The regulations are set so that in most cases the transport containers and shipping requirements are predefined. However the regulations recognize that not all shipments will fit into the predefined requirements and provide a mechanism called, a “special arrangement”, to deal with these individual approvals. The special arrangement review ensures that the shipment will achieve a level of safety that is equal to or greater than what is required for routine shipments.
A special arrangement is not unique to Canada, and is internationally used and recognized. A special arrangements permit is required because the steam generators are too large to fit into one of the standard approved transportation containers. However, the heavy steel outer shell container has been assessed and meets all the requirements of the CNSC, Transport Canada, IAEA and the International Maritime Organization (IMO). Most importantly, the surface radioactive contamination is only on the internal surfaces and is therefore not accessible during any stage of transport.
In addition to the stringent requirements for the container, there are specific regulations for each of the four steps in the Bruce Power recycling plan:
- Road transport to Owen Sound
- Ship transport to Sweden
- Offloading in Sweden
- Returning the low level waste to Canada
The following pages identify the regulations for each of these steps and show how our plan A special arrangement permit is required because the steam generators are too large to fit into one of the already approved standard transportation containers. As a result, Bruce Power’s application for a special arrangement permit has raised concerns that transporting the steam generators is unique, specially hazardous and precedent setting. The facts show that is is simply not true.
- Transportation by road is typical of thousands of oversized and overweight shipments on Ontario roads each year. Indeed, the steam generators are exactly the same size and weight as the 16 new ones previously shipped on Ontario roads without incident.
- The steam generators are low level radioactive waste. However, the radioactivity is completely contained and isolated inside a 2-inch thick heavy steel outer shell. This container or “package” is far stronger and more robust than regulations require.
- Aspecial arrangement permit does not imply any reduction in the level of safety during transport. Indeed, the regulations governing special arrangement permits explicitly require that nuclear substances transported under the special arrangement permit must be as safe or safer than routine shipments.
A special arrangement permit is required because the steam generators do not meet the specific requirements that apply to routine transportation of nuclear substances, including being able to fit into an already approved standard container.
The regulations anticipate that some shipments would fall into this category and clearly set out the rules that must be followed for non-routine shipments. Transportation throughout all steps of Bruce Power’s recycling plan meets or exceeds the requirements to ensure that the shipment is as safe or safer than routine shipments.CNSC specialists have reviewed Bruce Power’s transportation plans and concluded that the shipment would comply with all applicable Canadian and international regulations.
These specialists agree:
- The activity contained within the steam generator has been adequately estimated
- The radioactive characterization assumptions used by Bruce Power are correct
- The steam generators are appropriately classified as “Surface Contaminated Objects – Group 1”, the lowest categorization under the regulations
- The proposed tie-down and configuration during transportation meets all requirements