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COMPIANCE ASSESSMENT AT TRANSPORT OF RADIOACTIVE MATERIALS

ERSHOV V. - Emergency-Response Centre of the State Corporation “ROSATOM”, St.-Petersburg, ershov@nwatom.ru, phone/fax: (812) 297-73-10

Presentation at the TRANSSC-26 IAEA, Vienna, 27.06.2013

АТЦ СПбSOME DEFINITIONS

(for the same understanding of audience )

COMPLIANCE ASSESSMENT (CA) Direct or indirect determination (confirmation) of requirement execution for

object regulated FORMS OF COMPLIANCE ASSESSMENT

State control (supervision) Accreditation Tests Registration Compliance confirmation (voluntary certification, obligatory certification,

obligatory declaration) Acceptance and commissioning of an object whose construction is completed Other forms RULES OF COMPIANCE ASSESSMENT

Rules (procedures) of carrying out compliance assessment

from Russia Federal Law “ About technical regulating” (2002)

АТЦ СПб FORMS AND RULES OF COMPLIANCE ASSESSMENTAT RM TRANSPORT

FORMS OF COMPLIANCE ASSESSMENT FOR RM TRANSPORT

Examles of current forms of CA with TS-R-1 requirements :

Approval of design (package, SFRM) Approval of shipment Other RULES OF COMPIANCE ASSESSMENT FOR RM TRANSPORT

Examles of current rules of CA with TS-R-1 requirements :

“Administrative regulating on issuing certificates of approval …” (in Russia) Similar documents in other states BUT evidently in practice there are not only TS-R-1 requirements and

in presentation CA means all forms and rules of AC with all requirements that must be fulfilled for RM transport at all stages starting from packaging designing stage

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OBJECTIVES OF PRESENTATION

To consider situation on CA with TS-R-1 requirements

To present information of CA system with TS-R-1 requirements and requirements of other norm in action for RM transport in Russia

To encourage audience on the base of presentation and discussions to try to determine necessity of works for harmonizing CA of the states in RM transport field

АТЦ СПб STATUS OF CA HARMONIZATION

SAFETY REQUIREMENTS ARE HARMONIZED?

IAEA Safety Requirements – TS-R-1 – practically almost harmonized (unified) throughout the world

Requirements (additional) of the Modal organizations - unified or harmonized throughout the world as appropriate

Specific (additional) safety technical (package design) requirements of the states – practically there are not specific technical (design) requirements

But there are many additional requirements of the states (for conveyance, for routes, for fabricating packaging etc.) - are needed to be harmonized?

АТЦ СПб STATUS OF CA HARMONIZATION (cont.)

COMPLIANCE ASSESSMENT WITH TS-R-1 REQIREMENTS - more or less defined and harmonized (unified) for some forms of CA:

o Certificate of approval (but see Russian data further)o Declaration of consignoro Others approvals and consideration But CA with TS-R-1 requirements is harmonized only in general and

evidently needed to be more harmonized in details e.g:o Requirements for Safety report (in application for certificate of approval) o Requirements for report (expert conclusions) on application for

certificateo Requirements for specification of Quality Assurance Programmes (in

application for certificates)o Some others And in practice except certificates of approval it is very difficult before

international shipment to determine how many other permissions (licenses, certificates, approvals, agreements) are necessary to get in the states - See next slide with Russian situation

АТЦ СПбFORMS OF COMPLIANCE ASSESSMENT

FOR RM TRANSPORT IN RUSSIA

1. Licensing the activities of designers, manufacturers, experts, shippers, consignors, consignees, emergency response team (Rostechnadzor)

2. Licensing the activities of co-executors for item 1 above (Rostechnadzor)

3. Licensing the DG (including RM) transporting companies (Mintrans)

4. Conclusion on package nuclear (criticality) safety (SC “Rosatom”)

5. Certificates of approval for RM, package designs of A, B, C, F (SC)

6. Certificates of approval for shipments of IP-2, IP-3, A, B, C, F (SC)

7. Certification of packagings manufactured (practically for all types) (certification body)

8. Certification of conveyances (Mintrans)

9. Sanitary-epidemiological conclusions for SFRM, packages (MoH)

10. Sanitary-epidemiological conclusions for conveyances (MoH)

11. Agreement of Emergency plan of Consignors (SC)

12. Agreement of routes for road shipments (more 3000 A2) (Mintrans)

13. Permission for leaders of organization (Rostechnadzor)

14. Consigner Declaration (Consignors)

АТЦ СПб FORMS OF COMPLIANCE ASSESSMENT AT VARIOUS RM TRANSPORT STAGES

Design (SFRM, LDRM, PACKAGE):• Licenses for designing activity and examination activity (Rostechnadzor)• Conclusion on nuclear (citicality) safety for F package (SC «Rosatom»)• Certificate - permits for design of SFRM, LDRM, package (SC «Rosatom»)• Sanitary-epidemiological conclusion for SFRM, LDRM, package (MoH)

MANUFACTORING (SFRM, LDRM, packaging):

• Licenses for manufactores activity (Rostechnadzor)• Certification of item fabricated (SFRM, LDRM, packaging) (certification body) ;

SHIPMENT• Licenses for transport activity of consignor, consignee, carrier (RTN, Mintrans)• Agreement of route at road shipment (more 3000А , since 2012) (Mintrans)• Licenses or emergency response activity of professional emergency team (RTN,

Ministry of Emergency Situation)• Approval of Emergency Plan of consignor (SC «Rosatom»)• Certificate-permit for shipment (SC «Rosatom» on agreement of RTN and MoH)• Declaration of consignor• Sanitary-epidemiological conclusion for conveyance (MoH)

АТЦ СПбEXAMPLE OF SPECIFIC REQUIREMENTS

FOR CERTIFICATE OF APPROVAL FOR SHIPMENTT (as one of the form of Compliance Assessment)

Application for certificate of approval for shipment must contain:

a) name of consignor and consignee(s), planned routes, places of transit operations and storage;b) certificate -permit for package designe or package description if such certificates is not required and short data on basis of package safety, radioactive content c) real radioactive content of package(s) or range of possible content d) UN number(s), shipping name(s), category, TI, CSI, information about labels, marks, placards on the packages and transport means (TM);e) transport mode, type and description of TM, number of packages on TM and outline of placing and fastening of packaes at TM е) sum of CSI and TI on TMf) calculated or measured radiation levels at TM and 2 m from TM surface ;g) calculated conditions of environment of packages (temperature, isolation);h) measures of administrative and exploration controle that are assigned in certificate-permits for design(s)

АТЦ СПб EXAMPLE OF SPECIFIC REQUIREMENTS FOR CERTIFICATE OF APPROVAL FOR SHIPMENTT

(as one of the form of Compliance Assessment) (cont.)

h) category of shipments according to the special shipment classification i) number of emergency response card;j) plan of consignor\consignee for an accident situation at shipment k) number of agreement with FSUE ERC for emergency responseat accidentl) QAP at shipment of package(s) and manufactoring of packaging(s)m) radiation protection programme at shipment;n) number of packagings at manufactoring for which are valid certificate- permits or indication that certificate-permits are valid for all packaging of design approved o) information about assigned service term of SFRM, LDRM and packagings transportedp) provisions for transport of empty packaging(s)q) figure of package(s) for IP-2 and IP-3 types (r) term of sertification valid (requested)

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ASSESSMENT OF COMPLIACE FOR RM TRANSPORT IN THE STATES

Does it differ from IAEA approaches?

Does it differs from Russia form of CA?

What are additional forms (requirements) on CA in the states?

ON THE BASE OF AVAILABLE INFORMATUIN - YES!

IS IT REASONABLE TO HARMONIZE CA - YES!

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PROPOSALS FOR IAEA ACTIVITIES

1. To collect information on forms of CA in the states2. To issue list(s) CA forms and rules acting in the states 3. To analyze information on CA forms and rules in the states and to issue report4. To develop recommendations of IAEA on CA forms and rules and to issue appropriate safety guide5. To provide works on implementing the safety guide recommendations in practice of the states

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THANK YOU FOR ATTENTION!