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JL S hepherd & A ssociates 1010 Arroyo Ave., San Fernando, CA 91340-1822

JL S hepherd & A ssociates 1010 Arroyo Ave., San Fernando, CA 91340-1822. LLWF A Manufacturer ’ s Perspective re: Improving the Management & Disposition of Disused Sources April 14, 2016 Presentation by Mary Shepherd.

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JL S hepherd & A ssociates 1010 Arroyo Ave., San Fernando, CA 91340-1822

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  1. JL Shepherd & Associates 1010 Arroyo Ave., San Fernando, CA 91340-1822 LLWF A Manufacturer’s Perspective re: Improving the Management & Disposition of Disused Sources April 14, 2016 Presentation by Mary Shepherd

  2. JL Shepherd & Associates1010 Arroyo Ave., San Fernando, CA 91340-1822 In celebration of a wonderful life, JL, my Dad, founding the company in 1967. June 1929 – February 2016

  3. Background JLS&A is an Agreement State Part 32 Licensee – a specific domestic license to manufacture or transfer certain items containing byproduct material. JLS&A also holds a Part 71 Quality Assurance Program Approval for the Packaging and Transportation of Radioactive Material JLS&A distributes Category 1, Category 2 and Category 3 quantities of radioactive material in the form of sealed sources in devices to many diverse types of licensees.

  4. JLS&A distributes to these types of Agreement State or NRC licensees: Part 30 § 30.32 Specific Licensees. Other Part 32 Specific Licensees who manufacture or transfer certain items containing byproduct material.  Part 33 Specific Licensees for broad scope use of byproduct material Part 36 – Panoramic Irradiators

  5. Applications & clients: Calibration facilities for radiation protection equipment, used by instrument & dosimeter manufacturers, DOD, DOE, other federal agencies & national standards laboratories, first responders, nuclear utilities, universities, hospitals & industry. Biological research irradiators, used by the DOD, DOE, USDA, DHS, CDC & other federal agencies, universities, hospitals, & biotechnology firms, medical device and drug companies. The Aerospace Industry for radiation hardness testing facilities, used for validation of MIL Spec compliance for the survivability of electronic components in radiation and space environments, that are used in satellites, space vehicles, weapons & airplane components by the DOD, DOE, NRO, NASA, aerospace companies and their subcontractors .

  6. JLS&A currently does not distribute sources and devices used specifically for the following types of facilities. However, we do provide sources and devices to be used in maintaining radiation safety, such as instrument calibration or dosimeter irradiation. Part 34 Licensees - Industrial Radiography Sources & Devices Part 35 Licensees - Medical Use of Byproduct Material Part 39 Licensees - Well Logging Sources & Devices Part 40 Licensees – Source Material Part 50 Licensees – Production and Utilization Facilities Part 52 & 54 Licensees – Nuclear Power Plants Part 60 Licensees - Geologic Repositories Part 61 Licensees – Land Disposal Part 70 Licensees - Special Nuclear Material Part 72 Licensees – Storage of Spent Fuel, High-Level Waste & Greater than Class C Waste Part 76 Licensees - Gaseous Diffusion Plants

  7. Source Management & Disposition Options One-for-One Exchange: A new source/device is provided in exchange for one that no longer meets clients requirements. The source has decayed to where the output is no longer viable for that client’s application or the client’s program requirements have changed. For instance, a calibration facility exchanges a decayed 10 Ci. Cs-137 source for a new source, because the dose rate no longer meets that program’s high range calibration capability. The exchanged source is completely usable for a facility that calibrates lower range instrumentation.

  8. Source Management & Disposition Options Decommissioning for Recycling or Possession Transfer Between Licensees: A licensee does not require the source/device and they are viable candidates for recycling . There is an acceptance criteria for recycling – not every source/device is a candidate for recycling by JLS&A. Recycling of viable sources reduces the radioactive materials footprint, sources are not buried and foreign replacement sources are not imported. JLS&A can facilitate the transfer between a licensee who no longer needs a source/device to other licensee who requires such a device.

  9. Source Management & Disposition Options Decommissioning for Burial: JLS&A performs private recoveries or self-ships to LANL/OSRP for clients in need, for which the government had not allocated funding. JLS&A is a LANL/OSRP subcontractor for government funded recoveries. JLS&A assists the Brokers with identification and disposition of unknown sources and devices.

  10. Source Management Issues As described in the Background section of this presentation, there is a broad spectrum of licensees who use Category 1, 2, 3 and 4 radioactive material. The use of the radioactive material is diverse and individualized to the program’s requirements. Unlike a gauge, which can be fixed in place for continual use, or a well logger or radiographer, whose specific business model is the use of radioactive sources; an irradiator or calibrator may be a supplemental tool necessity for a program and the usage cycle may vary.

  11. Source Management Issues The meanings of the terms “end-of -life management”, “last date used” and “storage” need to be well defined before any changes are considered. For instance, a proposal that NSTS sources have a mandatory “last date used” field for inspection use and tracking. The “last date used” field might be confused to mean the irradiator source is not “in use” when the source is not in continuous use. “Storage” could also be used to cite violations if an irradiator source is not in continuous use.

  12. Source Management Issues NASA, addressed this issue. Specifically, some space projects are years in the development, planning and execution of space exploration. Some sealed sources are used for specific phases of missions are not in constant use. NASA is worried that the terms “Storage” or “Last Date Used on the National Source Tracking System may be used to include these sources. Space exploration programs can last decades and program funding may take years. A potential impact would require NASA be to dispose of a source or device not in continuous use, forcing not only disposal costs but the purchase of future replacement sources/devices at greater tax payer expense.

  13. Source Management Issues Aerospace work can last as long as a communications or weather satellite is in orbit, and can include the development for replacement systems. Defense work includes the upkeep and strategic readiness of our reconnaissance satellites and the nuclear and conventional weapons arsenal, again, decades of work in process. An unintended consequence could force our national defense and aerospace programs to dispose of a source/device not in continuous use, forcing disposal costs and replacement costs at tax payer expense, and potential weakening of our national defense capabilities.

  14. Sandia Research 2016 Article by Sue Ann Holmes Fred Sexton, Sandia Advanced Microelectronics & Radiation Effects Manager: “Sandia’s success in producing strategic radiation-hardened components was fueled by a need to ensure the deterrent value of the nuclear weapon stockpile. “ “As we continue to modernize the stockpile and develop new microsystem technologies, Sandia will need new ways to mitigate the threat caused by man-made and natural radiation environments.”

  15. Source Management Issues In medicine, a study may need reconfirmation in the midst of a pre-clinical or clinical trial. No one could predict the lifesaving aspect of this research or the lives lost if a trial was not completed because the irradiator source was identified as “not being used” within a specified time period. To add the cost of an unnecessary mandatory disposal could seriously impact the medical, potentially life-saving gains, particularly in the area of cancer research targeted directly to the genomic structure of the cancer.

  16. Source Management Issues In Agriculture, insects can be irradiated for sterile release to protect humans, animals or crops. The work can be seasonal and the irradiator may have periods of down time. If an insect sterilization program is successful, and the pest is eradicated, the facility would need to remove the irradiator. The irradiator would not be available if an outbreak occurred or a new threat emerges, and the economic recovery cost would be enormous. Brazil has started a sterile mosquito release to combat the Zika virus.

  17. Source Management Issues In some specialty laboratories, irradiators are used to deactivate dangerous biologics and pathogens, for research into therapies or medical interventions. If an irradiator source was removed because it wasn’t in constant use, there would be no response for emergent or mutated biologics, either naturally occurring or manipulated, as a weapon of mass destruction. Why should people and troops die or be put in harm’s way because the irradiator source was removed from service for not being in continuous use?

  18. Source Management Issues In a private or government calibration laboratory, instruments are calibrated periodically, annually or in less frequent intervals. For a “special use” instrument, pre-mature retirement of the source would deny the calibration lab of specialized instrumentation. If a first or emergency responder does not have instrument calibration or response check capability, the public and responders could be put in harm’s way.

  19. Source Management Issues If a source is required to be disposed of, then needs replacement, the replacement and disposal costs are capital expenditures. They are not inexpensive nor are they easily replaced. No entity embarks lightly or frivolously on capital equipment expenditures, and the cost of mandated disposal only increases any entity’s cost of business. Rather than embark on a regulation-mandated effort to control Category 1, 2, 3, or 4 sources, a phased, important to safety consideration of existing security measures, and safety culture-type approach, should be used.

  20. Source Management Issues This method would be fair to the responsible licensees, and also address irresponsible licensees. As stated in the October 7, 2015 webinar, there should be no differentiation between the exact same Category 3 or 4 source that can be used in a generally licensed or specifically licensed device. The owner licensee should be subject for identical financial surety or security requirements for the source, regardless of the type of device.

  21. Conclusion Good intentions often have unintended consequences.

  22. JL Shepherd & Associates 1010 Arroyo Ave., San Fernando, CA 91340-1822 Contact Info: Mary Shepherd Phone: 818-898-2361 Fax: 818-361-8095 Email: sales@jlshepherd.com

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