I.1 (Comment) ìThe Government could change air regulations. Could fly over less populated areas.î

I.1 (Transport Canada Response) ìNot until there were a container deemed safe enough to survive all credible airplane accidents.î

I.2 (Comment) ìNotes that the United States do not want to fly the shipment.î

I.2 (Transport Canada Response) ìIt is presently against both Canadian and United States law to fly the MOX test samples.î
 

Transport Canada Review of Two Emergency Response Assistance Plans Proposed by the Atomic Energy of Canada Limited for the Importation of up to Six Shipments of Test Samples of MOX Fuel, Transport Canada, Safety and Security, Dangerous Goods, November 4, 1999

Summary of Main Concerns/ Comments, page 46

"The fuel test elements will be transported directly by truck from Los Alamos National Laboratory to Chalk River Laboratories without additional handling at the border crossing.  The same transport will be used throughout." 
 

Atomic Energy Control Board, "Canadian Regulations Regarding MOX Parallex Tests and Possible Use of MOX Fuel in Canadian Power Reactors", Nov. 17, 1997, page 2.,
web reference: http://ulysses.srv.gc.ca/
aecb/docs/mox/moxe.htm

"Federal regulations under 10 CFR 71.88 (Air Transport of Plutonium) explicitly prohibit the transportation of plutonium by air or the delivery to a carrier for air transport unless the plutonium is 1) in a medical device, 2) in a form with a specific activity no greater than 0.002 uCi/g, 3) shipped in a single package with no more than a specified quantity, and 4) shipped in a specifically authorized NRC-package with a Certificate of Compliance. Plutonium is a component of MOX fuel. 

ìThe restrictions imposed for transportation of plutonium by air prohibits this alternative for shipment of the MOX fuel quantities needed for the Parallex Project. In addition, air transport is considered to be more hazardous than ground transport due to the potential for greater distribution of radioactive materials in the event of a major air accident. This alternative was dismissed from further analysis."
 

US Department of Energy, Office of Fissile Materials Disposition, DOE/EA-1216 Environmental Assessment for the Parallex Project Fuel Manufacture and Shipment, Los Alamos National Laboratory Los Alamos, New Mexico, January, 1999, Washington, DC, Page 17

"Air transport, rail, and highway transport are all possible modes of shipping the LANL MOX fuel to CRL. However, evaluations done for the USDOE [3] eliminated both air transport and rail options from further consideration. Accordingly, highway transport was the only mode considered in the current Canadian evaluation." 
 

AECL, Canadian Transportation Plan for the PARALLEX Project-Los Alamos to Chalk River Shipment, 100-37000-TD-003, Revision 0, 1999 August, Page 10 of 26

ìHow much plutonium, contained in so-called "low dispersible" MOX fuel, could be released in the event of a high-velocity air crash which the shipping cask would not be capable of surviving? Impact studies of uranium fuel pellets indicate that in the relevant range of impact energies (e.g. speeds of 90-130 m/s), roughly 1-10 joules per gram of material, from 0.1 - 1 percent of the fuel will be released in the form of particles less than ten microns in diameter, which can be easily inhaled and retained deep in the lung.î

ìA rapid release of one kilogram of plutonium at ground level in dispersible, inhalable form would cause a public health emergency of the first magnitude. Plutonium air concentrations could be on the order of hundreds of micrograms per cubic meter of air at one kilometer from the release site. Individuals breathing this air would inhale enough plutonium to cause cancer with certainty within minutes. In the worst case, a crash in a densely populated area could cause tens of thousands of latent cancers."
 

Edwin S. Lyman, PhD, Nuclear Control Institute, excerpt from: "Technical Backgrounder: ìPlutonium Air Shipments",  September 4, 1996
web reference:  
http://www.nci.org/
ib9496.htm
 

ìPlutonium is an alpha-emitting transuranic element. Of the possible routes of entry into the body, the most common and most dangerous is through inhalation. In addition to irradiating lung tissue, plutonium is gradually transported to other organs, in particular, liver and bone. Once an alpha-emitter is inside the body, its radiation can cause genetic mutations and cancer with greater potency than gamma or beta radiation of the same energy. ... Experiments with beagle dogs suggest that about 27 millionths of a gram of insoluble plutonium would be sufficient to cause lung cancer in an adult human being with virtual certainty, with significant risks probably associated with far lower doses.î 

Note: 100 million micrograms is equivalent to 100 grams.
 

International Physicians for the Prevention of Nuclear War, Institute for Energy and Environmental Research, Plutonium, Deadly Gold of the Nuclear Age, International Physicians Press, Cambridge, Mass., 1992, page 148
 

"A number of mechanisms exist which could result in a dispersal of plutonium from unirradiated MOX fuel rods in the event of a severe transport accident. Substantial releases could occur if the fuel rods were subjected to a high-velocity impact which breached the cladding, followed by a fire of moderate temperature (as low as 500°C) of several hours' duration. Exposure of the fuel pellets at this temperature to oxygen flowing through the breach would cause (disintegration into small particles)... A large fraction of these particles would be small enough to be easily dispersed in aerosol form by the flames of the fire.î

ìFuel melting, although less likely, cannot be excluded. ... Plutonium dioxide has a lower melting point than uranium dioxide and, if it is not uniformly distributed in the MOX fuel, it is possible that localized melting of MOX fuel can occur at temperatures hundreds of degrees lower, which would be in the range of temperatures encountered in aviation fuel pool fires."
 

Edwin S. Lyman, Ph.D Nuclear Control Institute, Behavior of Mixed-Oxide Fuel Under Transport Accident Conditions", September 21, 1995
web reference:
http://www.nci.org/
ib8596a.htm

"The shipment classification for the MOX pellets will be Type B(U)F. The shipping Package will be a Type B(U)F, specifically an "Atomic Energy of Canada Limited Model 4H Enriched Fuel Bundle Shipping Package""
 

AECL, Canadian Transportation Plan for the PARALLEX Project-Los Alamos to Chalk River Shipment, 100-37000-TD-003, Rev. 0, 1999 August, Page 8 of 26
 

ìType B casks only have to survive an impact speed of 13.2 meters/second (30 mph) and a 30-minute, 800 degrees C. fire.î

ìWhile Type C standards are more stringent than Type B standards, they are not stringent enough to guarantee that air transport of radioactive material will be acceptably safe.î

ìType C casks will be designed to survive an impact of 90 meters/second (203 mph) on an ìunyieldingî surface and a 60-minute fire.î

ìIn establishing its new standards, the IAEA (International Atomic Energy Agency) has ignored the criticism of professional aviation organizations. The Dangerous Goods Panel of the International Civil Aviation Organization regards the Type C impact speed, fire temperature and lack of sequencing of impact and fire tests as insufficiently severe.î
 

The Facts About Air Transport of Mixed-Oxide Fuel, Nuclear Control Institute, June 20, 1997
web reference:
http://www.nci.org/
pr62097.htm

see also:

"Status Report on Air Shipments of Plutonium" by Sharon Tanzer, updated: August 28, 1996
web reference: 
http://www.nci.org/
ib82896.htm
 

ìU.S. law bars shipments by air of plutonium until the Nuclear Regulatory Commission licenses a container that ìwill not rupture under crash and blast-testing equivalent to the crash and explosion of a high-flying aircraft.î

The Facts About Air Transport of Mixed-Oxide Fuel, Nuclear Control Institute, June 20, 1997
web reference:
http://www.nci.org/
pr62097.htm