Removal and Packaging of Category 1 & 2 Self-Shielded Devices Spring 2017 LLW Forum Meeting Denver, Colorado April 25, 2017 Gary Robertson, Chair of CRCPD’s G-71 Working Group Committee

G-71 Task Force on Licensing Criteria Category I and II Sources Found in Self-Shielded Devices Recovery and Packaging Operations TWO WORK ASSIGNMENT Develop criteria for issuance or amendment of radioactive material licenses to prepare for shipment Category I and II sources found in self-shielded devices, not to include source removal/transfer, primarily in Type B Shipping containers (not to include device relocation for maintenance or resourcing). Review the National Nuclear Security Administration (NNSA) contracted self-shielded device training program to determine adequacy. This is the formal name of the G-71 Working Group but for the duration of my presentation I will be referring to it as the Working Group. Actually the first G-71 charge was to be completed by October 2015. The good news is that we have completed both tasks are complete and CRCPD is preparing criteria or guidance document for publication

Cesium Chloride Blood Irradiators X-Ray Blood Irradiators

PURPOSE OF GUIDE   This guide describes the information needed when a service provider/broker is applying for a license for removal and packaging of CAT 1 & 2 self-shielded devices Such a license will authorize the service provider/broker to remove and package Category 1 & 2 self-shielded devices. The guidance document will assist in completing the license application however the service provider/brokers must successfully complete the CRCPD approved training program for persons who plan to engage in the removal and packaging of Category 1 & 2 self-shielded devices

CONTENTS OF THE APPLICATION APPLICATION LICENSE INFORMATION 2. NAME AND MAILING ADDRESS OF APPLICANT 3. STREET ADDRESS AT WHICH RADIOACTIVE MATERIALS WILL BE USED OR STORED IF DIFFERENT 4. NAME OF PERSON TO CONTACT ABOUT THIS APPLICATION5. FACILITY STAFFING/AUTHORIZED USERS 6. RADIOACTIVE MATERIAL 7. DEVICE MODEL NUMBER AND PURPOSE OF USE 8. INDIVIDUALS RESPONSIBLE FOR RADIATION SAFETY – THEIR TRAINING AND EXPERIENCE 9. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS 10. FACILITIES AND EQUIPMENT 11. RADIATION SAFETY PROGRAM

CONTENTS OF THE APPLICATION 12. SECURITY PROGRAM AND ACCESS AUTHORIZATION PLAN 13. WASTE MANAGEMENT 14. OCCUPATIONAL DOSE - EXTERNAL 15.OCCUPATIONAL DOSE - INTERNAL MONITORING 16. RADIATION DETECTION INSTRUMENTS 17.RADIATION INSTRUMENT CALIBRATIONS 18. SURVEY/MONITORING PROGRAMS 19. DEVICE HEAD LEAK TEST PROGRAM 20. RADIOACTIVE MATERIAL ACCOUNTABILITY 21. PUBLIC DOSE 22. REPORTING, NOTIFICATIONS, AND RECORDS 23. EMERGENCY PLANNING 24. PART 37 PHYSICAL PROTECTION REQUIREMENTS 25. REPORT OF PROPOSED ACTIVITIES 26. LICENSE FEE REQUIRED 27.CERTIFICATE

G-71 TRAINING OBSERVATION AT SOUTHWEST RESEARCH INSTITUTE September 13 – 15, 2016 San Antonio, Texas The CRCPD Team evaluated training provided by the Southwest Research Institute (SwRI) for the disassembly of the following self-shielded irradiators: Gamma Cell 1000/3000; Gamma Cell 40; IBL 437; and J.L. Shephard Mark I

(NOT TO INCLUDE SOURCE REMOVAL/TRANSFER) REMOVAL AND PACKAGING OF CATEGORY 1 AND CATEGORY 2 SELF-SHIELDED DEVICES (NOT TO INCLUDE SOURCE REMOVAL/TRANSFER)

Category 1&2 Source Decommissioning/Transfer Checklist   Preliminary planning prior to transfer/removal date: Obtain copy of vendor’s current Radioactive Materials License and ensure they are authorized to perform the tasks required to support and fulfill the transfer. Provide vendor receiving the source/device a copy of your current Radioactive Materials License. Ensure you have a current sealed source leak test (within 6 months). Ensure that a current, certificated, and source appropriate IATA DOT CASK is available for the date of your transfer. Ensure vendor representative or someone qualified and licensed to dismantle the device and package for shipment will be on site to perform this activity. Ensure vendor representative or qualified individual is trustworthy and reliable if not escorted at all times. Ensure that a qualified shipper is present to complete the US Department of Transportation required manifest, correct shipping name and category, and other transfer or disposal paperwork Know the weight of your device and any additional transport devices, dollies, and lifts. This is critical. There may be damage to the facility floor; existing structural support over areas travelled may be inadequate; and/or elevator weight limits may be exceeded (as discussed below). You may need to arrange for use of Masonite or other floor covering to distribute the weight of the irradiator and protect the floors along the route of movement. You will need the weight for adequate rigging equipment. If Elevator will be used to transport the device, Determine if elevator has capacity to transfer the weight of the device If not, consult manufacturer’s rep. Have Elevator Service Rep available during the transfer to operate the elevator and provide advice concerning the use of the elevator. Coordinate with your manufacturer’s rep to determine who will place the order for the rigging crew and/or equipment. Know what is ordered and make sure the weight rating is adequate for the more than the weight of your device. If transfer is in conjunction with Los Alamos National Laboratories or OSRP, make sure you provide copies of the approval to the vendor doing the packaging. Category 1&2 Source Decommissioning/Transfer Checklist Ensure vendor representative or someone qualified and licensed to dismantle the device and package for shipment will be on site to perform this activity.  Ensure that a qualified shipper is present to complete the US Department of Transportation required manifest, correct shipping name and category, and other transfer or disposal paperwork.  Know the weight of your device. This is critical.   If Elevator will be used to transport the device, Determine if elevator has capacity to transfer the weight of the device If not, consult manufacturer’s rep. Have Elevator Service Rep available during the transfer. 

Category 1&2 Source Decommissioning/Transfer Checklist Ensure that vendor has available, a US Department of Transportation/Nuclear Regulatory Commission certificated type B cask available for use. Determine mode of transportation. This checklist provides requirements for shipments by road. Rail shipments have additional requirements (see § 37.79 (b)) Coordinate with your LLEA. Have a security plan for each facet of the transfer. Plan for the unexpected. Know where the danger could come from and how to respond. It is recommended that you coordinate this with your LLEA. Individuals responsible for the security have been trained on the plan. Ensure that vendor has available, a US Department of Transportation/Nuclear Regulatory Commission certificated type B cask available for use. Determine mode of transportation. This checklist provides requirements for shipments by road. Rail shipments have additional requirements (see § 37.79 (b)) Coordinate with your LLEA. Have a security plan for each facet of the transfer. Plan for the unexpected. Know where the danger could come from and how to respond. It is recommended that you coordinate this with your LLEA. Individuals responsible for the security have been trained on the plan. The Security Plan should include at least the following items and processes: Dismantle prep for the device Unpacking the equipment Moving the device Elevator move, if applicable Source removal and transfer to type B package, if applicable Or, placement to type B package Dose Measurement and labeling Transfer to transport Repacking the equipment Other, such as protection from pedestrian and/or vehicle traffic, parking issues, workers, other entrances/exits, etc. Access control Temporary security zones using a combination of continuous physical barriers and direct control. First aid, if needed and security of source during this. Any other distractions which might occur. Problems of visibility, etc.

Team Findings The Team believes that upon successful completion of this training, service providers/brokers will be able to safely prepare GC40, GC1000, GC3000, Mark 1 and IBL437 self-shielded irradiators for packaging and transport. The SwRI’s training program address an important question that state regulators may have regarding the amount of practical experience a service provider may have with one of these self-shielded irradiators.

The review team made the following recommendation:   On Day One; include a radiation safety review session. Also on Day One; during the instructor led dismantling include a detailed discussion of survey techniques and wipe test procedures. Include a service provider check off sheet similar to Attachment 2 As an additional training tool during second day of training include a requirement that students reassemble self-shielded irradiators they just disassembled. Allow students to spend additional days preforming the disassembling and reassembling of self-shielded irradiators. Allow students to keep the step by step instruction (not to include the picture instructions) provided during the training. Consider possible additional training in rigging and transport requirements This type of “hands-on” training would be highly beneficial for state and federal regulators who perform licensing and inspection of these devices and should be offered to such agencies.

Special Thanks To: Anine Grumbles, Washington Bernie Bevill, Arkansas William Stewart, NNSA Mary Shepherd, J.L Shepherd and Associates

One Presentation Left Contact Information Gary Robertson, G-71 Chair 360-402-0370 glr0303@aol.com