Transport of Radioactive Materials in Brazil

Transport of radioactive material in Brazil shall be performed in full compliance with safety requirements as established by several different authorities. The Brazilian Nuclear Energy Commission-CNEN is the competent authority for transport regulations, but there are also requirements from the Ministry of Transportation (MT) and the Institute for Environmental and Renewable Resources (IBAMA). CNEN was created in 1956 and reorganized in 1962, becoming the regulatory body in charge of promotion, regulation and control of nuclear energy. IBAMA, created in 1989, is responsible for executing and enforcing the National Environmental Policy. According to Brazilian regulations, requests for transport of radioactive materials must be submitted to both CNEN and IBAMA. Compliance with safety requirements and environmental laws has to be demonstrated in a Contingency Transportation Plan, which includes material description, packaging selection and certification, and, procedures and documentation. Transport Permissions and Operation Licenses are issued based on independent assessments of the Transportation Plan, which are performed by CNEN and IBAMA. This licensing model and the lack of coordination between CNEN and IBAMA has led to undesired duplication of actions and, in some cases, an overlap of authority. As a consequence of such practice, ambiguous results on safety enhancement seem to be contradictory compared with the delays on granting transport permissions and operation licenses. To seek international expertise on the relationship between transport competent authorities and environmental agencies, an advisory panel was formed of experts from several countries and organizations, including IAEA, and a consultation session was convened. The panel focused on such aspects as the overlap of authority, duplication of actions and the existence of specific environmental regulations concerning transport of radioactive material, and its relation with IAEA regulations. This paper describes the consultation session performed, the contributions obtained and how experts’ recommendations were evaluated and selected according to Brazil’s specific characteristics and culture. A Term of Reference on how to comply with different regulations, as well as a Memorandum of Understanding between authorities, are among the results.