SAFETY AND SECURITY RELATED TO THE SHIPMENT OF RADIOACTIVE SOURCES
1.1. Mandatory and legally binding regulations 1. Transport safety
The safety of transport of radioactive material, which includes radioactive sources, is the objective of the Regulations for the Safe Transport of Radioactive Material, 1996 Edition (Revised), IAEA Safety Standards Series No. TS-R-1.
The Regulations are taken over in the United Nations Model Regulations and from there into the International Maritime Dangerous Goods (IMDG) code (for maritime transport), the International Civil Aviation Organization (ICAO) and International Air Transport Association (IATA) technical instruc-tions (for air transport), and the European Agreements Concerning the Inter-national Carriage of Dangerous Goods by Road (ADR) and by Rail (RID) in Europe.
In other regions, the Regulations are directly or indirectly used as a basis for domestic transport regulations. As such, the Regulations become mandatory and legally binding.
Safety in the transport of radioactive sources is attained through provisions:
— Concerning the source (special form requirements);
— Concerning the package design (type A, B or C);
— Concerning administrative requirements (approvals by the competent authority, quality assurance provisions, radiological protection programme, training programmes, etc.).
The Regulations ensure safety in normal and accident conditions and are, or should be, more or less harmoniously applied and implemented all over the world.
The graded approach used in the Regulations is based upon objective quantities (activity, A2 value) such that the radiological consequences of
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incidents or accidents are at first approximation independent of the activity present in the package or consignment (dose limits, maximum leak rates, etc., are similar for all consignments and are independent of the activity or the isotopes present).
The scope of the IAEA Regulations (paragraphs 106–109) explicitly does not consider routing control or physical protection which may be instituted for reasons other than radiological safety, and does not take specifically into account protection against theft, sabotage or intentional dispersion.
1.1.2. Transport security
Security during transport is not formally within the scope or objectives of the IAEA Regulations. Although not explicitly indicated as security measures, some provisions of the IAEA Regulations have a positive influence on the security of shipments.
— Paragraph 635: The requirement of “a feature such as a seal, which is not readily breakable and which, while intact, will be evidence that it has not been opened”;
— Paragraph 558: The requirement that shipments with an activity greater than 3000A1 or 3000A2, or 1000 TBq, whichever is the lower, shall be notified to the competent authority of each country through which or into which the consignment is to be transported.
— Paragraph 582: The requirement that where a consignment is undeliv-erable, the consignment shall be placed in a safe location and the appropriate competent authority shall be informed.
Security appeared only recently in the United Nations Model Regulations (13th Revised Edition) and the related regulations for the transport of dangerous goods (IMDG, ICAO, IATA, ADR and RID) as a specific and supplementary item.
The security provisions, as laid down in the United Nations Model Regulations and taken over in the international transport regulations for the different modes, are applicable for the transport of all dangerous goods, including radioactive materials, and, as such, also radioactive sources. There are provisions applicable for all modes of transport (Chapter 1.4) and mode specific provisions. There are provisions applicable for all dangerous goods, and there is a second level (higher requirements) for high consequence dangerous goods.
SAFETY AND SECURITY OF SHIPMENT OF RADIOACTIVE SOURCES
89 The general provisions applicable for all dangerous goods focus on identi-fying, training and assigning the responsibilities of all persons involved, and on securing and limiting access to transit sites or temporary storage zones.
The provisions for high consequence dangerous goods introduce the establishment and implementation of security plans, with specific allocation of responsibilities for security to competent authorities and all other services and persons concerned. Specific attention is given to limiting the distribution of information as far as possible. When appropriate, monitoring of movement shall be envisaged.
The limit above which radioactive material (including radioactive sources) has to be considered as being of high consequence is at present set at 3000A1 or 3000A2, as applicable, in Type B or Type C packages.
1.2. Recommendations
In the framework of commitments related to the Treaty on the Non-Proliferation of Nuclear Weapons (NPT), for specific radioactive materials (fissile materials), supplementary security provisions were introduced more than twenty years ago, not through the above mentioned Regulations but through guidance (Convention on the Physical Protection of Nuclear Material and Nuclear Facilities, INFCIRC/225 and associated documents).
Similar to these, in order to enhance the security of (use of) radioactive sources, an update of the Code of Conduct on the Safety and Security of Radioactive Sources has been approved by the IAEA and was issued early in 2004. Member States are invited to endorse and implement the Code of Conduct.
As supplementary guidance to the Code of Conduct, a guidance document, Guidance on the Import and Export of Radioactive Sources, was published in March 2005.
This guidance has a completely different legal value from the Regulations mentioned in Section 1.1.
— The Code and Guidance are non-legally-binding documents.
— The graded approach of the provisions is not universal and is directed not only by objective criteria such as the activity and radiotoxicity of the isotopes but also by an evaluation of the threat.
— It is left to the discretion of the local authorities to evaluate the risk and the threat and to impose the level of protection required and the precautions to be taken. There can be substantial differences between countries for the same shipment.
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The application of the Code of Conduct is limited to a definite number of isotopes, in principle only those isotopes that are used in sources with such activities that they are able to cause serious consequences to people or the environment if not safely managed or securely protected.
The Code of Conduct divides the sources into three categories as a function of the activity and the properties of the isotope concerned. This categorization is based upon the D values which define a dangerous source, i.e.
a source that could, if not under control, give rise to exposure sufficient to cause severe deterministic effects.
Most of the provisions and requirements, as foreseen in the Code of Conduct and the corresponding guidance document, are more or less adminis-trative (inventory, control, authorization, confidentiality of information).
2. REGULATORY FRAMEWORK
(REGIONAL OR COUNTRY SPECIFIC)
To supplement the regulations, recommendations, etc., issued by the United Nations or related organizations that are applicable and to be implemented worldwide, national or supranational (regional) regulations can be issued. One example of this is the ADR convention that regulates the road transport of dangerous goods in Europe. For radioactive materials, it implements the IAEA Regulations and makes them mandatory and legally binding for all European countries (for international transport). Through a directive, the European Community made these regulations also mandatory for domestic shipments all over Europe.
Within the framework of the transport/transfer of radioactive sources between its Member States, the European Community issued specific directives. Euratom Directive 1493/93, issued in 1993, controls the movement of encapsulated radioactive sources between Member States and ensures the traceability of these sources. It is a purely administrative tool. Euratom Directive 2003/122/Euratom, concerning high activity sealed sources and orphan sources, is more or less in line with the Code of Conduct (although other isotopes and activities are considered) and will be implemented at the end of 2005. This directive also organizes financial security, in order to cover the financial consequences of interventions connected with restoring control of orphan sources.
Work has long been under way on the part of some individual countries to organize the physical protection of high activity sources in line with the physical protection of nuclear material.
SAFETY AND SECURITY OF SHIPMENT OF RADIOACTIVE SOURCES
91 3. ORGANIZATION OF THE TRANSPORT OF HIGH ACTIVITY
SOURCES: A PRACTICAL EXAMPLE
Although not its core business, Transnubel has some experience in the shipment of sealed radioactive sources of different activity categories.
Within the framework of Transnubel’s quality assurance management system and in conformity with its radiation protection procedures, such shipments are described in Transnubel’s procedures. Several controls are executed during the process:
(a) Preliminary verifications
— Do package approvals, source certificates and shipment approvals, if necessary, cover the source (activity, isotopes)?
— Are the package and contents compatible with the available transport equipment (mass, dimensions, etc.)?
— Have the necessary permits and authorizations been delivered and are they valid?
— Is the consignee authorized to receive the source?
(b) Verification directly before the organization of the shipment
— Coordination between consignor and consignee (material ready for dispatch, consignor ready and in agreement to receive).
— Names of contact persons at consignor and consignee (people that will sign documents for dispatch and for receipt).
— Preparation of organization with driver(s): time schedule, itinerary, instructions, documents, names of contact persons.
(c) During transport (road transport)
— The driver verifies that he or she has been contacted by the correct person(s) and that the correct package accompanied by the proper documentation has been loaded on the vehicle. Turnaround inspection is performed to verify proper labelling, seals, absence of damage, etc.
— The driver informs the office and the consignee that the transport has started.
— The automatic tracking system will trace the vehicle during the whole journey.
— During the whole journey, a qualified radiation protection agent will be permanently present in the close vicinity of the tracking equipment in the office.
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— There will be a permanent and close supervision of the vehicle during the whole trip. If necessary, two drivers will be used (exceptional for sources, general for fissile material). Only if necessary or mandatory will the vehicle be halted (sanitary stop, driving time).
— The doors of the vehicle (also of the cabin) will be closed during the whole journey.
(d) Arrival and delivery
— The driver will verify that the correct person is present at the destination to receive the source and sign the corresponding documents for receipt.
— Turnaround inspection will be performed to verify the absence of damage.
— The driver will inform the office that the material has been delivered.
4. REMARKS
Several different regulations, recommendations, directives, etc., have to be complied with when radioactive sources are transported, with the consequence that such shipments are sometimes difficult and complex to organize.
Care should be taken to avoid contradictions in regulations. For example, the IAEA Transport Regulations (TS-R-1) require the labelling of packages and overpacks with labels indicating openly the isotopes and activity present, while security recommendations require that such information be treated as confidential.
If tracking of shipments is done, care should be taken that this information is received only by the appropriate people and not disseminated or hacked (if transmitted over the Internet, for example). Hoaxes should also be a concern, as well as the fact that sometimes vehicles are tracked by organiza-tions or authorities for reasons not at all related to safety or security. The misuse of information obtained by such organizations has to be avoided.
5. ONGOING WORK AND CONCLUSIONS
There are many ongoing activities in this field. For example, the IAEA is working on the development of guidelines for security in transport of nuclear and other radioactive materials.
SAFETY AND SECURITY OF SHIPMENT OF RADIOACTIVE SOURCES
93 It is important to be aware that, if supplementary constraints and obligations are added to the existing rules, this will not automatically enhance safety or security. Denial of shipment could be the first consequence.
The saying that “the safest shipment is that shipment that never takes place” is an oversimplification and is only valid for shipments that are not justified.
The goal of regulations should be to maximize safety and security with minimal constraints and complexity. This should be borne in mind in attempting to refine or rework the existing rules and regulations.
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