ML20134B625
| ML20134B625 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1995 |
| From: | Paperiello C NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| Shared Package | |
| ML20134B601 | List: |
| References | |
| FOIA-96-444 NUDOCS 9509050029 | |
| Download: ML20134B625 (21) | |
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UNITED STATES
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NUCLEAR REGUI ATORY COMMISSION E
f WASHINGTON, D.C. 2065M001
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g August 22, 1995 MEMORANDUM T0:
Dennis K. Rathbun. Director Office of Congressional Affairs THRU:
Hugh L. Thompson, Jr.
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Deputy Executive Director for F Nuclear Materials, Safety, Safegaards and Operations Support V
4 FROM:
Carl J. Paperiello, r
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Office of Nuclear and Safeguards
SUBJECT:
BRIEF STATUS OF ADVANCED MEDICAL SYSTEMS, INC.
i Attached is a brief status of the situation of Advanced Medical Systems, Inc., that has been generated to address Senator John Glenn's inquiry on the subject.
Attachment:
As stated CONTACT: Cynthia Jones, NMSS (301) 415-7853 i
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BRIEF STATUS OF ADVANCED HEDICAL SYSTEM 3, INC.
August 14, 1995 1.
WATER PROCESSING AND SITE REMEDIATION ACTIVITIE5 As a result of a Federal District Court judgment against Advanced Medical Systems, Inc. (AMS), a temporary restraining order was issued to prevent AMS from discharging waste water into the Northeast Ohio Regional Sewer District (NE0RSD) sewage collection and treatment system.
On November 15, 1994, NE0RSD installed plugs in the AMS connections to the sewage system. This resulted in increased water levels in the soil around the facility and, by mid-January 1995, ground-water intrusion into the basement of the facility.
The water in the basement became radioactively contaminated from facility surface contamination.
In April 1995, AMS began processing (cleaning) the water in the basement and the AMS manhole. Nearly 100,000 gallons of water were processed until the basement was clear of water, on June 23, 1995.
The processed water is currently stored in 25,000-gallon storage bladders inside the AMS facility.
The U.S. Nuclear Regulatory Commission (NRC) as well as the Environmental Protection Agency recently authorized AMS to dispose of the water by evaporation.
On July 3, 1995, excavation and immobilization projects began. A new manhole on AMS' property was installed, and the old AMS manhole and lateral connector to the NE0RSD sewer lines were grouted.
Extensive contamination was found throughout the underdrain system, which necessitated the removal of most of the old system and the installation of a new system.
The new system will not be connected to the NE0RSD sewer lines until both the NE0RSD and NRC grant permission. Until then, AMS will pump rain and ground water out of the new underdrain system and manhole into outdoor storage tanks, where the water will be analyzed for Co-60, and then processed, if necessary.
2.
AMS LICENSE RENEWAL The AMS license expired on December 31, 1994. On November 29, 1994, AMS submitted its application for renewal. This application was revised and resubmitted on January 26, 1995.
It consisted of four parts:
(1) application for materials license, (2) emergency plan, (3) decommissioning funding plan, and (4) financial assurance. NRC has reviewed and sent deficiency letters to AMS for each part of the application. Although NRC has received responses from AMS, several issues still need clarification and remain outstanding. On March 13,1995, NE0RSD and the City of Cleveland were granted their request for a hearing regarding the sufficiency of the license renewal application; this hearing is conducted under the 10 CFR Part 2, Subpart L, " Informal Hearing Procedures for Adjudications in Material and Operator Licensing Proceedings."
1 ATTACHMENT
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COMPLETION OF PHYSICAL INVENTORY l
License Condition No. 14 of the AMS license requires AMS to have conducted a j
physical inventory by June 1, 1993, and thereafter to conduct such an inventory every 60 months.
i On March 30, 1993, AMS had completed all aspects of the required physical inventory except for the contents of the front storage well in the hot cell.
The. floor plug covering this storage well could not be removed; thus the 4
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sources within the cell could not be inventoried.
l AMS made several attempts to remove the stuck floor plug, in 1993 and in 1994, but was unsuccessful.
It plans to mill out the plug sometime in the next few months. An outside contractor has already been chosen for the project, and all the necessary equipment has been fabricated.
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4.
COMPLETION OF EMERGENCY EXERCISE l
License Condition No.18 of the AMS license requires AMS to conduct an emergency exercise every 2 years. During an NRC inspection conducted at AMS in October 1994, NRC inspectors discovered that AMS had failed to conduct an l
emergency exercise.
1' By letter dated December 29, 1994, AMS indicated that a full-scale exercise i
with offsite emergency personnel would be scheduled by February 28, 1995, and
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conducted by August 31, 1995.
Since then, AMS has submitted a revised j
emergency plan as part of its license renewal application. This new plan is currently being revised, because of extensive input from NRC and local offsite
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response organizations. AMS has not scheduled the exercise because of the extensive revision of the submitted emergency plan and the other safety j
related issues at the facility requiring its immediate attention.
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5.
REDUCTION OF LICENSED MATERIAL 1
j According to AMS, approximately 22,000 curier, of unsealed-and 48,009 curies of sealed-source solid metal cobalt-60 are stored at the facility. Since AMS is no longer manufacturing sealed scurces and has no plans to make use of the j
sealed sources, AMS has indicated that this material is not necessary for its-operations. AMS has also stated that the material will eventually be i
i transferred offsite.
AMS has also stated that approximately 11 curies of cobalt-60 reside in various rooms in the facility as uncharacterized surface contamination.
In addition, approximately 29 curies of packaged, solid cobalt-60 waste reside in the high-level waste storage room, and in boxes and drums in the basement.
l The surface contamination and waste have been accumu;ating over many years.
4 AMS has indicated that the contaminated areas will eventually be i
i decontaminated, and the waste will be transferred offsite.
l In addition, AMS has indicated that approximately 40 curies of unpackaged i
2 i
4
l cobalt-60 waste are contained in the Waste Hold-Up TanA roum. This room is no longer used and was made inaccessible to workers in the late 1980s. AMS has indicated that this room will eventually be decontaminated, and the waste will be transferred offsite, 6.
OHIO STATE EMERGENCY RESPONSE COMMISSION (SERC)
On June 16, 1995, the SERC approved a resolution to designate AMS as an additional planning facility.
If this resolution becomes an order, it will authorize the Cuyahoga County local emergency planning committee to request from AMS the information necessary for developing ano implementing a chemical emergency response and preparedness plan. On October II, 1995, the SERC will vote on whether to issue this resolution as an order.
In the minutes of the SERC meetings in which this resolution was discussed, and in letters the SERC has received regarding the resolution, several statements have been found that required clarification concerning NRC oversight of the AMS facility. The statements primarily refer to AMS' inventory of radioactive material, its emergency response plan and exercises, and the security of the AMS facility.
In response, Region III (RIII) has written a letter to the SERC that includes clarifying information on these topics.
The letter, which was reviewed by RIII, the Office of Nuclear Material Safety and Safeguards, and the Office of General Counsel, was sent to members of the SERC and others, via fax and express mail, on August II, 1995.
7.
NRC STAFF ACTIONS l
The NRC staff is considering what additional iaformation and actions the licensee may need to provide and undertake regarding the following activities 1
(as discussed above):
(1) completion of physical inventory, (2) complei. ion of emergency exercise, (3) reduction of radioactive material inventory, (4) decontamination of facility, and (5) decommissioning / decontamination of the Waste Hold-Up Tank room.
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ADVANCED MEDICAL SYSTEMS,INC.
NORTHEAST OHIO REGIONAL SEWER DISTRICT STRATEGY PLAN Task No.1 - Resolve Facility Water issues Lead - Region III Suonort - IMNS/NMSS l
Task completion date: My@@If1995 Current Status License amendment # 32, March 17, 1995, authorizes water processing Wastewater stored outside facility in above ground tanks processed and pumped to " storage bladders" inside the facility
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Implement long term groundwater control and processing program t:vaporate processed water stored in " bladders" demediate city sewer interceptor and install new manhole / lateral system 1
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Task No. 2 - Evaluate Facility Structural Integrity and P.
Inventory and Decontaminate Facility Sub-Task A - Complete StructuralIntegrity Assessment Lead - Region III Suonort - IMNS/NMSS gdhintiiif 1995 Sub-task comoletion date:
f Assessment initiated by NRC civil engineer in October 19 foundation water problems existed i
in Re-assessment will commence upon completion of water pro MIMi#1[QEniMjMEGrXeisifpfgp1R{$][@(({M July 1995 Sub-Task B - Reduce inventory and Decontaminate Fac Lead - Region III Suonort - IMNS/NMSS, 0GC Late 1996 Sub-task completion date:
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i Expect inventory reduction program to be completed wi renewal fter months of license renewalContractor to mill-out the stuck f facility water issues are resolved J
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August 28, 1995
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t Task No. 3 - Develop Contingency Plan to Address Situation Where AMS Abandons the Facility 1
kgad - IMNS/NMSS Support - OGC & Region III Task Comoletion date: November 1995 In the event that AMS were to abandon the facility, NRC needs a contingency plan that addresses the actions identified below.
l Actions that must be taken to address oronosed situation:
Immediate Actions:
Order licensee to take responsibility for actions Verify that the facility is secure and in a safe shutdown condition.
Maintain ADT security services Maintain ventilation and emergency electrical back-up systems Maintain contractor control of basement water Maintain operation and testing of radiological monitoring systems Consider other federal options such as Superfund (EPA).
l Short term actions:
Order payment of decomissioning funds into standby trust (currently irrevocable standby letter of credit for $1.8 million from Bank One, Cleveland)
Work with Trustee to hire contractor for --
Immediate security and maintenance needs and submittal of decomissioning plan In the event AMS were to file for bankruptcy protection, file a notice of claim in bankruptcy proceeding a..d/or monitor proceeding.
l Long term actions:
I Review and approve decomissioning plan Monitor progress of decomissioning and use of funds August 28, 1995 3
Tack No. 4 - Complete Review and issue License Re Sub-Task A - Review Safety Program Lead - Region III I
Sucoort - N/A Il6sisti&j 1995 7 1995.
Sub-task completion date: Review completed and defElency le Response due Review license response to deficiency letter.
June 1, 1995 Review licensees response to deficiency letter.
Sub-Task B - Review Emergency Plan i
Lead - Region III Support - IMNS/NMSS November 1995 S_ub-task completion date:
13, 1995 NMSS review completed AprilLicensee soliciting comm l review Emergency plan deficiencies identified b response organizations i sion olve and County and City emergency planning committees to res l
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concerns Sub-Task C - Review Decommissioning Plan and C i
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Lead - Region III Suooort - DWM/NMSS l
({iisiliiij 1995 iub-task comoletion date:
h 29, Review has been completed and deficiency letter issued sj995 E @ lij M i@ 7 % M lHIElii 1995
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Sub-Task D - Review Decommissioning Financial Instruments Lead - Region III Support - DWM/NMSS Sub-task completion date: Njjj@ij1995 Review has been completed and deficiency letter issued March 13, 1995.
Licensee response dated March 31, 1995, forwarded to DWM/NMSS for review on April 14 1995
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Task No. 5 - Conduct License Renewal Hearing-Subpart l l
_Suooort - Region III, IMNS/NMS t
OPEN l
Task comoletion datet:
t blished.
Presiding Officer has been assigned and parties have been es 12, 1995 itten Hearing file filed on AprilPresiding officer to issue a sched Request from the Village of Newburgh Heights to particip presentation The interested municipality pending before the Presiding Officer.
Date for staff did not oppose request.
Staff prepare presentation for license renewal hearing.
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August 28, 1995
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1 Task No. 6 - Respond to 10 CFR 2.206 Requests from NEORSD Sub-Task A - First Petition dated March 3,1993 Lgad - IMNS/NHSS Support - OGC Task comol tion date: OPEN t
Petition Reauest: 1) AMS assume cost of cleanup of NE0RSD
- 2) AMS decontaminate sewer connecting London Road facility with public sewer and continue decontamination to extent sampling indicates is necessary aginowledaement of Petition: Published in FR on April 13, 1993 Status of Director's Decision:
NMSS forwarded draft Director's Decision to OGC for review on December 28, 1994. 0GC drafting Commission options paper.
i Options paper addresses the scope of responsibility of licensees for offsite contamination as a result of licensed activities, notwithstanding apparent compliance with applicable release limits during the period of those licensed activities, which results in a level of offsite contamination of another person's property that must be controlled and/or remediated.
Sucolemental Correspondence with NE0RSD that is beina handled under Petition 1 Letter from NE0RSD dated September 13, 1994 Request:
- 1) Pursuant to 10 CFR 2.206, NRC commence enforcement action against AMS, pursuant to NRC authority under 10 CFR 20.601 (Violations), for violation of 10 CFR 20.401(c)(3)(Records of surveys, radiation monitoring, and disposal); NE0RSD believes disposal records are grossly inaccurate
- 2) NRC commence enforcement action against AMS on violation of 10 CFR 20.303(a) (Disposal by release into sanitary sewerage systems), which requires that all material discharged be readily soluble or dispersible i
l August 28, 1995 7
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Letter from NE0RSD dated October 13, 1994 Request :
- 1) In addition to the enforcement actions requested on September 13, 1994, the NRC also commence an enforcement action against AMS for violation of 10 CFR 20.2003 (discharges that are not readily soluble) i Sub-Task B - Second Petition dated August 19,1994 Lead - IMNS/NMSS Suocort. - OGC Task comoletion date: CLOSED - June 16, 1994 Petition Reauest: AMS provide adequate financial assurance to cover public liability pursuant to section 170 of the Atomic Energy Act of 1954, as amended Acknowledaement of Petition: Published in FR on December 6, 1993 Status of Director's Decision:
Director's Decision sianed June 16, 1994, published in FR on June 24, 1994; Petition denied on the grounds that section 170 of the AEA (Price-Anderson) did not apply to this material licensee; NRC policy is not to apply Price-Anderson to specific material licensees.
Sub-Task C - Third Petition dated August 19,1994 Lead - IMNS/NHSS Support - OGC Task completion date: OPEN Petition Reauest: NRC require AMS to install, maintain, and operate a i
radiation alarm system on all drains at 1020 London Road, Cleveland, Ohio (AMS facility) that lead to either sanitary or storm sewers Acknowledaement of Petition:
Published in FR on September 19, 1994 Status of Direct,or's Decision:
NMSS forwarded draft Director's Decision to OGC for revies on Februar 2 1995 EsttMtsIbiTisikith~'WEOR$0!isdfEst1With'itTissifdiFitf6HKthis intitionlls@eferiFsdisntuithilhikingissidMgsr~titssubpst$j~Efs"t i
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I Task No. 7 - Respond to 10 CFR 2.802 Req"ests from NEORSD i
Dated August 2,1993 Lead - RES l
Suonort - IMNS/NMSS Task completion date:
Late 1999 Petition Reauest: 1)
.NRC amend regulations to require all licensees provide at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notice to the-appropriate sewage treatment plant before releasing radioactive material to the sanitary sewer 2)
NRC exempt materials that enter the sanitary waste stream from the requirement regarding NRC approval for incineration Acknowledaement of Petition: Published in FR on October 20, 1993 Status of Rulemakina Decision:
In the ANPR signed February 18, 1994, and published in FR on February 25, 1994, entitled Disposal of Radioactive Material by Release into Sanitary Sewer Systems, it was noted that comments on the issue raised by this Petition for Rulemaking would be considered in any possible revision to NRC regulations.
Prior to making revisions to the regulations, RES has proposed that a model be developed to evaluate the Part 20 sewer release limits ($1;ff9538l l
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August 28, 1995 9
Task No. 8 - Characterization /Remediation of NEORSD Facilities i
Lgad - DWM/NMSS Support - Region III Task completion date: March 1997 The current objective is to remediate cobalt-60 contamination so that the NE0RSD sites can be eventually released for unrestricted use. To achieve this objective, we will utilize a process consistent with our j
treatment of other unlicensed SDMP sites. We expect that the NE0RSD l
will propose a decay-in-storage approach as their remediation and waste disposal methods. As discussed with the NE0RSD representatives on February 27, 1995, we would likely approve a decay-in-storage approach for controlling subsurface contamination at both the Southerly and Easterly Plant sites with adequate controls.
If an appropriate radiological health and safety program is proposed, we do not plan to require an NRC license.
There is no immediate health and safety hazard at the Southerly and Easterly Plants because the contamination is below the surface and the NE0RSD's program includes controls and monitoring for any subsurface excavations that could result in public or worker exposure.
Sub-Task A:
Approval of the Southerly Plant Site Characterization Report Sub-task comoletion date: GEfBMg1995.
The NE0RSD's response dated February 27, 1995, to the NRC comments on the site characterization report submitted by the NE0RSD dated June 30, 1994; piis]K6debNiad}995]hpolt(GiidiMfM11@ij$.
Sub-Task B:
Preparation of the Remediation PlanMf S'66t@yffsfij including Waste Disposal Option (s) by the NEORSD Sub-task completion date: March 1996 NRCMstig)ntiiiWs'j6iii'sfTiNiiedjitjRpMii, based on the final site characterization reporf,' f6FNRC's review; expect a decay-in-storage approach to be oroposed with appropriate radiological controls over the storage period. We expect NEukSD to submit a remediation plan by October 1995. NE0RSD would propose a schedule for "remediation" in their remediation plan.
August 28, 1995 10
Sub Task C:
Performance of Remediation and Final Survey 6f
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@@jh~s~rl,yjjdj by the NEORSD Sub *esk completion date: March 1997.
NE0RSD will perform remediation of the site according to the remediation plan approved under Sub-Task B.
Schedules for completion of the remediation would be proposed in the remediation plan.
If NECRSD proposes to release site areas for unrestricted use, final surveys would be conducted and the data submitted to the NRC for review.
l Sub-Task D:
Review of the 5,6@[e~r]9M~j Final Survey Repo t Sub-tdsk completion date: June 1997 IF NE0RSD proposes to release site areas for unrestricted use, NRC staff will review any final survey reports and perform confirmatory surveys, if needed.
Sub-Task E:
Review of Easterly Plant Health and Safety Plan Sub-task completion date: Junc 1997 i
On March 16, 1995, NRC requested NE0RSD to provide a description of the radiological controls to be put in place at the Easterly Plant.
NE0RSD is considering the NRC request. NRC staff would review this plan when it is submitted.
Sub-Task F:
Periodic Site Visits Sub-task completion date: Ongoing 4
NRC inspection staff would conduct periodic site visits to assess the radiological control program implementation.
It is expected that site a
visits would be made on about a five year frequency. NRC inspection i
staff last visited NE0RSD Easterly and Southerly plants during the week of October 31 - November 4, 1994.
c:strtsy3.Jed August 28, 1995 11
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I ADVANCED MEDICAL SYSTEMS,INC.
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NORTHEAST OHIO REGIONAL SEWER STRATEGY PLAN Task Completion Date I
Near Term Operationalissues
@ @ j 1995 1.
Task No. 1 - Resolve Facility Water Issues d Reduce Task No. 2 - Evaluate Facility Structural Integrity an Inventory and Decontaminate Facility fl6iNiillsl61995 G W 1996 A - Complete Structural Integrity Assesst::::ntB - Re November 1995 i
tion Where Task No. 3 - Develop Contingency Plan to Address S tua AMS Abandons the facility l
License Renewa) Process
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l Task No. 4 - Complete eteview and Issue License Renewa N6Feistish 1995 November,1995
)
A - Review Safety Program Wivestieh 1995 B - Review Emergency Plan C - Review Decomm'tsioning Plan and Cost Estimate goleilsj1995 D - Review Decomtd:,sioning Financial InstrumentsOPEN L
Task No. 5 - Conduct License Renewal Hearing-Subpart fil. Petitions NE0RSD Task No. 6 - Respond to 10 CFR 2.206 Requests fromOPEN Cl0 SED A - First Petition dated March 3, 199319, 1994 OPEN 8 - Second Petition dated August 19, 1994 C - Third Petition dated August Late 1999 E0RSD Task No. 7 - Respond to 10 CFR 2.802 Requests from N Dated August 2, 1993 IV.
NEORSD Status March 1997 ilities Task No. 8 - Characterization /Remediation of NE0 tW~iss6iiii 1995
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A - Approval of the Southerly Plant Site March 1996 Characterization Report t
B - Preparation of the Remediation Plan including Was e March 1997 Disposal Option (s) by the NE0RSD C - Performance of Remediation and Final Survey by i
June 1997 the NE0RSD June 1997 D - Review of the Final Survey ReportE - Review of Ongoing i
F - Periodic Site Visits 12 August 28, 1995
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Summary of the telephone conference held at 10:00 am, August 31, 1995 among RIII, OGC, and INMS concerning the AMS site visit and exit meeting on August j
30, 1995.
i RIII CPederson l
BBerson i
.h jb KNull IMNS
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I DCool FCombs GPangburn JDeCicco OGC MZobler MStein i
There will now be an integrated inspection reporting procedure by RIII concerning AMS, with 6-8 week reports.
l David Cesar has been appointed Vice President of production, as well as being a chief financial officer of AMS.
Carol Berger is being retained as a member of AMS's Radiation Safety Committee; she will be looking at the overall program at AMS to bring P up to i
date, eliminate unnecessary procedures, and prioritize the work to be done.
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The underdrains have been completely replaced around the building; water from i
the drains will be collected, tested, and released to the parking lot if not detectable Co-60.
There is approximately 100,0G gallons of processed water in storage, at' about 118 pCi per liter (total of 45 microcuries); AMS is working on getting the l
City of Geneva to take this water into their sewerage system; AMS is not I
pursuing evaporation of the water at this time.
There is no progress with connecting the lateral to the NE0RSD interceptor f
line.
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r There has been access denial by NE0RSD to the intercept, probable denial until f
litigation settlement.
j WHUT room contains water from flooding; AMS evaluating method of dewatering it, possibly by. dehumidifying.
l AMS has expended I person-rem for the dewatering / drainage remediation since i
starting the process; 250 mres was the highest dose to any one individual.
The 4-inch line, and the drainage line around the source lab area (that was left in-ground) still needs to be grouted.
l Violations found will be properly documented for access to the public.
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i STRATEGIC PLAN
- 1. Sales - (proprietary information) Sales of therap., head is going up, 6 heads this year to India alone, 9 next year; AMS will not be making sources but will buy sealed source to place in heads.
- 2. N;S plans to ship 5,000 Ci in the next few weeks to NPI
- 3. Highest Priorities expressed oy AMS
- a. remediation program for water and drainage / sewerage discharge
- b. C8erger to look at license renewal and make a new submission as a revised renewal appitcation; present one is confusing.
- c. AMS wishes more flexibility in its Standard Operating Procedures (this in conjunction with b. above)
- d. expect to have revised application to NRC by end of the year.
- b. Coordination with Cleveland Fire Department indicates that an exercise could be performed within 3 month of the license approval l
- a. AMS wishes to submit a " conceptual plan", then submit an instrument to support financial assurance planb. part of the " conceptual p i
waste and decontamination material on site
- This runs into the face of Timeliness Rule and agency waste disposal policy INTERMEDIATE RANGE ACTION l
- 1. Need to recover hot cell function and use; need to have hot cell capabilit to prepare shipping package of large sources for shipping
- 2. Finding a place to ship sourcese 35 s urces, total of 20,000 C1, using NPI casks l
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- c. To get below DFP requirement level in 1 year I
- 3. Emergency pi r.
LOW PRIORITY
- 1. Plug removala. AMS feels low priority because in a safe situation; wish to clea l
hot cell for source shipment
- b. Presently in non-compliance with their license requirement for source
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I-i inventory
- 2. Solid waste removal i
- a. wish to use decay as an asset for overall ALARA
- b. possibly take advantage of new technology j
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- 3. Getting rid of water i
- a. not a radiological hazard i
- b. see Cuyahoga Emergency Management Assistance Center (CERMAC) letter dated August 23, 1995 ONGOING ACTION l
- 1. Carol Berger is reviewing the Emergency Plan and the renewal application for possible revision
- 2. Housekeeping improvements - AMS wishing to reclaim some of the London Road l
facility and make it useable space
- 3. Public Relations i
- a. wish to improve community relations, get out positive public i
relations
- b. possibly have tours of facility
.4. Litigation l
- a. NE0RSD desires $2M
- b. no decontamination of interceptor until litigation settled NRC ACTIONS 6
-RIII
- 2. revision to license renewal application review
- a. AMS and NRC could benefit - RIII
- b. have a bearing on license renewal application hearing - 0GC
- 3. Conceptual plan for decommissioning
- a. storage vice off-site disposition - IMS/DWM
- b. impact on DFP - IMS/DM 4.-Plug removal / inventory requirement
- a. presently in violation - RIII
- b. modify license condition - RIII 5.
CERMAC letter of August 23,1995 determine if this is a 2.206 Petition -
0GC 3:teleconf.ans
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Lummary of the telephone conference held at 10:00 am. August 31. 1995 amona Rill. OGC. and INMS concernina the AMS site visit and exit meetina on Auaust
- 30. 199L
- 1. The underdrains have been completely replaced around the building; water from the drains will be collected, tested, and released to the parking lot if nc detectable Co-60.
There is approximately 100,000 gallons of processed water in storage, at about 118 pCi per liter (total of 45 microcuries); AMS is working on getting the City of Geneva to take this water into their sewerage system; AMS is not pursuing evaporation of the water at this time.
- 3. License Renewal Application: AMS expects to submit a revised renewal application to NRC by end of the year.
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- b. Coordination with Cleveland Fire Department indicates that an exercise could be performed within 3 month of the license approval
- a. AMS wishes to submit a " conceptual plan", then submit an instrument to support financial assurance plan
- b. part of the " conceptual plan" is to propose safe storage status of waste and decontamination material on site
- This runs into the face of Timeliness Rule and agency waste disposal policy INTERMEDIATE RANGE ACTION
- 1. Need to recover hot cell function and use; need to have hot cell capability to prepare shipping package of large sources for shipping
- 2. Finding a place to ship sources
- b. J.L. Sheperd a maybe
- c. To get below DFP requirement level in 1 year NRC ACTIONS
- 2. revision to license renewal application review-RIII
- a. implications for license renewal application hearing - 0GC
- 3. Conceptual plan for decommissioning
- a. storage vice off-site disposition - IMNS/DWM
- b. impact on DFP - IMNS/DWM
- 4. Plug removal / inventory requirement l
- a. presently in violation - RIII
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- b. modify license condition - RIII j
5.
Determine if letter of August 23, 1995 from Cuyahoga Emergency Management Assistance Center (CEMAC) is a 2.206 Petition - OGC 1
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