Comment (1) from Victor Anderson

Document ID: NRC-2008-0419-0002
Document Type: Public Submission
Agency: Nuclear Regulatory Commission
Received Date: July 31 2008, at 02:40 PM Eastern Daylight Time
Date Posted: August 8 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: July 31 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: September 30 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806a52db
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The opinions expressed in the comments below are mine and mine alone and do not necessarily reflect those of my employer, co-workers, or colleagues. Cs-137 in the chemical form of CsCl is used throughout medicine, industry, and research. The National Academies of Science issued its report entitled, Radiation Source Use and Replacement." While the report is in the main well thought out, the executive summary under finding 2a reads, Radioactive cesium chloride sources are in the form of a steel-encapsulated, compressed powder." This statement is at best misleading and at worst an outright lie by omission. Radioactive CsCl starts out in a physical form similar to "rock salt." In other words, large hard crystals. It is not a powder. The CsCl is then compressed into pellets under pressure and temperature. These pellets will behave very differently in the environment of a high energy explosion than a powder. This is an important technical difference. The report then goes on to recommend in Finding 3b: "In view of the overall liabilities of radioactive cesium chloride, the committee judges that these sources should be replaced in the United States and, to the extent possible, elsewhere." This is the most onerous and foolish of the report's recommendations. To understand why this is, one must first realize that the actual fatalities from a radiological weapon due to ionizing radiation will be few to none. For the use of an explosive radiological dispersion device (RDD or "dirty bomb"), the most likely result will be no deaths due to ionizing radiation. There will be a need to remediate a large radioactively contaminated area. Cleanup is technically possible. The major issues will be costs and cleanup to what levels of residual radioactivity. To date, no individual or group has successfully used a radiological weapon capable of contaminating a large area. The hazard and risk from radioactive CsCl being used in a "dirty bomb" or other radiological weapon is a potential one that may or may not occur. The benefits from the uses of radioactive CsCl are enormous. Radiation survey meters are calibrated using Cs-137. This is an international standard that cannot be easily or inexpensively replaced. Blood irradiators are used to prevent host graft rejection for blood transfusions. The host graft rejection condition can be fatal. It occurs often enough to be of real concern to physicians. Thousands of very real lives are being saved by the use of blood irradiators. These are just two examples of the benefits of using radioactive CsCl. How many people will be killed in our mania to prevent the use of a weapon that will kill or injure less than 10 and most likely no individuals due to ionizing radiation? Furthermore, we can clean up the mess from a "dirty bomb" that uses radioactive CsCl, we can't bring back the dead from the non-use. Reasonable efforts should made for the security of these high activity sources. What we cannot do, is have that security end up killing patients because irradiation of blood products and other treatments are curtailed or can't be done. In addition, we cannot cost ourselves extremely large sums of money because of worries about a weapon use that has not occurred. Reasonable security measures such as the Nuclear Regulatory Commission's Increased Controls program are more than adequate to secure these radioactive sources. Improvements to these programs should be made after careful consideration of risks and benefits. Finally, I want to once again emphasize that removing these radioactive CsCl sources and the devices that use them from service is very, very bad idea. It is an idea that will place real lives in jeopardy, and cost untold amounts of money and resources. And for what? Because we might, maybe have to deal with cleaning up some radioactively contaminated land. This is madness. Far better to maintain and keep these very valuable devices that use Cs-137 in the form of CsCl, secure them appropriately, and continue to receive the very real benefits of their use.

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Total: 25
Comment (1) from Victor Anderson
Public Submission    Posted: 08/08/2008     ID: NRC-2008-0419-0002

Sep 30,2008 11:59 PM ET
Comment (2) from Vincent Yalon, Stanford Medical School Blood Center
Public Submission    Posted: 08/08/2008     ID: NRC-2008-0419-0003

Sep 30,2008 11:59 PM ET
Comment (3) from Curt Pendergrass, KY Radiation Health, Department for Public Health
Public Submission    Posted: 08/08/2008     ID: NRC-2008-0419-0004

Sep 30,2008 11:59 PM ET
Comment (4) from Ken Love, Christiana Core Health Services, Newark, DE
Public Submission    Posted: 08/08/2008     ID: NRC-2008-0419-0005

Sep 30,2008 11:59 PM ET
Comment (5) from Clare Grehofsky, Fluke Biomedical, Solon, OH
Public Submission    Posted: 08/08/2008     ID: NRC-2008-0419-0006

Sep 30,2008 11:59 PM ET