ML20046C244

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Insp Rept 99990003/93-10 on 930524-28.Violations Noted.Major Areas Inspected:Measurement of Radiation,Collection of Smear,Soil,Sediment & Water Samples
ML20046C244
Person / Time
Issue date: 07/29/1993
From: Glinski R, Grobe J, Sreniawski D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20046C238 List:
References
REF-QA-99990003-930802 99990003-93-10, NUDOCS 9308100030
Download: ML20046C244 (22)
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{{#Wiki_filter:. I U. S. NUCLEAR REGULATORY COMMISSION Region III Report No. 99990003/93010(DRSS) Docket No. 99990003 Facility: Advanced Medical Systems, Inc. 1120 London Road Cleveland, OH Inspection At: Residential, Public and Commercial Premises in the Vicinity of Advanced Medical Systems, Inc. Inspection Conducted: ay 24 - 28, 1993 Inspectors: Qwwh 7-3S O3 DonaldQ. Sreniawski Date Senior Health Physicist $6YiuOhm AC 2hr NfN Kayg' ant L.'Glinski, Jr. ~ Date [ Radiation Specialist Accompanying Personnel: Keith Andre Physical Science Technician i NRC RIII Carl Heller Ohio Department of Health Dwain Baer Ohio Department of Health Harvey Brugger Ohio Department of Health Approved: b h./ 7 ~ 24-13 J A. Grobe Date ef, Fuel Cycle and Decommissioning Branch { Inspection Summary Inspection of May 24 through 28. 1993 (Report No. 99990003/93010(DRSS)) t Areas Inspected: This was a radiological survey conducted at the residential, public, and commercial properties surrounding the Advanced Medical Systems, Inc.(AMS) facility on London Road in Cleveland, OH; and in the public sewer system that services the AMS facility. This inspection included the measurement of direct radiation; the collection of smear, soil, sediment and water samples; and the subsequent analysis of these samples by the Region III ] Mobile Laboratory and in the Region III Radiological Laboratory. REG 3 GA999 EMVADVAN.. 9308100030 930802 I 99990003 PDRg i

r:-- 3 I Results: The NRC inspectors did not identify any radiation levels or any radioactive contamination off the AMS property that would present a radiological health and safety concern to any members of the public. 5 i 5 6 9 i l -I I i 2

DETAILS 1. Persons Contacted Councilman Michael Polensik, Cleveland City Council Councilman Roosevelt Coats, Cleveland City Council Tom Marsalis, Department of Water Pollution Control Micheal Marcellino, Office of the Mayor Micheal Konicek, Director of Public Utilities Caroline Arnold, Sen. Glenn Staff Janice McCourt, Sen. Metzenbaum Staff Mark Loeser, Radiation Safety Officer, Advanced Medical Systems, Inc. (AMS) Sherry Stein, Director of Regulatory Affairs, AMS Robert Owen, Ohio Department of Health Richard Connelly, Northeast Ohio Regional Sewer District, (NE0RSD) Leonard Jufko, NE0RSD

===2. Background=== Advanced Medical Systems, Inc. (AMS) of Cleveland, OH, is the holder of Byproduct Material License No. 34-19089-01 issued by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 30. The license authorizes AMS to possess and use up to 150 kiloCuries of cobalt-60 as solid metal,150 kiloCuries of cobalt-60 in sealed sources and 40 kiloCuries of cesium-137 in the manufacture, installation and servicing of teletherapy units. The teletherapy units are used in medical facilities to treat cancer patients. The NRC first issued a lir.ense to AMS in November 1979 following a review of their application by NRC Headquarters, and from 1979 to the latter 1980's AMS actively manufactured sealed sources for distribution to medical licensees. Radiological surveys performed by the Oak Ridge Associated Universities (0RAU) in 1985 and then by the NRC in 1986 found that contamination levels at the London Road facility represented an unacceptable safety hazard. On October 30, 1987, the NRC issued a " Confirmatory Order Modifying License, Effective Immediately", which required AMS to complete decontamination of the London Road facility by April 1988. The NRC Region III office then contracted with ORAU to perform another radiological survey that included all of the AMS property at the London Road facility. This survey was conducted on November 14-17, 1988. Other than along the outside of the AMS facility south wall that faces the railroad tracks, no elevated radiation levels were found. Another portion of the ORAU survey included the collection of_12 soil samples from the AMS property. The results of the soil analyses revealed slight levels of contamination with a maximum level of 2.5 picoCuries per gram of cobalt-60 in the soil. This is below the 8 picoCuries per gram allowed by the NRC for release for unrestricted use. The levels of cesium-137 detected were consistent with radioactive fallout from atmospheric weapons testing (UNSCEAR, 1982). This area is fenced to prevent access by the general public. 3

The Mayor of Cleveland and a U.S. Congressional Delegation, led by l Senator Metzenbaum, expressed concern for Cleveland residents living i near AMS in letters to the NRC dated April 8 and 28, 1993. The l Cleveland City Council requested that the NRC perform a radiological survey of the neighborhood in the vicinity of the AMS facility to ensure that there are no health and safety concerns incident to the activities conducted at AMS. Although surveys had been completed over the AMS property on previous occasions, surveys had not been conducted in the neighborhood and 1 industrial areas around the AMS facility. In response to the' request made by Cleveland City Councilmen, the NRC Region III office, in conjunction with the Councilmen and City of Cleveland staff, developed a radiological survey plan for the immediate vicinity of the AMS London Road facility. The Northeast Ohio Regional Sewer District (NE0RSD) and the Ohio Department of Health assisted with the planning and the survey, i 3. Surve.y Conducted I i A) Direct radiation surveys were performed over the following areas: (refer to map on page 6 of 6 in Attachment D) l 1. At two locations approximately 0.5 miles west of AMS to l establish an area background. These locations were the l front yard of Collinwood High School and an area just south of the railroad bridge at the intersection of Ivanhoe Road & Enoch Road. 2. Along London Road approximately 0.25 miles north and south of the AMS facility, and along the railroad tracks approximately 0.25 miles east and west of AMS. 3. Along the streets of Wickford Court, Wayside Road, and Roseland Road east to the park. 4. Over the grounds, on the roofs, and at the gutter downspouts l of residential properties within 500 feet of the AMS hot cell. Three other residents requested that their property ( be surveyed and one other residence was added during the course of the survey. A total of 12 residences were surveyed. A list of the actual addresses is presented in i Attachment F and is not subject to public disclosure, in j accordance with 10 CFR 2.790. 5. Over the grounds, on the roofs, in the gutters, and at the gutter downspouts of six commercial properties in the vicinity of AMS. The following is a list of commercial j properties surveyed.

1) 1001 London Road
2) 1700 London Road
3) 1700 London Avenue, North Building i
4) 1725 London Road i

i 4 i

5) 1636 Wayside P,oad
6) 16626 Mandalay Avenue 6.

Over the grounds of the Mark Tromba Park located on Mandalay Avenue west of AMS, to include the baseball field, the basketball court, the tennis courts, the playground, and the diatomaceous earth filters used at the swimming pool. A map of the entire area surveyed is presented in Attachment A. 7. In the sewer lines immediately downstream of the AMS facility and in storm water catch basins immediately around the facility. 8. At the Easterly Sewerage Treatment Plant in areas determined to be collection points for solid material. B) The following samples were collected and analyzed: 1. Fourteen soil samples were collected from the residential, industrial, and public areas surveyed in the neighborhood surrounding the AMS facility. 2. To establish background levels for the soil from this area of Cleveland, two soil samples were collected approximately 0.5 miles west of the AMS facility. A copy of the soil sample collection form is presented in Attachment B. l 3. Nine samples consisting of water, sediment, and scrapings were collected from the sewer lines immediately downstream and the catch basins in the vicinity of the AMS facility (See Attachment E). Four samples of sludge and landfill soil were collected from the Easterly Plant. A copy of this collection form is presented in Attachment C. C) Changes frum the original survey plan. The two catch basins on London Road south of AMS and the catch basin at Rudyard Road and Mandalay Avenue were not surveyed or sampled because the surveys of London Road and catch basins closer to the AMS site showed no contamination. Subsequent analysis of sediment samples from offsite catch basins closer to AMS showed no significant cobalt-60 contamination. A copy of the original survey plan developed by the NRC Region III staff is presented in Attachment D. 4. List of Instruments Used for the Survey 1) Portable Gamma Spectroscopy Multichannel Analyzer Unit interfaced with sodium iodide detector. 2) Victoreen 190 with pancake GM probe, calibrated on 1/22/93. NRC Tag No. 42445. 5

3) Victoreen 190 with pancake GM probe, calibrated on 6/29/92. NRC Tag No. 40520. 4) Ludlum Model 19 R meter, calibrated on 5/15/93. NRC Tag No. 14808. 5) Ludlum Model 19 R meter, calibrated on 2/9/93. NRC Tag No. 10617. 6) Ludlum Model 19 pR meter, calibrated on 2/9/93. NRC Tag No. 14809. 7) Ludlum Model 19 R meter, calibrated on 5/8/93. NRC Tag No. 11021, 8) Bicron MicroAnalyst used by the Ohio Department of Health staff. t 9) Ortec High Purity Germanium detector interfaced with a personal computer (PC)-based Multichannel Analyzer in the Region III mobile laboratory. 10) Princeton Gamma Tech High Purity Germanium detector interfaced with a PC-based Multichannel Analzer in the Region III radiological laboratory. 5. Results of the Radiological Surve_y The radiation levels detected along London Road and the railroad tracks were consistent with the local background of 10-15 microRoentgen per hour. Slightly elevated readings below the NRC requirements for unrestricted areas were detected at the brushline between the railroad tracks and the AMS property line, with the radiation levels ranging from 18-22 microRoentgen per hour. Waist level and ground level surveys in this area were identical, indicating that the elevated readings were attributable to direct radiation from the AMS facility and not-i contamination of the ground from radioactive effluents. A soil sample was collected and analyzed, confirming the absence of soil contamination. I total of 16 soil samples were collected and analyzed for gamma emitting isotopes by the Region III Mobile Laboratory. The samples consisted of the following; (1) two soil samples as control to establish the local background, (2) seven samples from residential properties, (3) four samples from commercial grounds, and (4) three samples from public areas. The results of the soil analyses' are presented in Table I. No i cobalt-60 was detected in any of the soil samplest however, some of the residential soil samples possessed elevated levels of thorium-232 in equilibrium with its progeny. This phenomenon is discussed in Paragraph l 6. 6 y r-m v

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i The radiation levels found on the roofs, in the gutters, at the downspouts, and on the grounds of all the commercial properties were indistinguishable from the background level of 10-15 microRoentgen per hour. Only one of the industrial buildings possessed an air intake unit on its roof. Smear samples were taken on the air handling unit to determine whether contaminated air was being drawn into the building. No cobalt-60 was detected on the two smears taken from this air handling unit. The radiations levels found in the catch basins and sewer lines were consistent with the local background. In addition to determining the radiation levels in the sewer lines and catch basins, samples were r collected for gamma spectrometry analysis. No significant levels of cobalt-60 were found in these samples, except for approximately 1,800 picoeuries of cobalt-60 found on several small pebbles weighing 36.5 grams collected from manhole #1, the nearest manhole downstream of AMS. Based on the nature of this sample, which appeared to be mortar, it is r believed that the cobalt-60 in this sample is adhering to the surface of the material. Table Il presents the results of these analyses. The table is organized such that the sampling location closest to the AMS facility is listed first and the furthest sampling location is placed last. A map of the sampling points from the sewer lines and catch basins is also provided as Attachment E. No health and safety concerns were identified. l 6. Elevated Thorium levels at Two Residences The radiation levels detected on the roofs, at the gutter downspouts and over the grounds of the residential properties were all consistent with l background levels, except for areas of elevated radiation found at two residences. The backyard fenceline shared by these residences contained an area of approximately 12 square feet that had radiation levels that ranged from 70 - 350 microRoentgen per hour at ground level. The maximum reading at one meter above the ground was 60 microRoentgen per hour. One residence also had an area in the front yard shrubbery with levels of 30-50 microRoentgen per hour. Soil samples were taken from these areas and subsequent gamma spectrometry analysis revealed the presence of elevated levels of up to 90 picoCuries per gram of thorium-232 in equilibrium with its progeny. Although this level of thorium is unusual for the Cleveland area, there are certain places in the western United States that have equivalent radiation levels. Thorium is a material found naturally in the earth's crust and is also a chemical used in certain industrial processes. Thi NCRP Report No. 94, entitled " Exposure of the Population in the United i States and Canada from Natural Background Radiation", indicates that the ~ average amount of thorium in soil is approximately 1 picocurie per gram. Thorium levels in the other soil samples collected during this survey ranged from 1.2-2.2 picoCuries per gram. 1 The inspectors questioned the residents regarding the areas with elevated thorium levels. The residents stated that they had occupied i those premises since the middle of the 1950's, though they thought that 7

the houses had been built in the 1920's. These individuals also indicated that they had not added any soil or fill to these areas. On one side of the fence, a flower garden is present,_ while on the other i side of the fence the resident regularly applies a herbicide. The inspectors placed a GM pancake probe against the commercial herbicide r container and did not detect any radiation above background. The NRC and the Ohio Department of Health have evaluated the thorium soil levels at these residences and concluded that they do not pose a health and s safety concern. At this time, no determination has been made regarding the origin of the thorium and this remains an open issue. No action is i recommended concerning the soil. No health and safety concerns were identified. 7. Exit Meeting l An NRC Region III management representative, members of the inspection team and NRC's regional public and government affairs staff conducted a public exit meeting at the Holy Redeemer Roman Catholic Church on May 28, 1993. The purpose of the meeting was to: (1) discuss the { preliminary findings of the onsite inspection, as described in Inspection Report No. 030-16055/93002(DRSS); (2) describe the results of i surveys conducted by the inspection team in neighborhood areas surrounding the AMS facility, as described in Inspection Report i No. 99990003/93010(ORSS); and (3) respond to questions from elected officials and the public. The public meeting was attended by state and local government officials, licensee representatives, several media representatives and approximately 25 members of the public that reside in the vicinity of the AMS facility. Tables: I. Soil Analysis Results II. Analysis Results of Sewer Line and Catch Basin Samples l Attachments. A. Map of Entire Survey area B. Soil Sample Collection Form C. Sewer Line/ Catch Basin Sample Collection Form J D. Original Survey Plan E. Map of Sewer Line and Catch Basin Survey Locations F. List of Residences Surveyed { l i l i 8 l

l i Table I. Soil Analysis Results All results are in picoCuries per gram of wet weight. The uncertainties reported are two standard deviations. Location Co-60 Cs-137 Th-232 K-40 London Road, 93-398 <0.16 0.82 1.90 20.6 +/-0.16 +/-0.48 +/-2.0 London Road, 93-397 <0.15 0.65 1.96 19.6 +/-0.12 +/-0.40 +/-1.9 Alhambra Road, 93-395 <0.15 1.0 1.68 17.6 +/-0.14 +/-0.36 +/-1.8 Alhambra Road, 93-396 <0.14 0.83 2.17 20.5 +/-0.16 +/-0.40 +/-2.0 V Alhambra Road, front <0.26 0.53 34.4 27.4 yard near shrubs, 93-415 +/-0.25 +/-1.72 +/-3.2 Alhambra Road, #1 along <0.31 <0.43 91.4 31.9 backyard fence, 93-399 +/-3.0 +/-4.0 2 Alhambra Road, #2 along <0.29 0.47 84.6 27.4 backyard fence, 93-422 +/-0.30 +/-2.88 +/-4.4 Superior Die Casting, along <0.19 1.34 1.56 23.4 London Road +/-0.19 +/-0.30 +/-2.8 Superior Die Casting, Office <0.20 1.53 <1.42 17.3 Building +/-0.24 +/-2.9 i Tribco Parking Lot <0.17 0.54 1.51 7.2 +/-0.16 +/-0.66 +/-l.9 Atlas Sewer and Pipe <0.17 0.24 1.56 15.7 Cleaning, Grape Area +/-0.11 +/-0.58 +/-2.6 Between AMS fence and <0.18 0.47 <0.71 10.6 Railroad Tracks +/-0.16 +/-1.8 9

Mark Tromba Field, backstop <0.08 0.22 1.17 16.0 +/-0.08 +/-0.30 +/-1.58 Mark Tromba Field, left field <0.10 0.51 1.52 19.5 +/-0.08 +/-0.40 +/-1.74 Collinwood High School, l <0.10 0.85 1.90 18.6 background +/_0.14 +/-0.34 +/-1.6 Ivanhoe Road and Enoch Road, <0.08 0.69 1.16 15.5 background +/-0.11 +/-0.31 +/-1.54 f P B [ 10

I Table II. Analysis Results of Sewer Line and Catch Basin Sample. All results are presented as picoCuries per gram of wet weight unless otherwise indicated. The uncertainties reported are two standard deviations. ND indicates None Detected. A specific lewer limit of detection (LLD) was not assigned to these measurements due either to unique geometry contraints or the LLD value was not recorded. i Location Co-60 Cs-137 Manhole #1 - Water 1.17 ND +/-0.14 Manhole #1 - Rung Scrappings ND 1.09 Manhole #1 - Benchwall ND ND Manhole #1 - Pebbles off Bottom Appox.1800 ND picoCuries* Manhole #3 - Sediment / Water 0.69 ND +/-0.14 Manhole #3 - Rung Scrappings ND ND Catch Basin Sediment - Mandalay Avenue <0.06 0.06 and London Avenue +/-0.04 Catch Basin Sediment - Mandalay Avenue ND 0.15 and Alhambra Road +/- 0.16 Manhole #13 - Sediment ND ND NE0RSD Easterly Plant - Dewatering Unit <0.15 <0.14

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<0.10 <0.08 NE0RSD Easterly Plant Landfill Soil #1 <0.23 <0.22 NE0RSD Easterly Plant Landfill Soil #2 <0.14 <.10

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/ I~inal Radiological Survey Plan May 21, 1993 for AMS and Surrounding Areas 1. Purpose The purpose of this radiological survey is to determine whether there exists any contamination from AMS operations that would pose a health and safety concern outside of the AMS facility. II. Coordination Meetings have been conducted with concerned Cleveland elected officials, Cleveland City staff and Northeast Ohio Regional Sewer District staff to discuss the AMS facility, review the survey plans and obtain their input. Their input has been incorporated into this plan. Assistance has been secured from Northeast Ohio Regional Sewer District and Cleveland City personnel to gain access to sewers, basins and sewage treatment facilities and to assist in performing surveys and sampling those areas. The AMS Radiation Safety Officer will provide access to areas under AMS' control and any necessary radiation protection measures for access to those areas. The-Cleveland Public Services, Water Pollution Control and Public Utilities Departments will assist the survey team with access to industrial facilities and roofs, and residential buildings and roofs, and provide secure facilities to support the Mobile Laboratory. Federal, State and local elected officials will be notified of the survey and close out meeting plans. Coordination has occurred with the City of Cleveland (elected officials and staff), Cuyahoga County Department of Health,' Ohio Department of Health, and Northeast Ohio Regional Sewer District. Region III Public Affairs and Government Liaison staff will assure appropriate notifications are made. Federal elected officials will be notified through the Office of Congressional Affairs. A notificati.on to local residents and businesses will be delivered door to door by Cleveland City personnel to assure that the local neighborhoods are aware of the NRC activities. Region III has reviewed that notification. A press release will be issued by Region III announcing the time and location of the close out meeting for the surveys. i M ATTACIIMENT D noe I orknats

. May 21, 1993 Ill. Personnel The personnel conducting the survey will consist of two inspectors and one technician from the Region Ill staff. In addition to NRC personnel, the Ohio Department of Health (ODH) has committed staff support to the survey team. A separate inspection effort by two other inspectors will be concurrently conducted (See Attachment) within the AMS facility to evaluate release pathways and radiological conditions. That effort will be assisted by an NMSS Section Leader. A Region III Branch Chief will conduct the public close out meeting. IV. Equipment The Region III Mobile Laboratory will be used for the counting of soil / sludge / water samples collected during this inspection. MicroR meters, Hal crystals, and pancake GM probes will be used for direct radiation surveys. Sampling supplies will be obtained from the Region III lab. Any apparatus necessary to sample sewers will be provided by the NE0RSD and Cleveland City staff. I i V. Radiological Surveys A. Direct radiation surveys will be conducted over the following areas: r

1. At two locations approximately 0.5 mile west of AMS to i

establish a local background. This will include Collinwood High School and one other location identified by the City of Clevel and.

2. Along London Road 1/4 mile north and south of the AMS Tacility.
3. Along the railroad tracks 1/4 mile east and west of the AMS facility.
4. Along Wickford Court, along Wayside Road between Wickford Co6rt and Roseland Road, and along Roseland Road between Wayside Road and Avalon Road.

5. Over the on-site grounds of the AMS facility, and at all gutter downspouts. Particular attention will be paid to the external surfaces of the AMS facility to assure that they will be in compliance with the revised 10 CFR Part 20 (100 mrem /y. car in unrestricted areas). j M ATTACHMENT D 0 PAGE A ofkPAGES a

. May 21, 1993

6. Over the grounds and at the gutter downspout of representative industrial and residential properties within 500 feet of the AMS hot cell location. This will include residences north of Handalay Avenue on London Road, Alhambra Road and Rudyard Road.

In addition, the grounds of the following residences will be survevq: London Road ~ ( Alhambra Road ( SPECIFIC ADDRESSES WITHHELD Alhambra Road ( IN ACCORDANCE WITH Alhambra Road ( Rudyard Road ( 10 CFR 2.790

7. On representative industrial roofs within 500 feet of the AMS hot cell location including any air intake housings.
8. On representative residential roofs and gutters within 500 feet of the AMS hot cell location.
9. Over the grounds of the park, the swimming pool, the tennis courts, the park facilities, and the baseball field west of AMS on Mandalay Road.
10. In the manhole and sewer lines on-site at AMS and in the manholes, road way gutter basins, and sewer lines off-site and downstream of AMS. This will include two road way gutter basins along London Road north of the railroad tracks, two road way gutter basins along London Road south of the railroad tracks, road way gutter basins at the corner l

of Alhambra Road and Mandalay Avenue and at the corner of Rudyard Road and Mandalay Avenue, and three manhcles to the London Road sewers downstream (north) of the AMS outfall. I (

11. At the Easterly Plant in areas that the NE0RSD f

identifies as solids collection points. Any detected cobalt-60 off the AMS property will result in a j revision of the survey plan to address the scope and nature of that finding. Most surveys will be conducted using microR meters or Hal crystals. However, GM pancake probes will be employed in those circumstances in which they would be significantly easier to handle; The GM probes may also be used for confirmation of any areas giving elevated readings with microR meters. B. Sample Collection - At this time it is estimated that, as a minimum, the following samples will be collected and counted in the Mobile Lab. Preliminary tests show that a one hour count of a 500 ml geometry will generate a minimum detectable activity of <l pCi/ gram. The NRC safe release level for cobalt-60 in soil is 8 pCi/ gram. j ATTACIIMENT D S PAGE 0 of_h_ PAGES --)

4 t May 21, 1993 1. Two soil samples from the locations approximately 0.5 mile west of AMS identified by the City of Cleveland to establish a local backgrcund. These will be the same locations where background surveys are performed pursuant to 1. above. 2. Sludge samples from the basins, manholes, sewers, and sewage treatment systems, at locations described in

10. and 11. above.

3. Several soil samples consisting of on-site samples, residential samples and samples from the bordering industrial sites. Samples will also be taken at any location that yields elevated readings on the survey equipment. 4. A water sample will be taken from the public swimming pool, if it is filled. If it exists, used swimming pool filter media will be obtained and analyzed. A soil sample will be taken from the public baseball field. l' G [1 l 'l ] Approved: {p61CycleandDecommissioning

Attachment:

Advanced Medical Systems Onsite Inspection / Survey Plan A~ITACIIM ENT D S PAGEf of b PAGES

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i The addresses listed in this attachment are not to be disclosed publicly, in accordance with 10 CFR 2.790. The following is a list of the of residences surveyed: f 1) l 2)6 3 4) i 5) 6) t 7) I 8) I 9 10) 11) 3

12) W i

i i l e i i !~ s i ( 5 ATTACHMENT F ncel or.L nars h 1 ,,. _,}}

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