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National Institutes of Health

A Federal Licensee’s Experience in Decommissioning Sealed Source Irradiators Cathy Ribaudo, M.S. NIH Radiation Safety Officer. National Institutes of Health. The federal government’s medical research agency 27 Institutes and Centers 300+ acres in Bethesda, MD 47,000 daily population

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National Institutes of Health

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  1. A Federal Licensee’s Experience in Decommissioning Sealed Source IrradiatorsCathy Ribaudo, M.S.NIH Radiation Safety Officer

  2. National Institutes of Health The federal government’s medical research agency 27 Institutes and Centers 300+ acres in Bethesda, MD 47,000 daily population 106 buildings Employs ~6000 scientists Hosts thousands of fellows ~3800 radiation workers

  3. National Institutes of Health The federal government’s medical research agency 27 Institutes and Centers 300+ acres in Bethesda, MD 47,000 daily population 106 buildings Employs ~6000 scientists Hosts thousands of fellows ~3800 radiation workers 26* sealed source irradiators ~700 users/accessors

  4. NIH Irradiators • Used for cell studies: to render feeder cells incapable of cell division, to study DNA repair mechanisms, and to study mutagenic effects of radiation. • Used to irradiate small animals: for bone marrow ablation in preparation for creating a mouse model of a specific immune system, and for vaccine development. • Used to irradiate blood products: to prevent transfusion-associated “graft-versus-host disease”.

  5. NCI Radiation Biology Branch Gammacell 220 source strength 23,720 Curies Co-60 when new (March 1987); decayed strength at time of disposal = 736 Curies

  6. Radiation Biology Branch irradiator room Gammacell 220 El Dorado 78 El Dorado 8

  7. Gammacell 220 Timeline Oct - Nov 2012 – Informal solicitation for quotes by waste brokers/licensees ranged from $80K to $167K. March 28, 2013: GC-220 disposal job awarded to Best Theratronics. Nordion is original license-holder and agrees to accept return of source; Best has established relationship to perform service including source removals for this model.

  8. Gammacell-220 Timeline • Need Export Permit via NRC: $5500 • April 2013 – NCI changed Contracting Officers; contract award to Nordion for source disposal was overlooked, thus delay for Best in scheduling work. • May 2013 – Nordion’s Nov 2012 quote has expired; attempt to get new quote unsuccessful. “Nordion is currently reevaluating its cobalt disposal paths and therefore cannot extend a current quote at this time.” (Eventually got it in Sept 2013).

  9. Gammacell-220 Timeline • Best Theratronics now in limbo if no source disposal pathway available. • Only other suggestion is OSRP • Reached out to OSRP May 2013. OSRP says since we are a federal facility, they require us to pay the unloading fees, so Best Theratronics needs to include that cost in their new quote. • But at least the job can be managed in one contract.

  10. Irradiator Source Disposal Concerns • No commercial disposal pathway other than possible transfer or return to manufacturer • Sometimes not an option: [No interested party, exorbitant shipping costs, decayed source strength no longer of value, defunct manufacturer, etc.] • Offsite Source Recovery Project (OSRP) • Managed by the National Nuclear Security Administration/DOE under the Radiological Threat Reduction Program • Aims to recover disused radiation sources from sites to reduce homeland security concerns

  11. Offsite Source Recovery Project • Must register sources with OSRP and agree to turn over sources to the government for permanent disposal • OSRP prioritizes the sources in its registry for source recovery efforts • Allows access to DOE disposal facilities since OSRP assumes ownership of sources

  12. Gammacell-220 Timeline • New quote from Best received June 2013 • $87.4K includes weekend labor rates and OSRP unloading fees; uses F423 Type B shipping cask • Award made July 9, 2013 • Job completed Sept 7, 2013

  13. NRC Decommissioning requirement • No Decommissiong plan required: (Group 1) • Notify NRC as required by 10 CFR 30.36(d). • Provide to NRC results from the most recent leak tests demonstrating there has been no leakage. • Submit NRC Form 314 “Certificate of Disposition of Materials” and include written confirmation from the recipient that material has been transferred.

  14. Miscellaneous Requirements • Crated weight of Gammacell-220 = 8800 pounds; must lift through air shaft. NIH required: • Project Notification Form for Facilities Work Request • Safety & Rigging Plan • Site Selection Request Form • Road Closure Form • Structural Engineer Evaluation • Interim Life Safety Measures Survey • OSHA Accident Prevention Plan • After Hours Work Request

  15. Gammacell 220 Removal

  16. Gammacell 220 Removal

  17. Gammacell 220 Removal

  18. El Dorado Timeline El Dorado-8 source strength 7620 Curies Co-60 when new (Oct 2004); decayed strength at time of disposal = 2432 Curies El Dorado-78 source strength 1426 Curies Co-60 when new (Feb 1981); decayed strength at time of disposal = 20 Curies

  19. El Dorado Timeline • April 2013 – Fed Biz Opps posting for bid solicitations; 1 bid received: Neutron Products Inc. • May 2013 – Statement of Work finalized: “disposition of sources to SWRI; contractor responsible for all Hg and gear oil removal so as to avoid improper disposal to construction debris waste stream”

  20. El Dorado Timeline • June 2013 – Solid waste management walk-through: Source disposal will only include the lead teletherapy heads; will not include metal frames or lead-lined door to room. Plasma cutter needed for reduction of metal frames. Depleted Uranium in teletherapy heads: NPI to take. • June 2013 – Facilities walk-through: freight elevator permit; dock permit; forklift certification and safety plan; forklift driver OSHA training certification; electrician to be present for metal frame disassembly.

  21. El Dorado Timeline • July 2013 – Ensure Neutron Products completes all required notifications as per NRC Part 37. • July 8, 2013 – Last use of irradiators by researchers • July 9, 2013 –Police initiate job coverage for LLEA security from 7:30 am through job completion. Escort flatbed truck off campus; escort truck to County line.

  22. El Dorado Timeline • Quote from Neutron Products received May, 2013: $79.5K for packaging/ transport/ disposal to SWRI using USA/9215 Type B shipping container • Award made June 12, 2013 • Job completed July 9, 2013

  23. El Dorado Removals

  24. FDA Irradiators Gammacell-1000 Elite: source strength 2800 Curies Cs-137 when new (Apr 1994); decayed strength at time of transfer = 1771 Curies Gammacell-40: source strength 3482 Curies Cs-137 when new (Apr 1979); decayed strength at time of disposal = 1548 Curies

  25. FDA Irradiator Timeline • June, 2014 – Finalize agreement with FDA to have them fund the relocation of 2 FDA irradiators from NIH campus to FDA campus (1) and to SWRI (1). • One is a license transfer; one is a disposal. • Job contracted to Gamma Irradiator Service using Energy Solutions transportation and 10-160B Type B shipping container. • July, 2014 – Request permission to use NIH surplus yard for staging irradiator packaging, since insufficient space at building loading dock.

  26. FDA Irradiator Timeline • July 20, 2014 – Notify all irradiator users of last day. • July 22, 2014 – Gamma Irradiator Service arrives; Police provide security presence; doorway frames and floor thresholds removed along route; forklift delivered to site; Gammacell-1000 Elite irradiator transported to surplus yard. • Crane and rigging crew place Gammacell 1000 Elite irradiator into 10-160B model shipping cask; police escort off campus and on public highway to FDA site.

  27. Gammacell 1000 Elite Irradiator Removal

  28. FDA Irradiator Timeline • July 21, 2014 – Gamma Irradiator Service disassembles Gammacell-40 into its 2 source shields. • July 23, 2014 – forklift, flatbed truck, crane, and rigging crew return to NIH with (now empty) Type B shipping cask. • Surplus yard unable to be used for Day 2 staging work to package second irradiator; NIH Police aid in roping off large area of employee parking lot. • Gammacell-40 irradiator sources transported via forklift to staging area with police escort; loaded into cask; loaded onto truck; transported offsite.

  29. Gammacell-40 Irradiator Removal

  30. FDA Irradiator Timeline Lessons Learned: • Gamma Irradiator Services hindered by numerous researchers in process of vacating their labs; boxes of lab supplies and chemicals in hallways awaiting transport to FDA campus. • Parking lot asphalt is softer than loading dock asphalt; flatbed truck made ruts and had to be filled. • Irradiator staging is too visible in parking lot! Individual was caught taking a photo; required NRC suspicious event reporting.

  31. Don’t Forget… • NRC License Verification System • Special Form Certificates for source models • LLEA posted throughout job; escort of truck to County line • NRC National Source Tracking System update • Authorization to Transfer/Relinquish Ownership (ATRO) document signed and sent to OSRP/SWRI; counter-signed and returned • NRC License amendment / termination

  32. Thank you! Questions?? Cathy Ribaudo NIH Radiation Safety Officer 301-594-1303 cribaudo@nih.gov

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