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HomeMy WebLinkAboutCOM 0212.409 1996-1998 © Gamma Corporation P.O. Box 240370, Honolulu, HI 96824 Phone (808) 373-7009 I 'i ~ FAX (808) 373-7017 '97 fr1flY 19 8f~ 8 'i8 May 17, 1997 CC's?J James Arakaki COUNTY Ur HAWAII Hawaii County Council 25 Aupuni Street Hilo, HI 96720 via telefax 808-969-3291 Subj: Testimony on Ordinance No. 96-68 amendment related to Post Harvest Treatment Facility (Bill No. 62, Draft 2) By: Philip J. Manly, M.S., CHP, DABR /J ( V r v i ~Zy~ I am providing this testimony as guidance to determining the additions to infrastructure that maybe required to support the Post Harvest Treatment Facility, as outlined in Bill No. 62, Draft 2. My training and experience have been in the fields of medical and health physics, the professions dealuig v,~ith protecting man and the environment from the harmful effects of radiation. I hold comprehensive certification from the American Board of Health Physics and certification in Diagnostic Radiological Physics from the American Board of Radiology, and am on the list of qualified experts maintained by the state for radiation safety. I have not been paid to provide this testimony, although I normally charge for providing such consultation. The possession and use of radioactive materials is regulated by the Nuclear Regulatory Commission (NRC). This regulations and requirements for this particular use of radioactive materials for an irradiator are coeered in the Code of Federal Regulations, Title 10, Part 36. These regulations require the licensee to meet numerous facility design equipment requirements. They also require training of facility personnel and establishment of operating and emergency procedures. Specific emergency procedures must be established for the following situations: 1. Sources stuck in unshielded position, 2. Personnel overexposure, 3. Radiation alarm from the product exit portal monitor or pool monitor, Comm. D1a 2~•'WJ 850 west Hind Drive, Suite 176 Honolulu, HI 96821 l~ Mlle 2(e. tk~f. Presente !taf, i~te MAY 1 9 1997 Testimony on Bill No. 62, Draft 2 Page 2 May 1S, 1997 4. Detection of leaking sources, pool contamination, or alarm caused by contamination of pool water, A low or high water level indicator, an abnormal water loss, or leakage from the source storage pool, 6. A prolonged loss of electrical power, 7. Afire alarm or explosion in the radiation room, 8. An alarm indicating unauthorized entry into the radiation room, area around pool, or another alarmed area, 9. Natural phenomena, including an earthquake, a tornado, flooding, or other phenomena as appropriate to the geographical location of the facility, and 10. The jamming of automatic conveyor systems. Certain of these emergency procedures may require response by Hawaii County emergency personnel. Therefore, I would recommend that funds be allocated for the training of the following emergency personnel: I. Fire fighters - responding to a fire alarm at the treatment facility, including familiarization with the treatment facility, use of radiation survey meters, and first responder treatment of potential radiation and contamination injuries. 2. Emergency medical technicians -use of radiation survey meters, treatment of potential radiation and contamination injuries. 3. Hilo Medical Center emergency room personnel -medical treatment of potential radiation and contamination injuries, decontamination procedures Eor contamination, treatment of radiation injuries. 4. Civil Defense office -coordination of emergency plans for natural phenomena, such as earthquake. Oversight of the licensee's operation, through the licensing process and unannounced inspections, is provided by the Nuclear Regulatory Commission. As I have previous testified, I would also recommend that funds be allocated for an independent review of the licensee's operation by a qualified expert to provide assurance to the local population that a safe operation is being conducted. This type of independent review by a qualified expert is already specified in the Department of Health's proposed regulations for control of radiation for other operations, such as industrial radiography and certain medical x-ray Testimony on Bil] No. 62, Draft 2 Page 3 May 18, 1997 installations, that could pose a possible public health hazard if improperly used. Notification requirements by the licensee to regulatory authorities is outlined in The Code of Federal Regulations, Part 20. The regulations in lOCFR20.2202 outline the conditions that require immediate notification, 24 hour notification, and 30 day notification of the NRC. The NRC staffs the NRC Operations Center 24 hours per day to respond to immediate notification reports by licensees. Incidents requiring immediate notification of the NRC include a potential personnel exposure of greater than 25 rems, or release of radioactive that could result in a person receiving more than 5 times the annual limit of intake of the radioactive material. If the emergency reported to the NRC has a potential public health impact, they will notify the State Department of Health. Since the regulation of the facility is controlled by Federal law, the State has no official response requirements and any notification of the State is for informational purposes only. Since any response to a radiological emergency requires highly technically trained personnel, I feel the current notification requirements are appropriate and no other notification of local authorities is necessary. The level of hazard presented by an irradiation facility is not great compared with other industrial operations such as fuel tank farms. However, it is necessary that all personnel cvho maybe required to respond to an emergency at the facility be properly trained and familiarized with the operation at the facility and the proper emergency response procedures. Thank you for the opportunity to testify on this bill.