Health and Safety
Executive / Commission
Regulatory Impact Assessments: Radiation
1. This assessment looks at the practical impact of adopting the new requirements of the International Atomic Energy Agency's Safety Series 6 (IAEA:SS6) into UK law. SS6 forms the basis of rules concerning the transport by all modes of radioactive material. This will be done by an early amendment to HSE's existing regulations (RAMRail), following an agreement with a subcommittee of the IAEA. The regulations will then be consolidated along with some ten other statutory instruments at a later date.
2. The safety risks arising from carriage of radioactive material are already very low. When assessing previous regulations, it was found that in the five years to 1996, there were only two reportable dangerous incidents involving the carriage of radioactive material by rail, and it was thought unlikely at the time that the existing regulations could have prevented either of these. There have been no significant incidents in recent years. In addition, standards of compliance and expertise are very high throughout the industry, and are now aided by the statutory appointment of Dangerous Goods Safety Advisers.
3. The objective of the amendments is to improve the regime for the transportation of radioactive material, taking into account certain practical problems with the existing regulatory framework, and recent technological advances.
4. The UK is obliged to implement RID requirements. The only option available would have been not to implement the changes early, and hence to contradict the agreement with the IAEA. This would have brought no additional benefit, whilst leading to potential policy difficulties.
5. This initial assessment draws on three information sources. Firstly, the EU commissioned a study of the practical implications of the adoption of new exemption values in transport. This research was conducted by the Centre D'Etude Sur L'Evaluation de la Protection dans le Domain Nucleaire (the CEPN report), and included a case study of the United Kingdom, France and Germany. Secondly, the HSE commissioned Scientifics to advise on the extent and technical reasons for the changes (the Scientifics report).
6. Finally, HSE initially carried out some limited consultation with the industry on the practical implications of the changes, and respondents were asked to comment on specific areas during consultation. Three responses were received specifically on costs and benefits. A major consignor agreed with the broad conclusions that the longer term benefits could be expected to outweigh costs. Another major consignor thought that the cost estimates were not unreasonable, but noted some costs were difficult to separate from costs concerning other transport modes. A government agency thought that increased clarity and consistency could bring environmental benefits through reduced incidents (although incidents are very rare, the environmental effect of the regulations will be positive).
7. The changes will act improve safety standards generally, which are already very high.
8. The real benefit of the amendments is in greater clarity for those dealing with radioactive goods. In particular, placarding, indexing and numbering has been simplified or replaced so that the new system will be of greater benefit to transporters, and those responding in an emergency situation. In addition, a series of schedules will provide requirements for the transport of specific types of consignments.
9. All organisations who transport radioactive material are potentially affected by the changes. There is no reliable statistical information about the scale of the carriage of radioactive materials by rail. However, the number of organisations who are involved in the packaging, preparation and carriage of radioactive materials by rail was estimated to be around 50 in the mid 1990s and has since decreased. The main carriers of radioactive material by rail are English and Scottish and Welsh Railways (EWS), Freightliner, Direct Rail Services (which is a subsidiary of BNFL involved exclusively in transporting nuclear fuel) , and the Ministry of Defence.
10. Potential effects are considered below in two parts. Firstly, the new requirements are looked at on a case by case basis, using the Scientifics report and industry advice. Secondly, the effect of new exemption values and the new definition of a radioactive material are considered separately following the CEPN Study.
11. Existing placarding will have to be altered to reflect the new UN numbers. In addition, existing computer software will have to be reprogrammed to include the new numbers. This latter change is a one-off administration cost which is expected to be modest.
12. Changes in placarding are discussed below. The additional cost implications of the change in numbering were thought by both a major rail carrier and Scientifics to be negligible.
13. A new label has been introduced for packages, overpacks and freight containers carrying non-excepted fissile materials. This will now need to show the value of the `critical safety index', CSI, which is a number used to control the accumulation of packages. For rail carriage - including tank wagons - placards need to be placed on the two external lateral walls of the vehicles or container, and not on the ends.
14. This will introduce a small cost to the majority of carriers. Replacement plates will typically cost around £10 each, however their will be no additional cost of fitment once they have been purchased. We do not know how many movements of radioactive material involving rail there are annually. Around 5% (at most) of all rail good movements are thought to involve dangerous goods. Only a very small proportion, possibly 5% again, of these would involve radioactive material. This would indicate a total of around 100,000 train miles of carriage, representing something like 2,000 train movements involving radioactive material, given an average journey length of fifty miles. Even if all these journeys are affected, this would indicate a total industry cost of no more than 2,000 * £20 = £40,000. These figures are for illustration only, lacking detailed information on the number of rail freight movements on a national scale.
15. Stowage and segregation requirements relating to fissile material carried along with other radioactive material have been introduced. However, the only fissile material carried on the UK rail system is nuclear fuel, which is carried on dedicated containers and on dedicated trains (ie not alongside any other material).
16. More stringent requirements have been introduced for packages containing UF6. The main UK rail freight carrier, who we believe are the most likely organisation to be involved in carrying this material, were contacted and reported no additional cost. No further costs were reported by other organisations during formal consultation.
17. For radioactive materials in excepted packages, any other hazardous properties will now take precedence and the material and packaging will have to be treated accordingly. This means that some low level radioactive materials will effectively need to be re-packed and transported as other dangerous goods (according to their class). We believe the effect of this change will be extremely limited. No comments were received during formal consultation, which would appear to confirm this view.
18. This new, stronger, class of package will be required to be used when transporting radioactive goods by air. Additional costs may arise of some of these packages are then moved from air directly to rail, however industry advise that there are no cases where this is done in the UK.
19. The new regulations will include a minor change to the definition of a freight container. Scientifics advised that this would have no practical effect in the UK.
20. The CEPN report contained a detailed analysis of the impact of the new requirements on materials transported in the UK. The report found that the majority of materials possibly under scope of the new requirements will be unaffected either because they are not classed as radioactive under existing regulations and will still not be classed as radioactive under the new regulations, or they were considered radioactive and will continue to be so.
21. Mineral ores examined and not found to be affected because of low activity rates included coal, clay and other building materials, phosphorous and potash. Products containing these minerals, such as fertilisers, will also be exempt. However, some materials (and products) could be affected, particularly those containing relatively large amounts of Thorium. These are as follows.
22. These materials may contain high levels of Thorium isotopes and hence may exceed the activity concentration of that isotope for an exempt material for natural radiation, if they are transported in sufficient quantities. These materials are normally imported by ship in quantities of 5 to 10 metric tonnes and then transported by lorries. We do not know if any of these materials are moved by rail, and none were reported during formal consultation. However, if the activity limit for the isotope is exceeded (10 Bq/g), then the material will be classed as radioactive, since the amount of material that would normally be moved by rail (if any) would certainly exceed the quantity exemption (which is typically 5-10 kg).
23. Some of these products may be affected by the new exemption limits, however both the raw material, or the imported products, are currently imported by ship and transferred to the manufacturer or retailer by road.
24. The UK Lighting Federation and individual companies reported that they do not anticipate any of their members being affected.
25. In general, other products will either continue to be exempt, or continue to be classified as radioactive material. In any case, normal industry practice is to transport these products by road. These are specialist (and often delicate) products, which would not be moved in bulk transport by rail
26. About 200 metric tonnes of radioactive scale is removed from oil and gas pipework (including pumps, valves etc) by onshore specialists. The pipework is shipped on shore and moved by road to the descaling plant. We are not aware of any movements of these materials by rail, and none were reported during consultation. In any case much of this material will either continue to be exempt, or continue to be classified as radioactive material.
27. These materials are moved (both between hospitals, or to disposal sites) exclusively in relatively small amounts by road.
28. Staff dealing with the transport of radioactive material by rail will need to be briefed on the new regulations. EWS, who are the UK's largest rail freight company, report that additional staff training had already been rolled out gradually and integrated in the company's routine briefings to staff. It is also unlikely that `dedicated' training will be required for other organisations. The additional training costs associated with the regulations is therefore very limited.
29. Whilst the changes made to the new IAEA Regulations are intended to improve the regime for the transport of radioactive, the intention was not to radically alter a regime that has worked very well.
30. The only cost implications of these proposals to the UK rail industry are in the re-placarding of materials already classed as radioactive (and associated changes to computer software), and possibly in specialist ores that could be newly classed as radioactive. Replacarding costs, for all radioactive materials, will be in the order of £40,000 per year. Total costs, including training and software changes, are unlikely to exceed £100,000.
31. There are no SMEs involved in the carriage of radioactive material by rail.
32. There is a small ongoing cost in developing the regulations, also incurred by other enforcing authorities. There will also be a small cost in briefing inspectors in the field. These costs are very modest, and are not expected to exceed £50,000.
33. None.
34. None, other than the safety aspects already discussed.
35. The costs of the changes are very small, and will probably be less than £100,000 in total to the industry. However, the long-term benefits of the new system are highly likely to outweigh these one-off costs.
Contact
Geoff Lloyd
SPD A3
5 SW
Rose Court, HSE.
geoff.lloyd@hse.gsi.gov.uk
Added to HSE website 14 August 2002