Role and scope of Radiological Protection Programmes for ...

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Role and scope of Radiological Protection Programmes for the

transport of radioactive waste to a Geological Disposal Facility

Prepared by:

Andrew Cook, RPA, International Nuclear Services

Approved by:

Iain Phimister

Document Number:

INS/EH&S/2013/06

Issue Number:

4

Status:

Final

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This report has been prepared by International Nuclear Services under contract to the NDA. The report has been reviewed by the NDA, but the views expressed and conclusions drawn are those of the authors and do not necessarily represent those of the NDA. Conditions of publication This report is made available under the NDA Transparency Policy. In line with this policy, the NDA is seeking to make information on its activities readily available, and to enable interested parties to have access to and influence on its future programmes. The report may be freely used for non-commercial purposes. However, all commercial uses, including copying and re-publication, require permission from the NDA. All copyright, database rights and other intellectual property rights reside with the NDA. Applications for permission to use the report commercially should be made to the NDA Information Manager. Although great care has been taken to ensure the accuracy and completeness of the information contained in this publication, the NDA cannot assume any responsibility for consequences that may arise from its use by other parties. © Nuclear Decommissioning Authority 2013. All rights reserved. Publications If you would like to see other reports available from the NDA, a complete listing can be viewed at our website www.nda.gov.uk, or please write to the Communications Department at the address below. Feedback Readers are invited to provide feedback to the NDA on the contents, clarity and presentation of this report and on the means of improving the range of the NDA reports published. Feedback should be addressed to: Head of Stakeholder Engagement and Communications Nuclear Decommissioning Authority Radioactive Waste Management Directorate Building 587 Curie Avenue Harwell Oxford Didcot Oxfordshire OX11 0RH email [email protected]

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Revision Record Date Issue Status Comments Sept 2013 1 Draft Initial draft prepared for INS internal review Oct 2013 2 Draft Changes made to initial draft after INS

internal review Nov 2013 3 Final Changes made to draft 2 following

comments received from RWMD. Jan 2014 4 Final Final comments and amendments made. Abbreviations ALARA As Low As Reasonably Achievable (with economic and social factors taken into account) ALARP As Low As Reasonably Practicable GDF Geological Disposal Facility HLW High Level Waste IAEA International Atomic Energy Agency ILW Intermediate Level Waste IRR99 Ionising Radiation Regulations 1999 mSv milliSievert Pu Plutonium RPP Radiological Protection Programmes SQE Suitably Qualified and Experienced U Uranium µSv microSievert

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1. Introduction

1.1. As part of the UK Governments policy for the long-term management of highly active radioactive waste, the Nuclear Decommissioning Authority is working on a programme to implement a Geological Disposal Facility (GDF) in the UK.

1.2. This paper has been produced to describe the role and scope of Radiological Protection Programmes (RPP) for the transport of radioactive waste to a GDF. It outlines the legal requirements for RPPs within the UK Transport Regulations and requirements as set out in the Ionising Radiation Regulations 1999 (IRR99).

1.3. Throughout this document reference will be made to Transport Regulations; within the UK regulatory framework the Transport Regulations give regulatory status to the Modal Regulations. The Modal Regulations are as follows: • International Carriage of Dangerous Goods by Road (ADR) • International Carriage of Dangerous Goods by Rail (RID) • International Maritime Dangerous Goods Code (IMDG)

1.4. All references made within this document to requirements of the Transport Regulations refer to the requirements as set out in the above Modal Regulations.

2. Summary 2.1. This paper outlines the typical structure of an RPP and describes in depth the

expected content of each of the key elements. Appendix A gives an example of a generic RPP that could be used in support of the transportation of radioactive packages to a GDF.

2.2. When producing an RPP, prior dose assessment for the workers is essential and forms the basis for the degree of controls that are required to ensure their radiation protection. Similarly for members of the public, if there are any critical groups identified who are likely to receive a dose, a prior dose assessment will be required for them. This paper outlines examples of people who may be considered critical groups and what level of dose to the public is deemed unacceptable.

2.3. Under the IRR99 there is a requirement for prior risk assessment for any foreseeable hazards that have the potential to cause a radiation accident. The transport regulations address this by placing requirements on the design of the package to withstand a series of tests that represent foreseeable accident conditions of transport.

2.4. This paper looks into the effect on the RPPs of having one single or a number of

companies responsible for transport of radioactive packages to the GDF. The main issues that this will have on the RPP(s) will be the size of document(s), the quality control of the documents and how the responsibility for the transport is managed.

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2.5. This paper considers how the RPPs could fit into the GDF management system and outlines the general practice that is undertaken at nuclear licensed sites with respect to RPPs.

3. Radiological Protection Programmes.

3.1. Under UK legislation there is a legal requirement for carriers, consignors and

consignees to establish a RPP for transport which: • Takes into account the controls required with respect to the likely level of radiation

exposure • and adopts a structured and systematic approach.

3.2. The transport regulations do not apply to radioactive material moved within an

establishment which is subject to appropriate safety regulations and where the movement does not involve the public roads or railways. Therefore, consignors or consignees that work under a nuclear site licence (under the Nuclear Installations Act) are exempt from the need to establish an RPP for carrying out transport work on their site as the site licence conditions are deemed to cover the requirements.

3.3. The International Atomic Energy Agency (IAEA) first produced a set of guidance

transport regulation for radioactive material in 1961, the current version of which is SSR6 [1]. The UK adopts the principles of SSR6 into its regulations as shown in figure 1 below.

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3.4. An RPP is an overview of the radiological protection controls that are in place to ensure that doses to workers and the public during activities with radiological transport packages are as low as reasonably achievable (ALARP) with economic and social factors taken into account . ALARA is the term used in IAEA material but in the UK the principle is taken to mean “as low as reasonably practicable” (ALARP) and ALARP is the term used in this document. IAEA guidance document TS–G–1.3 [2] sets out a structure for a RPP and recommends that the following principal elements are documented with an appropriate level of detail:

• Scope of the programme • Roles and Responsibilities • Dose assessment • Dose limits, constraints and optimisation • Surface Contamination • Segregation and other protection measures • Emergency response • Training • Management systems (QA)

3.5. Each of these elements is discussed in further detail in Sections 3.9 to 3.17 of this

report.

3.6. Prior dose assessment is the fundamental starting block for a RPP and forms the basis for the degree of controls that are required to ensure the radiation protection of the workers and public. IAEA guidance document TS–G–1.3 suggests a graded approach to the controls required based on the magnitude of the likely radiation exposure (see Table 1 taken from IAEA guidance document TS–G–1.3).

3.7. Table 1 suggests that for expected radiation exposure less than 1mSv (milliSievert)

per year a minimal approach is required in the RPP. However, for the frequent transport of packages with higher external dose rates (where the expected radiation exposure is still less than 1mSv per year), it would be prudent to still take a more thorough approach to all of the basic elements of the RPP.

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3.8. The general practice when producing a RPP is to provide enough information to give reassurance to the reader that each of the elements is sufficiently addressed and to reference out to documents that contain the detailed arrangements. For example a brief description of the emergency response arrangements in place and a reference out to the emergency response plans would be sufficient.

3.9. Scope of the programme

3.9.1. The first section in a RPP is intended to give the reader a general outline of the

activities that the programme is covering. This will help the reader determine the radiological significance of the activities based on the materials carried, package used and frequency of the transports. The type of information supplied in this section is as follows: • A description of the operation being undertaken i.e. packaging, transport,

intermodal transfers, storage and unloading. This should be a brief description, for example if it was just for transport; transportation of HLW and

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ILW packages throughout the UK by road, rail and sea to a geological disposal facility.

• The name of the companies undertaking the activities. • The transport range. The transport range is an indication of the various

stages of transport that are likely to be used (i.e. road, rail, air and sea) and includes any stages where intermodal transfers are likely to happen (i.e. rail, port and airport facilities).

• Type of material. The type of material likely to be carried should be listed, for example HLW, ILW, U, Pu, Spent Fuel, radiological sources, surface contaminated objects and low specific activity material.

• Package categories likely to be used, which will be reflected in the labels that are placed on the outside of the packages. The package category gives an indication of the level of radiation at the contact point on the external surface of the packages i.e. I-White (up to 5µSv/hr), II-Yellow (between 5µSv/hr and 500µSv/hr) and III-Yellow (greater than 500µSv/hr).

• Package types likely to be used. The package type gives an indication of the radiological activity levels of the material in the package. These vary from low to high as follows; excepted, industrial type 1, industrial type 2, industrial type 3, Type A, Type B(U) and Type B(M).

• Frequency and break down of package categories, if known. By outlining the intended frequency of the activities and the breakdown of the package categories it helps the reader determine the level of controls needed to ensure the doses are kept ALARA. For example a reader would expect more controls for frequent III-Yellow packages than for infrequent I-White packages.

3.9.2. The intention of this section of the RPP is that it is brief but contains enough

information so that the reader can form an understanding of the scope of the programme. If the activities the programme is covering are known then the scope section of the RPP can be specific. If not, it can be generic so to avoid the need to update the programme for each new material and package. An example of a generic scope for a RPP can be seen in Appendix A.

3.10. Roles and Responsibilities

3.10.1. An RPP needs to clearly identify the roles and responsibilities of the designated people within the companies for implementing the requirements of the RPP. It is important that each person assigned a responsibility is suitably qualified and experienced to carry out that role and has enough authority to implement the RPP requirements.

3.10.2. The main roles and responsibilities that are expected to be identified in a RPP are listed below (with a suggestion of the type of person responsible in brackets). • Development and maintenance of the RPP (a Radiation Protection Advisor) • Ensuring that the requirements of the RPP are in place and implemented (a

Transport Manager)

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• Ensuring that the packages and means of transport are compliant with relevant regulations (a Dangerous Goods Safety Advisor in the case of a consignor)

• Emergency response requirements of the RPP (an Emergency Response Manager)

• Ensuring the training requirements for the people involved with the RPP are met (a Training Manager)

3.10.3. In addition to these roles, this section can be broken down into job roles such

as the driver, loading administrator, radiation protection supervisor and any other individual who may have a key role to play in optimising radiation protection. In the case where the transport of the package is complex and involves a number of different people and companies, only addressing the main roles listed in Section 3.8.2 may be easier for the reader to understand than breaking this section of the RPP into individual job roles.

3.10.4. The specific responsibilities for each role can also be included in the RPP, though this may not be necessary if they are already documented within the company’s procedures. For example a driver’s responsibility may be to; check the condition of the package and vehicle, check the placarding and labels are correct, check the dose rates around the loaded conveyance and be aware of actions to take in an emergency.

3.10.5. An example of a generic roles and responsibilities section for a RPP can be seen in Appendix A which includes the main roles listed above but does not break the roles down into specific responsibilities.

3.11. Dose Assessment

3.11.1. In order to evaluate the level of workplace and/or individual dose monitoring

needed, a prior dose assessment is required to evaluate the expected radiation exposure levels to the workers and possibly members of the public. It is expected that the prior dose assessment should take into consideration the following under routine and normal conditions of transport: • Type and category of package • Number of packages • Maximum external radiation levels • The radionuclides (gamma or neutron emitters) • The frequency of shipments • Duration of transport, storage and handling (exposure times) • Any shielding in place for the workers and public • Also, if there is likely to be any internal exposure

3.11.2. Under the transport regulations the following requirements are set for the levels of workplace or individual monitoring based on the expected radiation exposure levels for the workers: • Unlikely to exceed 1mSv per year – no individual or workplace monitoring is

required

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• Between 1mSv and 6mSv per year – a dose assessment programme via workplace or individual monitoring

• Likely to exceed 6mSv per year – individual monitoring shall be conducted.

3.11.3. For the frequent transport of packages with higher external dose rates, where the expected radiation exposure is still less than 1mSv per year, it would be prudent to undertake some form of workplace or individual monitoring.

3.11.4. Under the Ionising Radiation Regulations (IRR99) there is a requirement to limit dose to the public to less than 1mSv per year from your activities. If the prior dose assessment highlighted that there was a chance members of the public were likely to receive doses in the region or in excess of the 1mSv (or a more stringent dose constraint set by company policy), there would be a requirement to place controls in place and provide some form of dose assessment programme (see Section 4 of this report for more information).

3.11.5. A dose assessment programme can involve a combination of monitoring the following: • Package – Under the transport regulations there is only a requirement on the

consignor to carry out any monitoring of the package to ensure that it complies with the radiation and contamination limits set in the transport regulations. However, it is normally prudent for similar checks to be carried out during any intermodal transfers and by the consignee upon receipt to ensure that nothing untoward has happened to the package during operations.

• Workplace - Routine monitoring of areas associated with the workers or public can help demonstrate that conditions remain satisfactory and that the levels assumed in the prior dose assessment are correct. These can comprise various monitoring regimes for radiation and contamination in buildings, vehicles, and ships.

• Individual – There is a requirement for individual monitoring under the Transport regulations and the IRR99 if the individuals are likely to receive a dose greater than 6mSv per year. Although there is no legal requirement to provide individual monitoring to workers likely to receive less than 6mSv, it is prudent to supply those workers who are working closely with the packages to ensure that the assumptions in the prior risk assessment are correct and to reassure the workers that their doses are being monitored. Individual monitoring involves supplying equipment (normally dosimeters) to be worn by the person that will measure their levels of exposure during their work with the packages.

3.11.6. Where package, workplace or individual monitoring is conducted it is expected

that records of the results would be kept.

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3.11.7. All equipment that is supplied for package, workplace or individual monitoring should be suitable for the radiation type it is measuring and meet an appropriate calibration standard.

3.11.8. It is expected that the dose assessment section of an RPP will make reference

to the prior dose assessment and outline what type of dose assessment programme for workers and, if appropriate, the public are in place. An example of a generic dose assessment section for a RPP can be seen in Appendix A.

3.12. Dose limits, constraints and optimisation

3.12.1. The UK legal dose limits for employees over 18 years, trainees under 18 years,

women of reproductive capacity and members of the public are set within the IRR99. For employees over 18 years the limit is 20mSv/year and for member of the public it is 1mSv/year. It is the responsibility of the employer to ensure that people are not exposed to ionising radiation that would cause these limits to be exceeded.

3.12.2. Dose constraints are additional limits that are set below the IRR99 legal limits and are applied to a group of people. Dose constraints are usually set at a dose level that can be achieved if good practices are followed by that group of people. For example, if the prior dose assessment highlighted that a group of people (e.g. train drivers) could receive a dose of up to 4mSv/year if they followed good practices, a dose constraint of 4mSv/year would be set for this group of people. If during the year, one of these people received more that the dose constraint it would highlight that some investigation is warranted because either the assumptions in the prior dose assessment were wrong, best practices were not being followed or there has been a higher than expected exposure event.

3.12.3. If the prior dose assessment establishes that the expected radiation exposures

are not significant (i.e. less than 1mSv/year for employees), there is little benefit to setting additional dose constraints as a means of optimisation as the best practices in place are sufficient to ensure the radiation exposures are kept ALARA.

3.12.4. The principles behind dose optimisation are to put in place controls to ensure

that radiation exposures are kept ALARA with economic and social factors taken into account. This element of the RPP has some similarities and cross over with the segregation and other protection measures element of the RPP.

3.12.5. The first stage of optimisation is in the design stage of the packages and transport vehicles. The transport regulations set out requirements on the packages to have adequate shielding to ensure the external doses do not exceed the relevant transport limit (e.g. 2mSv at contact). In addition, further shielding may be designed in to the transport vehicles to ensure the doses are ALARA. Other design stage optimisation includes the; setting of distances between people

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and packages (e.g. the driver), use of remote handling and a reduction in the time required to safely secure the packages ready for transport.

3.12.6. In addition to designing in dose optimisation, further arrangements can be put

in place during handling, transport and storage that follow the radiological protection principles (i.e. time, distance and shielding). Examples of these are: • Dose review against expected levels – A review of dose profiles against

those predicted may identify any issues. • Segregation – setting up of barriers or other means to ensure that adequate

distances are maintained from the packages • Shielding – in addition to the shielding placed in at the design stage for the

package and transport vehicle, if required. • Procedural instructions to limit the number of people and time spent in the

vicinity of the packages during handling, transport and storage • Access restrictions – by physically preventing people coming into contact

with the packages during handling, transport and storage e.g. locking of holds on ships to prevent access during the voyage.

• Working schedules – job rotation to prevent one person from receiving more radiation exposure than necessary

• Use of auxiliary equipment – remote handling to prevent time spent in the vicinity of the package

• Routing, stops and weather restrictions – by carefully planning the time and route for the transport you can minimise exposure to the employees and public and reduce the chance of any accidents (e.g. avoid heavy traffic and arranging for any stops to be taken away from public areas).

3.12.7. The level of dose optimisation controls put in place is connected to the likely

exposure levels; more optimisation controls would be required when expected radiation exposures are significant or for work with packages that have a high external dose rate.

3.12.8. It is expected that the dose limits, constraints and optimisation section of an RPP will document any dose limits or constraints that are applicable and indicate the main dose optimisation controls that are in place. Where there are substantial amounts of dose optimisation controls it is sensible to briefly outline these and reference out to documents that contain the detailed arrangements. An example of a generic dose limits, constraints and optimisation section for a RPP can be seen in Appendix A.

3.13. Surface Contamination

3.13.1. It is important in order to prevent the spread of radioactive contaminants that the packages are clean or, failing that, have surface contamination that is ALARA.

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3.13.2. The Transport Regulations set out limits for loose surface contamination of 4 Becquerels/cm2 Beta/Gamma and 0.4 Becquerels/cm2 Alpha on the packages. It is the consignor’s responsibility under the Transport Regulations to ensure that the levels of loose contamination are below these levels otherwise the package can not be transported. This is the minimum level of surface contamination monitoring that is required.

3.13.3. The level of surface contamination monitoring carried out for a package will

depend on the following: • Package contents - sealed radioactive sources carried in dry storage

packages are less likely to have surface contamination • Known practices that result in surface contamination – pond loaded spent

fuel packages are known to be prone to surface contamination (although currently the GDF is not expected to receive pond loaded packages)

• Handling requirements – packages that are handled more i.e. intermodal transfers should be given greater attention as more people will be coming in contact with them.

• Number of companies involved – checks are often carried out at the point the responsibility for the packages are passed between the different companies

3.13.4. Surface contamination monitoring programmes can be routine or periodic and

can cover; packages, vehicle, equipment and personnel. They tend to be carried out by the consignor prior to departure, consignee on receipt and during intermodal transfers.

3.13.5. Surface contamination monitoring programmes can help detect failures of containment or highlights where operations are not meeting the ALARA principle.

3.13.6. Under exceptional circumstances (i.e. unsealed radioactive source in an

enclosed handling area) airborne contamination monitoring around packages may be considered (although currently the GDF is not expected to receive such packages).

3.13.7. It is expected that the surface contamination section of an RPP will document

the routine and periodic surface contamination monitoring that will be undertaken during transport by the consignor, carrier and consignee. An example of a generic surface contamination section for a RPP can be seen in Appendix A.

3.14. Segregation and other protection measures

3.14.1. Within the transport regulations there are specific sections on segregation that

this part of the RPP should address. These sections refer to segregation distance of the workers and the public from the packages to ensure that set dose levels in the transport regulations are not exceeded. These requirements do not apply to

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workers who are subject individual dose monitoring but will apply to members of the public such as passengers.

3.14.2. In addition, the transport regulations also set out segregation requirements between various other goods (e.g. photographic film and certain dangerous goods) during transport and storage.

3.14.3. It is also expected that segregation of packages with higher external dose rates should be considered during storage, transport or intermodal transfers. For example; keeping segregation distance largest for high dose packages and the handling of the high dose packages last to reduce the time spent in their vicinity for workers and the public.

3.14.4. Under the IRR99 there is a requirement to designate an area as controlled or supervised if special procedures are necessary to restrict the possibility of significant exposure. However, it is recognised that whilst the package is in transit it is unlikely that any controlled or supervised area would exist outside the edges of the package.

3.14.5. The situations when an area around a package may be designated controlled

or supervised arises when the package is stationary (i.e. in storage, intermodal transfers or scheduled stops) or the vehicle carrying the package is of sufficient size that a controlled or supervised area can be set up (i.e. a ships hold). Whenever an area is designated controlled or supervised the requirements of the IRR99 should be carried out (i.e. local rules, radiation protection supervisors, signage and demarcation, access and egress controls and monitoring of areas and people).

3.14.6. It is expected that the segregation and other protection measures section of an

RPP will document how the transport regulations segregation requirements are complied with and if any designated controlled or supervised areas are required. Where there are designated controlled or supervised areas under the IRR99 it is acceptable to briefly outline these and reference out to documents that contain the detailed arrangements. An example of a generic segregation and other protection measures section for a RPP can be seen in Appendix A.

3.15. Emergency response

3.15.1. The Transport Regulations set out requirements for the design and testing of

the packages to limit the contents so that the consequences of an accident are small (in the case of IP-2 packages) or design them to be able to withstand likely accident scenarios (see Section 5 of this report). For the packages that have limited amounts of material (i.e. IP-2 packages) the consequences of an accident would be small due to the limited material involved. Where the package is designed to withstand likely accident scenarios, this ensures that the chances of an accident causing the release of radionuclides into the public domain are

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remote. However, even though the chances are remote, it is expected that emergency arrangements are put in place to reduce the potential consequences of any incident involving the packages.

3.15.2. IAEA guidance document TS–G–1.3 suggests that an emergency plan can take

into account the following: • Speed of response required – a timely response is expected in all cases but

for higher risk packages the response would be expected to be rapid. • Immediate actions required on arrival – advance preparation of processes to

follow to provide an adequate response to the initial risks • Radiation Protection expert advice – a professional and knowledgeable

person to assess the state of the radioactive material involved. • Emergency dosimeters requirements – recording dose uptake to individuals

could be needed. • Medical and radiological care for injuries and contamination incidents • Clean up material and equipment – sufficient material and equipment to

clean up any radionuclides dispersed by the accident and restore the accident site to its normal condition.

• Communication routes with emergency services – in the event of an accident there must be clear routes of communication set up to initially inform the emergency services (police and fire brigade) and work with them to resolve the situation.

• Reporting requirements with the authorities – clear routes need to be established for notifying the authorities (e.g. Office of Nuclear Regulation) in the event of an accident.

3.15.3. Emergency response arrangements should also cover; lost, incorrectly

delivered and unexpectedly found packages, where necessary.

3.15.4. It is expected that the emergency response section of an RPP will document the emergency planning arrangements in place. Where the emergency plan is substantial and complex it is acceptable to briefly outline the plan and reference out to documents that contain the detailed arrangements. An example of a generic emergency response section for a RPP can be seen in Appendix A.

3.16. Training

3.16.1. Appropriate training should be carried out to ensure that the people involved

with the package are suitably qualified and experienced (SQE) in good radiation protection practices. In particular, the people identified in the roles and responsibilities section of the RPP should be provided with sufficient training for them to be able to carry out their roles.

3.16.2. The IAEA guidance document TS–G–1.3 suggests three levels of training to workers involved with the packages depending on their requirements. A graded

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approach should be taken to the level of training required depending on the degree of risk and complexity involved in the persons role:- • Basic Awareness - including basic knowledge of; radiation protection

principles, radiation risks, effects and measurement techniques. • Function specific - for those people who have a key role in the radiological

safety of the package, to ensure that they are SQE to carry out that role. • Emergency response - for those people involved in emergency response,

sufficient training should be given to ensure they can carry out the requirements of the emergency plan.

3.16.3. Where there are particular roles highlighted in the RPP (e.g. RPA or DGSA),

specific training should be provided to ensure the national qualification standards are met.

3.16.4. All training related to the RPP should be recorded, where possible, and a system put in place to ensure that it is refreshed at appropriate intervals.

3.16.5. It is expected that the training section of an RPP will give an overview of the training carried out by the companies to ensure the people working with the packages are SQE to carry out their roles. An example of a generic training section for a RPP can be seen in Appendix A.

3.17. Management systems (QA)

3.17.1. This element sets out requirements on the management systems for the safe

transport of radioactive material. There are requirements that are specifically for the RPP and requirements for the wider management system in place that covers the transport activities.

3.17.2. The RPP needs to be a good quality document with an appropriate level of quality assurance carried out. The RPP should be documented and reviewed on a regular basis by a competent person. This can be satisfied by providing the RPP with a unique reference, issue or revision number and a record of the changes that have taken place between revisions.

3.17.3. A documented management system should be in place that encompasses all

transport activities and quality assurance of these systems should be carried out to provide an element of control and inspection. The management system should be sufficient to provide confidence that all safety requirements are satisfied and be of a level that the competent authority would find acceptable.

3.17.4. It is expected that the management systems section of an RPP will give an overview of the management system that covers the transport activities and references the level of quality assurance that is carried out. An example of a generic management systems section for a RPP and the level of quality control

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required in an RPP (i.e. issue number and revision tables) can be seen in Appendix A.

4. Public Dose Assessments 4.1. For the purposes of the RPP, prior dose assessment for the workers is essential and

forms the basis for the degree of controls that are required to ensure their radiation protection. Similarly for members of the public, if there are any critical groups identified who are likely to receive a dose, a prior dose assessment will be required for them.

4.2. Examples of critical groups of public for the purposes of transport are: • People who live or work regularly in areas where the vehicle may stop for

extended periods of time on a regular basis. • People who live or work regularly in areas where any intermodal transfers take

place.

4.3. Examples of groups who are not generally considered critical groups of public for the purposes of the transport are: • People who live or work regularly in areas where the vehicle passes through

without stopping. • People who live or work regularly in areas where the vehicle may stop for an

extended period of time on an irregular basis e.g. traffic jams or vehicle breakdowns.

• People who are infrequent visitors to areas where any intermodal transfers take place.

4.4. Under the IRR99 there are dose limits set for members of the public of 1 milliSievert

per year. If the prior dose assessments show that member of the public are likely to receive a dose greater than this; radiation protection measure will be required to ensure their doses are kept below 1 milliSievert per year and as low as reasonably practicable (ALARP).

4.5. In addition the IRR99 approved code of practice [3] suggests dose constraints of 0.3 milliSievert per year to be applied at the planning stage for critical groups of the public. The RWMD radiological protection policy manual reduces this further to a constraint of 0.15 milliSievert per year and a target of 0.01 milliSievert per year. If the prior dose assessment for the members of public shows that the doses are below the RWMD constraint level there may be no need for further radiation protection measures for these people.

4.6. If there is a critical group of public identified, the control in place for radiation protection should follow the radiation protection principle (i.e. time, distance and shielding) and some form of dose monitoring may be required.

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4.7. If there are critical groups of public identified, as part of the transport stage, and control measures are required this should be recorded within the RPP dose assessment and dose limits, constraints and optimisation sections.

5. Accident Risk Assessment

5.1. The IRR99 sets out requirements for prior risk assessment for any foreseeable

hazards that have the potential to cause a radiation accident. It then sets out, for any identified radiation accidents, steps should be taken to; prevent any such accident, limit the consequences of any such accident and provide people with information, instruction and training to restrict any radiation exposure.

5.2. The transport regulations address this by placing requirements on the design of the package to limit the contents so that the consequences of an accident are small or design them to be able to withstand a series of tests that represent foreseeable accident conditions of transport.

5.3. For ILW and HLW packages the following tests would need to be carried out on a

manufactured package to prove that the design has the ability to withstand accident conditions of transport and will not lose containment or increase the external dose rate beyond the transport limits: • The packaged dropped 9 metres on to a flat unyielding surface (free drop test). • The package dropped 1 metre onto a rigid bar (penetration test). • An object weighing 500 kilogram dropped 9 metres onto the package (dynamic

crush test). • The package will be engulfed in flames and heated to 800ºC for 30 minutes

(thermal test). • The package will be placed in water to a depth of at least 15 metres (water

immersion test).

5.4. The tests are designed to represent foreseeable hazards that could result in loss of containment and shielding. If the package passes these tests and meets the transport regulation requirements it will be sufficient in design to withstand the foreseeable accident conditions of transport..

5.5. Even if the package design requirements cover all foreseeable accident conditions there will still be the need for emergency response to reduce the potential consequences of any accident that occurs with the package. The level of emergency response required and the contents of an emergency plan need to take into account a number of issues as detailed in section 3.14.2 above. The IAEA have also produced a guidance document (TS-G-1.2) for emergency response to transport accident involving radioactive material [4].

5.6. When the package is on a licensed site the emergency response requirements will fall under the regulatory requirements of the Radiation (Emergency Preparedness and

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Public Information) Regulations (REPPIR), the Control of Major Accident Hazards (COMAH) Regulations (COMAH) and the site licence condition under the Nuclear Installations Act.

6. Effects on the RPPs of a Single or Multiple companies carrying out the transports

6.1. It is not known at this stage what the arrangements for transportation of waste to a

GDF will be and who will undertake the duties of the carrier. There are two options; the first being a single company taking responsibility for the transport and the second is where the responsibility is split between multiple companies with each company being responsible for their part of the transport operation.

6.2. No matter if it is one company taking overall responsibility or multiple companies sharing responsibility, an RPP will be required for each stage of the transport and that can either be by having one RPP that covers all transports to the GDF or separate RPPs that cover individual legs of the transport journey.

6.3. The main issues that this will have on the RPP(s) will be the size of document(s), the quality control of the documents and how the responsibility for the transport is managed. Tables 2 and 3 below outline some of the pros and cons for a single RPP or multiple RPPs:

Table 2 – Pros and Cons of a single RPP covering the transport of radioactive packages to and from the Geological Disposal Facility

Pros

Cons

All radiation protection arrangements are in one document; this will make it easier for the people involved to gain a holistic understanding of the arrangements in place.

The RPP will be a large document, which may make for harder reading

It will outline all the responsibilities for the transport in one document.

If more than one company involved; there will be multiple responsibilities which may make for confusion.

It will be easier to integrate it into the GDF management system if it is a single document.

If more than one company involved; it may require lots of amendments so document control of the RPP will need to be good.

It will be easier for the competent authority to review if it is in one document.

If more than one company involved; it could lead to disagreement on the methods employed in the RPP.

If more than one company involved; some sections of the RPP may be the same throughout i.e. emergency arrangements, dose assessments.

If more than one company involved; it will result in multiple references to different company’s managements systems.

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Table 3 – Pros and Cons of multiple RPPs covering the transport of radioactive packages to and from the Geological Disposal Facility

Pros

Cons

The RPPs will be smaller and easier to read separately.

It will require someone to take overall responsibility to ensure that the separate RPPs are aligned and cover all the requirements for the transports.

Each company will have its own separate RPP which will make the responsibility section concise and clear within their company.

It will be harder to integrate it into the GDF management system if there are multiple documents.

Each company will have its own separate RPP which will make amendments and document control easier.

It will be harder to gain a holistic view of the transport if it is covered in multiple RPPs.

7. Implementation of RPPs into the GDF management system.

7.1. The purpose of an RPP is to outline the controls required with respect to the likely

level of radiation exposure during transports. Once the radioactive package has been transported onto the GDF site it will then fall under the site licence conditions as required by Nuclear Installations Act.

7.2. Within the nuclear transport industry it is often the practice for a radioactive package to be transported with a Transport Document File. The transport document file often includes records of package contents, radiation and contamination surveys at intermodal transfer points, vehicle checks and a section for signature of responsibility as the package is transferred from one company to another. It is a record of the condition of the radioactive package and who was responsible at each stage of the transport.

7.3. If a transport document file approach (or similar) was adopted by GDF as the

radioactive package came onto the GDF site. The responsibility for the package will pass to GDF upon signature of the transport document file and at this point will fall under the GDF site licence conditions.

7.4. It is general practice for nuclear licensed site to keep the RPPs separate as the

Transport Regulations do not apply on a nuclear licensed site. The RPPs could be referenced in the GDF management system and a transport document file approach used to manage the cross over from RPPs to GDF management system.

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8. References

1 International Atomic Energy Authority, Regulations for the Safe Transport of Radioactive Material 2012 Edition, IAEA Safety Standards Series No. SSR-6, 2012. 2 International Atomic Energy Authority, Radiation Protection Programmes for the Transport of Radioactive Material, IAEA Safety Standards Series No. TS-G-1.3, IAEA, 2007. 3 Health and Safety Commission, Work with ionising radiation – Ionising Radiation Regulations Approved Code of Practice and Guidance L121, HSE Books, ISBN 0-7176-1746-7 4 International Atomic Energy Authority, Planning and Preparation for Emergency Response to Transport Accidents Involving Radioactive Material, IAEA Safety Standards Series No. TS-G-1.2, IAEA, 2002 5 NDA RWMD, Geological Disposal: Generic Transport System Safety Assessment, NDA Report NDA/RWMD/022, 2010.

9. Appendices

Appendix A - Outline of a generic RPP with reference to the GDF transports

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Appendix A - Outline of a generic RPP with reference to the GDF transports

Radiation Protection Programme for the Transport of Radioactive Material to the

Geological Disposal Facility Prepared by:

(RPA)

Approved by:

Document Number:

RPP/GDF/01

Issue Number:

1

Status:

Draft

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Revision Record Date Issue Status Comments Jan 2015 1 Draft Initial draft

Abbreviations

ALARP - As low as reasonably practicable

HLW – high level waste

ILW – intermediate level waste

LLW – low level waste

mSv - milliSievert

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1. Scope of the programme

1.1. This radiation protection programme covers the transportation of HLW, ILW, LLW, Uranium, Plutonium, Spent Fuel, radiological sources, surface contaminated objects and low specific activity material throughout the UK by road, rail and sea to a geological disposal facility.

Company Responsible for RPP: Rad Transport R us Modes of transport: Road, rail and sea Materials: HLW, ILW, LLW, Uranium, Plutonium, Spent Fuel, radiological sources, surface contaminated objects and low specific activity material Packages: Type A, Type B, Type C, Industrial, Excepted and also packages containing non-fissile, fissile excepted or fissile material. Transport range: Within the UK Applicable Law: UK regulations Frequency of transports: 5-10 Packages per day

2. Roles and Responsibilities

2.1. Name of the person responsible for development and maintenance of the RPP:

Mr R Adman, Radiation Protection Advisor

2.2. Name of the person responsible for ensuring that the requirements of the RPP are in place and implemented: Mr T Ransport, Transport Manager

2.3. Name of person responsible for ensuring that the packages and means of transport are compliant with relevant regulations: Mrs C Onsignor, Dangerous Goods Safety Advisor

2.4. Name of person responsible for ensuring the training requirements of the RPP: Mr S Qep, Training Manager

2.5. Name of person responsible for ensuring the emergency response requirements of the RPP: Miss M Akesafe, Emergency Response Manager

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3. Dose assessment

3.1. A pessimistic prior dose assessment (similar to RWMD generic transport system safety assessment [5]) has been carried out for the activities involved in the transport of the radioactive material to the geological disposal facility. The prior dose assessment shows that the expected dose uptake to the workers is less than 1mSv per year.

3.2. There is no UK regulatory requirement to implement a programme of personal or workplace monitoring for exposures expected to fall below 1mSv. However; due to the planned frequent transport of packages with high external dose rates it is deemed prudent to carry out personal monitoring of certain workers involved in the transport for reassurance purposes.

3.3. When a transport of radioactive material is undertaken, each worker involved will be

issued with a personal dosemeter. Each dosemeter will be processed within an appropriate timescale and the results recorded as per…. Instruction.

3.4. Given the much lower exposure frequency for visitors, doses to these individuals will

be significantly less than 1 mSv and as a result no routine monitoring will take place.

3.5. An assessment of the likely doses to members of the public showed there to be no critical groups who will receive more than 0.15 mSv per year and as such no radiation monitoring will take place.

3.6. Workplace Monitoring? Details of any planned monitoring of packages or workplaces

should also be included as per…. instruction.

4. Dose limits, constraints and optimisation 4.1. A dose constraint of X mSv per year has been set for the workers, if any worker

receives a dose larger than this it should be investigated.

4.2. The package and vehicles have been designed to ensure that the doses to the workers and member of the public are kept as low as reasonably practicable (ALARP). The design features are shielding, setting distances between people and packages, and a reduction in the time required to safely secure the packages ready for transport.

4.3. In addition to the radiation protection controls designed into the package and vehicles

the following radiological protection measures are carried out: • List or explain in detail (see section 3.11.6 of this document) as per….

instruction.

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5. Surface Contamination 5.1. Prior to despatch the consignor will ensure that non-fixed contamination on the

external surfaces of each package meets the requirements stated within the Transport Regulations.

5.2. Routine surface contamination monitoring will be undertaken during the transports by the consignor, carrier and consignee at intermodal transfer points to ensure that there has been no change in the package and that the surface contamination is ALARP as per…. instruction

5.3. Individual monitoring of workers who come in contact with the packages will be undertaken to ensure there has been no cross-contamination as per…. instruction.

5.4. Workplace and equipment monitoring will be undertaken on a periodic basis to ensure

there has been no cross-contamination as per…. instruction.

6. Segregation and other protection measures

6.1. The segregation requirements of the transport regulations to ensure that set dose levels are not exceeded during transportation have been achieved by the design of the packages and vehicles and by the following procedural arrangements as per…. instruction.

6.2. When the packages are stationary (i.e. in storage, intermodal transfers or scheduled stops) an area around a package will be designate as a supervised area and procedural controls carried out as per…. instruction.

7. Emergency response

7.1. Emergency arrangements are in place to reduce the potential consequences of an

incident involving a package or to respond to a lost, incorrectly delivered and unexpectedly found package during transport operations.

7.2. For all transports carried out for the geological disposal facility there will be an emergency response team available.

7.3. The emergency response procedures are documented in…… instruction.

8. Training

8.1. Appropriate training is carried out to for all workers involved with the packages to

ensure they are suitably qualified and experienced in good radiation protection practices.

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8.2. The level of training required (basic, functional and emergency) will be carried out, recorded and refreshed at appropriate intervals as per…. training instruction.

9. Management systems (QA)

9.1. Rad Transport R Us management system (reference to management system) is

currently certified by (insert UKAS certified approval body) for quality assurance to ISO 9001. The quality management system encompasses all aspects of radiological transport including this radiation protection programme.

9.2. On a periodic basis the content and effectiveness of this RPP will be reviewed to ensure the aspects of the RPP are being met.

10. References

• Transport regulations • Prior dose assessments • Emergency arrangements operating instructions or management systems • Training arrangements operating instructions or management systems • Any other operating instructions or management systems referenced in the RPP

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