE, SPECIAL FORM, non fissile or fissile excepted

UN 2912 RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY, (LSA-I), non fissile or fissile excepted

UN 2913 RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECTS, (SCO-I or SCO-II), non fissile or fissile excepted

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Type A Package Limits

Nuclide

Special Form –A1

Other Form – A2

H-3 40 TBq 40 TBqC-14 40 TBq 3 TBqP-32 0.5 TBq 0.5 TBqP-33 40 TBq 1 TBqS-35 40 TBq 3 TBqI-125 20 TBq 3 TBqCo-60 0.4 TBq 0.4 TBqCs-137 2 TBq 0.6 TBqAm-241 10 TBq 1 GBq

See: ADR 2.2.7.2.4.4 & Table 2.2.7.2.2.1

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LSA – low specific activity

LSA-I-iv– Other radioactive material, activity distributed

throughout, av up to 30x exempt conc values.

LSA-1 ADR 2.2.7.2.3.1.2a(iv)Nuclide Activity in 10kg of waste

H-3 300GBq

C-14 3 GBq

S-35 30GBq

P-32 300MBq

I-125 300MBq

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SCO – surface contaminated objects

(ADR 2.2.7.2.3.2)

SCO-I– Non-fixed contamination

» <4 Bq/cm2 (b, g & low toxicity alphas)» <0.4 Bq/cm2 (other alphas)

– Fixed contamination» <4 x 104 Bq/cm2 (b, g & low toxicity alphas)» <4 x 103 Bq/cm2 (other alphas)

SCO-II– Non-fixed contamination

» <400Bq/cm2 (b, g & low toxicity alphas)» <40 Bq/cm2 (other alphas)

– Fixed contamination» <8 x 105 Bq/cm2 (b, g & low toxicity alphas)» <8 x 104 Bq/cm2 (other alphas)

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IP packaging of waste (ADR 6.4.5)

Type IP-1– Should be designed to contain radioactive

contents under routine transport conditions

Type IP-2 & IP-3– Protect against loss or dispersal and loss

of shielding under normal conditions of transport

Shipping waste under exclusive use– LSA-I or SCO-I use IP-1 container– LSA-II or SCO-II use IP-2 container

NB can ship waste in excepted packages

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Waste transported as excepted packages

Lockable lid

Bagged labelled waste

240L wheelie bin

Bin identifier

Transport label

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IP and Type A (ADR 6.4.5 – 6.4.7)

IP-1 – Minimum external dimension of 10cm

IP-2– As above + withstand dropping tests and

stacking tests 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.

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

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Testing of Packages

TYPE B Comp authority approval. Performance tests

Withstand accidents

during transport

HAZARDHIGH

TYPE AIP-2, IP-3

Self certificated + performance tests

Normal transport

EXCEPTEDIP-1

Self certificated (no tests)

Routine

EXEMPT Not applicable (no tests)

Routine HAZARD LOW

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Tests for Normal Transport

Water spray test – 5cm rain in an hour

Free drop test – Height dependent on mass, testing possible weak

points

Stacking test – over 24 hours Penetration test

– metal rod 3.2cm diameter weighing 6kg

See ADR 6.4.15 & 6.4.16 for full details

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Transport Documents for Type A packages etc

See ADR 5.4.1 & 5.4.1.2.5 for full details

Consignment Cert for CLASS 7 Radioactive MaterialThe Carriage of Dangerous Goods etc Regulations SI 2009 No.1348

From ConsignorName & Address + contact & tel no.

To ConsigneeName & Address

Description of Consignment: UN No. & Shipping Name + any subsidiary risks

Maximum dose-rate at surface of container in uSv/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: <4Bq/cm2 (b, g, U & Th); <0.4Bq/cm2 (other alphas)

Shippers Declaration Sign, Print Name, Date

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Transport Index

TI Max dose-rate at surface

Category

0 5uSv/h I-WHITE

0-1 500uSv/h II-YELLOW

1-10 2mSv/h III-YELLOW

>10 * 10mSv/h III-YELLOW

* Transported under exclusive use.

Determination of TI:- dose-rate at 1m in uSv/h ÷ 10 (mrem/h)

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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 10cm

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Training For All - ADR 1.3

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

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Level of Training for Drivers

Transport of excepted packages– ADR 1.3 + basic need to know training with record

kept by employer and employee

Transport of excepted packages and up to 10 Type A (sum of TI<3)– Certificated training by employer covering duties

under HASAW Act, CDG2009 and hazard awareness etc

Transport of higher activities and quantities– 2 day City & Guilds course for VTC valid for 5

years

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Need to Know – ADR (8.1)

ADR Requirement Excepted

Type A

Transport documents 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 Ch8.5 S12)

Placarding of vehicle n/a applies

FXs – dry powder minimum requirement (ignoring derogation)

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

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Need to Know – ADR (8.3 & 8.4)

ADR Requirement Excepted Type ACarriage of passengers prohibited n/a Applies

(except for White-I)

Training in use of FXs n/a applies

Prohibition on opening packages applies applies

Portable lighting apparatus prohibited

n/a Applies only if there are subsidiary

risks

Prohibition on smoking applies applies

Engine shutdown during loading etc

n/a applies

Compulsory use of parking brake n/a applies

Supervision of vehicles n/a if locked applies

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QUALITY ASSURANCE ADR 1.7.3

QA Programme to a standard acceptable to competent authority (DfT)

Certification that design specification has been fully implemented– See European Package Design Safety Reports

Guide Issue 1 (June 2008)

Packaging designed for repeat use is inspected, repaired and maintained in good condition

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QUALITY ASSURANCE

IAEA SAFETY SERIES No.113 (1994)

– Quality Assurance for the Safe Transport of Radioactive Material

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.

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QUALITY ASSURANCE

Policy Statement Nature and Scope of Activities Organisational Structure Document Control/Records Instrument and Test Control Procedure Control Staffing and Training Audits

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ENFORCEMENT by HSEAUDITS by DfT

DfT 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

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

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RAM TRANSPORT in the future.

DFT trying to make things simpler

ADR and IAEA recommendations getting closer together

More collaboration within EU

Less frequent issuing of regulations

Trevor Moseley: t.j.moseley@shef.ac.uk