Comments on August 2017 DS496€¦ · 3 103.8(a) Proposed revised text: “Radionuclides were...

1

Comments on August 2017 DS496

COMMENTS BY REVIEWER

Reviewer: Rick Boyle

Country/Organization: USA/ DOT Date:

RESOLUTION

Comment

No.

Para/Line

No.

Proposed new text Reason Accepted Accepted, but

modified as follows

Rejected Reason for

modification/rejection

1 103.8

through

103.15

Some new text is proposed below.

However, it is recommended that

the text of 103.8 through 103.15 be

reviewed and edited by an English

expert.

Need text to be edited

throughout for proper

English

2 103.8 Proposed revised text:

103.8, 2nd

sentence, suggest the

following change:

“It established the basic principles

and framework of the Regulations

that has have been inherited to

incorporated into the later editions,

such as:”

Proposed changes to

correct poor English.

3 103.8(a) Proposed revised text:

“Radionuclides were divided

classified into 3 groups (I, II and III)

to specify activity limits per

package.”

Proposed change to

properly reflect the

wording in para. 6.1 of

the 1961 edition.

4 103.8(b) Proposed revised text:

“Radioactive material were

classified divided into 9 8

categories including Special Form,

Materials of Low Specific Activity

Material (LSA),Fissile Material

(Class I, II and III) and Large

Radioactive Sources.

Suggest using the term

“categories” since that is

what is used in para. 14.1

of the 1961 edition.

Also suggest dropping

“LSA” since that

acronym was not used in

the 1961 edition.

Also, should drop

2




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


“special form” since that

term was not used in the

1961 edition. As a result,

that results in only 8

categories being

specified.

5 103.8(d) Proposed revised text:

Suggest the following text so as to

accurately reflect the 1961 text:

“Two conditions of transport were

considered specified, i.e. Normal

and Accident. No specific test

conditions were specified except

that, for Type B packages, ‘the

maximum credible accident

relevant to the mode of transport’

was required.”

Suggest changes for

clarity and accuracy.

The conditions were

specified not considered.

Also I suggested to add

that, for this initial

edition, “maximum

credible accident” was

specified (see para.

5.1.3(b) of the 1961

edition).


“The 1964 Revised Edition of the

Regulations defined four important

principles – containment, shielding,

criticality and heat transfer:

a) extended the radionuclide groups

to 8 (I to VIII);

b) eliminated the concept of

applying ‘maximum credible

accident’ to Type B package

designs, and replaced it with

Containment and

radiation shielding were

specifically addressed in

Part II. Criticality is

addressed, but mostly in

an indirect fashion.

Heat transfer is not

addressed per se.

Therefore suggest

deletion shown (it is

addressed later with

proposed added text for

3




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


specific accident conditions of

transport test requirements

including a 9 m drop and

exposure to an 800oC, 30-

minutes thermal test;

c) added special form radioactive

material as a category of

material, and included tests for

qualifying a material as special

form.”

the 1996 Edition.

Other changes proposed

are:

Item (a) retained from

draft text

Item (b) expanded for

accuracy. For example,

it does not say “fire”

test. Also suggested

additional text points

out elimination of

‘maximum credible

accident’.

Item (c) – this is the

first edition that added

‘special form

radioactive material’.


“The 1967 Edition of the

Regulations was issued in the

current formation of sections

(Sections I to VIII) with a new

format of 7 sections and

appendixes rather than Parts and

Annexes, containing with the

following major changes.”

Although the format

changed, it is not correct

to say “the current

formation of sections”

since the document was

restructured in 1985 and

has since changed a

number of times since.

Although the number of

sections has remained

constant, the flow of the

document changed

significantly in 1985, and

4




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


has changed since then.

8 103.12 (a) Proposed revised text:

“Specifically defined A1 and A2

activity limits (in para. 109), and

then individually listed activity

limit values for a large number of

radionuclides.”

Proposed change for

accuracy. This is the first

edition where A1 and A2

values were used.

9 103.12 (b) Proposed revised text:

Change “for” to “for”.

Fix typographical error

10 103.12 (c) Proposed revised text:

“The concept of unilateral and

multilateral approvals (B(U) and

B(M)) was introduced, and the

meaning of each was defined.”

Suggested addition for

completeness.


“The 1985 Edition of the

Regulations incorporated one a

fundamental change – the use of

the Q system as the basis for the

A2 and A2 values; a foundation

stone for all editions thereafter.

Other major additional changes

were:”

The A1 and A2 values in

the 1985 Edition are

based upon the Q system,

but the Regulations do

not mention the Q-system

per se; that system is

addressed in detail in, and

fully documented in SS7

(1985).

Thus the proposed text

change makes this

statement accurate.

12 103.13(a) Proposed revised text:

“Radiation protection principles to

satisfy IAEA Safety Series No. 9

Change is proposed for

proper grammar (were

versus was) and to also

5




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


“Basic Safety Standards for

Radiation Protection (1982 Edition)

was were incorporated in the

Foreword to the 1985 Edition.”

make note that, for this

edition, the radiation

protection standards were

not fully incorporated as

provisions in the

Regulations. This then is

in concert with 103.14(a).

13 103.13(e) Proposed revised text:

“Low Specific Activity (LSA)

Material and Low Level Solid

(LLS) Radioactive Material were

changed to three levels of LSA

(i.e. to LSA-I, LSA-II and LSA-III

material) and two levels of

Surface Contaminated Object

(SCO) (i.e. to SCO-I and SCO-

II).”

Propose this text change

for accuracy and

completeness.

14 103.13(g) Proposed revised text:

“A third mechanical test, the

dynamic crush test, was added for

low density, light weight packages

with contents exceeding 1000 A2;

and an enhanced water immersion

test was added for packages

containing irradiated nuclear fuel

was introduced.”

Propose this text change

for accuracy and

completeness.

15 103.13(i

bis)

Proposed revised text (as an added

subpara):

“The terminology of excepted

Previously, these

excepted packages (i.e.

limited quantities of

6




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


packages was introduced.” materials, instruments,

and articles, and empty

packages) were exempted

from multiple provisions

except for the general

design requirements; but

they were not specifically

identified as ‘excepted

packages’.

16 103.13(i

bis2)


subpara):

“Schedules that had been added in

the 1973 Edition of the

Regulations were removed from

the 1985 Edition.”

Since schedules were

mentioned for the 1973

edition, it should be

mentioned here that they

were not included. The

2nd

page of the Foreword

of the 1985 Edition

addresses why they were

removed.

17 103.14(a

bis)


subpara):

“(a bis) The objective of the

Regulations, specifying that

protection is achieved through

four principle features was first

specified in this Edition. Those

four are:

(a) Containment of the

radioactive contents;

The 1964 edition

specifically mentions

containment and radiation

shielding design

principles in Annex II,

Part II, criticality control

is address in text but not

specifically called out as

a key principle, and heat

transfer is not addressed

at all. The same is

7




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


(b) Control of external radiation;

(c) Prevention of criticality; and

(d) Prevention of damage caused

by heat.”

essentially true for the

1967, 1973 and 1985

Editions. The first time

these four were coupled

together in an

“Objective” was in the

1996 Edtion (para. 104).

Thus for accuracy, this

should be stated in the

discussion of the 1996

Edition.

18 103.14 (g

bis)


subpara):

“The requirement for the dynamic

crush test extended to all non-

exempted fissile material packages

that are defined as low density,

light weight packages, irrespective

of the activity of the fissile

material contents.”

To ensure it is understood

that the dynamic crush

test applies to all low

density, light weight

fissile material packages

not just those with

activity exceeding 1000

A2.


Propose changing the first part of

the first sentence to read:

“Since 2000, the Regulations were

revised reviewed in on a biennial

cycle to match……:.”

As stated, the current text

infers that there has been

a new edition every two

years since 2000. This is

not correct. The review is

every two years, the

revision occurs when

needed (e.g. 2000 to

2003, 2005 to 2009, 2009

8




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


to 2012; these are not

every two years).

20

103.15/6 “One important set of changes may

be was the revision of fissile

exemption provisions introduced in

the 2012 Edition of the

Regulations.”

Current draft reads as

though 2012 changes

have not been made yet.


Change second sentence to read as

follows:

“By placing primary reliance on the

package design and preparation, the

need for any special actions during

carriage (i.e. by the carrier) is

minimized reduced.”

Can it be demonstrated

that by placing reliance

on design and preparation

truly minimizes the need

for any special actions

during carriage, or does it

in fact reduce but not

minimize the need for

special actions during

carriage?


“’In-transit storage’ is a part of

shipment that is regulated by the

provisions of SSR-6. Storage in a

transport package, which may be

over time span of several years or

decades, as defined in the IAEA

Safety Glossary means the holding

of radioactive material in a

package that provides for its

containment, with the intention of

retrieval (for spent fuel see also

Revised for clarity.

9




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


SSG-15, and for radioactive waste

see also WS-G-6.1). Storage that

precedes shipment is regulated by

international and/or national

storage regulations and is out of

the scope of the transport

regulations. Such ‘shipment after

storage’ will also be regulated by

the provisions of SSR-6; but is a

specific shipment operation which

requires consideration of ageing

phenomena of package

components, as well as changes in

the transport regulations and

changes of technical knowledge

during the period of storage.”

23

107.4 Proposed revised text:

Revise the lead-in text of the new

material (i.e. second sentence) in

this paragraph as follows:

“Natural materials and ores are any

physical ….”

The preceding sentence

makes material and ore

plural. This sentence

should do the same, or

the first sentence should

make them singular.

Also, since two items are

discussed “is” should be

changed to “are”.


Revise the lead in part of the 2nd

sentence in the new material in this

paragraph in a manner consistent

See “Reason” provided

for comment 23.

10




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


with comment 22; i.e.

“Examples of natural materials and

ores include…..”.


Revise the lead in part of the 3rd

sentence in the new material in this

paragraph in a manner consistent

with comment 22; i.e.

“’Natural materials’ does do not

include…..”.

See “Reason” provided

for comment 23.

26 109.1,

First

Sentence

Proposed revised text:

“Additional measures may be required

by regulatory agencies to provide

appropriate physical protection in the

transport of radioactive material and to

prevent unlawful acts involving

without lawful authority which

constitute the receipt, possession, use,

transfer, alteration, disposal and/or

dispersal of radioactive material and

which cause, or are likely to cause,

death or serious injury to any person or

substantial damage to property.

For proposed text on relevant

references see Comments 27 and 30.

First sentence: changes

are proposed for clarity:

(a) stating “unlawful acts

involving” seems to

communicate better than

“acts without lawful

authority which constitute”;

and (b) suggest the use of

and/or since an unlawful

act by an malicious

individual or entity could

involve more than just

receipt, etc.

27 109.1,

Second

Sentence

Proposed revised text for

parenthetical part of para. 109.1:

“(See the Convention on the Physical

Protection of Nuclear Material,

Parenthetical part of para.

201: The listing of

relevant, security-related

documents should be

11




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


INFCIRC/274 Rev.1, IAEA, Vienna

(1980) [9]; Amendments to the

Convention on the Physical


IAEA (2005) [10]; IAEA Nuclear

Security Series No. 13, Nuclear

Security Recommendations on

Physical Protection of Nuclear

Material and Nuclear Facilities

(INFCIRC/225/Revision 5), (2011)

[11]; IAEA Nuclear Security

Series No. 26-G, Security of

Nuclear Material in Transport

(2015) [12]; IAEA Nuclear Security Series No. 9, Security in the

Transport of Radioactive Material

(2008) [13]; and IAEA Nuclear

Security Series No. 14, Nuclear

Security Recommendations on

Radioactive Material and

Associated Facilities, (2011) [14]).”

For proposed correct listing of these

references, see Comment 30.

made complete and up to

date. For example, the

Amendment to the

CPPNM is now in force,

and other related Nuclear

Security Series

documents as noted in the

column to the left.


“See also, Code of Conduct on the

Safety and Security of Radioactive

Sources, IAEA, Vienna (2004) [1215]

and Guidance on the Import and Export

of Radioactive Sources, IAEA, Vienna

Change to reference

numbers caused by

addition of up-to-date

listing of security-related

documents (see

12




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


(2005) [1316].”

For proposed corrections to

reference number see Comment 30.

29 References

to Section

I

Proposed revised text for References

2, 3 and 4:

See recommendation in the column

to the right.

References [2, 3, and 4]

cite editions that are out

of date. These documents

are revised every two

years. For consistency

and accuracy, and to

avoid confusion, would it

not be better to make a

statement with respect to

these 3 documents similar

to footnote 1- i.e.

indicating that

“Throughout this

publication, reference to

these modal regulatory

documents always

refers to the latest

edition.”?

30

References

to Section

I

Proposed revised text for references

referring to security in redraft of

para 109.1:

“[9] The Convention on the Physical


INFCIRC/274/Rev.1, IAEA, Vienna

To make the listing of

IAEA documents relevant

to transport security

accurate and up to date.

13




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


(1980).

[10] Amendment to the

Convention on the Physical


GOV/INF/2005/10-GC(49)INF/6,

IAEA, Vienna, 2005).

[11] INTERNATIONAL

ATOMIC ENERGY AGENCY,

Nuclear Security

Recommendations on Physical

Protection of Nuclear Material

and Nuclear Facilities

(INFCIRC/225/Revision 5), IAEA

Nuclear Security Series No. 13,

IAEA, Vienna (2011).

[12] INTERNATIONAL


Security of Nuclear Material in

Transport, IAEA Nuclear

Security Series No. 26-G, IAEA,

Vienna (2015).

[13] INTERNATIONAL


Security in the Transport of

Radioactive Material, IAEA

Nuclear Security Series No. 9,

IAEA, Vienna (2008).

14




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


[14] INTERNATIONAL


Nuclear Security

Recommendations on Radioactive

Material and Associated Facilities,

IAEA, Nuclear Security Series No.

14, IAEA, Vienna (2011).”

31 References

to Section

I

Proposed revised text for references referring to security in redraft of para

109.2:

“[15] INTERNATIONAL ATOMIC

ENERGY AGENCY, Code of Conduct

on the Safety and Security of

Radioactive Sources, IAEA, Vienna

(2004).

[16] INTERNATIONAL ATOMIC

ENERGY AGENCY, Guidance on the

Import and Export of Radioactive

Sources, IAEA, Vienna (2012).”

To adjust the reference

numbering accounting for

the addition of new

transport-security-related

IAEA documents

discussed in preceding

comments.


Change the URL for the listing of

competent authorities to the

following: http://www-

ns.iaea.org/downloads/rw/transport-

safety/competent-authorities-list.pdf

The listing of competent

authorities can now be

found on the Transport

Safety Unit’s website at

the URL shown in

column 3.

33 209.1/6-7 … The confinement system could be

(i) an inner receptacle with defined

dimensions, (ii) an inner structure

Editorial comment to

provide a more accurate

example of a package

http://www-ns.iaea.org/downloads/rw/transport-safety/competent-authorities-list.pdf



15




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


maintaining the outer dimension of

a fuel assembly and any interstitial

fixed poisons, or (iii) a complete

package, such as an irradiated

nuclear fuel a waste package, with

no inner container. …

which could be

considered a confinement

system. Note that (iii),

"irradiated nuclear fuel

package", is not a good

example of a system

where the confinement

boundary is the same as

the containment

boundary. Criticality

safety evaluations for

irradiated nuclear fuel

packages often rely on the

confinement capability of

the fuel itself, as well as

the basket structure for

assuring geometry control

of the fuel and neutron

absorber panels, making

it a better fit as an

example under (ii). A

better example would be

a Type B waste package,

where there may be no

internal geometry control

features, and the

confinement boundary

and containment

boundary are identical.

16




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


34 220A.1 –

220A.7

These paragraphs should be

renumbered 221.1 – 221.7.

For consistency with draft

DS495 which has Dose

Rate as para 221.

35

220A.1 “One of the limiting quantities in

radiological protection with respect to

the exposure of people is effective

dose (the others being equivalent dose

to the lens of the eye and to the skin

(e.g. see Section II-8 of Ref. [1]). As

protection quantities are not directly

measurable quantities, operational

quantities, which are measurable, had

to be created which are measurable.

Operational These quantities are

‘ambient dose equivalent’ for strongly

penetrating radiation and ‘directional

dose equivalent’ for weakly

penetrating radiation. The dose rate

should be taken as the value of the

operational quantity ‘ambient dose

equivalent’ or ‘directional dose

equivalent,’, as appropriate.”

In addition, paragraph 220A should

be renumbered as 221.1 to be

consistent with the numbering in the

draft DS495 document.

Editorial.

36 220A.7 (to

become

221.7)

“To reduce discrepancies of

measured dose equivalent dose rate

in different surrounding areas, the

Edited for clarity and to

update term from “dose

equivalent” to “dose

17




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


dose equivalent to determine the

relevant values dose rate for

packages, ove23cks, vehicles etc.

shall be determined as the absolute

values caused by the radioactive

material consignment only. Dose

equivalent rate caused by

surrounding areas shall be

subtracted from measured values of

packages, ove23cks, vehicles etc.”

rate”.

37 221.1 –

232.3

The paragraphs in this range should

be renumbered 222.1 – 233.3

With the insertion of dose

rate in DS495 as para

221 and the deletion of

radiation level, these

corresponding paragraph

numbers have changed.

38 223.1 (to

be 224.1)/

last line

“Platform” and “flat rack” may be

called as “open-sided”.

Editorial

39 225.1 (to

be 226.1)


“The concept of LDRM applies only

to the qualification of the

radioactive contents of a package

for exemption from the requirements

for Type C packages in the air

transport mode.

40 231.3 (to

be 232.3)


Modify the second sentence as

follows:

Propose text changes to

make clear what features

the designer must reach

18




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


“In the case of Type B(U), Type

B(M), Type C and packages designed

to carry fissile material, the designer

must reach certification agreement

with the competent authority with

respect to any equipment attached

to the package during transport. for

certification.

agreement on with the

competent authority.

41 Table 1 (currently

located

immediately

following

para. 233.5)

Revision needed:

The header in the table needs to be

corrected, to properly reflect the

topic of the three columns of data:

Column 1: “Distance between

detector centre and package

surface (cm)”.

Column 2:” Half linear dimension

of package (cm)”.

Column 3: “Correction factora.”

Correction needed to

properly display data in

the table.

42 Table 1 Table 1 is currently inserted after

para 232.3, however it is only

referenced in para 220A.5 (to

become 221.5) and should be placed

with it.

To correct misplacement

of Table 1.


Modify the 3rd

sentence as follows:

“The radiological protection criteria

defined in the BSS were therefore

used to establish radionuclide

specific exemption values (as listed

Additional text is

suggested to make clear

to readers where they can

find the radionuclide

specific exemption values

(needed here since this

19




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


in Table 2 of the Transport

Regulations) for transport purposes

(see para. 402.3).

text is not directly related

to Table 2 of SSR-6).


A paragraph number (236.2) needs

to be added at the beginning of the

paragraph of new text that begins

with “The activity concentration

value……”..

Add paragraph number

for completeness.


Add a carriage return before 236.2

and renumber para. 236.2 to become

236.3; and para. 236.3 to become

236.4.

Make change to

accommodate the above

correction for the large,

unnumbered paragraph

following para. 236.1.


Modify text beginning with the 3rd


“For example, a special

arrangement might be necessary

for the disposal of old equipment

containing radioactive material

where there is no reasonable way to

ship the radioactive material in an

approved package. The hazard

associated with repackaging and

handling the radioactive material

could outweigh the advantage of

developing and using an approved

Text needed to make the

3rd

sentence complete,

and to ensure the full

paragraph communicates

properly.

20




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


package, assuming a suitable

package were could be made

available. The special arrangement

provisions should compensate for

not meeting all the normal

requirements of the Transport

Regulations by providing an

equivalent level of safety. In

keeping with the underlying

philosophy of the Transport

Regulations, reliance on

administrative measures should be

minimized in establishing the

compensating special arrangement

measures.”

47 244.1 “The TI performs many functions in

the Transport Regulations, including

providing the basis for the carrier to

segregate radioactive material from

persons, undeveloped film, and other

radioactive material consignments,

and to limiting the level of radiation

exposure to members of the public

and to transport workers during

transport and in-transit storage.”

Slight editorial change to

make verb tenses

consistent for each

clause.


Modify the beginning sentence as

follows: “Beginning with In the

1996 Edition of the Transport

Proposed change for

clarity, the text in DS496

reads as though the

current edition of SSG-26

21




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


Regulations, the TI value no longer

makes any contribution to the

criticality safety accumulation

control accumulation control for

criticality safety of packages

containing fissile material.

Accumulation control for criticality

safety is now provided by a separate

CSI (see paras 218.1–218.23).”

is the 1996 edition. Also,

DS496 does not have a

subpara. 218.3 for CSI.

49 References

to Section

II

Proposed revised text for Reference

9:


to the right.

Reference [9] cites an

edition that is out of date.

This document is revised

every two years. For

consistency and accuracy,

and to avoid confusion,

would it not be better to

make a statement with

respect to this document

similar to footnote 1,

Section I- i.e. indicating

that “Throughout this


the UN Model

Regulations always


edition.”?


Modify the penultimate sentence as

follows: “In addition, in the case of

Suggest this change to

make it clear that this is

an action required for

22




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


potential exposures, the likelihood

of occurrence of accidents or events

or sequences of events is also to be

taken into account.”

optimization.


Modify the beginning of the first

sentence as follows: “The BSS [4]

defines radiological……”.

Since the BSS is a single

document, “define”

should be singular.


Appropriately number the three

following subparagraphs as follows:

a) “No practice is to be adopted

unless it produces a positive

net benefit (justification of a

practice).

b) All exposures are to be kept

as low as reasonably

achievable, economic and

social factors being taken

into account (optimization of

protection).

c) Total individual exposure is

to be subject to dose limits

or, in the case of potential

exposures, to the control of

risk (individual dose and risk

limits).”

Number subparagraphs

appropriately.

23




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for



Revise the 3rd


“In the case of workers devoted only

to transport activities, it will be

reasonable to set constraints for

transport of radioactive material. In

other cases, it may be appropriate

for individual users to include dose

constraints in their RPP, in which

case lower constraints would

normally be expected to be set

rather than for transport activity

only since, by definition ……”.

Add this word for clarity.


Edit the sub-paragraphs preceding

the text “The RPP should…” as

follows:

— To provide for adequate

consideration of radiation

protection measures in

transport;

— To ensure that the system of

radiological protection is

adequately applied;

— To enhance a safety culture

in the transport of

radioactive material;

For consistent editorial

style.

24




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


— To provide practical

measures to meet these

objectives.


Have the text beginning with “The

RPP should….” Be numbered as

302.2, and renumber existing 302.2

to 302.6 accordingly.

For consistent editorial

style.


“The BSS [4] sets an effective dose

limit of 1 mSv per year on the

effective dose for members of the

public of 1 mSv in a year, and for

workers of 20 mSv per in a year

averaged over five consecutive years

and not exceeding 50 mSv in a single

year for workers. Dose limits in

special circumstances;, dose limits in

terms of equivalent dose for the lens

of the eye, extremities (hand and

feet), and skin;, and dose limits for

apprentices and pregnant women are

also set out in the BSS and should be

considered in the context of the

requirements of para. 303. These

limits apply to exposures attributable

to all practices, with the exception of

medical exposures and of exposures

Since the BSS is a single

document, “set” should

be singular. To avoid

confusion in the first

sentence, particularly

with respect to worker

doses, the units for the

dose limits were changed

to “per year.” Also, to

avoid repetition in the

second sentence, the

words dose limits were

deleted for the second

and third list items and

the list punctuation was

corrected.

25




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


to certain natural sources.”

57 303.5 “Given that relatively high dose rates

are permitted during carriage under

exclusive use, meaning that it would

be relatively easy to exceed the 1

mSv level, additional care should be

taken to ensure that the requirements

of para. 303 are met by employing ,

since it would be relatively easy to

exceed the 1 mSv level, and

consequently, specific measures

regarding monitoring or control of

exposures should be taken. In the

assessment of the overall individual

exposure, any exposures received

during the carriage phase of transport

should be considered, together with

those received elsewhere, particularly

during loading and unloading.”

The wording in the first

sentence is confusing, so

it was rewritten to add

clarity to the sentence.


Revise the 2nd


“Where appropriate, the competent

authority will ensure that such a

management system is

implemented, as part of the timely

adoption and application of the

Transport Regulations.”

Propose adding this text

to make it clear that

ensuring implementation

of the management

system depends upon

more than just adoption

of the Transport

Regulations, it requires

application of the

provisions of the

Transport Regulations by

26




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


the competent authority

and the designers,

fabricators and users of

the packagings. This will

help bridge to this

concept which is

elaborated in para. 306.4.


Modify the second sentence as

follows:

“For packages intended to be used

for shipment after storage, the

management system should also

address an ageing management

programme.

Adding the word “also”

will emphasize that this is

an additional requirement

of a management system

for packages that are

intended to be used for

shipment after storage.


Modify the beginning of the second

sentence as follows; either:

“Emphasis should be placed….”; or

“Emphasis shall be placed….”.

The use of “is” implies

that this is already

accomplished. This is a

guidance document.

61 307.2 A carriage return is missing before

307.2.

62 308.2 “In order to comply with para. 308

of the Transport Regulations,

information on the radiation doses to

workers and to members of the

public should be collected and

reviewed as appropriate. For

Editorial.

27




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


example, Rreviews should be made

if circumstances warrant, for

example, if significant changes in

transport patterns occur or when a

new technology related to

radioactive material is introduced.

The collection of relevant

information may be achieved

through a combination of radiation

measurements and assessments.

Reviews of accident conditions of

transport are necessary in addition to

those of routine and normal

conditions.”


Propose revising the text beginning

with the 3rd


“It was recommended at these

meetings that text addressing

requirements for actions needed in

the event of non-compliance

be added to the Transport

Regulations. In addition, the May

2000 meeting of the Transport

Safety Standards Committee

(TRANSSC) recommended that

the IAEA undertake a

coordinated research project

(CRP) on contamination. The

The addition of the work

undertaken in the CRP

will assist in providing

additional guidance to

users of SSG-26.

28




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


results of that CRP can be found

in IAEA TECDOC-1449 [15bis].”

The reference to be added at the end

of the Section is:

“[15bis] INTERNATIONAL


Radiological aspects of non-fixed

contamination of packages and

conveyances, IAEA-TECDOC-

1449, IAEA, Vienna (2005).”


Revise the first part of the first


“309.3. The term ‘non-compliance’

has a very broad meaning and

includes any and all situations

(except transport accidents or

malicious incidents) ….”.

By stating “and and all

situations”, since the text

excludes accidents, it is

necessary to also include

in the exceptions actions

taken by those with

malicious intent (i.e.

“malicious incidents”).


Modify the 3rd


“Special arrangement is based on

the requirement that the overall level

of safety resulting from additional

operational control or other

alternative means must be shown

to be at least ….”.

The addition of “or other

alternative means” is

needed since, as currently

written, it is implied that

special arrangements can

only be accomplished

through the application of

additional operational

controls. Alternatives to

the design of packaging

may also be used to

29




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


demonstrate that an

equivalent level of safety

has been achieved. This

is elaborated in the 2nd

sentence of 310.2 (i.e.

“new controls and

techniques”); and thus

310.1 should reinforce

this concept.

66 References

to Section

III


For Reference 16, see

recommendation in the column to

the right.

Reference [16], as cited,

is an edition that is out of

date. This document is

revised every two years.

For consistency and

accuracy, and to avoid

confusion, would it not

be better to make a


these documents similar

to footnote 1, Section I-

i.e. indicating that

“Throughout this


this modal regulation

always refers to the

latest edition.”?

67 References

to Section

III


For Reference 18, see

recommendation in the column to

Reference [18], as cited,

is an edition that is out of

date. This document is

30




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


the right. revised every two years.

For the UN Model

Regulations, Section II

cited the 2011 edition,

whereas Section III cites

the 2015 edition; but in

fact the UN Committee of

Experts has now issued

the 2017 edition. Thus,

for consistency and

accuracy, and to avoid

confusion, would it not

be better to make a


these documents similar

to footnote 1, Section I-

i.e. indicating that

“Throughout this


the UN Model

Regulations always


edition.”?


Recommend changing the text of the

4th


“This identification can be is used

for many purposes.”

This proposed changes

strengthens the argument

that the UN numbers are

actually used for the

purposes stated in the

following sentences

31




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


instead of implying that

they “might” be used.



penultimate sentence as follows:

“Each UN number can be is

typically associated with a unique

emergency response advice

This proposed changes

strengthens the argument

that the UN numbers are

actually used for

referencing to unique

emergency response

advice instead of

implying that they

“might” be used in this

fashion.



last sentence as follows:

“In the 20xx Edition of SSR-6,

seven new radionuclides, Ni-57, Ge-

69, Sr-83, Ba-135m, Ir-193m, Tb-

149 and Tb-161, were added to

Table 2 of the Transport

Regulations, to provide ….”.

This proposed change

would make it clear that

the table being referred to

is in SSR-6 and not in

SSG-26. This is

consistent with the text of

402.3 where Table 2 is

cited.

71 402.4 (and

following

402.x para-

graphs)


Following the two sub-paragraphs

((a) and (b)) of para. 402.4,

recommend that the text then read

“402.5 The exemption values were

derived……”.

And then the following 402.x

paragraph numbers be adjusted

This recommended edit

would simply make the

text flow better.

32




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


accordingly.


Recommend changing the second

sentence as follows: “The same

exemption values are reproduced in

the Transport RegulationsSSR-6,

Table 2, Basic Radionuclide

Values.”

This change would make

the text consistent with

the wording used

elsewhere, i.e. using “the

Transport Regulations”

rather than “SSR-6”.



first sentence as follows: “For

individual radionuclides that are not

listed in Table 2 of the Transport

Regulations, activity concentrations

….”.

This proposed change

would make it clear

which table is being

referred to.



first sentence as follows:

“Multilateral approval is needed for

alternative activity limits for an

exempt consignment of instruments

and articles.”

The word “instruments”

needs to be plural.

75 405.3 “Calculation of the activity

concentration for exempt material is

only permitted in the case of a

homogeneous mixture, since the

models for determining these activity

concentrations are based on the

assumption that the isotopes are

Changed the words

homogeneously and

homogeneity to uniformly

and uniformity,

respectively, to be

consistent with the

discussions provided in

33




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


distributed uniformly homogeneously

throughout the material. A The

degrees of uniformity homogeneity

can be referred to are further

discussed in paras 409.15 and

409.10–409.14.”

paragraph 409. The

correct reference (409.1)

is added, and the

incorrect reference

(409.5) is removed.



first sentence as follows: “The

preamble to the LSA definition

(see para. 226.3) does not …..”.

This is suggested to make

it clear what preamble is

being referred to.

77 409.10/1-3 For material required to be

“distributed throughout”, that is

(LSA-II solids and LSA-III material

not incorporated into a solid

compact binding agent), a simple

method for assessing…

Editorial

78 409.10/5-6 It is suggested that tThe differences

in specific activity between portions

of a factor of less than ten would

should cause no concern if there is

no indication…

Editorial

79 409.13/6-7 It is suggested that sSpecific activity

differences between the portions of

less than a factor of three would

should cause no concern…

Editorial


It is proposed that para. 413.5 be

moved forward and made para.

This would place a key

constraint on SCOs at the

beginning of the

34




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


413.1; and that the remaining 413.x

paragraphs be incremented upward

by one digit.

discussion.

81 413.6 The existing guidance in 413.6 is

proposed to be deleted.

413.6. Examples of inaccessible

surfaces are:

(a) Inner surfaces of pipes, the ends

of which can be securely closed by

simple methods;

(b) Inner surfaces of maintenance

equipment for nuclear facilities

which are suitably blanked off or

formally closed;

(c) Gloveboxes with access ports

blanked off.

And replaced with the following

paragraphs:

413.6 An accessible surface is any

surface which can readily be wiped

by hand, using standard radiation-

measuring techniques. Any other

surface that is not accessible due to

a design feature, barrier or closure

that remains effective during routine

conditions of transport is an

To address the

commitment made at the

SCO-III working group at

TRANSSC 34 to add

guidance to SSG-

26(DS496) to clarify the

terms external, accessible

and inaccessible surfaces

in para. 413 for SCO

since CDN/8 and USA/9

change proposals were

accepted.

35




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


inaccessible surface. A good rule of

thumb is that, if a 300 cm2 area

could be reached by a person’s

hand, it is an accessible surface. The

phrasing “by hand” is not meant to

discourage use of as low as

reasonably achievable tools such as

telescopic sampling instruments.

The phrasing “standard radiation-

measuring techniques” is intended

to imply practices similar to those

used for complying with package

contamination limits in para. 508.

413.6 bis An accessible surface may

be rendered inaccessible for

transport by securely closing or

blanking it off, such as;

a) Large diameter pipes that are

closed off at the ends;

b) A tool box or other

maintenance equipment that

is securely closed;

c) A glovebox with the access

ports blanked off.

413.6 bis For SCO-III, external

inaccessible surfaces, such as the

narrow gap between manway covers

36




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


and the component, are normally

filled or closed out with weld

material or caulk to prevent

contamination leakage during

transport, as shown in the following

illustration:

82 413.11 413.11 For SCO-III, there is no

specific limits for the levels of fixed

contamination on the external

surfaces, since similar to packages,

the external radiation resulting

therefrom will combine with the

penetrating radiation from the

contents, and the net radiation levels

are controlled by other specific

requirements. The fixed

contamination may not be able to be

practically measured due to the dose

To address the



TRANSSC 34 to add

guidance to SSG-

26(DS496) to clarify why

limits for fixed

contamination are not

specified in para. 413 for

SCO-III, since CDN/9

and USA/7 change

proposals were accepted.

37




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


rate emanating from the large object,

the levels of which should be

minimal in nature, and will be

accounted for in label selection, as

with packages. The limit on the

external non-fixed contamination is

conservatively set to that for

packages which, combined with the

controls on radiation levels will

ensure that the risk from fixed

contamination is low. The major

percentage of the component’s

activity (A2 quantity) should be due

to surface contamination on interior

surfaces, rather than on exterior

surfaces or resulting from neutron

activation of the component.

Though a threshold value is not

specified, this is not intended to

allow transport of components with

non-fixed external surface

contamination exceeding the levels

specified in para. 508 of the

Transport Regulations or with overt

activation of material. Transport of

clearly activated components, such

as reactor vessels, are is outside the

scope of SCO-III.

The red text in the

following two paragraphs

of the current draft of

SSG-26 was deleted at

the January 2017 review

meeting, and should be

reinstated, as it now

applies after acceptance

of the Canadian and U.S.

change proposals to SSR-

6. The struck out text was

also deleted at the

January 2017 review

meeting, but should

remain deleted. The blue

text is new proposed text

added for further clarity.

38




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


83 413.12 413.12 For SCO-III, contamination

on the inaccessible surface may be

determined by conservative

estimates and/or analysis by

methods other than direct

contamination measurements. In the

Q system (see Appendix I), five

radiation exposure routes, i.e.

external photon dose (QA),external

beta dose (QB), inhalation dose

(QC), skin and ingestion dose due to

contamination transfer (QD) and

submersion dose (QE) are

considered. Among these, the

inhalation dose (QC) can be taken as

a major exposure route for SCO-III

in the event of an accident, since

most of the activity that is dispersed

is from the surface contamination

that comes from the surfaces of the

object which may be scratched

during an accident. If a SCO-III is

involved in an accident, the

maximum activity intake for a

person in the vicinity of the accident

should be approximately of the same

level as that from Type A packages

(see Appendix VII).

To address the



TRANSSC 34 to add

guidance to SSG-

26(DS496) to clarify why

limits for fixed

contamination are not

specified in para. 413 for

SCO-III, since CDN/9

and USA/7 change

proposals were accepted.

The red text in the

paragraph of the current

draft of SSG-26 was

deleted at the January

2017 review meeting, and

should be reinstated, as it

now applies after

acceptance of the

Canadian and U.S.

change proposals to SSR-

6.

84 417.1 Proposed revised text: This change is

39




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


Recommend changing the text in the

3rd

sentence to read as follows:

“These provisions are were

incorporated in the 2012 Edition of

the……”.

recommended since this

draft of SSG-26 is

intended to reflect the

20.xx Edition of SSR-6,

not the 2012 Edition.

85 422.3 “In the case of special form solid

material, the probability of release of

any dispersible radioactive material is

very small. Thus, if radiotoxicity

were the only hazard to be

considered, much higher activity

limits could be accepted for special

form solid material in excepted

packages. However, the nature of

special form does not provide any

additional protection where external

radiation is concerned. The limits for

excepted packages containing special

form material are therefore based on

A1

rather than A2. The basic limit

selected for special form solid

material is 10–3

A1. This limits the

external dose equivalent rate from

unshielded special form material to

one thousandth of the rate used to

determine the A1 values.”

Deleted equivalent from

dose equivalent rate.

86 501.5 “In performing the post-fabrication

tests and inspections on packagings

Corrected typos and

punctuation errors.

40




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


following fabrication to assess the

effectiveness of shielding of Type

B(U), Type B(M), and Type C

packages and packages containing

fissile material, the shielding

components may be checked by a

radiation test of the completed

assembly. The radiation source for

this test need not be the material

intended to be transported, but care

should be taken such that shielding

properties are properly evaluated

relative to energy, energy spectrum,

and type of radiation. Particular

attention should also be paid to the

homogeneity of packaging material

and the possibility of increased

localized dose rates at joints. For

methods of testing the integrity of a

package’s radiation shielding, (see

Refs [1, 2] and paras 659.14–

659.19).”


Recommend changing the lead-in

text of the first sentence as follows:

“A written transport plan is should

be used to govern ……”.

The use of “is” implies

that this is already

accomplished. Thus,

propose the change since

SSG-26 is a guidance

document. The use of

“should” is consistent

with the rest of the text in

41




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


this and the following

paragraph.

88 520.1 bis3

first bullet

(to become

520.5)

There is no explicit limit on the

dose rate on the external surface

(there is nevertheless a limit of 10

mSv/h at 3 m of the object and

there is a limit of 2 mSv/h at the

external surface of the vehicle).

Anyway, if the surface dose rate of

the SCO-III is higher than 2

mSv/h, the transport plan should

contain special precautions to

ensure workers and public

radioprotection, including during

loading and unloading phases if

applicable, and control of the

access to the object.

There is no alternative limit on the

dose rate for SCO-III (all existing

radiation dose rate limits apply

such as 10 mSv/h at 3 m from the

unshielded contents as well as

package limits). However, due to

the size of these objects and their

slow movement compared to most

packages, the transport plan should

contain special precautions to

ensure workers and public

The 10 mSv/hr at 3

meters applies to the

unshielded contents as

with any LSA/SCO,

suggest rewording.

42




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for




applicable, and control of the

access to the object.

89 520.1 bis3

second

bullet

(520.5)

Besides, there is no obligation to

label a SCO-III object. Then, the

transport plan should

contain provisions to ensure that the

workers are well-informed of the

dose rate in the vicinity of

the object, so that they can protect

themselves.

SCO-III should be

labeled as any other

package, suggest deleting

bullet.

90 520.1 bis3 “The transport plan should also

address the following points:

- Although There there is no explicit

dose rate limit on the dose rate on the

external surface, (there are is

nevertheless a limits of 10 mSv/h at 3

m of from the object and there is a

limit of 2 mSv/h at the external

surface of the vehicle). Anyway, iIf

the surface dose rate of the SCO-III is

higher than 2 mSv/h, the transport

plan should contain special

precautions to ensure radioprotection

of workers and the public



applicable, and control of the access

Editorial changes for

clarity.

43




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


to the object.

- Besides, tThere is no obligation to

label a SCO-III object. Thereforen,

the transport plan should contain

provisions to ensure that the workers

are well-informed of the dose rate in

the vicinity of the object, so that they

can protect themselves.

- Any supplementary requirements for

loading, stowage, carriage, handling

or unloading for the SCO-III.”

91 520.3 “As part of the SCO-III transport

plan, special attention should be paid

to the radiation protection programme

since the transport of SCO-III would

be conducted in a different manner

from the routine transport of ordinary

packages and may involve workers

not familiar with transport operations.

As such, it should take into account

all steps and activities of transport

and all relevant transport workers and

members of the public. Radiation

levels Dose rates of the object,

transport and handling methods,

including durations and distances of

workers from the object in each

Changed radiation levels

to dose rates. Also, the

last sentence needs to be

revised because it is

confusing. No suggested

replacement was

provided because the

meaning of the sentence

is unclear.

44




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


operation, should be carefully

examined and doses to workers

should be optimized with the proper

dose constraint.”


Recommend changing this text to

read as follows:

“Requirements for loading, stowage,

carriage, handling and unloading,

including any special stowage

provisions for the safe dissipation of

heat should are to be addressed

in the SCO-III transport plan.

The use of ‘are” should

not be used in a guidance

document.

93 520.1 bis3 AnywayHowever, if the surface

dose rate of the SCO-III is higher

than 2 mSv/h, the transport plan

should…

Editorial


Recommend changing the first

sentence as follows: “The basic

concept of allowing transport of

SCOs unpackaged is that, though

unpackaged, the objects should will

most likely comply with the

applicable Type IP package

requirements, …..”.

Propose this change to

emphasize that this

concept will probably

result in compliance with

the IP requirements (the

use of should seems to be

inappropriate here).


Recommend that the second

sentence be changed to read as

This change is

recommended since this

is an action that those

45




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


follows: “In addition to being

allowed to be transported

unpackaged, certain requirements

for Type IP packages may need to

be excluded, …..”.

preparing the item for

shipment may need to

take.


Recommend the following change

to the beginning of the first

sentence: ‘As addressed in para.

722.6 in this publication, if the ….”.

This is the first time that

a paragraph in SSG-26 is

cited where this

modifying text was

added. Suggest deletion

to be consistent.


Carriage return is missing before

521.1. Recommend changing the 2nd

sentence as follows: “In assessing

the potential hazards, the physical

form of the LSA material should be

has been taken into account.

The use of “has been”

implies that the

Regulations have taken

the physical form into

account. The entity

preparing the material for

shipment should be

responsible for taking the

physical form into

account.

98 522.1 “The The Conveyance conveyance

activity limits for LSA material and

SCO have been specified, the account

for potential hazards having been

taken into account, including the

greater hazards presented by liquids,

and gases, and combustible solids as

well as and possible contamination

This is an awkwardly

worded sentence. The

proposed text attempts to

clarify the sentence.

46




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


levels, in the event of an accident.”


Recommend changing this sentence

as follows: “If an SCO-III item is

involved in an accident, an the pre-

shipment equivalent level of safety

assessment should ensure have

demonstrated that the maximum

activity intake for a person in the

vicinity of the accident should

would be approximately of the same

as that from Type A packages (see

Appendix VII).”

As worded, this implies

that the Regulations have

achieved this. However,

the entity preparing the

item for shipment as

SCO-III needs to

demonstrate that “the

maximum activity intake

for a person in the

vicinity of the accident

would be approximately

of the same as that from

Type A packages”.


Recommend to following changes to

the 1st sentence and the beginning of

the 2nd

sentence: “For SCO-III, it is

permitted to exceed the limit of 100

A2 per conveyance, other than for

an inland waterway craft, or to

exceed the limit of 10 A2 per hold

or compartment except for of an

inland waterway craft, provided than

that the transport plan contains

precautions to which are to be

employed during transport to obtain

an overall level of safety at least

equivalent to that which would be

Several typos and

punctuation mistakes

were corrected, and

portions of the

paragraphs were rewritten

to make them clearer.

47




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


provided if the limits had been

applied. For inland waterway craft

crafts, there is a risk of activity

accumulation in the case of a sinking,

as there is are no strong currents in

the inland waterways and as nor are

there is any probably probable human

activities near the waterways. The

limit of the total activity per hold or

compartment allows to addresses this

risk. The precaution to put in the

transport plan can then be: transport

plan can include

- some precautions on the craft to

limit lower the risk of shrinking

sinking; or

- the designation of an organisation

capable of removing to be able to

remove the SCO-III from the water in

the case event of a shrinking sinking;

or

- some features on of the SCO-III that

guaranty guarantee that even in the

case of a realistically long stay in the

water, the activity release into the

water would be limited.

For conveyances other than inland

48




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


waterway craft, since there is a risk of

activity accumulation in the case of

an accident in a confined space (e.g.,

as a tunnel),. The the total activity

limit is lower. limit of the total

activity allows to address this risk. In

this case, the transport plan can

include The precaution to put in the

transport plan can then be:

- some precautions to limit minimize

the risk of an accident; or

- some itinerary limitations to avoid

confined areas; or

- some features on of the SCO-III that

guaranty guarantee that even in the

case of an accident in a confined area,

the activity release into the air would

be limited.”


Recommend the following changes

to the 3rd

sentence: “The limit of the

total activity per hold or

compartment allows to address

addresses this risk.”

Recommend these

changes to improve the

English text and to make

the provision

understandable and

complete.



to the text following the first 3 sub-

Recommend these

changes to improve the

English text and to make

49




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


bullets: “For conveyances other than

inland waterway craft, there is a risk

of activity accumulation in the case

of an accident in confined space (as

a tunnel). The limit of the total

activity allows to address this risk.

The precaution to put in the

transport plan can then be:

- some precautions to limit the risk

of an accident ; or

- some itinerary limitations to avoid

confined areas ; or

some features on the SCO-III that

guaranty that even in the case of an

accident in a confined area, the

activity release in the air would be

limited.

For conveyances other than

inland waterway craft, there is a

risk of activity accumulation in

the event of an accident in a

confined space (e.g. in a tunnel).

The total activity limit addresses

this risk. The transport plan could

provide provisions such as:

controls or features that limit the

risk of an accident;

- routeing constraints that avoid

confined areas; or

the provision

understandable and

complete.

50




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


features on the SCO-III that

guaranty that even in the case

of an accident in a confined

area, the activity release in the

air would be limited.

103 523.1(d) “The TI for a freight container, tank,

unpackaged LSA-I or unpackaged

SCO-I is the maximum dose rate at 1

m from the external surface of the

load, expressed in mSv/h and

multiplied by 100 and then further

multiplied by an additional factor

which that depends on the largest

cross-sectional area of the load. This

additional multiplication factor, as

specified in Table 7 of the Transport

Regulations, ranges from 1 up to 10.

It is equal to 1 if the largest cross-

sectional area of the load is 1 m2 or

less. It is 10 if the largest cross-

sectional area is more than 20 m2

. The

TI for a freight container may be

established alternatively as the sum of

the TIs of all the packages in the

freight container. For an open-sided

or open-top freight container, surfaces

of a rectangular prism encompassing

the container structure and the load

can be considered as the surfaces of

the load, and the largest cross-

Minor editorial changes

were made to the text.

51




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


sectional area of that prism is can

then be used to determine the

additional multiplication factor in

Table 7 of the Transport

Regulations.”

104 523.3 “The multiplication factors in Table 7

are intended to apply the to large

dimensional loads which that cannot

be simulated as a point source but

must be simulated as a surface source

or a volume source since the

radioactive material is distributed

uniformly throughout the load. such

as unpackaged material or

accumulation of packages. As the

dose rate distribution around a

package, which provides enough

shieldings around their its radioactive

source to comply with prescribed TI

limits prescribed (see such as in para.

527 of the Transport Regulations), is

rather similar to that obtained using a

of the point source model, no

multiplication factor need to be

applied to packages.”

The meaning of this

paragraph is unclear.

Minor editorial changes

were introduced to make

the sentence clearer, but

it is uncertain whether the

original intent of the text

has been preserved.

105 525.1 –

536.1


renumbered 526.1 – 537.1

In DS495, para. 524 from

SSR-6 has been divided

into para 524 and 525,

causing following

paragraphs to increment

52




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


by 1.

106 537.1 –

584.1



Same as above and the

addition of para 538 in

DS495 requires adding 2

to each of these para

numbers.

107 546.4 (to

be 548.4)

“Care should be exercised in

selecting the proper shipping name

from Table 1 of the Transport

Regulations. Portions of an entry that

are not highlighted by written in

capital (i.e., uppercase) letters are not

considered part of the proper shipping

name. When the proper shipping

name contains the conjunction ‘or’,

then only one of the possible

alternatives should be used. The

following examples illustrate the

selection of proper shipping names of

the entry for UN numbers 2909 , 2915

and 3332:

For UN No. 2909 RADIOACTIVE

MATERIAL, EXCEPTED

PACKAGE — ARTICLES

MANUFACTURED FROM

NATURAL URANIUM or

DEPLETED URANIUM or

NATURAL THORIUM, The the

proper shipping name is the

Attempted to modify the

text to more clearly

illustrate the selection of

proper shipping names.

53




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


applicable description from the

following:

a.) UN No. 2909 RADIOACTIVE

MATERIAL, EXCEPTED


MANUFACTURED FROM

NATURAL URANIUM,

b.) UN No. 2909 RADIOACTIVE

MATERIAL, EXCEPTED


MANUFACTURED FROM

DEPLETED URANIUM, or

c.) UN No. 2909 RADIOACTIVE

MATERIAL, EXCEPTED


MANUFACTURED FROM

NATURAL THORIUM.

UN No. 2915 RADIOACTIVE

MATERIAL, TYPE A PACKAGE,

non-special form, non-fissile or

fissile-excepted

UN No. 3332 RADIOACTIVE


SPECIAL FORM, non-fissile or

fissile-excepted

54




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


For UN No. 2915 RADIOACTIVE


non-special form, non-fissile or

fissile-excepted UN No. 3332

RADIOACTIVE MATERIAL, TYPE

A PACKAGE, SPECIAL FORM,

non-fissile or fissile-excepted, The

the proper shipping name is the

applicable description from the

following: UN No. 2915


A PACKAGE UN No. 3332


A PACKAGE, SPECIAL FORM.

As can be seen from the example of

UN No. 3332, the added

characteristic (in this case, “special

form”) is explicitly spelled out, and

the lowercase words “non-fissile or

fissile-excepted” are not part of the

proper shipping name.”

108 546.5 (to

be 548.5)

“Another example related to the

interpretation and use of the UN

number concept relates to empty

packagings which that previously

have contained radioactive material

(i.e., UN No. 2908). If there are

residues or heels in the packaging, for

example, in uranium hexafluoride

Minor editorial changes.

55




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


packages, the packaging should not

be called an ‘empty packaging’ but

should be shipped as a package (i.e.,

not as a packaging). The quantity

remaining would determine the

package category (see para. 427.4).”

109 562.1 (to

be 564.1)

“Operational controls that are applied

in the transport of radioactive

material can include the use of

segregation distances. Segregation

distances are usually tabulated as a

function of These generally take the

form of tables relating the total TI

with the segregation distance, along

with some time dependence. These

tables are generally derived at a

global or national level (e.g., the

ICAO Technical Instructions [12])

and include the effects of the

operations of many consignors,

shippers and carriers on either the

most exposed worker or a

representative person of the public.”

Minor editorial changes.

110 564.3 “An example of such a review was

carried out during the preparation of

the 1996 Edition of the Transport

Regulations. The model and dose

criteria were examined in light of the

developing philosophy of dose

constraints, as amplified discussed in

The use of the word

amplified seemed

inappropriate, so it was

replaced with the more

generic word discussed.

56




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


Ref. [38] (the methodology of which

is used in Ref. [39]). A dose

constraint of 0.7 mSv was considered

appropriate for exposure of a critical

group of the public to direct radiation

from sources such as radioactive

material in transport. This constraint

was envisaged as being applicable to

global transport operations in general

rather than the operations of one

particular consignor. Over a series of

three technical meetings, information

on assessed exposures to members of

the public was actively collected and

evaluated. The assessment of this

information demonstrated that

exposures being received by members

of the public from these operations

were far below the dose criterion used

in the modelling and the appropriate

dose constraint [40]. The conclusion

of these studies was that the existing

segregation tables and the other

provisions of the Transport

Regulations together provide for an

appropriate level of radiological

safety. However, these evaluations

were not adequately reflected in the

associated guidance publication. It is

considered that the current

57




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


segregation tables are consistent with

the use of appropriate dose

constraints. For example, the

postulated public doses presented in

the tables relate to a 1 mSv dose with

a very pessimistic model (exposures

are actually estimated to be of the

order of tens of microsieverts), not (as

was intimated in the 1996 guidance

publication) a realistic model.”

111 570.2 (to

be 572.2)

570.2. The basis for a 45 g

consignment limit in items (c) and

(e) is given in para. 417.5. A 15 g

consignment limit was set, not for a

technical or a safety reason, but for a

practical reason (physical

protection).

It is not clear how the 15g

consignment limit for

material transported

under para. 417(d)

provides physical

protection. Recommend

removing the sentence. If

retained, provide more

detail about how the limit

ties to physical protection

requirements.

112 575.7, 1st

sentence

For SCO-III, paras. 575(b) and

575(c) apply. The dose rate at the

surface of the SCO-III is limited as

specified in para. 517.

All standard dose rate

limit provisions apply,

such as paras 517, 573

and 575, unless

alternatively addressed

for watercraft to provide

an equivalent level of

safety.

58




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


113 575.7, 2nd

sentence



to the last sentence: “In the case of a

SCO-III with a surface dose rate

greater than 2 mSv/h, the

precautions to control the access by

workers and members of the

public, secure the object, limit risk

during loading or unloading, and

any other relevant precaution

precautions, should be set specified

in the transport plan.”

Proposed change to

provide clarity in the text.

114 575.1 (to

be 577.1)



to the last sentence: “Then, these

controls, and any other relevant

precaution precautions, should be

set specified in the transport plan.”

Proposed change to

provide clarity in the text,

and for consistency with

changes proposed for

573.7 noted above.

115 579.2 (to

be 581.2)



to the last sentence: “Then, these

precautions should be set specified

in the transport plan.”

Proposed change to

provide clarity in the text,

and for consistency with

changes proposed for

575.7 and 577.1 noted

above.

116 581.1 (to

be 583.1)

“When authorization is given to an

organization for the use of the postal

service, one a suitably knowledgeable

and responsible individual should be

appointed to ensure that the correct

Minor editorial change.

59




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


procedures and limitations are

observed.”

117 References

to Section

V


to Section V:


to the right for References 8, and

10-14.

Please see earlier

comments regarding the

UN Recommendations

and modal regulatory

documents that are


It is recommended that

similar wording be used

for these references in

this section.

118 602.1 –

613.2


renumbered 601.1 -612.2

In DS495, para 601 from

SSR-6 was deleted,

causing the following

paragraph numbers to

shift 3.

119 605.2/42-

44

It may be possible, with competent

authority approval, to specify that

the material be transported in a

minimum quantity to provide

protection in the case of an accident

(e.g. thermal inertia).

This paragraph appears

redundant, and it is not

clear what is intended by

the “thermal inertia”

example. Recommend

removing it.

120 613A.1 -

613A.5



In DS495, para 613 was

inserted and combined

with above comment,

paragraph numbers now

match.

121 613A.1 Proposed revised text: Proposed changes to

60




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for



to this text: “Package components

are subjected to degradation

mechanisms and ageing processes

which depend on the component

itself and its operational conditions.

Thus the design of a package should

take into account ageing

mechanisms commensurate to with

the operational conditions with

following a graded approach

manner. A designer of package

should evaluate the potential

degradation phenomena over time,

such as corrosion, abrasion, fatigue,

crack propagation, changes of

material compositions or

mechanical properties due to

thermal loadings or radiation,

generation of decomposition gas,

and their impact on the functions

important to safety. How to apply

Applying the graded approach to

ageing consideration depends on the

intended use of the package and its

operating conditions.”


122 613A.2 Proposed revised text: In the last

sentence of this paragraph, reference

should be to para. 613.4.

Need to clarify reference

to another paragraph.

61




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


123 613A.3 Proposed revised text:

In the first two sentences, make the

following change: “For packages

intended for the repeated use, during

the design phase, ageing mechanism

mechanisms should be evaluated

during the design phase to

demonstrate adequate safety in the

safety demonstration. Based on this

evaluation, an inspection and

maintenance programme should be

developed.”

Proposed changes to



The following is revised text (not

showing the original text):

“The ageing degradation of

Structure, System, and Components

(SSCs) Important to Safety (ITS)

should be considered in design and

maintenance of packages for

transportation, storage, and

transportation after storage. This

situation recognizes that the

Transport Regulations do not apply

to long-term storage. During long-

term storage of packages containing

radioactive contents, it may be

difficult to perform inspections to

detect ageing effects of SSCs ITS.

Proposed changes to

provide clarity in the text

and to shorten a very long

sentence.

62




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


An ageing management programme

(see e.g. para. 306.4bis, and for

details see Ref. [10bis]) to address

ageing degradation (para. 809.3) and

a gap analysis program (see para.

809.4) to incorporate changes in

current regulations, technical

knowledge and package design

should be provided. These

programmes are required in the

application of the design approval of

packages for shipment after storage

as prescribed in para. 809.1 of the

Transport Regulations. The ageing

management and gap analysis

programmes should be incorporated

into an inspection plan prior to

transport.”


This new paragraph mentions ISO

7195 and ANSI N14.1 without

reference citation.

Para. 631.1 cites the ISO 7195

standard as Reference 18; and para.

631.2 mentions ANSI N14.1, but

does not provide a reference number

citation. Also, the references at the

end of Section VI cite ANSI N14.5

Need for consistency in

citing references.

63




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


and ANSI N14.6.

Should this be cited by reference

number also?


Recommended change to the

beginning of the 2nd

sentence as

follows: “The compliance to

Compliance with this requirement

can be…..”.

Proposed change to




to the beginning of the first

sentence: “In case when the When

compliance to the requirement….”.

Proposed change to




to the added parenthetical text: “(i.e.

Co-60 or Na-24 for general package

use or specific nuclides for a certain

specific package design and or

appropriate related activities which

that could result the in a detectable

change of dose rate to be

detectable).”

Proposed change to


129 673.6/4 Typical neutron absorbent absorber

materials used for criticality control

“Absorbent” not typically

used to describe neutron

absorber materials.

Appears to be a

64




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


typographical error.


Recommend changes to the added

sentence as follows: “These

provisions are were incorporated in


Regulations, and their technical

background and detail guidance for

application are provided in Ref.

[48bis].”

To properly reflect that

this document is

providing guidance on

the 20xx version of the

Transport Regulations.

131 683.2/3 Paragraph 683.2(a) requires a single

package, …

Typographical error.

132 References

to Section

VI


to Section VI:


to the right for References 11, 12,

14, and 15.

Please see earlier


UN Recommendations

and modal regulatory

documents that are




for these references in

this section.

133 701.1/3 The intent is to allow the applicant

to use accepted engineering practice

to evaluate a package or of

radioactive material.

Typographical error.


Recommend changing the text of as

follows: “As the package packages

Proposed change to


65




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


used for shipment after storage will

be may have been put into in

service for a long duration with the

radioactive contents loaded, the

effects of degradation mechanisms

and ageing process processes

should be demonstrated to comply

evaluated to demonstrate that the

packages satisfy the original or

new safety requirements prior to

shipment following storage. safety

justifications throughout the storage

period in order to

maintain transportability after

storage. It This may be

demonstrated through periodic

will be demonstrated by the

periodical safety assessments

assessment together with inspection,

monitoring and surveillance of the

package, its contents, and its

operational and environmental

conditions as well as maintenance

during storage. Such manner will

evaluations should be documented

by the applicant in an Ageing

Management Programme, which

will be is maintained under the

management system (see para.

66




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


306.4). Examples for consideration

on ageing mechanism of the

package used for shipment after

storage can be found in Refs

[1bis12] to [1bis67].”


Recommend changing the text of as

follows:

“A gap analysis programme

should be established. This

programme, which may or may

not be considered as a periodic

safety review of the package

design, is an assessment of

whether the package design

complies with the current storage

and transport regulatory

requirements. It should consider

changes of the regulations,

changes in technical knowledge

and changes of the state of

package design during storage;

identifying existing gaps.

Furthermore, it should describe

the applicant’s procedure for

conducting such an analysis or

review in order to support the

package design approval

certificate renewal process or the

Proposed change to


The text was revised

without using track

changes.

67




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


validity of existing certificates

throughout the storage period and

transport following storage.

Detailed information relative to

objectives of the gap analysis

programme can be found in

[1bis78], and further references

on gap analysis for package used

for shipment after storage can be

found in Refs [1bis89] and

[1bis1112].”

136 819.1 Following the adoption of the 1985

Edition of the Transport

Regulations, packages not requiring

approval of design by the competent

authority based on the 1973 Edition

of the Transport Regulations and the

1973 (As Amended) Edition of the

Transport Regulations could no

longer be used. Continued

operational use of such packages

required either that the design be

reviewed according to the

requirements of the 1985 latest


Regulations, or that shipments be

reviewed and approved by the

competent authority as special

arrangements, although this was not

Revert back to 2012 text.

Not clear why these

changes were made and

they do not appear to be

needed.

68




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


explicitly stated in the Transport

Regulations.

137 820.3 The 1973 and 1973 (As Amended)

Editions of the Transport

Regulations only required quality

assurance programmes (now

referred to as the management

system)2 to be established for the

manufacture of packagings. The


Regulations properly identified the

need for quality assurance

programmes (now referred to as the

management system) to cover all

aspects of transport from design,

manufacture, testing,

documentation, use, maintenance

and inspection of all packages, to

actual transport and in-transit

storage operations. Following

adoption of the 2018 Edition of the

Transport Regulations these

packages based on the 1973 Edition

of the Transport Regulations and the

1973 (As Amended) Edition of the

Transport Regulations could no

longer be used.

To clarify “these

packages”. As drafted, it

could be read to apply to

1985 designs as well.

Change is to be consistent

with paragraph 820.1.

138 820.6 In the process of developing the

1996 2018 Edition of the Transport

Changed to eliminate

continued use of 1973

69




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


Regulations, it was determined that

there was no need for an immediate

change of the Transport Regulations

following their adoption, but that

changes aiming at a long term

improvement of safety in transport

were justified. Therefore, it was also

decided to accept continued

operational use of certain packages

designed and approved under the

1973, or 1973 (As Amended), or

1985, or 1985 (As Amended 1990),

1996 Edition, 1996 Edition

(Revised), 1996 (As amended

2003), 2005, 2009 and 2012

Edtions of the Transport

Regulations. The continued use of

existing packagings with a 1967,

1973, or 1973 (As Amended),

Edition of the Transport Regulations

based package design approval was

considered to be no longer necessary

or justified.

design packages and to

add transition for 1996-

2012 package designs (as

modified by Feb. 2016

CSM).

139 820.7 The continued use of approved

packages meeting the requirements

of the 1973, or 1973 (As Amended),

or 1985, or 1985 (As Amended

1990), 1996, 1996 (as Amended

2003), 2005, 2009, 2012 Editions

Changed to eliminate

continued use of 1973

design packages and to

add transition for 1996-

2012 package designs (as

modified by Feb. 2016

70




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


of the Transport Regulations is

subject to multilateral approval from

the date that the 1996 Edition of the

Transport Regulations entered into

force, in order to permit the

competent authorities to establish a

framework within which continued

use may be approved. Additionally,

no new manufacture of packagings

to such designs is permitted to

commence. This transition period

was determined on the basis of an

assessment of the time needed to

incorporate the 2012 2018 Edition

of the Transport Regulations into

national and international

regulations, taking into

consideration the experience gained

during implementation of the

transitional arrangements of the


Regulations.

CSM plus correction to

time needed for 2018

edition).

140 820.8 See para. 535.2. Delete paragraph, per

Feb. 2016 CSM.

141 820.9

(should be

revised as

820.8)

For any revision to the original

package design, or increase in

activity of the contained materials,

or addition of other types of

radioactive material, which would

To update from 2012 as

per Feb. 2016 CSM.

71




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


significantly and detrimentally affect

safety, as determined by the

competent authority, the design

should be reassessed and approved

according to the 2012 latest Edition

of the Transport Regulations. Such

factors could include an increase in

the mass of the contents, changes to

the closure, changes to any impact

limiters, changes to the thermal

protection or shielding and changes

in the form of the contents.

142 820.10

(should be

revised as

820.9)

When applying para. 820, the

original competent authority

identification mark and the design

type codes, assigned by the original

competent authority of design,

should be retained both on the

packages and on the competent

authority certificates of design

approval, notwithstanding that these

packages become subject to

multilateral approval of design. This

means that packages originally

designated Type B(U)-85 or Type

B(U)F-85 under the 1973 1985


should not be redesignated Type

B(M) or Type B(M)F, nor should

Changed to reflect proper

treatment of -85 designs

(as per Feb. 2016 CSM.)

72




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


they be redesignated Type B(M)-96

or Type B(M)F-96, when used under

the provisions of para. 820. This is

to ensure that such packages can be

clearly identified as packages

grandfathered under the provisions

of para. 820, having been originally

approved under the 1973 a previous


Regulations.

143 820.11

(should be

revised as

820.10)

See para. 832.4 832.2 and 832.3. Revised per Feb. 2016

CSM.

144 823.1

(should be

revised as

824.1)

Paragraph 824 provides introduces

transitional arrangements for special

form radioactive material, the design

of which is also subject to

competent authority approval. It

emphasizes the need to apply

management system measures

according to the 2012 Edition of

the Transport Regulations to

ensure that such special form

radioactive material remains in use

only where it continues to meet the

original design intent or regulatory

requirements. This can best be

achieved by ensuring that the latest

Revised per Feb. 2016

CSM.

73




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


management system measures are

applied to post-manufacturing

activities such as servicing,

maintenance, modification and use

of such special form radioactive

material. It should be noted that the

scope of the transitional

arrangements of the Transport

Regulations only extends to the

requirements for certain special

form radioactive material. In all

other aspects, for example,

concerning general provisions, the

requirements and controls for

transport, including consignment

and conveyance limits, and approval

and administrative requirements, the

provisions of the 2012 current

edition of the Transport Regulations

apply.

145 823.2

(should be

revised as

824.2)

In the process of developing the

2012 2018 Edition of the Transport

Regulations, it was determined that

there was no need for an immediate

change of the Transport Regulations

following their adoption, but that

changes aiming at a long term

improvement of safety in transport

were justified. Therefore, it was also

Revised per Feb. 2016

CSM.

74




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


decided to accept continued

operational use of special form

radioactive material designed and

approved under the 1973 or 1985

and 1985 (As Amended 1990),

1996, 1996 (Revised) and 1996 (As

Amended 2003), 2005, 2009, and

2012 Editions of the Transport

Regulations. However, no new

manufacture of such special form

radioactive material is permitted to

commence. The continued use of

existing special form radioactive

material with a 1973, 1973 (As

Amended), or 1967 Edition of the

Transport Regulations based design

approval was considered to be no

longer necessary or justified.

146 823.3 (to

be 824.3)

See para. 832.5 834.2 and 834.3. Revised per Feb. 2016

CSM.

147 823.1 –

826.2



The addition of paragraph

822 in DS495 causes

renumbering of

subsequent paragraphs.

148 829.1 –

840.3


renumbered 831.1- 842.3.

Previous change plus new

para 829 in DS495 causes

these to change by 2.

149 832.2 (to

become

It is essential that easy means are

available, preferably in the

Per Feb. 2016 CSM to

reflect updates to

75




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


834.2) identification mark, for

determining under which edition of

the Transport Regulations the

original package design

approval was issued. Beginning with


Regulations, this was This will be

achieved by adding the symbol ‘-96-

85’ to the identification

mark. , which was then changed to

‘-96’ when the 1996 Edition of the

Transport Regulations was issued.

The identification mark including ‘-

96’ continued through the 1996

(Revised) and 1996 (As Amended

2003), 2005, 2009, and 2012

Editions of the Transport

Regulations. The 2018 Edition of

the Transport Regulation only

includes the symbol of the year

within the identification mark only

for grandfathered package designs.

Example:

Edition of Transport Regulations

/Package design identification mark

1973 A/132/B(U), or A/132/B(M)

1985 A/132/B(U)-85, or

A/132/B(M)-85

transitioning.

76




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


1996 A/132/B(U)-96, or

A/132/B(M)-96

2018 A/132/B(U), or A/132/B(M)

150 832.3 This technique of adding a symbol

may continue to be used provided

later editions of the Transport

Regulations essentially maintain the

present package identification

marks.

Deleted per Feb. 2016

CSM.

151 832.4 (to

become

834.3)

The continued procedure of adding

the symbol ‘-96’ to the type code

since for the 1996 through the 1996

(Revised) and 1996 (As Amended

2003), 2005, 2009, and 2012


is was justified because, since that

time, no significant safety

related changes to design or test

requirements for packages, special

form radioactive material

and low dispersible radioactive

material have been were introduced.

Such designs, with the addition

‘-96’, must meet the current

Transport Regulations in full. On

the other hand, all All other designs

with no addition or with the addition

‘-85’ or “-96” are subject to the

provisions of transitional

Per Feb. 2016 CSM to

reflect updates to

transitioning.

77




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


arrangements according to paras

820–823, respectively, and can be

clearly identified as such.

152 840.3 (to

be 842.3)


Recommend this paragraph be

revised as follows:

“For packages which are intended

to be used for shipment after

storage, the competent authority

of the country where storage takes

place and shipment after is

initiated may be different from

the country of origin of package

design. When a package design

approval is withdrawn or not

renewed in the country of origin

of the design, the package may no

longer be authorized to be

transported in the country where

the packages are stored without

package design approval granted

in that country. For this reason,

the competent authority

concerned with storage and

shipment after storage may need

to issue and maintain its own

package design approval which

may be based in part on an

assessment already made by the

Proposed change to


The text was revised

without using track

changes.

78




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


competent authority of origin of

design, but then completed by an

additional assessment addressing

aspects specific to long-term

storage and shipment after

storage addressing ageing

management, gap analysis,

requirements before shipment,

requirements during post-storage

shipment, and different approval

periods.”

153 References

for Section

VIII


The citation of references listed at

the end of Section VIII needs to be

sorted out. The following references

are listed at the end, they not cited in

the text; but they should be cited:

[3] Chopra, Dierchs, et. al.

[NOTE: Dierchs should be

spelled Diercks]

[4] Saegusa

[5] Wille, Wolfe, et. al.

[6] Nuclear Energy Institute

[10] Pacific Northwest National

Laboratory

[11] Droste, Wille

The citation of the

references listed at the

end of Section VIII

should be properly sorted

out in the text.

79




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


154 References

to

Appendix

III


to Appendix III:


to the right for References III.5.

Please see earlier


modal regulatory

documents that are




for this references in this

appendix.

155 Para. IV.2 Proposed revised text:

Recommend changing the text to

replace “tie-down system” with

“retention system”, as follows:

“This appendix provides guidance

on considering the effects of the tie-

down system retention system

loads applied to the package during

routine conditions of transport. It

describes possible methods for

demonstrating compliance with

package design requirements. The

package will include the tie-down

retention system attachment points

but not the remainder of the

retention system tie-down system.

Other components of the retention

system tie-down system, which

are not part of the package, are

addressed by modal and national

This appendix should

consistently use

“retention system” rather

than “tie-down system”

since the title of the

appendix is “retention”

not “tie-down”, Para.

IV.5 uses “retention

system” stating that such

systems may include “tie-

downs”.

80




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


requirements.”

156 Title of

Fig. IV.1.


Recommend changing the title to:

“Fig. IV.1. Retention Tie-down

system components”


consistently use


than “tie-down system”.

157 Para.IV.5,

last line


Suggest the following change to the

text:

“…shows examples of components

of tie-down retention systems.”


consistently use


than “tie-down system”.

158 2nd

paragraph

under

Fig. IV.1

of

Appendix

IV (not

numbered)

.


Suggest the following changes to the

text:

a) Should this be given a new

paragraph number? If so, the

following paragraph numbers

will need to be adjusted

accordingly.

b) In the lead-in text of this

paragraph, make the following

change: ‘For the purposes of the

guidance notes noted in this

appendix, the following

definitions of terms used in

appendix IV apply:’

c) First item in the list “Attachment

point”: in the text change “tie-

Proposed modifications

in text to make text

consistent throughout,

using retention rather

than tie-down where

appropriate, and tyo

correct (in item b listed to

the left) an apparent

typographical error.

81




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


down member” to “retention

member”.

d) Second item in the list “Anchor

point” : in the text change “tie-

down member” to “retention

member”.

e) Penultimate item in the list “Tie-

down member”: change Tie-

down member to read

“Retention member”.

f) Last item in the list “Tie-down

system (or Retention system)”:

Recommend changing as

follows:

“Retention System The

assembly of an attachment

point, an anchor point and a

retention member.”


Recommend the addition to the text

in the last sentence as follows:

“Operating, and handling, and

maintenance instructions should be

drawn up developed for the use of

any dedicated retention equipment.

Maintenance should be

part of the instructions on

the use of retention

equipment.


Recommend changing the first part

For consistency of text

within the appendix.

82




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


of the sentence to read:

a) “Training for persons involved

in tie-down the retention of

packages……”.

b) First and second bulleted items,

change “”tie-down operations”

to “retention operations”.

c) 6th

bulleted item, change “tie-

down” to “retention”.

d) 8th

bulleted item, change “tie-

down equipment” to “retention

equipment”; and “tie-down

operations” to “retention

operations”.


Recommend changing “lifting and

tie-down” to “lifting and retention”.

For consistency of text

within the appendix.

162 Para. VII.2

and

References

listed at

the end of

Appendix

VII.


The only place in this appendix

where references are cited is toward

the end of para. VII.2, and it only

lists References [VII.11, VII.12].

References VII.1 through VII10 are

not cited.

It is recommended that the reference

citation in para. VII.2 be changed as

Utilize all of the

references cited in

Appendix VII.

83




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


follows: “.....should be demonstrated

as being appropriate through the

literature [VII.1 through VII.12

VII.11, VII.12], tests or reasoned

argument. “

163 Paras.

VIII.13

through

VIII.15


Two issues need to be addressed

here.

a) After the three-line paragraph

VIII.13, the next paragraph should

be numbered VIII.4, and what is

now numbered VIII.14 should be

numbered VIII.15.

b) The sub-header “COMPLETION

OF SHIPMENT” is part of the

header dealing with a shipment

involving a country without

regulations. Therefore the sub-

header should not be all caps.

The text of these paragraphs should

be corrected as follows:

“VIII.13. If no regulations for the

safe transport of radioactive material

are implemented in a country, the

Transport Regulation (current

edition of IAEA Safety Standards

Series No. SSR-6) should be applied

for the transport within, from, to or

through that country.

Consistency in text

84




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


VIII.14. If no regulatory body for

the safe transport of radioactive

material is appointed in a country,

the first certificate of approval

(special arrangement), which should

be approved by all countries

relevant to the shipment, may be

issued by the existing national

radiation protection regulator of the

country. The IAEA’s Division on

Radiation, Transport and Waste

Safety can provide guidance on the

application of international

regulations on transport safety.

COMPLETION OF SHIPMENT

Completion of Shipment

VIII.14. VIII.15. In such special

situations, the competent authority

or the concerned safety regulator

should continue tracking the

shipment until its safe completion.

The consignor should inform

the appropriate authority about the

safe completion of such shipments.

164 Various See the attached table. Due to

paragraph renumbering in SSR-6

To correct references to

paragraph numbers that

85




RESOLUTION

Comment

No.

Para/Line

No.


modified as follows

Rejected Reason for


and in SSG-26 (as noted in above

comments), cross-references to

paragraphs need to be updated in

many paragraphs. The attached table

lists the updates needed.

changed.

86

Paragraph Cross-Reference Corrections

Found in Para # (old #)

New Para # for text Containing Reference

Currently Referenced Para #/ Updated or Corrected Para # that Should be Referenced

218.1 same 526/527, 525/526, 566(c)/568(c), 567/569, 568/570, 569/571, 541/543, 542/544

222.11 223.11 222/223

228.3 229.3 TS-R-1/SSR-6

239.2 same 603.1-603.4/602.1-602.4, 604.1/603.1, 604.2/603.2

240.5 Same 226/227

244.2 Same 218.3/218.2

302.1(e) Same 562.1-562.14/564.1-564.14

309.3 Same 526-529/527-530, 566/568, 573/575

310.4 Same 830.1/832.1

405.3 Same 409.10-409.14/409.9-409.13

409.1 Same 226.3/227.3

409.10 Same 409.14/409.13

413.5 Same 409.16/409.15

417.1 Same 570/572 (twice)

417.5 Same 570(c)/572(c)

417.6 Same 570(d)/572(d)

417.7 Same 570(e)/572(e)

417.8 Same 606.7/605.7

418.2 Same 606/605

420.8 Same 419(b)/419(c)

501.1 Same 547/549

501.6 Same 659.21-659.24/659.20-659.23

502.1 Same 547/549

503.1 Same 547/549

503.5 Same 838/840

513.5 Same 233.1-233.6/221.1-221.7

516.2 Same 562.12-562.14/564.12-564.14

520.9 Same 613/612

521.2 Same 226.1/227.1

87




526.1 527.1 527/528, 528/529

527.1 528.1 526.1/527.1

528.1 529.1 526.1/527.1

528.2 529.2 573/575, 233.2/221.2

530.1 531.1 530/531

531.2 532.2 533.2-533.6/534.2-534.6

532.4 533.4 533.2-533.6/534.2-534.6

533.5 534.5 533.2-533.4/534.2-534.4

534.3 535.3 533.2-533.6/534.2-534.6

535.1 536.1 832(c)/834(c)

535.3 536.3 533.2-533.6/534.2-534.4

538.2 540.2 536/537

541.1 543.1 568/570, 569/571

541.2 543.2 538/540

542.1 544.1 541.1-541.3/543.1-543.3

543.1 545.1 571/573

546.1 548.1 546/548, 532.1/533.1

546.3 548.3 546(k)/548(l) (L, not K)

546.6 548.6 546(f)/548(g) (G, not F)

546.7 548.7 540.3/542.3

562.13 564.13 562/564

565.1 567.1 554/556

567.1 569.1 526.1/527.1, 825/826

570.1 572.1 570/572

571.1 573.1 543.1/545.1, 544.1/546.1

572.1 573.1 544.1/546.1

573.1 575.1 221.1-221.6/222.1-222.6

573.4 575.4 564.1-564.3/566.1-566.3

573.6 575.6 573(a)(iii)/575(a)(iii)

575.1 577.1 573/575

575.2 577.2 574/576

88




576.1 578.1 566/568

578.1 579.1 578/580

583.1 585.1 562.1-562.14/564.1-564.14, 568.1/570.1

584.1 586.1 584-588/586-590

603.3 602.3 603/602

606.4 605.4 606(b)/605(b)

606.5 605.5 606/605

606.6 605.6 606/605

606.7 605.7 606/605

607.1 606.1 613/612

607.2 606.2 564.1/566.1, 564.2/566.2

610.3 609.3 610/609

611.2 610.2 610.2-610.4/609.2-609.4

621.2 same 578.1/579.1, 229.1-229.3/230.1-230.4

627.5 same 624.8/624.5

629.5 same 624.8/624.5

648.6 same 624.8/624.5

659.14 same 527/528, 528/529, 526/527

659.19 Same DELETE this paragraph as it references 624.8 which has been deleted (and then renumber paragraphs 659.20-.26 as 659.19-.25)

663.1 same 229.3/229.4

666.3 same 229.3/229.4

665.1 same 605/604

671.2 same 659.24/659.24

674.2 same 566(c)/568(b)

674.10 same 606/605 (3 times)

677.2 same 503.4/503.5

683.2 same 683.2(a)/683(a)

701.25 same 716.7/716.11

704.2 same 603/602

704.3 same 603.3/602.3, 603.4/602.4

89




705.1 Same 603.1/602.1

712.2 same 605/604, 605(b)/604(b)

712.4 same 605.5/604.5, 605.7-605.9/604.7-604.9

716.13 same 659.19/659.18

728.17 same 659.24/659.23

803.2 Same 602-604/601-603

804.1 same 832.1-832.5/834.1-834.4

807.1 same 832/834

832.4 834.4 823/824

840.2 842.2 833(b)/835(b)

App.III, III.1(i) Same 562/564

III.1(iii) Same 562(d)/564(d)

III.2 Same 562.11/564.11

III.3 Same 562/564

III.4 same 562/564

III.27 same 562(c)/564(c)

App. IV, IV.1 Same 607/606, 612/611, 613/612

App. VI, VI.25(a) Same 222/223

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