STI/PUB/1203

Appraisal for Turkey of the

Safety of the Transport of

Radioactive Material

IAEA Safety Standards Applications — TranSAS-4

Provision for the Application of the IAEA Safety Standards

IAEA SAFETY RELATED PUBLICATIONS

IAEA SAFETY STANDARDS

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APPRAISAL FOR TURKEY

OF THE SAFETY

OF THE TRANSPORT

OF RADIOACTIVE MATERIAL

The following States are Members of the International Atomic Energy Agency:

The Agency’s Statute was approved on 23 October 1956 by the Conference on the Statute of

the IAEA held at United Nations Headquarters, New York; it entered into force on 29 July 1957.

The Headquarters of the Agency are situated in Vienna. Its principal objective is “to accelerate and

enlarge the contribution of atomic energy to peace, health and prosperity throughout the world’’.

Permission to reproduce or translate the information contained in this publication may be

obtained by writing to the International Atomic Energy Agency, Wagramer Strasse 5, P.O. Box 100,

A-1400 Vienna, Austria.

Printed by the IAEA in Austria

August 2004

STI/PUB/1203

AFGHANISTAN

ALBANIA

ALGERIA

ANGOLA

ARGENTINA

ARMENIA

AUSTRALIA

AUSTRIA

AZERBAIJAN

BANGLADESH

BELARUS

BELGIUM

BENIN

BOLIVIA

BOSNIA AND HERZEGOVINA

BOTSWANA

BRAZIL

BULGARIA

BURKINA FASO

CAMEROON

CANADA

CENTRAL AFRICAN

REPUBLIC

CHILE

CHINA

COLOMBIA

COSTA RICA

CÔTE D’IVOIRE

CROATIA

CUBA

CYPRUS

CZECH REPUBLIC

DEMOCRATIC REPUBLIC

OF THE CONGO

DENMARK

DOMINICAN REPUBLIC

ECUADOR

EGYPT

EL SALVADOR

ERITREA

ESTONIA

ETHIOPIA

FINLAND

FRANCE

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GERMANY

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HONDURAS

HUNGARY

ICELAND

INDIA

INDONESIA

IRAN, ISLAMIC REPUBLIC OF

IRAQ

IRELAND

ISRAEL

ITALY

JAMAICA

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JORDAN

KAZAKHSTAN

KENYA

KOREA, REPUBLIC OF

KUWAIT

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LIBERIA

LIBYAN ARAB JAMAHIRIYA

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PHILIPPINES

POLAND

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SEYCHELLES

SIERRA LEONE

SINGAPORE

SLOVAKIA

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SOUTH AFRICA

SPAIN

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SUDAN

SWEDEN

SWITZERLAND

SYRIAN ARAB REPUBLIC

TAJIKISTAN

THAILAND

THE FORMER YUGOSLAV

REPUBLIC OF MACEDONIA

TUNISIA

TURKEY

UGANDA

UKRAINE

UNITED ARAB EMIRATES

UNITED KINGDOM OF

GREAT BRITAIN AND

NORTHERN IRELAND

UNITED REPUBLIC

OF TANZANIA

UNITED STATES OF AMERICA

URUGUAY

UZBEKISTAN

VENEZUELA

VIETNAM

YEMEN

ZAMBIA

ZIMBABWE

APPRAISAL FOR TURKEY

OF THE SAFETY

OF THE TRANSPORT

OF RADIOACTIVE MATERIAL

INTERNATIONAL ATOMIC ENERGY AGENCY

VIENNA, 2004

IAEA SAFETY STANDARDS APPLICATIONS — TRANSAS-4

IAEA Library Cataloguing in Publication Data

Appraisal for Turkey of the safety of the transport of radioactive material.

— Vienna : International Atomic Energy Agency, 2004.

p. ; 24 cm. — (Safety standards applications, ISSN 1684–7520 ;

TranSAS-4)

(Provision for the application of the IAEA safety standards)

ISBN 92–0–109804–9

Includes bibliographical references.

1. Radioactive substances — Transportation — Turkey.

2. Radioactive substances — Safety regulations — Turkey.

I. International Atomic Energy Agency. II. Series.

IAEAL 04–00374

FOREWORD

Within the family of the United Nations, the IAEA has the specific

statutory function of establishing standards of safety for the protection of

health against exposure to ionizing radiation. As a result, in 1959 the United

Nations Economic and Social Council requested that the IAEA be entrusted

with the drafting of recommendations on the transport of radioactive

substances. Within its statutory mandate and pursuant to this request, in 1961

the IAEA issued the Regulations for the Safe Transport of Radioactive

Material (the Transport Regulations). The Transport Regulations have been

periodically reviewed and, as appropriate, amended or revised. Moreover,

several guides and technical documents supporting the Transport Regulations

have been issued by the IAEA. The latest version of the Transport Regulations

was issued in 2000 by the IAEA as Safety Series No. TS-R-1 (ST-1, Revised).

On 25 September 1998 the IAEA General Conference adopted

resolution GC(42)/RES/13 on the Safety of Transport of Radioactive Materials.

In adopting that resolution the General Conference recognized that

“compliance with regulations which take account of the Agency’s Transport

Regulations is providing a high level of safety during the transport of radioactive

materials…”

The IAEA’s Statute also authorizes it to provide for the application of its

standards at the request of any State. The IAEA discharges this statutory

function through a number of mechanisms, including rendering independent

peer review appraisal services to determine the status of compliance with its

standards. Consistent with this statutory function, resolution GC(42)/RES/13

requested the IAEA Secretariat to provide for the application of the Transport

Regulations by, inter alia, providing a service for carrying out, at the request of

any State, an appraisal of the implementation of the Transport Regulations by

that State.

In response to this request, on 10 December 1998 the IAEA offered to

render such an appraisal service to all States. The service was termed the

Transport Safety Appraisal Service (TranSAS). Since then the IAEA General

Conference, through resolutions GC(43)/RES/11, GC(44)/RES/17, GC(45)/

RES/10, GC(46)/RES/9 and GC(47)/RES/7, has commended the Secretariat

for establishing TranSAS, commended those Member States that had

requested an appraisal, and encouraged other Member States to avail

themselves of an appraisal.

On 12 September 2000 the Permanent Mission of Turkey to the Office of

the United Nations and other International Organizations informed the IAEA

that the Turkish Atomic Energy Authority had decided to request a TranSAS

appraisal. To lay the groundwork for the appraisal, a preparatory mission was

undertaken in October 2001. At that time a preliminary agreement was

reached on the scope of the appraisal as well as on the tasks and activities to be

undertaken prior to and during the appraisal. Owing to the difficulty in

obtaining funding for the appraisal, the actual appraisal, initially planned for

May 2002, was postponed until March 2003.

The IAEA Department of Technical Cooperation provided support for

this TranSAS appraisal under project number TUR/9/013.

The TranSAS appraisal for Turkey involved four independent experts

from the IAEA and Member States of the IAEA and was conducted between

3 and 14 March 2003. This report presents its findings.

EDITORIAL NOTE

Although great care has been taken to maintain the accuracy of information

contained in this publication, neither the IAEA nor its Member States assume any

responsibility for consequences which may arise from its use.

The use of particular designations of countries or territories does not imply any

judgement by the publisher, the IAEA, as to the legal status of such countries or territories,

of their authorities and institutions or of the delimitation of their boundaries.

The mention of names of specific companies or products (whether or not indicated

as registered) does not imply any intention to infringe proprietary rights, nor should it be

construed as an endorsement or recommendation on the part of the IAEA.

CONTENTS

SUMMARY, FINDINGS AND CONCLUSIONS . . . . . . . . . . . . . . . . . . . 1

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Findings of the TranSAS appraisal for Turkey . . . . . . . . . . . . . . . . . . 3

General conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Request from Turkey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Scope of the appraisal for Turkey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Activities completed prior to the appraisal . . . . . . . . . . . . . . . . . . . . . 11

Appraisal team . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Appraisal process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Appraisal report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

2. DOCUMENTS RELEVANT FOR THE

TRANSAS APPRAISAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

IAEA safety standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

International regulatory documents and standards . . . . . . . . . . . . . . 15

3. APPRAISAL PROCESS IN TURKEY . . . . . . . . . . . . . . . . . . . . . . . 16

Overview of the appraisal process . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Preparatory session . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Entrance meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Interviews, updating the questionnaire and developing the report. . 18

Visit to the Çekmece Nuclear Research and Training Centre . . . . . 18

Exit meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

4. APPRAISAL OF THE IMPLEMENTATION

OF THE TRANSPORT REGULATIONS IN TURKEY . . . . . . . . 19

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Legislative and governmental responsibilities . . . . . . . . . . . . . . . . . . . 20

Authority, responsibilities and functions of the regulatory body . . . 30

Organization of the regulatory body . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Authorization process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Review and assessment process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Inspection and enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Development of regulations and guides . . . . . . . . . . . . . . . . . . . . . . . 46

Emergency preparedness for transport. . . . . . . . . . . . . . . . . . . . . . . . . 49

5. GENERAL CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

APPENDIX I: ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

APPENDIX II: THE TURKEY TRANSPORT SAFETY

APPRAISAL SERVICE TEAM . . . . . . . . . . . . . . . . . . . 54

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

SUMMARY, FINDINGS AND CONCLUSIONS

SUMMARY

Background

S01. On 25 September 1998, the General Conference of the IAEA adopted

resolution GC(42)/RES/13 on the Safety of Transport of Radioactive Materials.

The General Conference recognized in adopting that resolution, inter alia, that

compliance with regulations that take account of the IAEA’s Regulations for

the Safe Transport of Radioactive Material (the Transport Regulations) is

providing a high level of safety during the transport of radioactive material. In

addition, it requested the IAEA Secretariat to provide for the application of

the Transport Regulations by, inter alia, providing a service for carrying out, at

the request of any State, an appraisal of the implementation of the Transport

Regulations by that State. In response to this request the IAEA has created

and made available to all States the Transport Safety Appraisal Service

(TranSAS).

S02. The objective of a TranSAS appraisal is to assist any requesting State to

achieve a high level of safety in the transport of radioactive material by

reviewing its implementation of the Transport Regulations and by making

recommendations for improvement where appropriate.

S03. In a letter dated 12 September 2000 the Permanent Mission of Turkey to

the Office of the United Nations and other International Organizations in

Vienna informed the IAEA that the Turkish Atomic Energy Authority

(TAEK) had decided to request the IAEA Transport Safety Appraisal Service.

To lay the groundwork for the appraisal, a preparatory mission was undertaken

from 1 to 5 October 2001. At that time a preliminary agreement was developed

addressing the scope of the appraisal as well as the tasks and activities to be

undertaken prior to and during the appraisal. Owing to the difficulty in

obtaining funding for the appraisal, the actual appraisal, initially planned for

May 2002, was postponed until March 2003.

Scope of the appraisal

S04. A TranSAS appraisal covers all modes of transport (i.e. road, rail,

maritime and air). In accordance with the request from Turkey, the appraisal

considered in detail all relevant aspects of the regulation of the transport of

radioactive material in Turkey with regard to the requirements specified in the

Transport Regulations [1], the guidance provided in other IAEA publications

[2–5] and other relevant international regulatory documents.

TranSAS questionnaire

S05. A detailed TranSAS questionnaire was developed by the IAEA in 1999

in order to facilitate the appraisal process in a consistent manner. The question-

naire has detailed questions in the following eight key areas:

(a) Legislative and governmental responsibilities;

(b) The authority, responsibilities and function of the regulatory body;

(d) The authorization process;

(e) Review and assessment;

(f) Inspection and enforcement;

(g) The development of regulations and guides;

(h) Emergency preparedness for transport.

The completed TranSAS questionnaire is a working document for the appraisal

and may be used by representatives of the host organization to prepare for

interviews and to develop presentations.

Tasks and activities prior to the appraisal

S06. Turkey provided the IAEA with a completed TranSAS questionnaire.

The IAEA assembled a team of experts for the appraisal, the members of

which were subject to approval by Turkey. The approved experts were provided

with guidelines for the appraisal, information from the preparatory mission and

the completed TranSAS questionnaire submitted by Turkey.

Appraisal team

S07. The team for the TranSAS appraisal was composed of four independent

experts. The members of the team represented regulatory authorities

responsible for the transport of radioactive material in three States and were

led by a transport safety expert from the IAEA.

Appraisal process

S08. The appraisal process included the following:

(a) A preparatory session for the appraisal team;

(b) An entrance meeting involving presentations by key representatives

from the TAEK and other authorities concerning their responsibilities

for the safe transport of radioactive material;

additional or more detailed information;

(d) Updating the TranSAS questionnaire and preparing the draft report

with findings;

(e) Ongoing feedback on the updated questionnaire and the draft report

with findings;

(f) A visit to the Çekmece Nuclear Research and Training Centre

(ÇNAEM);

(g) Visits to the Turkish Airlines cargo departments at the Ankara

Esenboga airport and the Istanbul Ataturk airport;

(h) An exit meeting to present and discuss the findings.

Appraisal report

S09. The appraisal report provides background information on TranSAS in

general as well as more detailed information on the appraisal process in the

host country. It also presents the findings for each area considered in the

appraisal, together with a background discussion and a basis for any finding

(tied to an international regulatory requirement or recommendation). The

findings are presented as recommendations, suggestions and good practices.

FINDINGS OF THE TRANSAS APPRAISAL FOR TURKEY

S10. Background information and the basis for the findings are presented

together with the findings in Section 4 of this report. Each finding has a basis in

the Transport Regulations, in the modal international regulations and/or in

other relevant international regulatory documents and standards.

S11. The findings for each key area of review are presented in the order in

which they appear in Section 4 of this report.

S12. The findings of the appraisal include three recommendations and 17

suggestions for areas in which the implementation of the Transport Regulations

can be streamlined or improved. The appraisal also identified three good

practices that can serve as a model for other competent authorities in the

radioactive material transport sector to emulate.

S13. The findings are presented for the eight key areas of review in the

TranSAS questionnaire and are followed by the general conclusions.

S14. General conclusions concerning the findings are also presented in

Section 5 of this report.

Legislative and governmental responsibilities

S15. Recommendation: The process of formalizing the draft Turkish

regulation on the safe transport of radioactive material should be completed as

soon as possible.

S16. Suggestion: It is suggested that in the areas of overlapping responsibil-

ities, memoranda of understanding be developed between the authorities

involved.

Authority, responsibilities and functions of the regulatory body

S17. Suggestion: It is suggested that memoranda of understanding be

prepared to manage interfaces between the different authorities involved in the

transport of radioactive material. Such memoranda of understanding would

detail the procedures to be followed in the authorization process and might

include provisions for the training of personnel in radiation safety, as well as

provisions regarding inspection and enforcement.

S18. Suggestion: Cooperation agreements between the different parties

involved could help to achieve harmonization of the applicable national and

international regulations for the transport of dangerous goods by different

modes.

S19. Suggestion: It is suggested that the regulatory functions be more clearly

separated from the operational and promotional functions. This separation

would be evident from the organizational chart.

S20. Suggestion: In order to clarify the duties and responsibilities of the

specialized departments and the affiliated institutions in accordance with the

Turkish Atomic Energy Authority Act, it might be envisaged to set up a section

of the Radiation Health and Safety Department (RHSD) in Istanbul. This

section would carry out the work actually done by the Health Physics

Department of ÇNAEM. As an alternative, part of the Health Physics Division

of ÇNAEM would continue to carry out the work but would formally become

part of the RHSD.

Organization of the regulatory body

S21. Suggestion: In order to make the organization more transparent, it

might be envisaged that a specific division be set up within the RHSD to deal

specifically with all transport issues. The personnel of this division would be

given the opportunity to increase their expertise in order to be able to perform

the necessary assessments.

Authorization process

S22. Suggestion: It might be envisaged to replace the system of individual

permission by a more generalized system of prior notification (as applies, for

example, to movements of radioactive sources for industrial radiography),

giving the TAEK the opportunity to perform more specific inspections to verify

compliance with the Turkish regulation on the safe transport of radioactive

material.

S23. Suggestion: It is suggested that a specific division be set up within the

RHSD dedicated specifically to the transport of radioactive material, in

particular the evaluation of applications for approval, as mentioned in para.

802 of the 1996 edition of the Transport Regulations, which are not necessarily

related to a specific use of the radioactive contents. The personnel of this

division would be given the opportunity to improve their expertise in order to

be able to perform the necessary assessments. This division would also inform

the different divisions of changes in the regulations and ensure coordination

between the different divisions with regard to transport issues, and ensure in

particular that applications for licences and permits are handled in a consistent

way.

S24. Good practice: A database with information on the use, storage and

movement of radioactive material in Turkey is updated on a continuous basis.

The system is comprehensive and a well established practical tool for everyday

work. It might also be used for more specific inspections.

Review and assessment process

S25. Recommendation: It should be ensured that the consignor has a copy of

the instructions, as required in para. 561 of the 1996 edition of the Transport

Regulations.

S26. Suggestion: As more packages become eligible for multilateral approval

with the introduction of the 1996 edition of the Transport Regulations, and in

particular pursuant to paras 816 and 817, some thought could be given to the

desirability of a formal assessment of designs of packages in this category and

of issuing a validation approval.

S27. Suggestion: It is suggested that checks be made that certified packages

have been maintained in accordance with the approved maintenance

instructions.

S28. Good practice: Overall control is exercised over radioactive material in

Turkey. This overall control includes transport aspects and therefore ensures

that packages that normally do not require competent authority certification

under the Transport Regulations (i.e. Type IP and Type A packages) are also

checked.

Inspection and enforcement

S29. Recommendation: A planned and systematic programme should be

implemented for quality assurance and compliance assurance concerning the

inspection and audit of packages, as required in paras 310 and 311 of the 1996

edition of the Transport Regulations.

S30. Suggestion: It is suggested that paperwork be completed in SI units and

that measuring instruments also display SI units. This will avoid confusion and

misinterpretation and will ensure consistency.

S31. Suggestion: It is suggested that memoranda of understanding be

produced to determine the responsibilities and interfaces between the various

authorities involved in the inspection and enforcement activities carried out in

support of authorizations for the transport of radioactive material.

Development of regulations and guides

S32. Suggestion: In order to avoid discrepancies between the implemen-

tation of the various editions of the Transport Regulations (and potential safety

hazards), it is suggested to simultaneously apply in Turkey the same regulations

for the national and international transport of radioactive material (i.e. to

formally promulgate the Turkish translation of the 1996 edition of the

Transport Regulations as soon as possible).

S33. Suggestion: It is suggested to change Article 61 of the radiation safety

regulation so that authorizations are issued in a more generic way, for example

to issue permits covering the same material in the same package, for a given

time frame (e.g. 6 months or 12 months).

S34. Suggestion: It is suggested for the ongoing revision of the radiation

safety decree to use only SI units, so as to be in line with the international

regulations in the field of radiation protection, especially with the Transport

Regulations and the Turkish radiation safety regulation.

S35. Suggestion: In order to be in line with the other international standards

for radiation safety and radiation protection (e.g. the International Basic Safety

Standards for Protection against Ionizing Radiation and for the Safety of

Radiation Sources), it is suggested that the transport of radioactive material be

incorporated into the radiation safety decree.

S36. Suggestion: It is suggested that expanded responsibilities may justify the

creation of a separate division within the RHSD that would be dedicated

exclusively to the transport of radioactive material.

Emergency preparedness for transport

S37. Good practice: The emergency capabilities for the transport of

radioactive material have been incorporated into the overall emergency

preparedness structure across the country. The regulations of Turkey in the

area of the transport of radioactive material, and the nuclear and radiological

emergency plan, which is updated by the TAEK every year, are a good basis for

emergency response, which also extends to the transport area.

GENERAL CONCLUSIONS

S38. The TranSAS appraisal team completed a thorough appraisal of the

implementation of the Transport Regulations in Turkey. The cooperation of the

Turkish authorities, and of all those who participated in the discussions, was

excellent and contributed much to the value of the appraisal.

S39. The transport of the relatively small number of packages of radioactive

material in Turkey is well controlled. Customs regulations specify permission of

the TAEK for the import of radioactive material. Only companies licensed by

the TAEK can import, export, transit and transport radioactive material. Each

shipment of radioactive material is subject to a permit from the TAEK. A

comprehensive database with information on the use, storage and movement of

radioactive material is updated on a continuous basis. This high level of control

and monitoring enhances the safety of the transport of radioactive material in

Turk ey.

S40. A draft revision of the national transport regulations based on the 1996

edition of the Transport Regulations [1] has been used in Turkey since the

requirements of these Transport Regulations became effective for interna-

tional transport in 2001. It is recommended that these draft regulations be

approved formally as soon as possible.

1. INTRODUCTION

BACKGROUND

1.1. In order to facilitate safety in the transport of radioactive material

throughout the world, the IAEA, pursuant to its statutory authority, has

established the Regulations for the Safe Transport of Radioactive Material (the

Transport Regulations). The latest edition of the Transport Regulations was

published in 1996 and revised in 2000 [1]. In addition to publishing the

Transport Regulations, the IAEA also issues various guidance publications

5].

1.2. Details regarding the manner in which the Transport Regulations are

incorporated into international regulatory documents are provided in Section 2

of this report. Effective implementation of the Transport Regulations at the

State level is essential for ensuring a high level of safety in the transport of

radioactive material. Other key documents that should be considered by a

State in regulating its transport of radioactive material are discussed in

Section 2.

1.3. On 25 September 1998 the General Conference of the IAEA, which

meets annually, adopted resolution GC(42)/RES/13 on the Safety of Transport

of Radioactive Materials. In adopting that resolution, the General Conference

recognized that “compliance with regulations that take account of the Agency’s

Transport Regulations is providing a high level of safety during the transport of

radioactive materials…” In addition, it requested the IAEA Secretariat to

provide for the application of the Transport Regulations by, inter alia,

providing a service for carrying out, at the request of any State, an appraisal of

the implementation of the Transport Regulations by that State.

1.4. In response to this request the Director General offered the Transport

Safety Appraisal Service (TranSAS) to all States in letter J1.01.Circ., dated 10

December 1998.

1.5. The first TranSAS was undertaken and completed at the request of

Slovenia in 1999. Turkey was the third State to request a TranSAS.

1.6. In each of the General Conferences since 1998 resolutions focused on

transport safety have commended the Secretariat for establishing TranSAS,

commended those States that have requested this service and encouraged other

States to avail themselves of this service (see GC(43)/RES/11, GC(44)/RES/17,

GC(45)/RES/10, GC(46)/RES/9 and GC(47)/RES/7).

REQUEST FROM TURKEY

1.7. In a letter dated 12 September 2000 the Permanent Mission of Turkey to

the Office of the United Nations and other International Organizations in

Vienna informed the IAEA that the Turkish Atomic Energy Authority

(TAEK) had decided to request the IAEA Transport Safety Appraisal Service.

The points of contact in Turkey and the IAEA exchanged initial information

and arranged a preparatory mission that was conducted at the TAEK offices in

Ankara from 1 to 5 October 2001. During the preparatory mission, a

preliminary agreement was developed, which covered the scope of the

appraisal and the tasks and activities to be completed prior to and during the

appraisal.

1.8. The preliminary agreement addressed the following:

(a) The scope of the appraisal;

(b) The tentative dates of the appraisal;

authorities during the period leading up to the appraisal;

(d) A preliminary list of activities to be undertaken during the appraisal;

(e) The facilities required during the appraisal.

SCOPE OF THE APPRAISAL FOR TURKEY

1.9. The general scope of any TranSAS includes:

(a) An appraisal of the State’s regulatory practices for transport safety with

respect to the requirements of the Transport Regulations and related

international standards and guidelines;

(b) Recommendations or suggestions, as appropriate, in areas in which the

State’s transport safety regulatory programme might be improved.

1.10. The more specific scope for Turkey, as requested, included the

following:

(a) An evaluation of the national transport legislation and regulations,

taking into account applicable international practices;

(b) A review of the implementation of the requirements of the 1996 edition

of the Transport Regulations [1] into the Turkish regulations for

national and international transport for all modes of transport;

regulatory body with regard to the transport of radioactive material;

(d) A review and evaluation of the efficiency of the inspection and

enforcement programme related to the transport of radioactive

material;

(e) An evaluation of the cooperation arrangements with key governmental

organizations, with specific attention to areas of overlapping responsi-

bilities;

(f) A review of compliance practices, for example of a major importer.

ACTIVITIES COMPLETED PRIOR TO THE APPRAISAL

1.11. Preparations completed by Turkey included the following:

(a) The completion and transmittal to the IAEA of the detailed TranSAS

questionnaire;

(b) Ensuring the availability of key personnel from the TAEK and other

authorities during the appraisal;

dation and local transport for the team members, and some services for

the translation of documents during the appraisal.

1.12. Preparations completed by the IAEA included the following:

(a) The recruitment of the appraisal team (this included arranging for the

necessary approvals for the recommended team members);

(b) Providing the appraisal team with the relevant documentation and the

TranSAS guidelines;

APPRAISAL TEAM

1.13. The appraisal team was composed of four independent experts. These

experts were representatives of regulatory authorities of Belgium, Germany

and the United Kingdom responsible for the transport of radioactive material,

and the team leader, a transport safety expert from the IAEA. The expertise of

the appraisal team was broad and covered all aspects of the implementation of

regulations for the safe transport of radioactive material. Specific experience

was taken into account for the assignment of the lead responsibilities for

appraising the eight areas addressed in the TranSAS questionnaire.

APPRAISAL PROCESS

1.14. The appraisal process included the following:

(a) A preparatory session for the appraisal team;

(b) An entrance meeting involving presentations by key representatives

from the transport authorities and industry concerning their responsi-

bilities for the safe transport of radioactive material;

additional or more detailed information;

(d) Updating the TranSAS questionnaire and preparing the draft report

with findings;

(e) Ongoing feedback on the updated questionnaire and the draft report

with findings;

(f) A visit to the Çekmece Nuclear Research and Training Centre

(ÇNAEM) near Istanbul;

(g) Visits to the Turkish Airlines cargo departments at the Ankara

Esenboga airport and the Istanbul Ataturk airport;

(h) An exit meeting to present and discuss the findings.

More details on the appraisal process are provided in Section 3 of this report.

APPRAISAL REPORT

1.15. This report documents the results of the TranSAS appraisal conducted

in Turkey from 3 to 14 March 2003. It includes, in Section 4, the findings for

each area considered in the appraisal, together with a background discussion

and a basis for any finding (tied to an international regulatory requirement or

recommendation). The findings are presented as recommendations,

suggestions and good practices, which for the purposes of a TranSAS appraisal

have been defined as follows:

(a) A recommendation is advice on improvement in the reviewed area. It

can, but need not, be an indication of shortcomings either in the

national statutory legislative and regulatory regime or in the methods of

fulfilling the regulatory requirements.

(b) A suggestion is either an additional proposal in conjunction with a

recommendation or it may stand on its own. A suggestion should

stimulate the regulatory body’s management and staff to consider ways

and means of enhancing performance.

enough to be worth bringing to the attention of other nuclear regulatory

bodies as a model in the general drive for excellence.

Final remarks concerning the findings are presented in Section 5 of this report.

2. DOCUMENTS RELEVANT FOR THE

TRANSAS APPRAISAL

IAEA SAFETY STANDARDS

2.1. The Transport Regulations are key to the development of a regulatory

regime for the safe transport of radioactive material. These regulations were

first developed in the late 1950s at the request of the United Nations Economic

and Social Council. The first edition of the Transport Regulations was

published in 1961, and has been updated regularly. The latest edition of the

Transport Regulations was issued in 1996, and revised in 2000 to accommodate

editorial changes [1]. The previous edition, upon which some States still base

their national transport regulations, was issued in 1985 and amended in 1990

[6]. There are also additional guidance publications issued by the IAEA to

support the application of the Transport Regulations by regulators and users

[2–5]. Explanatory material [7] and advisory material [8] related to the 1985

edition of the Transport Regulations is relevant where that edition is still being

applied.

2.2. These publications provide a sound basis for competent authorities in

States to regulate the transport of radioactive material. Specifically, the

Transport Regulations [1], and their preceding editions (e.g. the previous 1985

edition (as amended in 1990) [6]), have provided and continue to provide a

model to be followed by relevant international organizations and States in

developing binding regulations for the international and national transport of

radioactive material. The guidance publications [2–5] also are valuable tools for

competent authorities, consignors, carriers and consignees for describing how

they may apply specific requirements of the regulations. For example, the

general advisory publication [2] and its predecessor publications [7, 8] provide

insight into why various regulatory requirements have been established and

define ‘a way’, or ‘ways’, but not ‘the way’ in which specific requirements may

be satisfied in practice. Guidance is also provided in specific key areas, inter

alia planning and preparing for emergencies [3], compliance assurance [4] and

quality assurance [5].

2.3. The Transport Regulations have a foundation, from a radiation

protection standpoint, in the IAEA Safety Fundamentals publication

Radiation Protection and the Safety of Radiation Sources [9] and in the Inter-

national Basic Safety Standards for Protection against Ionizing Radiation and

for the Safety of Radiation Sources [10] (the Basic Safety Standards).

2.4. Finally, a key publication for the application of the Transport

Regulations in a State is the publication Legal and Governmental Infra-

structure for Nuclear, Radiation, Radioactive Waste and Transport Safety [11],

which discusses in detail the legislative and governmental responsibilities of a

State and the responsibilities, functions, organization and activities of a

regulatory body.

2.5. These IAEA publications serve as a basis for appraising the regulatory

activities for the transport of radioactive material. However, it must be

recognized that these publications are not backed by the rule of law, that they

are generally not mandatory for a State and that they are advisory in nature.

For example, the Transport Regulations [1, 6] serve as models for a State’s

national transport regulations.

2.6. In striving to foster a consistent basis for communicating these

recommended requirements to its Member States, the IAEA also issues a

safety glossary [12].

INTERNATIONAL REGULATORY DOCUMENTS AND STANDARDS

2.7. The Transport Regulations serve as the model for the radioactive

material portions of international regulations for the transport of dangerous

goods by the various modes of transport.

2.8. The first step in applying the Transport Regulations to the international

transport of radioactive material was the incorporation of their requirements

into the recommendations on the transport of dangerous goods drawn up by

the United Nations Committee of Experts on the Transport of Dangerous

Goods [13], which provide a detailed set of ‘model regulations’ for all nine

classes of dangerous goods. Radioactive material is Class 7 in these regulations.

These model regulations of the United Nations serve as a basis for national and

international regulations for the transport of dangerous goods by the various

modes of transport.

2.9. Accordingly, the International Civil Aviation Organization (ICAO)

publishes its regulations as the Technical Instructions for the Safe Transport of

Dangerous Goods by Air [14] (the ICAO Technical Instructions). These

Technical Instructions are mandatory upon all member States of the ICAO. In

addition, the International Air Transport Association (IATA) publishes its

Dangerous Goods Regulations [15], which incorporate all the requirements of

the ICAO Technical Instructions as well as additional operator variations.

2.10. The International Maritime Organization (IMO) publishes the Interna-

tional Maritime Dangerous Goods Code [16] (IMDG Code) for the transport

of dangerous goods by sea. Many of the detailed requirements of the IMDG

Code became mandatory for all Contracting Parties to the International

Convention for the Safety of Life at Sea (SOLAS Convention) on 1 January

2004.

2.11. For States in Europe, the United Nations Economic Commission for

Europe (UNECE) and the Intergovernmental Organization for International

Carriage by Rail (OTIF) publish dangerous goods regulations (including

requirements derived from the Transport Regulations [1]) for road (Annexes A

and B of ADR) [17] and rail (RID) [18]. These regulations apply through

agreements and conventions (respectively ADR and COTIF) that make their

application to the international carriage of dangerous goods by road and rail

between Contracting Parties mandatory. The ADR/RID requirements are also

mandatory for domestic transport in States that are members of the European

Union (EU), through EU directives. A number of non-EU countries have also

adopted the ADR and RID requirements as the basis for their national

legislation.

2.12. Similarly, another agreement concerning the international carriage of

dangerous goods by inland waterways (ADN) was adopted in 2000 under the

auspices of the UNECE and the Central Commission for Navigation of the

Rhine. The conditions for entry into force (seven Contracting States) had not

been met in February 2004 (ten Signatory States, two Contracting States), but

the annexed regulations, which also incorporate the Transport Regulations, are

already of mandatory application on the Rhine and have been adopted by

several Danubian States.

3. APPRAISAL PROCESS IN TURKEY

OVERVIEW OF THE APPRAISAL PROCESS

3.1. The appraisal process included the following:

(a) A preparatory session for the appraisal team;

(b) An entrance meeting involving presentations by key representatives

from the transport authorities and industry concerning their responsi-

bilities for the safe transport of radioactive material;

additional or more detailed information;

(d) Updating the TranSAS questionnaire and preparing the draft report

with findings;

(e) Ongoing feedback on the updated questionnaire and the draft report

with findings;

(f) A visit to the Çekmece Nuclear Research and Training Centre

(ÇNAEM) near Istanbul;

(g) Visits to the Turkish Airlines cargo departments at the Ankara

Esenboga airport and the Istanbul Ataturk airport;

(h) An exit meeting to present and discuss the findings.

PREPARATORY SESSION

3.2. A preparatory session preceding the formal part of the appraisal was

held in order for the team members to meet with their counterparts from

Turkey, and to review the programme for the appraisal, the procedures to be

followed, the reference material to be used and the work to be carried out.

3.3. The members of the team had broad experience and expertise in the

implementation of regulations for the transport of radioactive material. They

represented regulatory authorities in Belgium, Germany and the UK, and were

led by a transport safety expert from the IAEA. Further details on the team

members are provided in Appendix II.

3.4. Specific experience was taken into account for the assignment of lead

responsibilities for appraising the eight areas addressed in the TranSAS

questionnaire.

ENTRANCE MEETING

3.5. The entrance meeting involved key representatives of the regulatory

authorities and of an import organization.

3.6. The agenda of the entrance meeting covered the following items:

(a) Welcome address by the President of the TAEK (M. Tomak);

(b) Outline of the objectives of the appraisal by the TranSAS team leader

(G.J. Dicke);

(d) Introduction of the Turkish participants in the appraisal;

(e) Overview of the organization of the Radiation Health and Safety

Department (RHSD) of the TAEK by its director (I. Uslu);

(f) Overview of the responsibilities of divisions in the RHSD concerning

the transport of radioactive material (G. Arslan);

(g) Overview of the organization and functions of the Committee for the

Preparation and Application of Legislation (K. Ertürk);

(h) Overview of the legal and technical processes for implementing changes

to the Turkish regulations (K. Ertürk);

(i) Overview of work carried out by an importer to comply with the

Transport Regulations (I. Soytemiz, Tibbi Endüstriyel Sistemler Sanayi

ve Ticaret Ltd ti (TESST));

(j) Overview of cooperation with the General Directorate of Civil Aviation

(E. Ertus, Department of Transport);

(k) Overview of cooperation with the Undersecretariat of Customs

(F. Damancioglu, Division of Environment);

(l) Overview of cooperation with the Undersecretariat for Maritime

Affairs (UMA) (S. Onur, Navigation Safety Department);

(m) Overview of cooperation with the Ministry of Environment (A. Nuray,

Waste Management Department), General Directorate for the

Prevention of Pollution to the Environment;

(n) Overview of transport related emergency response procedures

(I. Arikan);

(o) Overview of inspection procedures (G. Arslan).

INTERVIEWS, UPDATING THE QUESTIONNAIRE AND

DEVELOPING THE REPORT

3.7. In addition to the discussions following the presentations, the team

invited several of the Turkish representatives to discuss in more detail the

information provided in the questionnaire. Subsequently, the team members

pursued further information specific to the areas for which they had the lead

responsibility. The additional information was used to update the question-

naire. On 5 March 2003 the team visited the Turkish Airlines cargo department

at the Ankara Esenboga airport. On 6 March the updated questionnaire was

made available to the Turkish representatives for their review, and in the

afternoon the team flew to Istanbul and prepared for visits to the Turkish

Airlines cargo department at the Istanbul Ataturk airport on 7 March and to

ÇNAEM on 10 and 11 March. In the afternoon of 11 March the team flew back

to Ankara. The following two days were used to prepare the draft report for the

exit meeting, taking into account the comments received and the information

gained from the Istanbul visit. The draft report of the findings was presented at

the exit meeting on Friday 14 March.

VISIT TO THE ÇEKMECE NUCLEAR RESEARCH AND

TRAINING CENTRE

3.8. The agenda for the visit to ÇNAEM involved the following:

(a) Welcome by the Director of the Centre (G. Köksal);

(b) Overview of activities of the Health Physics Division (N. Chelebi);

Facility (A. Kahraman);

(d) Visit to the facilities of the Radioisotope and Radiopharmaceuticals

Division (F. Akgün);

(e) Review meeting involving all presenters as well as E.M. Köksal (Head

of the Radiobiology Division) and K. Ertürk, B. Onat and T. Özdemir

from the RHSD in Ankara.

EXIT MEETING

3.9. The findings of the team were presented by the team members for the

areas in which they had the lead responsibility. These findings are summarized

in the Summary, Findings and Conclusions section of this report. The findings,

together with the relevant background information and the basis for the

findings, are presented in detail in Section 4.

4. APPRAISAL OF THE IMPLEMENTATION

OF THE TRANSPORT REGULATIONS IN TURKEY

INTRODUCTION

4.1. This section of the report is structured around the key topic areas

covered in the TranSAS questionnaire. These key areas are:

(a) Legislative and governmental responsibilities;

(b) The authority, responsibilities and functions of the regulatory body;

(d) The authorization process;

(e) Review and assessment;

(f) Inspection and enforcement;

(g) The development of regulations and guides;

(h) Emergency preparedness for transport.

This section provides, for each of these areas, an overview of relevant infor-

mation, followed by the findings for that area. Each finding is preceded by a

basis from appropriate international regulatory and guidance documents. The

findings are presented in terms of recommendations, suggestions and good

practices, as applicable.

LEGISLATIVE AND GOVERNMENTAL RESPONSIBILITIES

Overview

4.2. The legal documents relevant to the implementation of the Transport

Regulations focus primarily upon three areas:

(a) Documents concerning responsibilities and regulations with regard to

the transport of radioactive material;

(b) Documents concerning responsibilities and regulations for the transport

of dangerous goods, which include radioactive material;

transport of radioactive material.

Legal documents concerning responsibilities and regulations for the transport

of radioactive material

4.3. The following legal documents provide the basic framework for the

implementation of the Transport Regulations in Turkey:

(a) The Turkish Atomic Energy Authority Act, Act No. 2690 of 13 July

1982;

(b) The radiation safety decree of 7 September 1985;

(d) The regulation for the safe transport of radioactive material (the

Turkish version of Ref. [6]) of 10 September 1997;

(e) The draft revision of this Turkish transport regulation based on the 1996

edition of the Transport Regulations [1], applied as of 1 July 2001.

Turkish Atomic Energy Authority Act, Act No. 2690

4.4. The TAEK was established by the Turkish Atomic Energy Authority

Act, Act No. 2690 of 13 July 1982. The objective of this act was to: provide for

the peaceful use of atomic energy in Turkey for the benefit of the country in

conformity with the national development plans; define and recommend the

basic principles and policies; and implement, inspect, organize, support and

coordinate scientific, technical and administrative studies and affairs. More

specifically, in Chapter 1, on objectives, scope and establishment, and further in

Article 3, Act No. 2690 establishes the TAEK as a public legal entity reporting

directly to the Prime Minister, and it identifies the major organs of the TAEK,

which are:

(a) The Atomic Energy Commission;

(b) The Advisory Committee;

(d) Affiliated institutions.

4.5. In Article 4, Chapter 2, of Act No. 2690, the overall duties and responsi-

bilities of the TAEK are addressed in more detail. These include specifically for

transport:

(a) “to determine the general principles to be complied with and to make

recommendations” (Article 4, para. (b));

(b) “to prepare decrees and regulations” (Article 4, para. (d));

4.6. Other general requirements in Article 4 also apply to transport. For

example, in Article 4, para. (h): “to train personnel who will work in the nuclear

field or to assist their training if necessary and to co-operate with the organiza-

tions and higher educational institutions working for this purpose.”

4.7. In Chapter 3, on organs, duties and jurisdictions, the duties of the

Atomic Energy Commission include in Article 6, para. (b): “to prepare the draft

acts and decrees related to the nuclear field and submit them to the Prime

Minister, and to approve the regulations related to the Turkish Atomic Energy

Authority.”

4.8. Article 8 establishes the various departments in the TAEK. The duties

of the RHSD are provided under para. (b) as follows: “Among the duties laid

down in Article 4 of this Act: to carry out services for licensing, determination of

the regulations and principles of radiation protection, transport and storage of

radioactive materials, and inspection of radiation emitting devices and systems;

and to perform other related tasks.”

4.9. Article 9 gives the TAEK the authority to establish affiliated institu-

tions to carry out fundamental and applied research in the nuclear field and to

establish their working procedures by regulation.

Radiation safety decree

4.10. The relevant sections of the radiation safety decree include the

following. Article 1 states that the provisions to be observed for the transport

of ionizing radiation sources are spelled out in the decree. Article 3 states that

the RHSD is responsible for carrying out the necessary services for radiation

safety. Article 4 defines the functions of the RHSD, including that of issuing

licences for the purpose of allowing the transport of sources of ionizing

radiation, issuing permits for import, export, transport or transit passage,

defining the necessary measures to be taken in the event of a radiation accident

and the mode of cooperation with the governmental offices and organizations

concerned with radiation safety. Article 7 states that the possession, use,

production, import, export, purchase, sale, transport and storage of radiation

sources require a licence from the TAEK, and that if such operations require

any other permit, licence or documentation from other governmental offices

and organizations, the issuance of such documents is subject to a licence from

the TAEK. Articles 14 and 16 of the radiation safety decree provide additional

requirements for the TAEK to issue permits for the transport of radioactive

sources.

Radiation safety regulation

4.11. The requirements of the radiation safety regulation relevant to the

transport of radioactive material are provided in particular in Part IV, on

licences, permits, inspections and records; specific details are provided in

Articles 50–70.

Turkish regulation for the safe transport of radioactive material

4.12. The Turkish version of the Transport Regulations is essentially a trans-

lation. The version published on 10 September 1997 is based on the 1985

edition of the Transport Regulations [6]. A draft version of the Turkish

regulation, which is essentially a translation of the 1996 edition of the Transport

Regulations [1], has been applied based on an 11 October 2001 letter from the

TAEK to the competent organizations. The draft regulation was attached to

the letter. This draft version has not yet been submitted to the Atomic Energy

Commission for its approval and subsequent publication in the Official Gazette

for formal implementation.

Legal documents concerning the transport of dangerous goods

4.13. The following legal documents provide the basic framework in Turkey

for the implementation of the requirements for the transport of dangerous

goods (which include radioactive material) in accordance with international

and national regulations.

International requirements for transport by air

4.14. The following international regulations apply to the air transport of

dangerous goods:

(a) The ICAO Technical Instructions [14];

(b) The IATA Dangerous Goods Regulations [15].

4.15. Turkey has been a member of the ICAO since 1944 and ratified the

Chicago Convention in 1946. Accordingly, the ICAO Technical Instructions

apply to the international air transport of dangerous goods, including

radioactive material. The requirements for radioactive material in the ICAO

Technical Instructions have been in accordance with the 1996 edition of the

Transport Regulations [1] since 1 July 2001.

4.16. Airlines are required to comply with the IATA Dangerous Goods

Regulations [15], which embrace all the requirements of the ICAO Technical

Instructions. The requirements for the transport of radioactive material in the

IATA Dangerous Goods Regulations [15] have therefore also been in

accordance with the 1996 edition of the Transport Regulations [1] since 1 July

2001. The IATA Dangerous Goods Regulations [15] have some requirements,

the ‘operator variations’, which are in addition to the requirements of the

ICAO Technical Instructions. An operator variation from Turkish Airlines

applicable specifically to the transport of radioactive material is identified as

TK-03. This variation states that “Permission of the Turkish Atomic Energy

Authority is necessary for the transport of radioactive elements to/from Turkey.”

National requirements for transport by air

4.17. The Turkish requirements governing the air transport of dangerous

goods are established by:

(a) Law No. 3348 of 9 April 1987, concerning the establishment and respon-

sibilities of the Ministry of Transport;

(b) Law No. 2920 of 14 October 1983, the Turkish civil aviation law;

the responsibilities of air cargo agencies;

(d) Ground handling regulations for airports, SHY-22 of 28 August 1996,

Official Gazette No. 22760;

(e) A regulation concerning commercial air transport companies, of 13 July

1992, Official Gazette No. 21283;

(f) Draft Turkish instructions on the air transport of dangerous goods,

SHT-18, 17 February 2003.

Law No. 3348 of 1987, concerning the establishment and responsibilities of the

Ministry of Transport

4.18. Paragraph (a) of Article 12 of Law No. 3348 provides that the General

Directorate of Civil Aviation is responsible for regulating transport by air in

Turkey. Paragraphs (c) and (d) address the qualification of personnel and

companies and their licensing. This responsibility includes the licensing of

cargo agents who deal with the import or export of dangerous goods. This

article also states that for the control of safety and security the opinions of

other relevant national authorities should be taken into account.

Law No. 2920 of 1983, the Turkish civil aviation law

4.19. Article 6 of this law states that all transport by air in Turkey lies under

the responsibility of the Ministry of Transport.

Aviation circular SHY-150.11, of 13 June 2000

4.20. The basis for this circular is the Turkish civil aviation law and Article 14,

item (i), of the airports ground handling regulation, SHY-22. Article 2 of the

circular defines the scope for responsibilities of cargo agencies, air transporters

and ground handling companies. Article 5 forbids the transport of dangerous

goods, including radioactive material, unless it is transported in accordance

with the requirements of: (a) the General Directorate of Civil Aviation; (b)

ICAO Annex 18, document 9284-AN/905; (c) the IATA Dangerous Goods

Regulations [15]; and (d) subpart R, Transport of Dangerous Goods by Air, in

JAR-OPS 1 [19] of the European Joint Aviation Authority. These requirements

apply to both national and international air transport. Item (a) of Article 11

states that all licensed agents have the obligation to train in accordance with

the IATA Dangerous Goods Regulations [15] and to certify at least one staff

member.

Regulation concerning commercial air transport companies

(13 July 1992, Official Gazette No. 21283)

4.21. Article 27 states that all explosives and dangerous goods, including

radioactive material, require a special permission for transport from the

Ministry of Transport and the competent authorities of other countries.

Draft Turkish air transport of dangerous goods instructions

4.22. Currently in draft form are the air transport of dangerous goods instruc-

tions being prepared by the General Directorate of Civil Aviation. Articles 2

and 3 of these instructions state that the ICAO Technical Instructions (except

those parts on ammunition and explosives) are to be met by all registered

aircraft used by air companies and shippers.

International requirements for the transport of dangerous goods by sea

4.23. Turkey is a member of the IMO. The major IMO conventions, including

the SOLAS Convention and the International Convention for the Prevention

of Pollution from Ships (MARPOL Convention), have been ratified by Turkey.

Additional instruments are in the process of ratification at the Turkish

Parliament. The IMO publishes the IMDG Code [16], which since 1 January

2001 includes the requirements of the 1996 edition of the Transport

Regulations [1]. A one year transition period allowed the requirements of the

1985 edition of the Transport Regulations [6] to remain applicable until 1

January 2002, after which time only the requirements of the 1996 edition of the

Transport Regulations [1] apply pursuant to the IMDG Code. The require-

ments of the IMDG Code are widely applied but are not yet mandatory. Turkey

has applied the general principles of the IMDG Code, but not the detailed

requirements. As of 1 January 2004 many of the detailed requirements of the

IMDG Code have become mandatory for all IMO member States.

National requirements for the transport of dangerous goods by sea

4.24. The Turkish regulations governing the transport of dangerous goods by

sea include the following:

(a) Law No. 4922, on protecting life and property, issued on 10 June 1946;

(b) A decree concerning the technical conditions of commercial ships,

issued on 11 February 1948, based on Law No. 4922, as amended in

1973;

(d) Government Decree No. 491, on the establishment of the UMA, dated

August 1993, as amended by Amendment 602 dated June 2000;

(e) Regulation No. 3/14831 of 1952 on the transport of dangerous goods by

commercial ships;

(f) The Istanbul port decree of 6 September 1996, Official Gazette No.

22749;

(g) The maritime traffic regulations for passage through Turkish straits,

published in 1994, revised in 1998 and 1999.

4.25. The UMA lies directly under the authority of the Prime Minister. The

UMA has three general directorates, including the General Directorate of

Maritime Transport, and seven district directorates. The responsibilities of the

district directorates include coordination of the actions of harbour masters.

4.26. There are 68 harbour masters for the 130 ports in the four maritime

regions along Turkey’s 8330 km of coastline. (Approximately 120 million

tonnes of dangerous goods, including crude oil and derived products, pass

through the Turkish straits per year in about 7000 of the approximately 45 000

ships in transit.) The responsibilities of the harbour masters include some tasks

in relation to dangerous goods.

Law No. 4922 of 10 June 1946

4.27. This law provides the principles for maritime safety. It is now only

considered a legal framework, providing in particular for penalties in the event

of violation. Article 12 defines dangerous goods.

1948 decree concerning the technical conditions of commercial ships

4.28. This decree, which is based on Law No. 4922, aims to set up minimum

technical standards for any kind of ship. This decree was amended in 1973.

According to the amended decree, international rules apply whenever national

regulations are missing or deficient.

Port law and port decrees

4.29. The port law has governed the principles of port organization and

management since 1925. It is based on a clear separation between the port

authority in charge of the commercial aspects of port operation and the State

authority, locally represented by harbour masters and ship surveyors, in charge

of maritime safety. Each harbour master authority has its own port decree

within its responsibility area. The general principles are the same, but the most

detailed decree is the Istanbul port decree. Article 23 of this decree stipulates

the requirements for loading, unloading and stowage. Item (g) defines

radioactive material and states that, prior to unloading, all necessary

documents must be provided to the port authority. For radioactive material

there is also a need for a certificate that should include a statement that the

material has been packaged in a manner that does not pose any risk to the

environment. In order to obtain port clearance, the captain, owner or agent of

a ship carrying dangerous goods must submit details to the harbour master

authority on the quantity, nature and packaging of the dangerous cargo at least

24 h before entry into a port. Unloaded radioactive material is not to be stored

in the port area.

Maritime traffic regulations for passage through Turkish straits, published in

1994, revised in 1998 and 1999

4.30. The purpose of these regulations is to provide for the safety of

navigation, life and property and the protection of the environment in the

straits without jeopardizing the principle of freedom of passage as set forth in

the Montreux Convention. Along with the introduction of these regulations,

the Turkish authorities have also established traffic separation schemes (TSSs)

in the straits, in accordance with the provisions of the Convention on the Inter-

national Regulation for Prevention of Collision at Sea (COLREG). The TSSs

were approved by the IMO General Assembly in November 1995, with the

associated Rules and Recommendations on Navigation Through the Strait of

Istanbul, the Strait of Canakkale and the Marmara Sea. The number of

collisions and accidents has been drastically reduced in the straits since the

introduction of these regulations.

National and international requirements for the road and rail transport of

dangerous goods

4.31. Overall responsibility for the transport by road of dangerous goods lies

with the Ministry of Environment in accordance with the Act of Environment,

Act No. 2872, issued on 11 August 1983, Official Gazette No. 18132. Section 3

addresses measures and prohibitions for protection of the environment.

Article 8 states that it is prohibited to store or transport waste unless the

requirements of the relevant regulations are met. The regulation specific to

these requirements is the dangerous waste control regulation, issued on

27 August 1995, Official Gazette No. 22387. According to this regulation, all

dangerous waste, including radioactive waste, can only be transported by road

by a licensed carrier. Provincial authorities are authorized by the Ministry of

Environment to issue licences in this connection. According to Article 132 of

the regulation concerning transport of dangerous goods by road, issued on 22

October 1976, Official Gazette No. 15742, obtaining a permit from the TAEK is

a prerequisite for applying for a licence to carry radioactive waste by road.

4.32. Overall responsibility for the rail transport of dangerous goods lies with

the General Directorate of Turkish State Railways, in accordance with Act

No. 3938, issued on 14 December 1993, Official Gazette No. 21788. This act

incorporates all the annexes of RID [18] based on the COTIF Protocol of 20

December 1990. The COTIF Protocol was signed on 20 December 1990 and

ratified on 28 June 1994, and entered into force on 1 November 1996. The

protocol of 3 June 1999, which includes the requirements of the 1996 edition of

the Transport Regulations [1], was signed on 30 December 1999, but has not

been ratified.

4.33. It should be noted here that many European countries and several

countries outside Europe apply the international ADR (road) [17] and RID

(rail) [18] regulations for the transport of dangerous goods. Since 1 July 2001

these regulations have included the requirements of the 1996 edition of the

Transport Regulations [1].

Legal documents concerning some specific aspects, other than safety, of the

transport of radioactive material

4.34. Aspects other than safety may also be subject to requirements for the

transport of radioactive material. Such aspects include import or export and

physical protection.

Customs regulation

4.35. Customs officers have some responsibilities with regard to the import or

export of radioactive material and with regard to the prevention of smuggling

of radioactive material. They have made arrangements with the TAEK to be

trained in dealing with radioactive material.

4.36. The list of goods imported into Turkey that are subject to authorization

in accordance with the legislation in force is included in Annex 27 of the

customs regulation issued on 1 July 2002. This annex provides for an ‘import

notification’ concerning radioactive material that requires permission from the

TAEK.

4.37. Import notifications, issued by the Undersecretariat of Foreign Trade,

are used to inform other authorities in Turkey of specific requirements related

to their area of responsibility. The import notification in Annex 27, issued on 31

December 2001, Official Gazette No. 24627, covers radioactive material and

other sources of ionizing radiation. This notification informs the Undersecre-

tariat of Customs of all items that require permission from the TAEK. In order

to prevent smuggling of nuclear material, radiation detectors have been

installed at airports and borders. All regional directorates have also been

provided with handheld radiation detectors.

Physical protection of special nuclear material regulation, issued on 20 July 1979,

Official Gazette No. 16702

4.38. Physical protection requirements are not within the scope of the

TranSAS appraisal.

Findings

4.39. Basis: The international regulations of the ICAO, IATA and the IMO

on the transport of radioactive material incorporated the requirements of the

1996 edition of the Transport Regulations [1] in 2001. Since then the require-

ments of the 1996 edition of the Transport Regulations [1] have become

formally applicable for the international transport of radioactive material. The

Turkish regulation on the safe transport of radioactive material is formally still

based on the 1985 edition of the Transport Regulations [6]. For harmonization

of the transport regulations, it is important to formally update the national

regulations and harmonize them with the international regulations.

Recommendation: The process of formalizing the draft Turkish regulation on

the safe transport of radioactive material should be completed as soon as

possible.

4.40. Basis: Areas of overlapping regulatory responsibilities, as occur, for

example, with regulating all aspects concerning radioactive material on the one

hand and all aspects of the transport of dangerous goods, including radioactive

material, on the other, have the potential for duplication and the creation of

regulatory gaps. A memorandum of understanding between the involved

authorities could ensure effective regulation in areas of overlapping

responsibilities.

Suggestion: It is suggested that in areas of overlapping responsibilities,

memoranda of understanding be developed between the authorities involved.

AUTHORITY, RESPONSIBILITIES AND FUNCTIONS OF THE

REGULATORY BODY

Overview

4.41. The TAEK was established pursuant to Act No. 2690 of 13 July 1982

(the Turkish Atomic Energy Authority Act). The duties, responsibilities and

jurisdictions of the TAEK are addressed in Article 4 as follows:

(a) To determine the bases of the national policy and the related plans and

programmes for the peaceful use of atomic energy for the benefit of the

country, and to submit them to the Prime Minister for approval; to

perform any kind of research, development, study and investigation on

the benefit of using atomic energy for the scientific, technical and

economic development of the country; to coordinate and support such

activities.

(b) To determine the general principles to be complied with and to make

recommendations on and cooperate with any kind of exploration,

mining, purification, process, production, distribution, import, export,

trade, transport, usage, transfer and storage of raw nuclear material,

special fissionable material and other strategic material used in the

nuclear field.

tories, test centres, and pilot plants not intended for power production,

or arrange for the establishment and operation of these installations,

within the country wherever necessary; to perform studies for the

national industry with a view to acquiring nuclear technology; to make

recommendations for the establishment of processing, purification and

other necessary facilities relating to the fuel cycle.

(d) To establish and operate facilities for the production of radioisotopes,

for quality control, for measurement and for distribution, in order to:

(i) Determine the principles, measures and limits of liability for

protection against the damaging effects of ionizing radiation while

using radiation equipment, radioactive material, special fissionable

material and other similar sources of ionizing radiation.

(ii) Grant licences as a basis for operating permits to governmental or

private institutions and organizations or persons who keep, use,

import, export, transport, store or trade in radioactive material and

radiation equipment, and to inspect these institutions and organiza-

tions for compliance with radiation safety legislation; to enforce

insurance obligations for implementing the above activities; to

cancel licences temporarily or permanently in the event of non-

compliance with radiation safety legislation; to decide to close down

the above institutions and organizations; and to initiate legal investi-

gations in accordance with general legal principles.

(iii) Prepare the decrees and regulations determining the principles of

insurance obligations, usage, export, import and transport of radio-

isotopes.

(e) To issue approvals, permits and licences for site selection, construction,

operation and environmental safety of nuclear power reactors, research

reactors and nuclear fuel cycle facilities; to carry out the necessary

investigations and inspections; to limit the operating authorizations in

the event of non-compliance with permits and licences; to cancel

permits or licences, permanently or temporarily, and to make recom-

mendations on the closing down of such installations to the Prime

Minister; to prepare the necessary technical guides, decrees and

regulations for these purposes.

(f) To take the necessary measures, or arrange for them to be taken, for the

processing, transport and safe temporary or permanent storage of

radioactive waste generated in nuclear facilities and radioisotope

laboratories.

(g) To establish relations and cooperate with the national institutions and

organizations concerned with atomic energy; to participate in the

scientific studies of, and to contact and cooperate with, foreign and

international institutions and organizations in the nuclear field; to

programme and administer the assistance obtained from national or

foreign sources for any studies in the nuclear field.

(h) To train personnel to work in the nuclear field, or to assist in their

training if necessary, and to cooperate with the organizations and higher

educational institutions working to this purpose; to make recommenda-

tions on the distribution of fellowships in the nuclear field supplied by

national sources; to distribute fellowships in the nuclear field supplied

by foreign sources; to conduct or assist in conducting training courses

within the country; to support students and personnel training abroad;

to plan and follow their education and studies.

(i) To compile, disseminate and introduce the necessary information and

the conclusions of national and foreign studies relating to the

application of atomic energy; to enlighten the public on nuclear matters.

(j) To carry out studies relating to national and international legislation in

the nuclear field and to propose necessary amendments to regulations.

(k) To prepare and implement decrees and regulations determining the

bases for the protection of nuclear material and facilities, and to carry

out inspections towards these aims; to comment on relevant regulations

prepared by other institutions.

4.42. Work permits to transport material to and from nuclear installations are

given by other ministries, such as the Ministry of Transport for transport by air,

the Ministry of Environment for transport by road, and the Undersecretariat

for Maritime Affairs for transport by sea. In cases in which radioactive material

is involved, the radiation safety decree states in Article 7 that any additional

permits or licences can only be obtained after issuance of the necessary licence

by the TAEK.

4.43. According to the Turkish Atomic Energy Authority Act, the TAEK

reports to the Prime Minister. However, it must be noted that, due to a

reorganization of the Government, the TAEK now reports to the Minister for

Energy and Natural Resources.

4.44. The TAEK also acts as the operator of nuclear installations (e.g. for the

production of radiopharmaceutical products and for the treatment and storage

of low level radioactive waste). These activities and the installations involved

are to be licensed by the RHSD.

Findings

4.45. Basis: The TAEK has to approve activities in which radioactive material

is involved, in some cases in addition to licences or authorizations issued by

other authorities. For instance, the General Directorate of Civil Aviation

licenses Turkish Airlines for the carriage of dangerous goods, but the TAEK

has to issue an additional licence, since Turkish Airlines also transports

radioactive material. Only a limited number of formal arrangements exist or

are in preparation. For example, Article 9 of a draft aviation instruction issued

by the General Directorate of Civil Aviation, SHT-18, issued on 17 February

2003, requires the permission of the TAEK for air transport within Turkey, to

confirm compliance with the Turkish regulation for the safe transport of

radioactive material. When two organizations or ministries have overlapping or

complementary responsibilities, it is of utmost importance that an agreement

be reached on the specific responsibilities and on the management of the

interfaces. A memorandum of understanding between the different parties

involved could help to clarify the interfaces and overlaps.

Suggestion: It is suggested that memoranda of understanding be prepared to

manage interfaces between the different authorities involved in the transport of

radioactive material. Such memoranda of understanding would detail the

procedures to be followed in the authorization process and might include

provisions for the training of personnel in radiation safety, as well as provisions

regarding inspection and enforcement.

4.46. Basis: The Ministry of Transport (General Directorates of Civil

Aviation and Road Transport), the Undersecretariat for Maritime Affairs, the

Ministry of Environment and the General Directorate of the Turkish State

Railways are also involved in regulating the transport of dangerous goods,

including radioactive material.

Suggestion: Cooperation agreements between the different parties involved

could help to achieve harmonization of the applicable national and interna-

tional regulations for the transport of dangerous goods by different modes.

4.47. Basis: The statutory functions of the TAEK include both the regulation

and the licensing of nuclear activities, but the TAEK also has responsibilities as

an operator of nuclear facilities (research institutes and other facilities). An

affiliated institution (ÇNAEM) is the operator of nuclear installations, but also

issues customs clearances and permits and performs inspections. Despite the

fact that the affiliated institutions of the TAEK must be licensed just as any

other operator, there is a potential conflict of interest, and the independence of

the competent authority may be questioned. According to para. 2.2(2) of Ref.

[11], the regulatory body shall be effectively independent of organizations or

bodies charged with the promotion of nuclear technologies or responsible for

facilities or activities.

Suggestion: It is suggested that the regulatory functions be more clearly

separated from the operational and promotional functions. This separation

would be evident from the organizational chart.

Suggestion: In order to clarify the duties and responsibilities of the specialized

departments and the affiliated institutions in accordance with the Turkish

Atomic Energy Authority Act, it might be envisaged to set up a section of the

RHSD in Istanbul. This section would carry out the work actually done by the

Health Physics Department of ÇNAEM. As an alternative, part of the Health

Physics Division of ÇNAEM would continue to carry out the work but would

formally become part of the RHSD.

ORGANIZATION OF THE REGULATORY BODY

Overview

4.48. The organs of the TAEK are as follows (Turkish Atomic Energy

Authority Act, Article 3):

(a) The Atomic Energy Commission;

(b) The Advisory Committee;

(d) Affiliated institutions.

4.49. The structure of the TAEK is illustrated in Fig. 1.

4.50. The Atomic Energy Commission, chaired by the President of the TAEK

(or the Prime Minister when he deems necessary), consists of the Vice

Presidents of the TAEK, one member each from the National Defence, Foreign

Affairs, and Energy and Natural Resources ministries, and four faculty

members active in education, training and research in the nuclear field. The

members representing the ministries and higher educational organizations are

selected by the Prime Minister for a four year term of appointment.

4.51. The duties of the Atomic Energy Commission are:

(a) To determine the working principles and programmes of the TAEK and

to approve the draft budget and submit it to the Prime Minister;

(b) To prepare draft acts and decrees relating to the nuclear field and

submit them to the Prime Minister, and to approve regulations relating

to the TAEK;

annual work programme and report and submit them to the Prime

Minister;

Prime Minister

Atomic Energy

Commission

Advisory

Committee

President

Vice President Vice President Vice President

Research,

Development and

Coordination

Nuclear Safety

Administration

and Finance

Radiological Health

and Safety

Nuclear

Technology

Diagnostic

Radiology

Nuclear Medicine

Radiotherapy

Nuclear Gauges

Industrial

Radiography

Environmental

Radiation

Monitoring

Structural line

Reporting line

Departments

Affiliated institutions

Çekmece Nuclear

Research and

Training Centre

Ankara Nuclear

Research and

Training Centre

Ankara Nuclear

Agriculture and

Animal Health

Research Centre

Turkish States

Nuclear Cooperation

Research and

Training Centre

Emergency

Crisis Centre

International

Nuclear

Information

System

FIG. 1. Organizational chart of the TAEK.

(d) To submit the necessary arrangements to the Prime Minister for

approval by reviewing the personnel and organizational structure of the

TAEK in order to meet developing needs.

4.52. The Advisory Committee consists of the faculty members working in

the nuclear field and experts from other related institutions and organizations,

whose numbers, qualification and selection criteria are determined by a

regulation. The members of the Advisory Committee are appointed at the

proposal of the Atomic Energy Commission and with the approval of the

Prime Minister. The President of the TAEK calls the Advisory Committee for

a meeting at least once a year, and chairs the meeting. The Advisory

Committee investigates the topics specified by the Atomic Energy Commission

and submits its conclusions and recommendations to the Atomic Energy

Commission.

4.53. The duties of the RHSD are, inter alia, to carry out services for

licensing, to determinate the regulations and principles of radiation protection,

to transport and store radioactive material, to inspect radiation emitting

devices and systems, and to perform other related tasks.

4.54. The RHSD has six licensing divisions that deal with:

(a) Diagnostic radiology;

(b) Radiotherapy;

(d) Nuclear gauges;

(e) Industrial radiography;

(f) Environmental radiation monitoring.

4.55. In addition, four standing committees within the RHSD cover the

following areas:

(a) Radiation sources and waste;

(b) Radiological accident management;

(d) Training.

4.56. As can be seen from Fig. 1, there is no specific division for the transport

of radioactive material. Transport issues are dealt with by the various divisions,

depending on the use that is made of the material. It must be noted that the

TAEK acts not only as a regulator but also as an operator of nuclear installa-

tions (e.g. the affiliated institution ÇNAEM produces and distributes radio-

pharmaceutical products, and its Health Physics Department is responsible for

the treatment and storage of low level radioactive waste). It is felt that there is

a potential for conflict of responsibilities and for the regulatory departments of

the TAEK not to be able to carry out their functions in an effectively

independent manner (see para. 4.47 of this report).

Finding

4.57. Basis: The TAEK is recognized as the competent authority for the

transport of radioactive material. However, from the organizational chart of

the TAEK, it is not clear which division is responsible for this activity.

Suggestion: In order to make the organization more transparent, it might be

envisaged that a specific division be set up within the RHSD to deal specifically

with all transport issues. The personnel of this division would be given the

opportunity to increase their expertise in order to be able to perform the

necessary assessments.

AUTHORIZATION PROCESS

Overview

4.58. The radiation safety decree and the radiation safety regulation provide

a general framework for the licensing of the import, transit, export and

transport of radioactive material. Applications for a licence are not evaluated

by a specific transport division, but by the division that is in charge of the

licensing of the use of the radioactive material involved. Transport is one of the

components of an application for a licence. The evaluation seems to be

performed essentially on an administrative basis, with less attention paid to

radiation and transport safety issues (e.g. the relevance or validity of transport

documents).

4.59. The licences are issued to the consignor. It must be noted here that the

importer or exporter is considered to be the consignor, although this is not

explicitly stated in the legislation. Eighty-six companies have been licensed for

the import, export, transit and transport of radioactive material. The licences

are valid for five years.

4.60. Each shipment is subject to a permit, also issued to the consignor. For

movements of radioactive sources for industrial radiography, the operator has

to notify the TAEK in advance. As a consequence, the TAEK is well informed

of movements of radioactive material and of the presence of radioactive

material in Turkey. For these purposes, the TAEK has set up a database that is

continuously updated.

4.61. It must be noted that permits are normally issued by the Ankara based

headquarters of the TAEK. However, the Health Physics Division of the

Istanbul based ÇNAEM issues customs clearances and approvals for shipments

of radiopharmaceutical products. The Health Physics Division of ÇNAEM

forwards to the RHSD, on a monthly basis, an overview of the permits and the

associated documentation.

4.62. A typical breakdown of the applications dealt with annually by the

TAEK is as follows:

(a) Transport permissions: 801.

(b) Special form designs: 0.

(d) Designs of packages containing fissile material: 0.

(e) Shipment approvals (as per para. 820 of the 1996 edition of the

Transport Regulations [1]): 0.

(f) Special arrangements: 0.

4.63. The TAEK has very little experience with applications for the approvals

referred to in para. 802 of the 1996 edition of the Transport Regulations [1].

Provisions in the (revised) Turkish regulation on the safe transport of

radioactive material do, however, deal with these applications. It is not clear

which division of the RHSD has been designated to evaluate these

applications.

Findings

4.64. Basis: Issuing permits for each movement of radioactive material lays a

heavy administrative burden on the TAEK. It could be argued that such a

system is not the optimal situation from the point of view of radiological

protection and the use of human resources.

Suggestion: It might be envisaged to replace the system of individual

permission by a more generalized system of prior notification (as applies, for

example, to movements of radioactive sources for industrial radiography),

giving the TAEK the opportunity to perform more specific inspections to verify

compliance with the Turkish regulation on the safe transport of radioactive

material.

4.65. Basis: Applications for a licence or a permit are handled by one of the

divisions of the RHSD, depending on the use of the radioactive material. It

must be noted that, as a consequence of the entry into force of the revised

regulation on the safe transport of radioactive material, the workload of the

RHSD may increase, due in particular to the multilateral approval of packages

that are still in use and that were approved in accordance with an earlier

edition of the Transport Regulations.

Suggestion: It is suggested that a specific division be set up within the RHSD

dedicated specifically to the transport of radioactive material, in particular the

evaluation of applications for approval, as mentioned in para. 802 of the 1996

edition of the Transport Regulations, which are not necessarily related to a

specific use of the radioactive contents. The personnel of this division would be

given the opportunity to improve their expertise in order to be able to perform

the necessary assessments. This division would also inform the different

divisions of changes in the regulations and ensure coordination between the

different divisions with regard to transport issues, and ensure in particular that

applications for licences and permits are handled in a consistent way.

Good practice: A database with information on the use, storage and movement

of radioactive material in Turkey is updated on a continuous basis. The system

is comprehensive and a well established practical tool for everyday work. It

might also be used for more specific inspections.

REVIEW AND ASSESSMENT PROCESS

Overview

4.66. There is no radioactive material packaging or special form material

production in Turkey, and hence no need to carry out a package design or

special form design assessment. There are, however, several imports to and

exports from Turkey each year of special form sources for medical and

industrial purposes. These are carried in a variety of packagings meeting IP,

Type A or Type B requirements, as necessary, and come from countries

worldwide. These packages have to be approved before they can be

transported within the country.

4.67. The package approval function is carried out by the RHSD. The power

to carry out this review and assessment work is provided in the regulations,

especially the regulation on the safe transport of radioactive material and the

radiation safety regulation. The latter is based on para. (d) of Article 4 of the

Turkish Atomic Energy Authority Act, Act No. 2690. Details of the actual

legislative route are covered in paras 4.13–4.37 of this report.

4.68. The review and assessment process is carried out in accordance with

Refs [1, 10]. The Turkish regulation on the safe transport of radioactive

material currently in force adheres to the 1985 edition of the Transport

Regulations [6], but the version that accords with the 1996 edition [1] is in draft

form and is currently being applied by the RHSD. The review and assessment

process is confined to checking the applicability of paperwork and whether the

package and special form certificates are applicable and valid. The check on the

special form paperwork and certificates is limited to the ISO designation for

use. No verification is made to confirm that the ISO designation is also suitable

to meet the requirements of para. 709 of the 1996 edition of the Transport

Regulations [1] if this paragraph is used to prove special form acceptance. No

mechanical assessment is carried out for packages currently requiring multi-

lateral approval, either in their own right or as required in para. 816 of the 1996

edition of the Transport Regulations [1] for packages approved under the 1973

or 1973 (as amended) editions of the Transport Regulations. It should be noted

that from 1 January 2004, Type B(U) packages approved under the 1985 or

1985 (as amended 1990) editions of the Transport Regulations also require

multilateral approval in accordance with the requirements of the transitional

arrangements in para. 817 of the 1996 edition of the Transport Regulations [1].

No checks are carried out to confirm that the packagings comply with

maintenance specifications or requirements. Operation and maintenance

instructions are not specifically requested. These documents should be

available, as they are required for an application for design approval (see para.

807(d) of the 1996 edition of the Transport Regulations [1]).

4.69. Modifications applicable to the design of packages are covered by

Article 54 of the radiation safety regulation. No modifications have been seen

to date. However, if this aspect arises in the future and thus requires review and

assessment, the TAEK will investigate the matter by contacting the relevant

competent authorities.

4.70. The main thrust of the assessment process is that RHSD personnel

check the paperwork provided by the importer for each shipment of

radioactive material. To assist in this work, the regulatory body is also able to

use external consultants, if necessary, to complement its review and assessment

activities. Relevant international experience gained from the IAEA and this

TranSAS appraisal will also be of benefit. In addition, RHSD personnel

occasionally visit the import point to check radiation levels, categorization,

marking, labelling and placarding. The authority for such visits is provided

under Article 67 of the radiation safety regulation. For Type B packages

containing

Co sources for teletherapy use, all imports and exports are

checked in this way, as well as the processes carried out at the site of use.

During these visits, a comparison verification is also carried out between the

TAEK records and those held by the personnel of the airline and the user of

the source.

Findings

4.71. Basis: Applications for approval of package designs are required to

have maintenance and operating instructions, as specified in para. 807(d) of the

1996 edition of the Transport Regulations [1], in order to gain a package design

certificate. Paragraph 561 of the 1996 edition of the Transport Regulations [1]

also states that the consignor shall have a copy of each certificate required by

these regulations, and a copy of the instructions with regard to the proper

closing of the package and other preparations for shipment, before making any

shipment under the terms of the certificates.

Recommendation: It should be ensured that the consignor has a copy of the

instructions, as required in para. 561 of the 1996 edition of the Transport

Regulations.

4.72. Basis: Packages currently approved under the 1973 or 1973 (as

amended) editions of the Transport Regulations require multilateral approval,

as specified in para. 816 of the 1996 edition [1]. As from 1 January 2004,

packages approved in accordance with the 1985 edition [6] will also require

multilateral approval, as specified in para. 817 of the 1996 edition [1].

Suggestion: As more packages become eligible for multilateral approval with

the introduction of the 1996 edition of the Transport Regulations, and in

particular pursuant to paras 816 and 817, some thought could be given to the

desirability of a formal assessment of designs of packages in this category and

of issuing a validation approval.

4.73. Basis: Applications for the approval of package designs are required to

have maintenance and operating instructions, as specified in para. 807(d) of the

1996 edition of the Transport Regulations [1]. It therefore follows that a

certified package should be maintained and used in accordance with these

instructions.

Suggestion: It is suggested that checks be made that certified packages have

been maintained in accordance with the approved maintenance instructions.

4.74. Basis: Turkey has developed a system of close checks and inspection for

the transport of every shipment of radioactive material coming into and going

out of the country. This work forms part of the overall control of radioactive

material while it is in Turkey.

Good practice: Overall control is exercised over radioactive material in Turkey.

This overall control includes transport aspects and therefore ensures that

packages that normally do not require competent authority certification under

the Transport Regulations (i.e. Type IP and Type A packages) are also

checked.

INSPECTION AND ENFORCEMENT

Overview of inspection

4.75. The Turkish competent authority does not have a separate section

dealing solely with quality assurance or quality compliance matters. All experts

that carry out inspections have to combine this aspect of their work with other

duties. The consignor’s declaration, together with the approval certificate and

any other documents provided, is examined for completeness and to confirm

that the packages are in conformity with the requirements of the 1996 edition

of the Transport Regulations [1]. For the transport of dangerous goods into

Turkey by air, reliance is placed on General Directorate of Civil Aviation and

Undersecretariat of Customs personnel. Following a visit to the Turkish

Airlines cargo department in Istanbul, it was found that Turkish Airlines had

an ISO 9002:1994 accreditation issued by the German Technischer Überwa-

chungsverein (Technical Inspection Association). Turkish Airlines was also

working towards accreditation to ISO 9002:2000. Each Turkish Airlines

department produces its own procedures based on the company’s quality

assurance manual. These procedures are audited by the company’s quality

assurance directorate annually in October. The procedures are also audited by

the General Directorate of Civil Aviation annually in August.

4.76. There is no specific planned and systematic programme for monitoring

the inspection and maintenance of packaging and the required activities of

consignors and carriers, as required in para. 311 of the 1996 edition of the

Transport Regulations [1], to provide evidence that the provisions of the

regulations are being met in practice. There are no specific inspection

procedures to provide evidence that the regulatory requirements related to the

applicable consignor’s responsibilities as specified in paras 548–561 and 801 of

the 1996 edition of the Transport Regulations [1] have been met or that any

required certificates are valid and applicable. However, the regulatory body

does visit some incoming and outgoing shipments to check radiation levels,

categorization, marking, labelling and placarding, to ensure that the shipments

conform to the related requirements of the 1996 edition of the Transport

Regulations [1]. These visit checks are carried out routinely on all incoming

and outgoing shipments of

Co sources in Type B packages and randomly on

all other sources that enter Turkey or leave a user’s site. These checks are in

addition to other non-transport related compliance work carried out by the

regulatory body. Any inspection visits deemed necessary are mostly

unannounced, and all expert inspectors are from the TAEK headquarters in

Ankara or from the ÇNAEM in Istanbul.

4.77. Inspections are carried out following an application for a licence to use

and transport a source. The application needs to be submitted before the

source enters Turkey. Details of this application procedure are covered more

fully in paras 4.58–4.65 of this report. The inspections are confined to the

requested transport only. Although these sources enter Turkey in packagings

designed, manufactured, tested and maintained outside the country, there are

no procedures to check that there are quality assurance programmes, as

required in para. 310 of the 1996 edition of the Transport Regulations [1], to

confirm that:

(a) The manufacturing methods and materials used are in accordance with

the approved design specifications;

(b) All packagings are periodically inspected and, as necessary, repaired

and maintained in good condition so that they continue to comply with

all relevant requirements and specifications.

4.78. Checks are also carried out on the adequacy of the person responsible

for transport, driver training aspects and vehicle suitability, emergency instruc-

tions (planning), package integrity control and personal dosimetry, as required.

The inspection requirements are stipulated in Article 67 of the radiation safety

regulation, which states that “The general principles of inspection shall be

implemented in conformity with the provisions of the related Articles of the

Decree, and in addition shall cover the following issues…” The inspection report

requirements are then detailed in Article 68 of the radiation safety regulation,

as is the procedure for dealing with unsatisfactory findings. The requirements

for the responsible party to control the adequacy of the services and

procedures supplied to it are detailed in Article 71 of this regulation, and the

regulatory body checks compliance accordingly. In the event of an abnormal

occurrence, experts or a group of experts, depending on the occurrence, are

assigned to investigate and report on the incident.

Overview of enforcement

4.79. The enforcement procedures are covered in Article 68 of the radiation

safety regulation, which provides that “The inspection report prepared by the

radiation safety experts of the Authority as a result of the investigations shall be

evaluated by the Radiation, Health and Safety Department. Following the

evaluation of the report, if it is determined that the provisions regarding radiation

safety and the licensing terms are violated, a period of maximum 3 (three)

months shall be given to eliminate the deficiencies and violations, and a written

notification shall be made to the licensee to this effect. If the deficiencies are not

eliminated, the licensee and the relevant bodies shall be notified on the decision

of temporary termination of the licence by the Presidency of the Authority. If the

specified deficiencies and violations are eliminated after the due time, the

decision on the temporary termination of the licence shall be lifted. The facility

cannot carry out any activity within this period. The licence shall be revoked if

deficiencies and violations are not eliminated.” In the event of a non-

compliance, regardless of its severity, the regulatory body can proceed to

investigate the occurrence, and the resulting actions will be as specified in

Article 75. This article provides that “If it is determined that the activity is

carried out without a licence or if the conditions of the licence are violated and

the other provisions laid down in the Regulations are not complied with, the

Authority shall apply to authorized bodies to start legal proceedings within the

frame of the general principles of law.” The regulatory body does not have the

legal power to immediately order the non-compliant organization to cease

operations, but it can suspend or withdraw the licence of the organization, as

stated above in Article 68.

4.80. Concerning reporting requirements, the radiation safety regulation

covers the following requirements:

(a) The basic arrangements and requirements for the responsible party for

incident reporting (Articles 42, 43, 46 and 47);

(b) The reports that the responsible party must submit to the regulatory

body (Articles 54, 55, 56, 57 and 60);

frame for record keeping (Article 69);

(d) The notification of import shipment requirements (Article 62);

(e) The notification of export shipment requirements (Article 66).

4.81. The causes and consequences of accidents and incidents are analysed to

draw lessons from these events (‘lessons learned’), and reports of accidents are

published on the web site of the TAEK with the particulars of the events,

including what actions were taken in response, in Turkish and English. The

requirements for keeping records on accidents are detailed in Article 69(d) of

the radiation safety regulation.

Findings

4.82. Basis: The overall control of the movement of radioactive sources in

Turkey is good and is covered either by a documentation check or a documen-

tation check complemented by site visits. However, Turkey does not have a

planned and systematic programme for inspection and audit of packages, as

required in paras 310 and 311 of the 1996 edition of the Transport Regulations

[1].

Recommendation: A planned and systematic programme should be

implemented for quality assurance and compliance assurance concerning the

inspection and audit of packages, as required in paras 310 and 311 of the 1996

edition of the Transport Regulations.

4.83. Basis: It was noted during the visits that many forms were completed in

non-SI units. Moreover, many measuring instruments in use also gave readings

in non-SI units. This is acceptable for compliance with the 1985 edition of the

Transport Regulations [6], as the 1985 edition uses data in both SI and non-SI

units and the Turkish regulations currently in force still reflect the provisions of

that edition. However, the new Turkish regulation, which has not been

promulgated but is now being observed, reflects the provisions of the 1996

edition [1], which expresses units in the SI system exclusively.

Suggestion: It is suggested that paperwork be completed in SI units and that

measuring instruments also display SI units. This will avoid confusion and

misinterpretation and will ensure consistency.

4.84. Basis: Approval of the various activities involved in the transport of

radioactive material can be undertaken by different authorities (for further

details see paras 4.1–4.47 of this report). The TAEK is consulted on this matter,

owing to its acknowledged expertise in the field of the use and transport of

radioactive material. This situation could lead, however, to an overlap of

responsibilities in the inspection and enforcement areas. It is important,

therefore, that the responsibilities of the various authorities be defined and

clarified by memoranda of understanding.

Suggestion: It is suggested that memoranda of understanding be produced to

determine the responsibilities and interfaces between the various authorities

involved in the inspection and enforcement activities carried out in support of

authorizations for the transport of radioactive material.

DEVELOPMENT OF REGULATIONS AND GUIDES

Overview

4.85. In Turkey the revision of, and development of new, regulations on the

transport of radioactive material is the responsibility of the RHSD, with the

Standing Commission on Legislation playing a role. Draft proposals for new

regulations or the revision of current regulations are to be submitted to the

Atomic Energy Commission.

4.86. According to Turkish law, all orders are mandatory. The hierarchy of

regulations can be described as follows:

(a) Acts, which have to be signed by Parliament;

(b) Decrees, which have to be signed by all ministers of the Government;

Minister;

(d) Instructions (e.g. licence instructions for applicants and/or licensees),

which have to be approved by the President of the TAEK and signed by

the director of the relevant department.

4.87. The regulations and guides that are now applied to the transport of

radioactive material are described in paras 4.1–4.40 of this report. As

mentioned, the RHSD is responsible for the development of new orders and

guides in the field of the transport of radioactive material. In developing

regulations and guides, the regulatory body (the TAEK) takes into account

staff experience, enforcement results, the findings of investigations and interna-

tionally recognized standards.

4.88. To date in Turkey, pursuant to Article 65 of the radiation safety

regulation, only the regulations set forth in Ref. [6] are mandatory. However,

the TAEK has prepared a draft Turkish translation of the 1996 edition of the

Transport Regulations [1]. This draft has to be reviewed by all relevant

authorities (the General Directorate of Civil Aviation, the General Directorate

of Road Transport, the Undersecretariat of Maritime Affairs and the Under-

secretariat of Customs). It then has to be approved by the Atomic Energy

Commission and signed by the President of the TAEK. After clearance by the

Prime Minister, the regulation can be published in the Official Gazette. At the

time of the appraisal it was expected that the Turkish version of the 1996

edition of the Transport Regulations [1] would come into force around the end

of 2003.

4.89. The Ministry of Transport, General Directorate of Civil Aviation, is

responsible for the implementation of the ICAO Technical Instructions. For

transport by sea and the general implementation of the IMDG Code for

Turkey, the Undersecretariat of Maritime Affairs is responsible. For road and

rail transport regulations, the Ministry of Transport has the lead responsibility.

Findings

4.90. Basis: As provided in Article 4 of the Turkish Atomic Energy Authority

Act, the TAEK, as the competent authority, is responsible for the implemen-

tation of the regulation on the safe transport of radioactive material for all

modes of transport. Nevertheless, the present regulations of the Ministry of

Transport (for air and sea transport) refer to the newest version of the IMDG

Code and the ICAO Technical Instructions. At present these are contradictory

for radioactive material, as the IMDG Code and ICAO Technical Instructions

refer to the 1996 [1] edition of the Transport Regulations, while the Turkish

regulation on the safe transport of radioactive material refers to the 1985 [6]

edition.

Suggestion: In order to avoid discrepancies between the implementation of the

various editions of the Transport Regulations (and potential safety hazards), it

is suggested to simultaneously apply in Turkey the same regulations for the

national and international transport of radioactive material (i.e. to formally

promulgate the Turkish translation of the 1996 edition of the Transport

Regulations as soon as possible).

4.91. Basis: According to the radiation safety regulation, Part IV, Chapter II,

Article 61, the TAEK has to issue for each single shipment a permit (in

addition to the general licence, which each applicant and licensee needs to

obtain).

Suggestion: It is suggested to change Article 61 of the radiation safety

regulation so that authorizations are issued in a more generic way, for example

to issue permits covering the same material in the same package, for a given

time frame (e.g. 6 months or 12 months).

4.92. Basis: Concerning the radiation safety decree, the use of non-SI units

(Ci) and of SI units (Bq) is allowed for quantifying activity. In addition, non-SI

units are applied for the equivalent dose (rem) and the absorbed dose (rad).

Suggestion: It is suggested for the ongoing revision of the radiation safety

decree to use only SI units, so as to be in line with the international regulations

in the field of radiation protection, especially with the Transport Regulations

and the Turkish radiation safety regulation.

4.93. Basis: Both a decree and a regulation deal with radiation safety in

Turkey, but the transport of radioactive material is mentioned only in the

regulation.

Suggestion: In order to be in line with the other international standards for

radiation safety and radiation protection (e.g. the International Basic Safety

Standards for Protection against Ionizing Radiation and for the Safety of

Radiation Sources), it is suggested that the transport of radioactive material be

incorporated into the radiation safety decree.

4.94. Basis: It is a common practice to have a standing commission within the

TAEK that includes representatives from different divisions within the RHSD

to formally review changes to the regulations.

Suggestion: It is suggested that expanded responsibilities may justify the

creation of a separate division within the RHSD that would be dedicated to the

transport of radioactive material.

EMERGENCY PREPAREDNESS FOR TRANSPORT

Overview

4.95. Turkey has a regulation on nuclear and radiological national emergency

preparedness, which was issued in the Official Gazette on 15 January 2000. This

regulation was prepared taking into consideration related IAEA technical

documents [20–22]. Since Turkey does not operate nuclear power plants, this

regulation deals mainly with off-site emergencies, and provides for organiza-

tional aspects, roles and responsibilities. Roles and responsibilities are clearly

identified for each participating organization. According to the relevant

national legislation, a national crisis management centre has to be set up

immediately for Category I and Category II accidents. All the responsible

organizations are represented in this centre. The chairperson of the centre is

the Prime Minister.

4.96. For Category III, IV and V accidents, the TAEK organizes, coordinates

and handles all aspects of the situation. Category IV includes transport. In the

event of an emergency in the transport of radioactive material, the TAEK

decides and provides advice on all protective measures. However, implemen-

tation of these measures is carried out with other participating organizations

(e.g. the Ministry of Health, Ministry of Agriculture, Ministry of Interior

(General Directorate of Civil Defence, Police Department), Ministry of

Environment and Turkish Red Crescent Society). In the event of an accident,

all users involved in the transport of radioactive material can call the TAEK by

dialling the toll free number that is displayed on a label that is affixed on all

packages used for radioactive material in Turkey.

4.97. The TAEK has a nuclear and radiological emergency implementation

plan (emergency plan) aimed at determining the measures to be taken and

activities to be performed for the protection of individuals, the public and the

environment in the event of an emergency. The emergency plan is to be

activated with the first notification of an emergency and deactivated when all

governmental agencies have terminated their responses. The TAEK is the lead

organization and coordinates all the radiological aspects of the governmental

response. In this plan, the emergency organization, pre-emergency prepar-

edness activities and protective measures are outlined. In addition, the plan

details items such as the intervention levels, contact points of national and

international organizations, notification procedures and inventory of

measuring equipment. The plan is updated annually.

4.98. According to the radiation safety regulation issued in the Official

Gazette on 24 March 2000, all users, importers and transporters are obligated

to prepare an emergency preparedness plan as part of the licensing procedure

(Article 39, Article 71(h)). In accordance with Article 41 of the regulation, this

plan has to be approved by the TAEK.

4.99. According to Article 40 of this regulation, the plan should include:

(a) The names, titles, addresses and telephone numbers of the persons

assigned for emergency and accident response;

(b) A description of the communication system, with identification of the

responsible persons;

(d) Probable accident scenarios and the precautions to be taken;

(e) A description of the equipment, tools and devices necessary to respond

to an emergency.

4.100. Concerning the requirements for accident reports, Article 43 of the

radiation safety regulation further provides that “Following the termination of

the accident or emergency cases, the characteristics of the accident, the doses

received by the radiation worker and other individuals, and the ways and reasons

for body intake of radioactive substances shall be investigated by the Licensee or

an expert assigned by the Licensee, and the Authority shall be notified promptly

about the results with a report accompanied by the films, and/or TLD dosimeter

and the chromosome aberration test results, if required.”

4.101. Pursuant to the legislation on the national crisis centre for emergencies

and the emergency plan of the TAEK, an emergency response centre (ERC)

has been established and is operational; it is managed by the President of the

TAEK, with the participation of the representatives of the related departments

in the TAEK. The ERC is responsible for emergency preparedness and for the

management of emergencies relating to nuclear accidents and radiological

emergencies. In the event of an emergency, the ERC coordinates all the radio-

logical aspects of the response. Competent groups in the ERC decide and

provide expert advice on all emergency activities. However, the implemen-

tation of these activities is carried out in coordination with the related

departments of the TAEK. The ERC is linked with national and international

information and data centres on-line (i.e. the Emergency Response Centre of

the IAEA, the International Nuclear Event Scale, the Power Reactor

Information System, the European Centre for Medium-Range Weather

Forecasts, the Early Warning Environmental Radiation System (RESA) of the

TAEK (with 66 online RESA stations in operation around the clock) and the

national authorities involved in crisis management).

4.102. At the international level, Turkey is a party to the Convention on Early

Notification of a Nuclear Accident and the Convention on Assistance in the

Case of a Nuclear Accident or Radiological Emergency. Turkey entered into

bilateral agreements on early notification of a nuclear accident and exchange of

information on nuclear facilities with Bulgaria on 28 July 1997 and Ukraine on

23 November 2000. In the event of an emergency, the ERC of the TAEK is the

national contact point for the implementation of these conventions and

agreements. Further agreements of this type are under negotiation with the

Russian Federation and Romania.

4.103. For emergency arrangements according to the emergency plan and the

radiation safety regulation, emergency exercises are proposed to be held at least

once a year. The TAEK, with the cooperation of related organizations, is

responsible for training the related personnel. The exercise scenarios are prepared

at the local level by licensees of the facilities according to their emergency plans

and by the TAEK at the national level with the collaboration of related organiza-

tions such as governors’ offices and related ministries. The scenarios take into

account all probable radiological accidents, which may include car accidents, theft

of material and sabotage. The exercises are performed annually, and all partici-

pating organizations have their own budget for these purposes.

4.104. For nuclear and radiological emergencies, the TAEK is responsible for

public information, with the cooperation of the Ministry of Interior, the

Ministry of Education, the Ministry of Health, the Ministry of Environment

and the Ministry of Agriculture (in accordance with Article 10 of the nuclear

and radiological national emergency preparedness regulation).

4.105. In general, the following information can be released to any member of

the public:

(a) The location of the accident;

(b) The nature of the hazard and risks;

(d) The protective measures to be taken;

(e) The final results of emergency response actions;

(f) The recommended follow-up.

Finding

4.106. Basis: Emergency preparedness regulations and capabilities are well

developed in Turkey. These address all aspects of the transport of radioactive

material as a part of the use of radioactive material.

Good practice: The emergency capabilities for the transport of radioactive

material have been incorporated into the overall emergency preparedness

structure across the country. The regulations of Turkey in the area of the

transport of radioactive material, and the nuclear and radiological emergency

plan, which is updated by the TAEK every year, are a good basis for emergency

response, which also extends to the transport area.

5. GENERAL CONCLUSIONS

5.1. The appraisal team completed a thorough appraisal of the implemen-

tation of the transport regulations in Turkey. The cooperation of the Turkish

authorities, and of all those who participated in the discussions, was excellent

and contributed much to the value of the appraisal.

5.2. The transport of the relatively small number of packages of radioactive

material in Turkey is well controlled. Customs regulations specify permission of the

TAEK for the import of radioactive material. Only companies licensed by the

TAEK can import, export, transit and transport radioactive material. Each

shipment of radioactive material is subject to a permit from the TAEK. A compre-

hensive database with information on the use, storage and movement of

radioactive material is updated on a continuous basis. This high level of control and

monitoring enhances the safety of the transport of radioactive material in Turkey.

5.3. A draft revision of the national transport regulations based on the 1996

edition of the Transport Regulations [1] has been used in Turkey since the

requirements of these Transport Regulations became effective for interna-

tional transport in 2001. It is recommended that these draft regulations be

approved formally as soon as possible.

Appendix I

ABBREVIATIONS

The abbreviations below are for the purposes of this report only.

ADR European Agreement Concerning the International

Carriage of Dangerous Goods by Road

ÇNAEM Çekmece Nuclear Research and Training Centre

COLREG Convention on the International Regulation for Prevention

of Collision at Sea

ERC emergency response centre

EU European Union

IATA International Air Transport Association

ICAO International Civil Air Organization

IMDG Code International Maritime Dangerous Goods Code

IMO International Maritime Organization

RESA Early Warning Environmental Radiation System

RHSD Radiation Health and Safety Department

RID Regulations Concerning the International Carriage of

Dangerous Goods by Rail

SOLAS International Convention for the Safety of Life at Sea

Convention

TAEK Turkish Atomic Energy Authority

TESST Tibbi Endüstriyel Sistemler Sanayi ve Ticaret Ltd ti

(Medical Industrial Systems Limited)

TSS traffic separation scheme

UMA Undersecretariat for Maritime Affairs

UNECE United Nations Economic Commission for Europe

Appendix II

THE TURKEY TRANSPORT SAFETY APPRAISAL SERVICE TEAM

L. BAEKELANDT — Team member

L. Baekelandt is a physicist and at present Head of the Regulatory and

Licensing Department of the Federal Agency for Nuclear Control, Belgium.

He started his professional career as an assistant at the Institute for Theoretical

Physics at the Catholic University of Leuven. From 1973 to 1988 he worked for

the competent authority for radiation protection and nuclear safety at the

Belgian Ministry of Public Health and the Environment. In 1988 he moved to

the Belgian Agency for the Management of Radioactive Waste and Enriched

Fissile Materials, where he served as an adviser to the general management in

charge of radiological protection, environmental protection and safety issues.

In May 1999 he was appointed Head of the Regulatory and Licensing

department of the newly established Federal Agency for Nuclear Control, the

regulatory authority for radiation protection and nuclear safety, which is also

competent in the area of the transport of radioactive material. In this capacity

he is involved in the implementation of the Belgian and international

regulations dealing with the transport of radioactive material.

He has been involved in several revisions of the Transport Regulations and in

developing the supporting explanatory and advisory material. He has lectured

at several IAEA transport training courses and IAEA workshops.

L. Baekelandt is also Chairman of the IAEA Waste Safety Standards

Committee (WASSC). He participated in the TranSAS appraisal of Brazil.

G.J. DICKE — Team leader

G.J. Dicke is a Transport Safety Specialist in the IAEA Transport Safety Unit

of the Division of Radiation, Transport and Waste Safety, Vienna, Austria. He

is the Scientific Secretary for the annual IAEA meetings on the review and

revision of the Transport Regulations. He represents the IAEA at meetings of

the United Nations Committee of Experts on the Transport of Dangerous

Goods and the Dangerous Goods Panel meetings of the ICAO for the incorpo-

ration of the Transport Regulations into the United Nations model regulations

and the ICAO Technical Instructions. He chairs the annual interagency

meeting with the ICAO, United Nations and IMO in support of the

harmonized and integrated implementation of the Transport Regulations into

the United Nations model regulations and the international modal transport

regulations. G.J. Dicke had the lead role in the development of the working

procedures and the questionnaire for the IAEA TranSAS service and has

served as Team Leader or co-Team Leader for all TranSAS appraisals to date.

Prior to joining the IAEA in May 1997, G.J. Dicke worked for 26 years for the

Nuclear Operations Division of Ontario Hydro in Canada. For close to 20 years

he was responsible, initially as Unit Head and later as Section Head, for the

operational and regulatory aspects of Ontario Hydro’s transport of radioactive

material. He completed his doctoral examinations in chemical engineering at

Delft University in the Netherlands. He is a Professional Engineer in Ontario,

a Member of the Chemical Institute of Canada and a Member of the Editorial

Board of the International Journal of Transport of Radioactive Material.

C. FASTEN — Team member

C. Fasten is a physicist and a Scientific Co-worker at the Bundesamt für Strah-

lenschutz in Germany. She has been working in the radiation protection field

since 1974 and has held responsibilities in the field of the safe transport of

radioactive material since 1983.

At the Bundesamt für Strahlenschutz (the competent authority for the safe

transport of radioactive material in Germany) she has been involved in the

implementation by Germany of the 1985 edition as well as the 1996 edition of

the Transport Regulations in Germany and the incorporation of these require-

ments into international agreements for road and rail transport. She has

worked as the international chairperson of the United Nations Joint Meeting

on the RID Safety Committee and the Working Party on the Transport of

Dangerous Goods. This joint meeting prepared the revisions to the RID/ADR

regulations for the rail and road mode in Europe. These revisions have

included the incorporation of all the requirements of the Transport Regulations

into the RID/ADR regulations.

C. Fasten’s work with the IAEA has included participation in meetings on the

review and revision of the Transport Regulations and related Consultant

Services Meetings since 1984. At these meetings she has often been a Group

Leader or Secretary. She has also coordinated the IAEA Transport Safety

course in Germany and has lectured in IAEA training courses.

A.R. WEBSTER — Team member

A.R. Webster is an Assessment Engineer in the Mechanical Assessment

Branch of Radioactive Materials with the Transport Division of the

Department for Transport, which acts as the competent authority in the UK.

He has worked for the UK civil service for over 39 years, starting his career in

the Ministry of Defence and then transferring to his current post in 1985,

thereby having over 17 years’ experience in the field of radioactive material

transport and the mechanical assessment of radioactive material transport

packages for all categories of packaging of the Transport Regulations.

He has previously served as a member at several IAEA Consultants Services

Meetings and Technical Services Meetings to develop UF

transport

regulations and the brittle fracture guidelines, Appendix VI of the IAEA

Advisory Material for the Regulations for the Safe Transport of Radioactive

Material, Ref. [2] in this report. He has also chaired an IAEA Technical

Committee Meeting convened to evaluate methods of communicating

information on the level of safety provided during the modal transport of

radioactive material. In addition, he has contributed to the Regulatory Review

Process by acting as both Working Group Secretary and Chairman at two past

review sessions.

A.R. Webster is also a member of two ISO working groups reviewing and

developing International Standards for UF

Packaging (ISO 7195) and

Leakage Testing on Packages for the Safe Transport of Radioactive Materials

(ISO 12807). He also served on an international working group that provided

the Class 7 input to the restructured version of RID/ADR.

A.R. Webster is an Incorporated Engineer and a member of the UK Institution

of Incorporated Engineers.

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