Measures on Permit for Safe Transportation of Radioactive Substances was adopted at the first executive meeting of MEP in 2010. It was released by MEP on Sept. 25, 2010 and will be put into effect on Nov. 1.
To help readers deepen their understanding of the Measures and promote its implementation, our journalist invited related official from Department of Nuclear Safety, MEP to interpret the regulation.
Q: Why do we need to formulate the Measures on Permit for Safe Transportation of Radioactive Substances?
A: The 80th executive meeting of the State Council adopted the Regulation on Management of Safe Transportation of Radioactive Substances (hereinafter referred to as the Regulation) on Sep. 7, 2009. On Sept. 14, Premier Wen Jiabao signed State Council Decree No. 562 to issue the Regulation, which was put into effect upon Jan. 1, 2010. This is of great significance for regulating transportation of radioactive substances, reducing risks amid transportation, promoting development and application of nuclear energy and nuclear technology and ensuring public and environmental safety.
The Regulation set up requirement on design, manufacture and use of containers for radioactive substances and related transportation activities. Some of the administrative permits handled by MEP (National Nuclear Safety Administration (NNSA)) include approval and filing of container design, permit and filing of container manufacture and approval of report of nuclear and radiation safety analysis, etc. However, the Regulation did not give details on the procedures and application requirements of these permits. MEP (NNSA) therefore developed Measures on Permit for Safe Transportation of Radioactive Substances (hereinafter referred to as Measures) to facilitate effective implementation of the Regulation, regulate government approval and offer convenience to corporate application.
In order to maintain consistency with generally accepted international management systems, we also consulted some regulations of IAEA (Regulation for the Safe Transport of Radioactive Material, (IAEATS－R－1)) and added information on design of special radioactive material and approval of special transport arrangement.
Q: What are the rules for approval of container design in the Measures?
A: As radioactive substances pose the harm of radiation, nuclear criticality and decay heat, the safety of their transport has to be guaranteed by containers that may hold goods, serve as protective screen, dissipate heat and prevent critical section. Therefore, transport containers are the focus of the Regulation. Container design is an important factor to ensure container performance. Strict examination and approval of container design is universally accepted in international management of safe transport of radioactive substances.
The Measures raise explicit requirement on the qualification of designers based on the principle of the Regulation, which includes legal entity of applicant, achievements that are related to or close to the design activities, professionals employed and perfect management system and quality control system.
The Measures identify that permit for containers of Level I radioactive substances will be valid for 5 years. This is because changes of standard for safe transportation of radioactive substances and advance in safety assessment technology will have some impact on original design and assessment conclusions. So the design has to be reassessed and approved periodically. In addition, regular check on the capacity of designers is also needed. This provision conforms to international practice. For instance, the design permits issued by the US, France and Germany all bear validity term clearly.
Special and low dispersible radioactive material is the basic concept in management of radioactive substances. Inclusiveness can be taken as part of the inclusive system of transport containers. Therefore, examination and approval of the design of low dispersible radioactive material in special form is a necessary link in the approval of container design and is generally accepted in international practice. While drafting the Regulation, it is supposed that such inconceivable term for the public should not be used in the Regulation and should be identified in departmental rules instead. So the Measures had supplementary provision on the approval of design for low dispersible radioactive substances in special form.
Q: What provisions were established in the Measures to regulate manufacture permit and filing on transport containers?
A: Based on the principle of the Regulation, the Measures give detailed requirement on the qualification of container manufacturers including their performance, technical staff, production condition and management system and also clarify the time limit and procedures for issuing manufacture permit and filing.
Q: What are the provisions for using transport containers made by foreign countries?
A: The Measures identify the requirement on documents submitted for approving the use of foreign-made transport containers, approval procedures and the content of approval letter. The letter is valid for five years. Renewal and change of application and related procedures are also provided.
Q: What provisions were made for approving the report on nuclear and radiation safety analysis for transport of radioactive substances?
A: The Measures provide that the report on nuclear and radiation safety analysis must be prepared by professional institute with Level A EIA certification.
The Measures provide that approval letter for transport remains valid for 5 years and set requirement on procedures for renewal and change of the letter.
According to international practice of radioactive substance transport, the Measures also make provision on special arrangement. Some radioactive material is not suitable for designing and making special transport containers. It has to be transported through special arrangement to improve its safety. In this case, the consignor should prepare report on nuclear and radiation safety analysis and apply for approval to the nuclear safety watchdog under the State Council.
Q: What are the provisions on management of radioactive articles with short half-life?
A: Short half-life radioactive articles, especially medicine, have always been the priority of management because their short life requires timely transport and the daily transport volume is big. The Regulation classifies radioactive medicine into Category III radioactive articles. In practice, some radioactive medicine should belong to Category II, given the requirement on container design. So the Measures simplify the monitoring and management of imported short half-life radioactive articles. It provides that importers of radioactive articles with the same radioactive element, less than 60-day short half-life and using similar transport containers may put radiation monitoring report on record every half year.
Q: How were the rules for approving container design and filing code prepared?
A: There is a mature and complete set of coding rules for approving the design of transport containers used internationally. To meet international standard, we affixed the translated and organized version of international coding rules to the end of the Measures. The coding rules include country code, type of transport container, international standard for transport of radioactive material that the design is based on and code of approval letter, etc.
