4-6-2 Compliance Russian presentation

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4-6-2 Compliance Russian presentation
АТЦ СПб
COMPIANCE ASSESSMENT
AT TRANSPORT OF RADIOACTIVE MATERIALS
ERSHOV V. - Emergency-Response Centre of the State Corporation “ROSATOM”,
St.-Petersburg, [email protected], phone/fax: (812) 297-73-10
Presentation at the TRANSSC-26
IAEA, Vienna, 27.06.2013
АТЦ СПб
SOME DEFINITIONS
(for the same understanding of audience )
 COMPLIANCE ASSESSMENT (CA)
 Direct or indirect determination (confirmation) of requirement execution for
object regulated
 FORMS OF COMPLIANCE ASSESSMENT
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State control (supervision)
Accreditation
Tests
Registration
Compliance confirmation (voluntary certification, obligatory certification,
obligatory declaration)
 Acceptance and commissioning of an object whose construction is completed
 Other forms
 RULES OF COMPIANCE ASSESSMENT
 Rules (procedures) of carrying out compliance assessment
from Russia Federal Law “ About technical regulating” (2002)
АТЦ СПб
FORMS AND RULES OF COMPLIANCE ASSESSMENT
AT RM TRANSPORT
 FORMS OF COMPLIANCE ASSESSMENT FOR RM TRANSPORT
Examles of current forms of CA with TS-R-1 requirements :


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
Approval of design (package, SFRM)
Approval of shipment
Other
RULES OF COMPIANCE ASSESSMENT FOR RM TRANSPORT
Examles of current rules of CA with TS-R-1 requirements :
 “Administrative regulating on issuing certificates of approval …”
(in Russia)
 Similar documents in other states
 BUT evidently in practice there are not only TS-R-1 requirements and in
presentation CA means all forms and rules of AC with all requirements
that must be fulfilled for RM transport at all stages starting from
packaging designing stage
АТЦ СПб
OBJECTIVES OF PRESENTATION
 To consider situation on CA with TS-R-1 requirements
 To present information of CA system with TS-R-1 requirements and
requirements of other norm in action for RM transport in Russia
 To encourage audience on the base of presentation and discussions to
try to determine necessity of works for harmonizing CA of the states in
RM transport field
АТЦ СПб
STATUS OF CA HARMONIZATION
 SAFETY REQUIREMENTS ARE HARMONIZED?
 IAEA Safety Requirements – TS-R-1 – practically almost
harmonized (unified) throughout the world
 Requirements (additional) of the Modal organizations - unified or
harmonized throughout the world as appropriate
 Specific (additional) safety technical (package design)
requirements of the states – practically there are not specific
technical (design) requirements
 But there are many additional requirements of the states (for
conveyance, for routes, for fabricating packaging etc.) - are needed
to be harmonized?
АТЦ СПб
STATUS OF CA HARMONIZATION (cont.)
 COMPLIANCE ASSESSMENT WITH TS-R-1 REQIREMENTS more or less defined and harmonized (unified) for some forms of CA:
o Certificate of approval (but see Russian data further)
o Declaration of consignor
o Others approvals and consideration
 But CA with TS-R-1 requirements is harmonized only in general and
evidently needed to be more harmonized in details e.g:
o Requirements for Safety report (in application for certificate of approval)
o Requirements for report (expert conclusions) on application for certificate
o Requirements for specification of Quality Assurance Programmes (in
application for certificates)
o Some others
 And in practice except certificates of approval it is very difficult before
international shipment to determine how many other permissions
(licenses, certificates, approvals, agreements) are necessary to get in the
states - See next slide with Russian situation
АТЦ СПб
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FORMS OF COMPLIANCE ASSESSMENT
FOR RM TRANSPORT IN RUSSIA
Licensing the activities of designers, manufacturers, experts, shippers,
consignors, consignees, emergency response team (Rostechnadzor)
Licensing the activities of co-executors for item 1 above (Rostechnadzor)
Licensing the DG (including RM) transporting companies (Mintrans)
Conclusion on package nuclear (criticality) safety (SC “Rosatom”)
Certificates of approval for RM, package designs of A, B, C, F (SC)
Certificates of approval for shipments of IP-2, IP-3, A, B, C, F (SC)
Certification of packagings manufactured (practically for all types)
(certification body)
Certification of conveyances (Mintrans)
Sanitary-epidemiological conclusions for SFRM, packages (MoH)
Sanitary-epidemiological conclusions for conveyances (MoH)
Agreement of Emergency plan of Consignors (SC)
Agreement of routes for road shipments (more 3000 A2) (Mintrans)
Permission for leaders of organization (Rostechnadzor)
Consigner Declaration (Consignors)
АТЦ СПб

•
•
•
•
FORMS OF COMPLIANCE ASSESSMENT
AT VARIOUS RM TRANSPORT STAGES
Design (SFRM, LDRM, PACKAGE):
Licenses for designing activity and examination activity (Rostechnadzor)
Conclusion on nuclear (citicality) safety for F package (SC «Rosatom»)
Certificate - permits for design of SFRM, LDRM, package (SC «Rosatom»)
Sanitary-epidemiological conclusion for SFRM, LDRM, package (MoH)
 MANUFACTORING (SFRM, LDRM, packaging):
• Licenses for manufactores activity (Rostechnadzor)
• Certification of item fabricated (SFRM, LDRM, packaging) (certification body) ;

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•
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SHIPMENT
Licenses for transport activity of consignor, consignee, carrier (RTN, Mintrans)
Agreement of route at road shipment (more 3000А , since 2012) (Mintrans)
Licenses or emergency response activity of professional emergency team (RTN,
Ministry of Emergency Situation)
Approval of Emergency Plan of consignor (SC «Rosatom»)
Certificate-permit for shipment (SC «Rosatom» on agreement of RTN and MoH)
Declaration of consignor
Sanitary-epidemiological conclusion for conveyance (MoH)
АТЦ СПб
EXAMPLE OF SPECIFIC REQUIREMENTS
FOR CERTIFICATE OF APPROVAL FOR SHIPMENTT
(as one of the form of Compliance Assessment)
Application for certificate of approval for shipment must contain:
a) name of consignor and consignee(s), planned routes, places of transit operations
and storage;
b) certificate -permit for package designe or package description if such
certificates is not required and short data on basis of package safety, radioactive
content
c) real radioactive content of package(s) or range of possible content
d) UN number(s), shipping name(s), category, TI, CSI, information about
labels, marks, placards on the packages and transport means (TM);
e) transport mode, type and description of TM, number of packages on TM and
outline of placing and fastening of packaes at TM
е) sum of CSI and TI on TM
f) calculated or measured radiation levels at TM and 2 m from TM surface ;
g) calculated conditions of environment of packages (temperature, isolation);
h) measures of administrative and exploration controle that are assigned in
certificate-permits for design(s)
АТЦ СПб
EXAMPLE OF SPECIFIC REQUIREMENTS
FOR CERTIFICATE OF APPROVAL FOR SHIPMENTT
(as one of the form of Compliance Assessment) (cont.)
h) category of shipments according to the special shipment classification
i) number of emergency response card;
j) plan of consignor\consignee for an accident situation at shipment
k) number of agreement with FSUE ERC for emergency responseat accident
l) QAP at shipment of package(s) and manufactoring of packaging(s)
m) radiation protection programme at shipment;
n) number of packagings at manufactoring for which are valid certificatepermits
or indication that certificate-permits are valid for all packaging of design approved
o) information about assigned service term of SFRM, LDRM and packagings
transported
p) provisions for transport of empty packaging(s)
q) figure of package(s) for IP-2 and IP-3 types
(r) term of sertification valid (requested)
АТЦ СПб
ASSESSMENT OF COMPLIACE FOR RM TRANSPORT
IN THE STATES
Does it differ from IAEA approaches?
Does it differs from Russia form of CA?
What are additional forms (requirements) on CA in the states?
ON THE BASE OF AVAILABLE INFORMATUIN - YES!
IS IT REASONABLE TO HARMONIZE CA - YES!
АТЦ СПб
PROPOSALS FOR IAEA ACTIVITIES
1. To collect information on forms of CA in the states
2. To issue list(s) CA forms and rules acting in the states
3. To analyze information on CA forms and rules in the states
and to issue report
4. To develop recommendations of IAEA on CA forms and
rules and to issue appropriate safety guide
5. To provide works on implementing the safety guide
recommendations in practice of the states
АТЦ СПб
THANK YOU FOR ATTENTION!

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