From the IAEA

"...the safety standards currently used for multimodal approval of package designs do not cover the same large fraction of possible conditions likely to be encountered in an aircraft accident as are encountered in sea or land mode accidents." IAEA Tecdoc702, p.11

"It would be relatively simple ot specify a performance test for a package which would guarantee that no package would ever fail in an accident situation. such a performance test would reduce public risk from transport of radioactive material or radiation exposure to zero, but would exact a tremendous economic toll from world economies." Ibid, p. 15

" The next edition of the Regulations . . . will provide the first occasion to introduce the new testing and acceptance criteria for the Type C packages. Until that time, organizations wishing to transport radioactive material by air can only do so in accordance with conditions based on the 1985 edition of the Regulations. Clearly, individual states have the option to forbid this if they wish." Ibid, p. 35

". . . the incorporation of higher speed impact is clearly justified. This is the accident environment which has great potential to exceed the capability of ordinary Type B packagings. Similarly the thermal impact to packagings in the air mode has the potential to be somewhat greater than in surface modes as a result of the amount and proximity of fuel to the packages, the potential for burning of aircraft structural materials and the potential for fires in areas where no effective fire-fighting can be provided in short time. In addition, a fuel fire in an aircraft crash, instead of being a relatively rare event as it is on road and rail, is the dominant scenario." Ibid, p. 37

"...The difficulties, (or the alleged impossibility in some cases,) of producing Type C packages and their high production costs were cited as supporting the need for the adoption of the VLDM concept." Fourth Technical Committee Meeting on the Revision of the IAEA Regulations for the Safe Transport of Radioactive Material, Vienna, September 25-29, 1995

U.S. Government Objections

"On numerous occasions, the United States has stated its belief that all large quantities or high activities of radioactive materials, as defined by the IAEA, should be subject to the air transport packaging standards and that an exemption based on dispersibility of a material is not justified....Although the concept of VLDM [very low dispersible material] makes intuitive sense, we believe its adoption negates the original intent for developing air transport standards. Furthermore, we believe this concept is too immature for inclusion into the 1996 edition of Safety Series No. 6 and we would propose it be reviewed by either a Consultants Service Meeting or an independent party. Specifically, we are concerned that the [proposed radioactive] release limit has not been used previously in the regulations and is not based on any defined model or rationale and that no risk analysis has been conducted on this proposal...." U.S. position paper, "Issue Related to the Air Transport of High Activity Packages and the Concept of Very Low Dispersible Material, 1995.

". . . the proposed Type C standards are less restrictive than the current U.S. legal requirements for the air transport of plutonium. Accordingly, as you have noted in your letter, U.S. delegations have repeatedly advised IAEA and its member state representatives, that any air shipment of plutonium (including mixed oxide fuels) to, from, or over the United States will be subject to U.S. legal requirements, regardless of IAEA standards. . . . Further, in the attempt to achieve compatibility with IAEA, U.S. delegations have on several occasions advanced the adoption of its legally mandated plutonium standards as the IAEA's general air mode standards. However, the technical experts from other member states have consistently declined to support the more stringent U.S. standards." Letter to NCI from James M. Taylor, Executive Director for Operations, U.S. Nuclear Regulatory Commission, and U.S. representative to the IAEA Advisory Commission on Safety Standards, August 1, 1996

From the Aviation Associations

". . . IFALPA firmly believes that if radioactive materials were to be transported in any form other than solid, . . . the packaging as detailed in the TECDOC is inadequate. In consideration of accidents, the worst-case scenario should always be considered as failure of the airframe at high altitude. This could result in an unacceptable distribution of these materials into the upper atmosphere, causing a major ecological catastrophe. . . . the Federation believes that the testing requirements for Type C packages should be equivalent to the more stringent criteria developed in the United States: NUREG 0360." Letter to the IAEA from International Federation of AirLine Pilots Associations (IFALPA), 8 July 1994

"The conclusion of the [Dangerous Goods] Board [of IATA] was that notwithstanding the increased level of safety afforded by this packaging type, the ability of the package to withstand crash conditions could and should be improved to the levels already prescribed the United States regulation and required for flight data records, the so-called black box. The Board considers that such performance is readily achievable for little cost . . . The Board agrees with the representatives from IFALPA and ICAO and strongly suggests that this higher performance standard be adopted." Letter to the IAEA from International Air Transport Association, 1 August, 1994

State Prerogative to Prohibit Plutonium Overflights

"The situation is that dangerous goods, including plutonium, are regulated in accordance with the International Civil Aviation Organization Convention to which over 100 countries belong, which stipulates that states retain the power to apply their domestic regulations concerning the carriage of cargo to international overflights. We also have to keep in mind that we have already filed with ICAO what is called a state variation, which requires our approval for any overflight transporting fissile material across Canadian air space." The Honorable John C. Crosbie (Canadian Minister of Transport), House of Commons Debates, November 5, 1987

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