IMO/CCC/E&T35 Meeting Outcome and Proposed Amendments
The IMO/CCC/E&T35 virtual meeting in September 2021 aimed to finalize proposed amendments to the IMDG Code. The meeting discussed the deletion of "closed containers" from certain tables and raised questions to the IAEA regarding criticality safety indexes. The draft report includes recommendations from the IAEA on the distinctions between open and closed containers for radiation protection and criticality safety. Further advice from the IAEA is sought on the appropriate criticality safety indexes in the IMDG Code tables.
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Agenda item 6.2: - FCWG -Working Paper on IMO Query E&T35 - TTEG-OM-FCWG response to IMO-E&T35 NMRI Response to E&T35 questionary Akiko KONNAI and Makoto HIROSE National Maritime Research Institute, Japan
What happens in IMO/CCC/E&T35? IMO/CCC/E&T35 met virtually in 13-17 September 2021 to finalize the proposed amendments to the IMDG Code Amdt.40-20. IMO Secretariat submitted a proposal, E&T35/5, to delete (closed container) in the table for TI and CSI limits, based on the conclusion of TRANSSC 42. Not adopted, and three additional questions were raised to IAEA. CCC: the Sub-committee on Carriage of Cargoes and Container E&T: Editorial and Technical group belonging to CCC. 2 NMRI TRANSSC 46, 5-9 June 2023
E&T35/5Submitted by IMO Secretariat Proposed amendments emanating from IAEA, Note by the Secretariat 7.1.4 Special stowage provisions 7.1.4.5 Stowage of goods of class 7 In 7.1.4.5.3.1, in the table, delete the words "(closed containers)" (twice). In 7.1.4.5.3.4, in the table, delete the words "(closed containers)" (twice). 3 NMRI TRANSSC 46, 5-9 June 2023
Extracts from the draft E&T35 report Proposed amendments emanating from IAEA 3.17 The Group had for its consideration document E&T 35/5 (Secretariat), containing proposals for amendments to the IMDG Code, emanating from IAEA. As indicated in the document, IAEA had advised that "As there is no need to differentiate open-type freight containers from closed type containers on the basis of TI and CSI limits on the conveyance, it is recommended to IMO to delete "(closed containers)" in table 7.1.4.5.3.1 and table 7.1.4.5.3.4 of the IMDG Code". 3.18 During the ensuing discussion, the Group noted the following statement by Germany: "When the tables for the maximum TI and CSI values in 7.1.4.5.3 of the IMDG Code had been developed, a freight container for class 7 was defined in 2.7.2 of the Code as transport equipment "of a permanent enclosed character, rigid and strong enough for repeated use." The permanent enclosed character might have been the rationale for the distinction between packages/small freight containers and large freight containers. For a hold, compartment or defined deck area, the maximum TI is limited to 50 for package/small freight containers. For large freight containers the value is 200. For the total vessel, the value for packages/small freight containers is 200, for large freight containers it is unlimited. The same applies to the CSI values for the total vessel. 4 NMRI TRANSSC 46, 5-9 June 2023
Extracts from the draft E&T35 report (cont.) The views of IAEA are noted that it is irrelevant for the purpose of radiation protection and criticality safety whether the packages are in a closed container or on an open flatrack or directly loaded into the cargo hold. Consequently, a freight container needs no longer to be closed in order to benefit from the higher values." 3.19 In conclusion, the Group agreed to seek further advice from IAEA on the following issues: .1 criticality safety indexes in the tables in 7.1.4.5.3 of the IMDG Code are appropriate? Should the value be 200 or no limit? If it is irrelevant if the freight container is closed or open, which values for the sum of transport indexes and .2 distance of radioactive material from passengers and crew found in table 7.1.4.5.18 of the IMDG Code? Further, if the answer to the above question is 200, does this present an inconsistency with the segregation .3 no distinction between closed and open freight containers. This measurement is required to make a determination if a freight container is a "large freight container". Lastly, the Group seeks guidance on how to calculate the internal volume of a freight container if there is 5 NMRI TRANSSC 46, 5-9 June 2023
The answers for the three questions from E&T35 (a) If it is irrelevant if the freight container is closed or open, which values for the sum of transport indexes and criticality safety indexes in the tables in 7.1.4.5.3 of the IMDG Code are appropriate? Should the value be 200 or no limit? => No limit, since there is no difference in TI limit and CSI limit between closed-type and open-type freight containers. 6 NMRI TRANSSC 46, 5-9 June 2023
The answers for the three questions from E&T35 (b) If the answer to (a) is 200, does it cause inconsistency with the table 7.1.4.5.18 of the IMDG Code? IAEA is not in position to answer the question, since Table 7.1.4.5.18 has been established by the IMO through its own calculation is not existing in SSR-6 or SSG-26. An observation from IAEA is that there is no inconsistency since there is no difference in TI limit and CSI limit between closed- type and open-type freight containers. 7 NMRI TRANSSC 46, 5-9 June 2023
Table 7.1.4.5.18 of IMDG code 8 NMRI TRANSSC 46, 5-9 June 2023
The answers for the three questions from E&T35 (c)Is any guidance on how to calculate the internal volume of open-type freight containers available? => Guidance on the calculation of internal volume or open-type freight containers is available in para 223.3 of the new Advisory Material, SSG-26 (Rev.1) (2108 Edition), which will be published soon published in 2022. 9 NMRI TRANSSC 46, 5-9 June 2023
Technical Basis for Table 7.1.4.5.18 of IMDG Code The segregation distance D (m) between the consignment on deck and the front surface of the accommodation can be calculated using a simple model as illustrated in Figure A2.1. When the total sum of transport indices is TI, then the dose rate at 1 m from the consignment surface is (10 TI) Sv/h. Assuming that the radiation source is a point source at the consignment surface, and using the inverse square law, the dose rate at point A (front surface of the accommodation, = 3 Sv/h) can be expressed as Equation A2.1. The basis of the table by simple calculations with acceptable assumptions was prepared by FCWG using Appendix III of SSG-26 (Rev.1). 10 ?? (1 ? )2 (? ? )2= 3 ( Sv/h) (Eq. A2.1) Thus, D can be calculated by following equation: FIG. A2.1 Calculation Model for Segregation Distance 10 3 ?? (m) (Eq. A2.2) ? = Using Equation A2.2 a set of segregation distance D can be obtained as in Table A.1 corresponding to the TIs of the consignment. The values concluded as round-ups of the calculated value. TRANSSC 46, 5-9 June 2023 in Table 7.1.4.5.18 are NMRI
Recent TRANSSC and the next step Two documents were considered and approved by the FCWG and TTEG-OM and submitted to the IAEA/TSU, but were not on the TRANSSC agenda. At TRANSSC44, the IMO and Japan made a request on this matter. They were uploaded to the TRANSSC45 website. However, at TRANSSC45 a plenary discussion focusing on the SSR-6 proposal was prioritized and there was no agenda item on this matter. TRANSSC46 is requested to approve the draft response to the IMO prepared by the FCWG (including the amendments proposed in this presentation). If approved, TRANSSC response will be submitted to IMO by the NMRI IAEA Secretariat. 11 TRANSSC 46, 5-9 June 2023
NMRI Thank you for your attention ... and the discussions will be continued. konnai@m.mpat.go.jp
