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HomeMy WebLinkAboutCOM 0212.436 1996-1998 MAY 19 '97 a5:27PM ISOMEDIX CORPORATE P.c^/6 ~SOtNiEOr3c , _ ~ '~7 ~i~Y 19 P(`l 2 15 May 19, 1997 - ~ CCUNY :.~L~ " Ms. Margarita Hopkins COUNTY CF HAWAII County of Hawaii ° Department of Research and Development 25 Aupuni Street; Room 219 Hilo, Hawaii 96720 Dear Ms. Hopkins: In reference to your letter to George Dietz dated May 16, 1997, we are pleased to provide the following responses. 1. If a piece 'of cobalt 60 is dropped in the pool, will the .water get. contaminated? If we take the piece out of the pool, is the water no longer contaminated? Cobalt 60 source material is both nickel plated and doubly encapsulated in stainless steel tubes to prevent the possibility of exposed cobalt 60 coming in contact with the water. Also, since cobalt 60 is not soluble in water, should a piece of exposed cobalt 60 get into the pool outside of its normal encapsulation, it could be easily captured using the existing water filtration system and the water would not be contaminated. Only source-encapsulation designs registered with the USNRC are approved for use in an industrial irradiator. The manufacturers of cobalt 6o sources must submit their encapsulation design along with the appropriate test data indicating compliance to the criteria listed in 10 CFR part 36.21(a)(5), attached, to ,the USNRC for approval. 2. If only 10.4 of the original energy of the cobalt 60 remains, what does this mean? Ts that IeveZ safe? Why do we sti31 have to dispose of it properly? Can we not just throw it in the ground? The half life decay of cobalt 60 is approximately 5.3 years. " Therefore, after a little more than 16 years from theme dQate of manufacture, the curie content of the cobalt 6 e is approximately 10~ of its original value. ZIl6m FND GAP g{~, Presented MAY 2 0 1997 CORPORATE OFFICES • 11 APOLLO DRIVE, WHIPPANY,' NEW JERSEY 07981 • (201)887-4700 AX~----°- MAY 19 '97 a5~28PM ISOMEDIX CORPORRTE P.3i6 , At this point the cobalt 60 capsule still possesses between 600 and 1000 curies of useful activity and must still be handled with the same level of caution as a new capsule. If not needed at this site, the capsule will be transferred to one of the other 10 existing Isomedix irradiator facilities. 3. How many people died resulting from accidents in irradiation plants all throughout the world? .Are data available on this? How about the U.S.? There have been four documented fatality events at irradiator facilities worldwide out of a total of 170 such facilities containing approximately 19o million curies of ,cobalt 60. a. Italy, May 1975 An operator, while adjusting a conveyor belt, was transported into the irradiation unit while the source was exposed. Fault placed on poor management. b. Norway, September 1982 A Maintenance Technician arrived on morning shift after unattended night operations. Conveyor belt had jammed and source failed to descend into the storage pool. The door interlock was unbarred allowing entrance to the irradiation room. The radiation monitor was removed for repair. Fault placed on poor interlock design. c. El Salvador, February 1989 No preventative maintenance program, no operator training program, overridden safety interlock systems and no regulatory oversight were determined to be the primary causes which allowed three workers to enter an irradiator while the source was stuck in the raised position. One of the three workers died,. d. Israel, June 1990 Similar to the Norway event. The operator bypassed the door interlock radiation monitor and entered the irradiator with a non functional hand held geiger counter while the source was stuck in the raised position. ISOIVIEOIX INC. CORPORATE OFFICES • 11 APOLLO DRIVE, WHIPPANY, NEV/ JERSEY 07981 • (401) 887-4700 • FAX (201) 887-1476 MAY 19 '97 a5~3aPM ISOMEDIX CORPORATE P.4i6 , It should be noted that the same irradiator design was associated with the Norway, El Salvador and Israel events. After ttie Norway event, the irradiator manufacturer issued an information notice along .with a design modification to prevent a reoccurrence of the cause of the source rack jam. The notice was apparently ignored by both the other facilities. There are .no documented fatalities associated with industrial irradiators in the United States. An interlock system designed to meet today's requirements does not allow far any type of entry with the source in the exposed position. 4. How long w.il1 it take for cobalt 60 to turn nonradioactive? It depends on the. original level of activity but can be approximated to be around 1~5 years. 5. Is there a guarantee from the manufacturer that the cobalt 6o pencils will not Zeak? Yes; The current guarantee is for 20 years, though pencils properly stored will never leak. 6. What will happen if there is no water in the pool? The radiation levels outside the concrete shield will be no different than when the source rack is in the raised position during routine production. With no water- in the pool, the in-cell radiation monitor would be in an alarm condition thus preventing entry. NRC regulations require that the means to replenish water losses from the pool be incorporated into the design. 7. Do you have any idea on cost of decontamination in case of accident? How much insurance do you carry for this purpose? For a small facility possessing less than 250,000 curies, as planned for Hawaii, with a stainless steel pool liner, the estimated cost would be in the order of $150,000. The source manufacturer would be responsible for the cost of the cleanup should the cause prove to be a manufacturing defect in the source capsule. ISOMEDIX INC. CORPORATE OFFICES • 11 APOLLO DRIVE, WHIPPANY, NEVN JERSEY 07981 • (201) 887-4700 • FAX (201) 887-1476 MAY 19 '97 aS~SaPM ISOMEDIX CORPORATE P.Si6 In light of the extremely remote possibility of a contamination event the Company has chosen to self insure against such an occurrence. Sincerely, ni ~FJ~i / 6 Jonathan/ ~6ur,~Cj ~ ~Directo /of Safe~y cc: Mayor Steve Yamashiro All Council Members Ms. Diane Quibiquit Mr. Rory Flynn ISOMEOIX INC. CORPORATE OFFICES • 11 APOLLO DRIVE, WNIPPANY, NEW JERSEY 07981 • (201) 887-4700 • FAX (201) 887-1476 MAY 19 '97 05:~1PM ISOMEDIX CORPORRTE P.6i6 PART 36 a LICENSES 1D RADIATION SAFETY REQUIREME). i FOR IRRADIATORS (di Impact. A 2•kilogtam eta! weight, with paraonnel acpa door lacks to 2.5 wntimetara in dismatsr, must ha caveat room eccaa when radiation dropped from a height of 1 mater onto levels era high. Aitemplad psnoansl the feu source. entry while the monitor maesuns high ' (e) Vibration. She red eourp must be radiation Lvslr, must, ectivala the alarm subjected 3 times for 10 minutes esch to described in paragraph (b) of this vibrations evrrplmg from Z5 hero to asdion. She monitor rosy ba located in St10 hertz with • peak empllluds of 5 the mtranee (normally nferrad to as the times the mLration of gravity. la mess) but trot is the direct gdiatlon additlon;each tat source mart be beam. vibnrad for 30 minute u earh:aamsnt (d) Hafon the soutps move from their E~yueacy found. ah(elthtd podtltm is • pmmeadc . (Q :Punceure. A Sll-gram wdght and lrradiuo~. the comp ~nttolmud ppin. t).3~oalimelar pia dLmeter, mace autometltally aetiwte paspitarous be dropped from a height of I mater vidbL end audible eLems to alert onto:the tad souroe. people in tM tedistlon room.thst the (g) Bend.lf the length o[ the saurw is aromas will b• moved from their mon.thsa 15 time Lrgu than the shielded. on: the ahnma`mmt give mfaimum aoas•sectlond dlmrdoa. indivldu~wough Hms to lave the ' the lost source mud be sub)xted to a room before the crops leave the toreof200nnswlansdlVosaty ahialdad'p~itlon. equidistant from.ewo support gllndan, (e) Sec6 ndfaUoa Comm u ¦ the diatsnce bslwasn whirA is 29~ima panoramic irradiator tnut2 bare • cLsrly the minimum noes-seriiooal dimewim vLlbla sad raadilyeonadbk control of the satrrp. thu would allciur tm individual is the Aeeus ~ Boom to mats the. rmpa estum'to Choir Cal Far~i eatrsun to ¦ radiation room ti tttU ehldtlad pritloo. rt a e irtediatae mmt have a ¢ (A ~ ~aU® r°°m of a Paanra~ psoonmie ieadlator muse morale! door or othv physiml harries to prevent m papm? slut ptevm4 tM emteor from ¢ inadvertent entry of pertrpnsl tf the moving ft~ the ahitdded poeitlon , m' aourps an sot is the atiiehied podtlon. udea the txatrol hr bees eetlretsd Product conveyor syd®a may emus a sad the dada or bsedm to tlw radiation Subpart G-Csaipa .nd PsAornunu bamtan as long a ffiey ntiably and nom 6a hr~aa dosed within a preset ilequlrarnente for trradletore confidently funttioa a s herder. It time after eWrettoa of the cmtnt. - mustnet he poeeibL /o more the (d tech egtrmta to the radiation ! 3s3t hrrorrnarwe criteria hr raw. sources out of tFteir shielded pofitloa if room of ~ panoramic hradlalor sad each - aO1fO~ the door. ar haeria is open. t)paring the saran®to tiro area within the (a) Aaquinmenty. Sealed sources door or hsszier while the somtxa are patsonnd across herder of sa inualled aRea• )uly 1,11193:. azpoead must ease the aom®s to underwater irradiator mart lava a dgo U) Mud have a metl8mte of return promptly to thefr ahialded baertag the radlatlon ej~mbol sad the ca~strs~ion iaeued under to CPR 32.210: position. The panamnal rmtrance door words, "Caution (as damger) ndiaeGire (2) Muat ha doubly enmpsulsted: or bseiar mart hew a lack thst is matedal,° fhnersmie.inadiums must (3i Must ace radiwctive material that operated by the esme key used to move aLo havra atgn datlmg "High ndfstloa is a aondisparfibla r pnctital and that the aourca. She dean and baedme mud anr," but the dga may be umovsd. is as inwluble a practical Ifthe saueoe sot pravent any Individual b the covered. m atharwir made iaopntive is used in a wetsourr$dorega or wet• radLtlon room from laving. whoa the source ono fully ahie[dad. sourctchmge irradiator, (h) In edditlaa, each eotranp to a (h) II the radiation room of a (a) Mud be ennpsuLted in a material radiation nom at a panoramic irradiator psaonmic imdiemr br roof plugs to reaistaat to general cotradop sad to mart have an independent bacTcup other movable obis it road sot be ¢ lomlired corrosem, ouch u 936E mac metro! to drtaet.panooas ®try poasibis to opera4 the for unless ~ stainlea rtrl or otlwr muedrl with while the comps ate aP•s•tL the ehLhliog lie la lee proper lagalon. ~ equivalent rasisteop if the sources ere 1]etactim of emery while !hs sources are 1Lis rsq~tiremant may he met by far use in iaedutor pool; end a:posed rotor cause the nmwa to intarlo6ks that pnvamt opantlan tf ' (5) la,protatype testingg ottlre aeeled ratum to their fully ehieWed podtlon ehieldirtg carom pLad achy as . wur®, mud' have been lasktaelsd and and mart aLo amivw • vWbls sad opsesting proodma found: leak•frea eRar ach of the tests audible dsrm ro melee the individual mspectim of shieldlag fora operatlng. deecihed is peragrapha (h) through (gl entering the nom swan of the Gerard. of thin action. 't'he chum mud aLo shat u Lot op (b) Temperotun. The ted'wutce niud other individual who L ondu of the be hdd at -4o`C for 20 osinrrtes, 6lq°C entry: That 1adLviduel shell be trained for i hour, and then be subjected to a on how to rrepond to the aLrm and thermal shock feu with . t~pantms prepared to promptly randee m.ummon drop fivm 90.0'C to 2n'C within 15 aeateunra. roondt. (c).A ndiatlan momitar mart ba (ci Precvura. The test source mud be provided to dates ehs pnaoo otbigh ewio aub)act~d for u lent ti aainuta to radLtlm LvsL /a the ndletlon room of m aatsimal prasun (aluolute] of 2 e panoramic fresdialor befon penomel million newtons per aquera meter. entry, The monitor mud bs iategramd F+bnrsty 211, 1993 38.1