NVIC 03-94: IMO code for carrying irradiated nuclear fuel

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 3-94 United States COMDTPUB P16700.4 Coast Guard NVIC 3-94 May 26, 1994 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 3-94 Electronic Version for Distribution on the World Wide Web SubJ: INTERNATIONAL MARITIME ORGANIZATION CODE FOR THE SAFE CARRIAGE OF IRRADIATED NUCLEAR FUEL, PLUTONIUM AND HIGH-LEVEL RADIOACTIVE WASTES IN FLASKS ON BOARD SHIPS (IMO RESOLUTION A.748(18))

International Maritime Organization Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships — PURPOSE. This Circular calls the attention of Coast Guard field units, marine surveyors,

shippers and carriers of nuclear materials to the International Maritime Organization (IMO) Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships (IMO Resolution A.748(l8)).

International Maritime Organization Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships — DIRECTIVES AFFECTED None. (Note that Navigation and Vessel Inspection Circular 2-87,

entitled Domestic Barge Transportation of Radioactive Materials/Nuclear Waste, remains applicable to domestic barge movements.)

International Maritime Organization Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships — BACKGROUND.

a. The International Maritime Organization (IMO) establishes codes and standards for the maritime transportation of packaged hazardous materials. The principal code issued by IMO in this regard is the International Maritime Dangerous Goods (IMDG) Code. The IMDG Code includes provisions for transportation of all classes of hazardous materials including class 7 (radioactive) materials. The IMDG Code standards for transport of class 7 materials primarily address documentation, marking, labeling, placarding, stowage, segregation and other handling requirements. For packaging requirements for class 7 materials, the IMDG code relies on the International Atomic Energy Agency (IAEA) requirements as set forth in Safety Series No. 6, Regulations for the Safe Transport of Radioactive Material, 1985 Edition (As amended 1990). b. The IMDG Code and IAEA Safety Series No. 6 do not contain special design and equipment requirements for the vessels which transport class 7 materials. Also, the International Convention for the Safety of Life at Sea (SOLAS) does not contain special requirements for vessels transporting class 7 materials as it does for vessels carrying other classes of dangerous goods (SOLAS Regulation 11-2/54). c. The IMO Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High- Level Radioactive Wastes in Flasks on Board Ships (IMO Resolution A.748(18)) was developed to complement the provisions of the IMDG Code by providing specific requirements for ship design and construction. IMO Resolution A.748(18) was developed as a Joint effort of IMO and the IAEA.

International Maritime Organization Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships — DISCUSSION.

a. IMO Resolution A.748(18) applies to new and existing ships, regardless of size, that transport irradiated nuclear fuel (INF), plutonium and high level radioactive wastes in flasks (packagings which are also known as casks). The casks are extremely robust packagings which meet stringent design and testing requirements. The casks may or may not be contained within an intermodal freight container for shipment. NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 3-94 b. The specific scope of radioactive materials to which Resolution A.748(18) applies is defined in'the resolution. Irradiated nuclear fuel is also known as spent nuclear fuel and in general terms is nuclear fuel which has been~removed from a reactor following irradiation. c. Resolution A.748(18) assigns ships covered by its requirements to three separate classes depending on total radioactive quantity of materials which may be carried on board. These are INF 1, INF 2 and INF 3 in increasing order of maximum quantity of material which may be carried, and level of ship requirements which apply. d. Resolution A.748(18) sets forth requirements which address the following main areas of ship design or equipment: damage stability, fire protection, temperature control of cargo spaces, structural considerations, cargo securing arrangements, and electrical arrangements. In each case, the Code relies on established international standards particularly those of the SOLAS Conventi~ rather than defining a new set of requirements. The Code also contains more general provisions for ships to have appropriate radiological protection equipment and a management, training and shipboard emergency plan. e. Resolution A.748(18) also calls for the flag Administration to provide a ship which meets the provisions of that Code with an appropriate document as evidence of compliance with the construction and equipment requirements of the Code.

International Maritime Organization Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships — IMPLEMENTATION.

a. A shipper intending to offer for transport by vessel materials covered by IMO Resolution A.748(18) should include compliance with the provisions of IMO Resolution A.748(18) as a criterion in selection of the ship to transport the material. b. An owner or operator of a U.S. flag vessel intending to transport materials covered by IMO Resolution A.748(18) should request the cognizant Coast Guard Officer in Charge, Marine Inspection (OCMI) to issue an endorsement to the Certificate of Inspection to document compliance with the provisions of IMO Resolution A.748(18). To facilitate handling a request, it should be submitted to Comandant (G-MTH) for initial review prior to forwarding to the cognizant OCMI or Commanding Officer, Marine Safety Center for technical review. End: (1) International Maritime Organization Code for the Safe Carriage of Irradiated Nuclear Fuel, Plutonium and High-Level Radioactive Wastes in Flasks on Board Ships (IMO Resolution A.748(18))