Radioactive Waste – Transfer to Shore | OEUK Environmental Legislation

Radioactive Waste – Transfer to Shore

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Key Legislation:

For more detail on the Legislation relevant to this page, please use the following links:

Main UK Legislation
Radioactive Substances Legislation

Guidance:

HSE Offshore Safety Division Operations Notice 4 – Radioactive Substances Act 1993 Special Waste Explanatory Note 019 – Radioactive Waste Managing the use and disposal of radioactive and nuclear substances and waste
PARCOM Recommendation 94/8 Concerning Environmental Impact Resulting from Discharges of Radioactive Substances – In the meeting of the Oslo and Paris Commissions on 20 June 1991; agreement was made to renounce the possibility of resuming dumping at sea of radioactive substances, including waste. This Recommendation superseded the Recommendations on radioactive discharges made by the Paris Commission in 1990 (Recommendation 90/3), and in 1988 (Recommendation 88/5).
PARCOM Recommendation 91/4 on Radioactive Discharges – These regulations implement provisions for the transport of radioactive substances in certain circumstances to require prior authorization, in accordance with Directive 2013/59/EURATOM. They also set out the necessary requirements when shipping radioactive substances, such as the declarations which should be filled out under Annex I and Annex II of these regulations.

Use of Registered Carrier:	The Duty of Care makes it the waste producer’s (consignor’s) responsibility to ensure that waste is only transferred to an appropriately licensed carrier, carrying an appropriate approval certificate issued under the Radioactive Material (Road Transport) Regulations. The Carrier must also display the appropriate identification marks on the vehicle. If waste is also classified as Special or Hazardous Waste due to its characteristics (e.g. toxicity), Special Waste/Hazardous Regulations will also apply (see Transfer of Special/Hazardous Waste and SWEN 019 (PDF document)).
Transport of Waste from Offshore:	If the waste is being transferred from offshore, the Road Transport Regulations do not apply to the transfer vessel, but will apply once this waste is transferred onshore. Vessels carrying radioactive materials must comply with the Merchant Shipping Regulations and stow and label goods in accordance with the International Maritime Dangerous Goods (IMDG) Code. The ship’s manifest must also detail all the dangerous goods being carried. Note: Transport of some radioactive material is exempt from registration under RSA93 (e.g. closed sources).
Consignor and Carrier Responsibilities:	The Consignor must ensure the following: That each package is correctly marked and labelled That freight containers are carrying appropriate placards Provide required information in the transport documents, including consignor name and address, the UN Number of the radioactive material, the name or symbol of each radionuclide, description of the physical and chemical form of the material, maximum radioactive activity, package category and transport index (as per the Regulations) Provide information to the carrier on any actions required, e.g. supplementary requirements for loading, stowage and handling and any emergency arrangements Notify the competent authority before the first shipment Retain copies of the certificate of approvals and a copy of the instructions regarding packaging and shipment preparation The Carrier also has a number of responsibilities under the Regulations, in particular: Correct segregation and stowage of packages during transport and in storage when in transit If a consignment is undeliverable, the consignment must be placed in a safe location and the DfT/HSE informed as appropriate Carry appropriate fire fighting equipment
How to Apply:	In writing to appropriate competent authority.
Who to Apply To:	DfT, HSE
When to Apply:	Before transfer of radioactive waste.

Safe Transport:

The Radioactive Material (Road Transport) Regulations put in place a system to ensure safe carriage of radioactive material by road. Similar controls are in place for transport by rail. The Regulations require carriers to be authorised by DfT/HSE and set out packaging/stowage requirements for different types of radioactive material. Specific requirements are given for LSA.

None.

Records to be Kept:

The consignor of any consignment must retain any information regarding measurements of contamination of that consignment for a period of not less than 2 years. In addition information on packaging used must also be retained.

Inspections:	N/A
Non-compliance:	Non-compliance with the Regulations is an offence liable to a financial penalty or term of imprisonment.

Renewal of Permit:

N/A – A consignment certificate must be issued for each transfer.

If the same packaging/radioactive contents is/are consigned as a package on a regular basis by the same consignor, who is also the carrier of that package, a regular consignment certificate may be issued.

Committee on Radioactive Waste Management (CRWM) Triennial Review 2015	The government has published the findings of the review which concluded that CoRWM should continue in its role as an advisory Non-Departmental Public Body (NDPB) providing independent advice, based on the available evidence (link here).
CAA: Dangerous Goods Radiation Programme	The Civil Aviation Authority has announced that all radioactive cargo must be subject to a Radiation Protection Programme. Oil and gas operators wishing to transport radioactive material should have a dangerous goods approval and permit.