ML20197F868

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Ack Receipt of to Chairman Jackson,Re Use of Cs-137 in large-scale Commercial Applications Such as Food Irradiation.Source Was Susceptible to Leakage
ML20197F868
Person / Time
Issue date: 12/12/1997
From: Paperiello C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Fraser F
CANADA
Shared Package
ML20197F873 List:
References
SSD, NUDOCS 9712300311
Download: ML20197F868 (7)
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' Association of Int;rnationalIndustrialirradiators ATTN: Mr. Frank Fraser J

6 clo MDS Wordion 447 March Road Kanata Ontano K2K 1X8 Canada r

Dear Mr. F6aser:

I would like to thank you for your letter dated November 27,1997, to Chairman Jackson, concerning the use of Cesium 137 ("'Cs) in large-scale commercial applications such as food irradiation. As you are aware Nuclear Regulatory Commission regulations require that sealed sources used in large scale commercialirradiators be as insoluble and nondispersible as practical, in part, to reduce the possibility of the spread of contamination. This requirement was codified in $36.21 Title 10 of the U.S. Code of Federal Regulations, Part 36 in 1993.

The Statements of Consideration for Part 36 recognize the solubility of "'Cs and indicate that, in general, "'Cs will not be authorized for use in wet-source-storage irradiators, but that specific requests for the use of "'Cs may be considered on a case-by-case basis The Statements of Consideration further indicate that WESF (Waste Encapsulation and Storage Facility) sources (containing "'Cs) may not be used in wet-source-storage irradiato s. On the effective date of Part 36, WESF sources were in use at some large-scale wet-source storage irradiation facilities. However, based on the determination that the cesium in the sources is soluble and, in at least one case, the source was susceptible to leakage, all WESF sources were removed from service and replaced with a less solubla alternative.

We recognize your concern with the use of "'Cs in large scale irradiators and appreciate your offer of participation and consultation regarding any future requests for the use of "'Cs in these types of applications. I would like to assure you that we will endeavor to continue to ensure that only sources that are as insoluble and nondispersibic as practical are authorized for use in wet-source-storage irradiators. I hope that this alleviates any concerns vou may have regarding the use of "'Cs for *his application. If you have any 6dditional questions or concerns, please call Mr. Douglas Broaddus at (301) 415-5847.

Sincerely, (Original signed by)

Carl J. Paperiello, Director 300078 office of Ncciear uateriai Safety and Safeguards Distnbution G9708d')

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Associ tion of int:rnation:I Industnal trradiators ATTN: Mr. Frank Fras r c/o MDS Nordion 447 March Road Kanata, Ontario K2K 1X8 Canada

Dear Mr. Fraser:

I would like to thank you for your letter dated November 27,1997, to Chairman Jackson, concerning the use of Cesium 137 ('2'Cs)in large scale commercial applications such as food irradiation. As you are aware, NRC regulations require that sealed sources used in large-scale commercialirradiatorn be as insoluble and nondispersible as practical, in part, to reduce the possibility of the spread of contamination. This requirement was codified in $36.21, Title 10 of the U.S. Code of Federal Regulations, Part 36 in 1993.

The Statements of Consideration for Part 36 recognize the solubility of '37Cs and indicate that, in general, '3'Cs will not be authorized for use in wet source-storage irradiators, but that specific requests for the use of '35s may be considered on a case by-case basis. The Statements of Consideration further indicate that WESF (Waste Encapsulation and Storage Facility) sources (containing '2'Cs) may no?, be used in wet source-storage irradiators. On the effective date of Part 36, WESF sources were in use at some large-scale wet-source storage irradiation facilities.

However, based on the detemlination that the cesium in the sources is soluble and, in at least one case, the source was susceptible to leakage, all WESF sources were removed from service and replaced with a less soluble attemative.

We recognize your concern with the use of '3'Cs in large scale irradiators and appreciate your offer of participation and cc isultation regarding any future requests for the use of '3'Cs in these types of applications. I would like to assure you that we will endeavor to continue to ensure that only sources that are as insoluble and nondispersible as practical are authorized for use in wet-source-storage irradiators. I hope that this alleviates any concoms you may have regarding the use of '3'Cs for this application. If you have any additional questinns or concerns, please call Mr.

Douglas Broaddus at (301) 415-5847.

Sincerely, Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards Distribution:

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Association of international Industrial irradiators ATTN: Mr. Frank Fraser c/o MDS Nordion 447 March Road Kanata Ontario K2K 1X8 Canada Dear Mr. Fraser; I would like to thank you for your letter dated November 27,1997, to Chairman Jackson concerning the use of Cesium 137 (Cs) in large-scale commercial applications such as food irradiation. The Nuclear Regulatory Commission is always concerned whenever radioactive material is used on or near products for which there is an ingestion pathway. This is especially true for the irradiation of foodstuffs and other products intended for human use and/or consumption. NRC regu!ations require that sealed sources used in large-scale commarcial irradiators be as insoluble and nondispersible as practical,in part, to reduce the possibility of the spread of contamination. This requirement is codified in @36.21, Title 10 Code of Federal Regulations, Part 36.

The Sta:ements of Consideration for Part 36 recognizes the solubility of '2'Cs and indiantes that, in general, '8'Cs will not be authonzed for use in wet-source-storage irradiators, but t,t specific requests for the use of '3'Cs may be considered on a case-by case basis. In additio'., the Statements of Co,1 sideration further indicate that the use of WESF (Waste Encapsulation and Storage Facihty) sources (containing Cs) may not be used in wet-source-storage irradiators.

As of the effective Jate of Part 36 WESF sources were in use at large scale wet source-storage irradiation facilities. However, based on the determination that these sources are soluble and, in at least one case, susceptible to leakage, all WESF sources were removed from service and replaced with a less soluble alternative.

Wo recognize your concern with the use of '3'Cs in large scale irradiators Lnd appreciate your offer of participation and consultation for any future requests for the use of '2'Cs in these type applications. I would like to assure you that we will endeavor to continue to ensure that only sources that are as insoluble and nondispersible as practical are authorized for use in wet-source-storage irradiators. I hope that this alleviates any further concerns you may have regarding the use of '3'Cs for this application. If you have any additional questions or concerns, please call Mr. Douglas Broaddus at (301) 415-5847.

Sincerely, Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards Distribution; SSSS Staff NE02-SSD-5 CPoland 970843 NMSS R/F IMNS CIF HThompson NMSS Ticket CEstep DOCUMENT NAME: G:'.! RAD _RES. DIS n...,v.. con e e e.com.ni. inoic.i. in in. o.o c - p9ev witnout.ti.com.nie.nciosu,.

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' Association of Int:rnational Industrial irrediators 1.

ATTN: Mr. Frcnk Frcstr e

clo MDS Nordion J

447 March Road Kanata, Ontario K2K 1X8 Canada:

Dear Mr. Fraser:

I would like to thank, you for your letter dated November 27,1997, to Chairman Jackson, concerning the use of Cesium 137 ('3'Cs) in large-scale commercial applications such as food irradiation. The Nuclear Regulatory Commission is always concerned whenever radioactive materialis used on or near products for which there is an ingestion pathway. This is especially true for the irradiation of foodstuffs and other products intended for human use and/or const mption.- NRC regulations require that sealed sources used in large-scale commercial irradiators be as insoluble and nondispersible as practical, in part, to reducc the possibility of the spread of contaminaion. This requirement'is codified in 936.21, Title 10 of the U.S. Code of Federal Regulations, Part 36.

The Statements of Consideration for Part 36 recognize the solubility of '87Cs and indicate that, in general, Cs will not be authorized for use in wet-source storage irradiators, but that specific requests for the use of 'S'Cs may be considered on a case by case basis. In additicn, the Statements of Consideration further indicate that the use of WESF (Waste Encapsulation and Storage Facility) sources (containing "'Cs) may not be used in wet source storage irradiators.

As of the effective date of Part 36, WESF sources were in use at large-scale wet-source-storage irradiation facilities. However, based on the determination that these sources are soluble and, in at least one case, susceptible to leakage, all WESF sources were removed from service and replaced with a less soluble alternative.

We recognize your concern with the use of ' 'Cs in large-scale irri.diators and apprec: ate your offer of participation and consultation regarding any future equests for the use of '37Cs in these types of applications. I would like to assure you that we will endeavor to continue to ensure that only sourcec that are as insoluble and nondispersible as practical are authorized for use in wet-source s'orage irradiators. I hope that this alleviates any further concerns you may have 4

regarding the use of 3'Cs for this application. If you have any additional questions or concerns, i

please call Mr. Douglas Broaddus at (301) 415 5847.

Sincerely, Carl J. Paperiello, Director Office of Nuclear Material Gafety and Safeguards Distribution; IMAB r/f NRC File Center NMSS r/f PTressler HThompson JCallan EDO r/f CPoland

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-ChairmanJabkson' FOR SIGNATURC OF :

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