Review on the Possibility of Distinguishing Between "Packaging Container" and "Transport Container" in Domestic Nuclear Regulations

2019 ⦽ǎႊᔍᖒ⠱ʑྜྷ⦺⫭ ⇹ĥ⦺ᚁݡ⫭ םྙ᫵᧞Ḳ

197

Review on the Possibility of Distinguishing Between ³Packaging Container´ and

³Transport Container´ in Domestic Nuclear Regulations

1

Korea Nuclear Engineering & Service, 65, Myeongdal-ro, Seocho-gu, Seoul, Republic of Korea 2

KHNP Central Research Institute, 70, Yuseong-daero 1312beon-gil, Yuseong-gu, Daejeon, Republic of Korea *

mokim@kones21.com

1. Introduction

After permanent shutdown of the Kori unit 1, the transportation of mass-produced decommissioning waste has been being a pending issue. In Korea, the process of disposal of nuclear decommissioning or radioactive waste from the generator to the Gyeongju radioactive waste disposal facility has been classified into three stages of ³packaging´, ³transportation´ and ³disposal´, and the containers required for each stage are being developed. In this paper, ³packaging´ is distinguished from packaging of IAEA SSR-6 [1].

In Nuclear Safety Act [2], Enforcement Decree [3], Enforcement Regulations [4] and NSSC (Nuclear Safety and Security Commission) notices [5-6], there are no clear codes & standards for ³packaging container´, while code & standard for WKH³WUDQVSRUW FRQWDLQHU´ H[LVW )RU WKLV UHDVRQ WKHUH KDV EHHQ confusion about design criteria or requirements for the design of ³packaging container´ used in the field.

The authors investigated the nuclear regulations or design requirements for the design of ³packaging container´ and found that ³packaging container´ and ³transport container´ were not considered as separate concepts in domestic laws and notices. It was FRQFOXGHG WKDW ³WKH SDFNDJLQJ FRQWDLQHU´ and the ³transport container´ could not be distinguished in domestic codes and standards.

The purpose of this paper is to review the possibility of distinguishing between ³packaging´ and ³transport´ container based on domestic laws and notices. Therefore, in order to understand the meaning of the original text as it is, the domestic law and notices were captured via following website: http//www.law.go.kr and presented without being translated into English. In this paper, the provisions of Refs. [2-6] have been reviewed from the legal perspective and those of Regulations on the Technical Standards for Radiation Safety Control [7] were classified into technical aspects.

2. Review of Nuclear Regulations

2.1 Definition

In SSR-6 of IAEA and 10 CFR 71 [8] of NRC, package and packaging are similarly defined as follows: Package is defined as the product consisting of the packaging and its contents prepared for

transport, and packaging is defined as one or more receptacles or the assembly of components to perform containment and other safety functions.

The meanings of those defined in domestic NSSC notice No. 2017-56[5] are also similar with those in IAEA and NRC. As shown in Fig. 1, however, the terms that were intended to mean packaging (Hereinafter Clause 2 of Article 2 in [5] is referred as ³WUDQVSRUW FRQWDLQHU´ DQG SDFNDJH +HUHLQDIWHU &ODXVH  RI $UWLFOH  LQ >@ LV UHIHUUHG DV ³WUDQVSRUW SDFNDJH´ EXW FRXOG EH PLVLQWHUSUHWHG DV PHDQLQJ only for transport, were used. That is, the container for packaging radioactive contents is defined as a ³WUDQVSRUWFRQWDLQHU´

Fig. 1. Article 2 of NSSC notice No. 2017-56.

NSSC notice No. 2017-60 [6] GHILQHV ³SDFNDJH´ as containers containing waste to be delivered to RSHUDWRUVRIGLVSRVDOIDFLOLW\$OWKRXJK³+,&+LJK-,QWHJULW\ &RQWDLQHU´ LV FRQVLGHUHG DV RQH RI ³SDFNDJLQJ FRQWDLQHU´ QR GHILQLWLRQ RI ³SDFNDJLQJ FRQWDLQHU´ ZDV IRXQG LQ QRW RQO\ 5HI [6] but also other domestic law and regulations.

In the meantime, the US NRC TC [9] regulated that HIC must meet the requirements of Type A containers. In other words, it was stated that the HIC, ZKLFKLV³WKHSDFNDJLQJFRQWDLQHU´LQ5HI>@PXVW satisfy the transportation requirement of type A.

2.2 Review on the Legal Aspects

As shown in Fig. 2 and Fig. 3, Article 76 of the Atomic Energy Act, Article 112 of the Enforcement Decree, Article 98 and 104 of the Enforcement Regulations referred to the container for packaging RU WUDQVSRUWLQJ UDGLRDFWLYH PDWHULDOV DV ³WUDQVSRUW FRQWDLQHU´ ,Q RWKHU ZRUGV ³WKH WUDQVSRUW FRQWDLQHU´ LV QRW D FRQWDLQHU IRU RQO\ ³WUDQVSRUW´ EXW IRU ERWK ³SDFNDJLQJ´DQG³WUDQVSRUWDWLRQ´

198

2.3 Review on the Technical Aspects

As shown in Fig. 4, Article 90 of Ref. [7] refers to ³WKH UDGLRDFWLYH PDWHULDOV DQG LWV SDFNDJH´ DV ³WUDQVSRUWSDFNDJH´&ODXVHRI$UWLFOHLQ>@DQG classifies the type of package as L-type, IP type and $W\SH³WUDQVSRUWSDFNDJH´

Fig. 4. Article 90 of Ref [7].

As shown in Fig. 5, Article 96 of Ref. [7] regulates WKDW WKH ³SDFNDJH´ VKRXOG FRQIRUP WR WKH GHVLJQ VWDQGDUGVRI³WUDQVSRUWSDFNDJH´VDPe as package in SSR-6). That is, the design requirements of the ³SDFNDJH´LVWKHVDPHDVWKDWRI³WUDQVSRUWSDFNDJH´

Fig. 5. Article 96 of Ref [7].

As shown in Fig. 6, Article 115 of Ref. [7] stipulates that the type L - ³WUDQVSRUWSDFNDJH´W\SH L SDFNDJH VKRXOG FRQIRUP WR ³WKH SDFNDJLQJ VWDQGDUG´EXWWKHFRUUHVSRQGLQJ³SDFNDJLQJVWDQGDUG´ LVLGHQWLFDOWRWKHWHFKQLFDOVWDQGDUGRI³WKHWUDQVSRUW FRQWDLQHU´ 7KDW LV WKH UHJXODWRU\ VWDQGDUG IRU ³SDFNDJLQJ´DQG³WUDQVSRUWDWLRQ´DUHWKHVDPH

Fig. 6. Article 115 of Ref [7].

3. Conclusion

In this study, the provisions of the Korean Nuclear Regulatory Act (Safety Act, Enforcement Decree, and Enforcement Regulations) and NSSC Notices were reviewed.

In the domestic code & standard system, ³SDFNDJLQJ FRQWDLQHU´ ZDV QRW GHILQHG VHSDUDWHO\ and no legal or technical basis was found to distinguishbetween³SDFNDJLQJ´DQG³WUDQVSRUWDWLRQ´

Rather, it was confirmed that the same technical standards were applied to ³SDFNDJLQJ´ and ³WUDQVSRUWDWLRQ´ in Ref. [5].

Internationally, containers for the purpose of packing and transporting radioactive materials were defined as packaging, and no distinguishing GLIIHUHQFH EHWZHHQ ³WUDQVSRUW FRQWDLQHU´ DQG ³SDFNDJLQJFRQWDLQHU´ZDVIRXQGVHSDUDWHO\

IntrinsicaOO\ ³SDFNDJHV´ DQG ³WUDQVSRUW SDFNDJH´ in domestic law and regulations have the same concept. Both of them mean package of IAEA and 15& DQG ³WUDQVSRUW FRQWDLQHU´ PHDQV SDFNDJLQJ RI IAEA and NRC.

,I WKH VHSDUDWLRQ EHWZHHQ ³SDFNDJLQJ FRQWDLQHU´ DQG ³WUDQVSRUW FRQWDLQHU´ LV QHHGHG QHZ WHFKQLFDO VWDQGDUG IRU ³SDFNDJLQJ FRQWDLQHU´ VKRXOG EH required.

ACKNOWLEDGEMENT

This work was supported by the Korea Institute of Energy Technology Evaluation and Planning (KETEP) granted fund by MOTIE, Republic of Korea (No.20181510300870).

REFERENCES

>@ ,$($ ³5HJXODWLRQV IRU WKH 6DIH 7UDQVSRUWDWLRQ Materials, IAEA SSR-6, Rev. 1, (2018).

[2] Nuclear Safety Act, Act No. 15281, June.20,2018. [3] Enforcement Decree for Nuclear Safety Act,

Presidential Decree No.28987, June.20, 2018. [4] Enforcement Regulations for Nuclear Safety Act,

Prime Minister Regulation No.1459, June.20, 2018.

>@ 166& ³5HJXODWLRQV IRU 3DFNDJLQJ DQG 7UDQVSRUWDWLRQ RI 5DGLRDFWLYH 0DWHULDO´ 1R 2017-56 (2017).

>@166&³5HJXODWLRQVIRUWKHGHOLYHU\RI Low and ,QWHUPHGLDWH /HYHO 5DGLRDFWLYH :DVWH´ 1R 2017-60 (2017).

>@ 166& ³5HJXODWLRQV RQ WKH 7HFKQLFDO 6WDQGDUGV IRU5DGLDWLRQ6DIHW\&RQWURO´1R-20 (2018). >@  &)5  ³3DFNDJLQJ DQG 7UDQVSRUWDWLRQ RI

5DGLRDFWLYH0DWHULDO´15&-DQ [9] US NRC Waste Form TP, Jan. 1991.