ML20134E439
| ML20134E439 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/1995 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Axelson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20134C763 | List: |
| References | |
| FOIA-96-444 NUDOCS 9702060238 | |
| Download: ML20134E439 (6) | |
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March 2,1995 I
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'HEMORANDUM T0: W. L. Axelson, Director i Division of Radiation Safety and Safeguards i
L FROM: John A. Grobe, Chief Nuclear Materials Inspection Section 2 i
SUBJECT:
MEETINGS WITH CLEVELAND, OHIO ENVIRONMENTAL PROTECTION 1
AGENCY AND NORTHEAST OHIO REGIONAL SEWER DISTRICT OFFICIALS j- REGARDING ADVANCED MEDICAL SYSTEMS, INC.
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On February 21, 1995, I met with Bob Staib, Director, Cleveland Department of Health, Environment Division, to discuss the status of Advanced Medical
} Systems, Inc. (AMS) activities and NRC oversight of the licensee. Director
! Staib appeared satisfied with the NRC actions regarding this licensee. The substance of my discussions will be documented in a letter to the Director in 4 response to his letter dated February 16, 1995.
l On February 22, 1995, I visited the site to discuss status of activities with the Radiation Safety Officer and tour the facility. There have been no '
substantive changes in the facility status. I witnessed the procedures used j by the licensee for measuring water levels and identified no concerns.
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! On February 22, 1995, I attended a meeting at the Ohio Environmental i Protection Agency (0 EPA) offices in Twinsburg, Ohio, with OEPA, Northeast Ohio
! Regional Sewer District (NE0RSD) and AMS. The list of attendees is attached.
l The meeting was chaired by OEPA and was intended to identify if there was any
- common ground between NE0RSD and AMS to build consensus for a solution to AMS' discharge problems that would include acceptance of waste waters by the
! NE0RSD. The NE0RSD stated that they would not accept any risk on resulting
! from discharge of cobalt-60 to the sewers.
! AMS committed to:
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Process all waste waters through sub-micron filtration and 4 demineralization until there was no insoluble cobalt-60 and less e than 25 pCi/1 soluble cobalt-60; Discharge less than 10,000 gallons per day; i -
Provide monitoring to the satisfaction of NE0RSD of waste water
, outflow from AMS, waste water inflow to Easterly, sludge outflow j from Easterly, and ash outflow from the Southerly incinerator; and j -
Take possession of any material identified as containing cobalt-60.
9702060238 970127 4 PDR FOIA ENGLISH96-444 PDR /
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W. L. Axelson On behalf of the NRC, I indicated that Robert Bernero would consider issuing a letter indicating that should AMS discharge within those limits, the NRC would not exercise regulatory authority over any cobalt-60 in the resultant ash.
NE0RSD did not believe that there was a functional way to intercept ash that was determined to be contaminated and expressed that they would only accept such a plan if AMS were to indemnify NE0RSD from any costs associated with dealing with any ash contaminated with cobalt-60. AMS was unwilling to make such a commitment, since other licensee's are authorized to discharge cobalt-60 and AMS was not willing to incur expenses due to their discharges.
AMS expressed willingness to pay their share should any cobalt-60 be discovered; however, NE0RSD could not identify a method to segment financial liability due to the NE0RSD's inability to identify other contributors to the waste stream.
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The meeting ended with NE0RSD remaining unwilling to accept waste waters from AMS.
If you have any questions please contact me.
Docket No. 030-16055 License No. 34-19089-01
Attachment:
Attendees List cc w/att: Cynthia Pederson, RIII Gary Shear, RIII Cathy Haney, NMSS l Mike Stein, OGC Steve Crockett, OGC Marian Zobler, 0GC DOCUMENT NAME: A:\AMS-TRIP. JAG Ta voosiw c copy of this document, indicate in the boc 'C' = Copy without attachment / enclosure "E' = Copy with attachment / enclosure "N" = No
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, OFFICIAL RECORD COPY
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March 2,19%
Advanced Medical Systems, Inc. '!
ATTN: David Cesar I Treasurer
!. 121 North Eagle Street 2
Geneva, OH 44041
Dear Mr. Cesar:
This refers to the special safety inspection conducted by Dr. John House and Messrs. Wayne Slawinski and Keith Andre of this office on December 12-13, 1994
, and January 18, 1995, to review certain aspects of your NRC, licensed
! activities authorized by NRC Byproduct Material, License No. 34-19089-01. This
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! also refers to the January 18, 1995 meeting with you and your representatives
- and myself and Mr. James Caldwell of the NRC Region III office, regarding' f current water problems at your facility.
i The inspection was prompted by your London Road facility's water control :
problems and was conducted to: (1) observe ongoing facility water intrusion 1
- problems and ground / surface water control activities; (2) perform i radiochemical analyses and limited filtration studies of wastewater samples; I and (3) observe licensee contractor efforts in conducting a radiological i- assessment of the Waste Holdup Tank (WHUT) room in the basement of your
- facility. ,
!- The enclosed copy of,our inspection ~ report identifies areas examined during the inspection. Within these areas, the inspection consisted of observations, t
water sampling and analyses, and interviews with personnel.
No violations were identified during the course of this inspection. However, concerns with ground and surface water control and its potential eff:et on the integrity of your building's foundation were noted. The lack of timely and effective long-term solutions to the water problems was also identified as a Concern. -
+ We have continued to monitor your facility water problems since these problems arose in December 1994, including daily communications with you or your staff upon escalation of these problems on January 16, 1995. To confirm your specific comitments to address these ongoing concerns, we issued a Confirmatory Action Letter (CAL No. RIII-94-008) on December 15, 1994. Due to changes in the status'of your facility and its escalating water problems, the CAL-was revised on February 1, 1995.
As you know, we are currently' evaluating your January 27, 1995 Act. ion Plan for dealing with these water problems and the remediation of the contaminated sewer discharge system. This evaluation includes your consultant's proposal for wastewater processing, forwarded by letter dated February 2,1995. You ww s -
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Advanced Medical Systems, Inc. ( !
will be informed by separate correspondence regarding the results of our review. Consequently, no response to these matters is required at this time.
We will continue to monitor your facility's water problems and evaluate the effectiveness of your remedial actions via periodic inspections at your London Road facility.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed report will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, Original S!;r.ed by John A. Grobe John A. Grobe, Chief '
Nuclear Materials Inspection Section 2 License No. 34-19089-01 Docket No. 030-16055
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Enclosure:
Inspection Report No. 030-16055/95001(DRSS)
See Attached Distribution DOCUMENT NAME: G:\INSPRPTS\MTLS\030\03016055.951 Ta toosive a copy of this document. Indicate in the boc 'C" = Copy without attachment /erv.losure *E" = Copy with attachment / enclosure 'N" = No copy 0FFICE DRSS/RIII g DRSS/RIllA f- DRSS/RIIA 4 6 l NAME WJSlawinski:bt:dp1 JHouseLFJ JAGrobelhN 0"E 02/p(/95 W2 [02/>/9$ 03/ 1-/95/
( OFFICIAL RECORD COPY
Advanced Medical Systems, Inc. (
Distribution Robert Meschter Radiation Safety Officer Advanced Medical Systems, Inc.
121 N. Eagle Street Geneva, OH 44041 Michael R. White, Mayor City of Cleveland 601 Lakeside Avenue Cleveland, OH 44114 Lisa Mehringer City of Cleveland Law Department 601 Lakeside Avenue Room 106 Cleveland, OH 44114 Robert E. Owen, Administrator Radiological Health Program Department of Health 246 North High Street, 3rd Floor P.O. Box 118 Columbus, OH 43266
( Erv Ball, Deputy Director '
Cuyahoga County Board of Health 1375 Euclid Ave. Suite 524 Cleveland, OH 44115 Erwin J. Odeal, Executive Director Northeast Ohio Regional Sewer District 3826 Euclid Avenue Cleveland, OH 44115 ,
hf&i -
Mike Stein,.0GC Cathy Haney, HMSS PUBLIC IE07 Steve Crockett, OGC John A. Grobe, RIII Marian Zolber, OGC Gary L. Shear, RIII E-mail:
Bill Axelson (WLA) Joe DeCicco (JXDI) Donald Cook (DAC)
Bruce Berson (BAB1) Jack Goldberg (JRG) Josie Piccone (JMP1)
Bernie Bordenick (BMB) Jack Grobe (JAG) Gary Shear (GLS)
Bill Brach (EWB) Cathy Haney (CXH) Wayne Slawinski (WJS2)
Jim Caldwell (JLCl) Tim Johnson (TCJ) Micheal Stein (MHS)
Fred Combs (FCC) Steve Lewis (SHL) Mike Weber (MFW1)
John Cordes (JFC) John Madera (JRM4) Marian Zobler (MLZ)
Steve Crockett (SFC) Kevin Null (KGN) i
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UNITED STATES NUCLEAR REGULATORY COMMISSION l[ REGION III l
Report No. 030-16055/95001(DRSS)
License No. 34-19089-01 Priority I Category B l
Docket No. 030-16055 i Licensee: Advanced Medical Systems, Inc. (AMS) 1020 London Road Cleveland, Ohio 44110
! Site Inspection Conducted: December 12-13, 1994 and January 18, 1995 Inspectors: 9w M- 1-to -9 d~
Wayne / Slawinski, Senior Date I Radiation Specialist, Nuclear Materials Inspection Section 1 !
& .2l/o/9f hn House', Ph.D. , Senior Date ' l l adiation Specialist, Radiological !
Programs Branch l
diOAd MKfith Andre, Physical Science 3/v/4/
Dat'e '
[/ fechnician, Fuel Cycle and i Decommissioning Branch Approved By: J /1-/9(
n A. Grobe, Chief Date '
uclear Materials Inspection Section 2 Inspection Summary l Inspection on December 12-13. 1994 and January 18. 1995 (Report No. 030-16055/95001(DRSS))
Areas Inspected: Special, announced inspection to: (1) observe recent London Road facility water flooding problems and licensee ground and rain water runoff control activities; (2) conduct radiological analyses and limited filtration studies of rain and flood water samples; and (3) observe licensee contractor efforts in conducting a radiological assessment of the facility's Waste Holdup Tank (WHUT) room.
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i Results: No violation of regulatory requirements was identified. Cobalt-60
[:- was found, as expected, in water samples collected from the flooded basement
! and in water sampled from the plugged sewer manhole located just outside the i facility on licensee property. The lack of an effective long term solution to the ground water hydrostatic pressure problem and collection, processing and i' disposal of contaminated basement, manhole and potentially contaminated ground waters was identified as a concern.
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DETAILS ;
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l 1. Persons Contacted l licensee Representatives l
L l David Cesar, Treasurer I
! Steven Haddock, Isotope Technician !
l Robert Meschter, Radiation Safety Officer !
Christopher Reed, Technician Vincent Rocco, Technician l Licensee Contractor Representatives j
Henry Billingsley, Attorney, Arter & Hadden i John Denega, Civil Engineer, Neff & Associates Maurits Hartog, Senior Technician, Scientific Ecology Group, Inc.
Kevin Wright, Field Engineer, Scientific Ecology Group, Inc.
- 2. Purpose and Scope of Inspection l l
This was a limited scope special safety inspection conducted primarily to observe London Road. facility water problems, independently sample and '
analyze the water, and evaluate ground / flood water control activities i recently undertaken by the licensee. The NRC Region III mobile laboratory was present at the London Road site on December 12-13, 1994,
( and used to analyze water samples and to conduct water i filtration / solubility studies. The inspectors also observed licensee l l
i contractor efforts in conducting a radiological assessment of the WHUT l room located in the basement of the facility. .
- 3. Water Samplina. Analyses and Filtrati_o_n Studies (a) Backaround Information During the period August 17 through October 14, 1994, the NRC conducted a special inspection to examine the radiological l conditions of wastewater exiting the AMS London Road facility
, through its sanitary piping and into the City of Cleveland t
sewers in the vicinity of the sewer outfall from the facility.
Inspection findings are documented in Inspection Report No. 030-16055/94003(DRSS), transmitted to the licensee on December 6, 1994. During that inspection, the NRC identified one apparent violation concerning the discharge of insoluble cobalt-60 into the sanitary sewer system.
l Since that inspection, the Northeast Ohio Regional Sewer District isolated the London Road Facility from the sewage treatment
- system. The isolation impacted on the ability of the facility's i
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foundation drainage system to function as designed. Subsequent to
>( the isolation, rains saturated the soils about the facility and coupled with surface water contributors, caused a buildup of water
' and consequently hydrostatic pressure on the building foundation structure. In addition, the combination of rains and isolation of the facility from the sewage system led to ground and storm water intrusion into the facility basement, creating a-contaminated wastewater problem within the facility.
On December 15, 1994, a Confirmatory Action Letter (CAL No. RIII-94-008) was issued to AMS, confirming the licensee's commitment to implement appropriate steps.to reduce the hydrostatic pressure on the building foundation to ensure its structural integrity remains intact, and that appropriate plans were developed to address the radioactively contaminated water that was being removed from the facility sewer manhole and that -
located in the basement of the facility. The CAL also discussed the development of plans to remediate the radioactively contaminated manhole and sewer line exiting the facility to the London Road interceptor. The licensee responded to the CAL and outlined its plans for remedial action in a letter dated December 28, 1994.
The groundwater buildup and flooding problems worsened on January 16, 1995, after heavy rainfall in the Cleveland area. t The rainfall caused additional water intrusion into the facility ~
basement and necessitated a revision to the December 15, 1994 CAL.. I The revised CAL (No. RIII-94-008 (Revision I)) was issued I February 1, 1995. Since the flooding problems escalated, the NRC has been in daily communication with the licensee and is closely monitoring the water problems. As a result of these escalating concerns, the licensee developed an action plan to address:
(1) long term solutions to the foundation drainage system problem; (2) control of sub-surface contamination; (3) collection, processing and disposal of contaminated wastewaters; and (4) remediation of the contaminated sanitary and storm water piping, manhole and sewer lateral. The licensee's plans and proposals for remedial action are currently being reviewed by the NRC.
(b) Water Analyses
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The inspectors collected several wastewater samples on December 12-13, 1994, and conducted radiochemical analyses on-site at the licensee's facility using the Gamma Spectroscopy system aboard the Region III mobile laboratory. Additional samples were collected on January 18, 1995 and analyzed in the Region III laboratory in Lisle, Illinois. Water samples were collected by the inspectors from the following areas in and around the licensee's London Road facility:
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. One sample taken from each of the three tanks used to i
.( collect rainwater runoff from.the facility roof. One sample was collected from each tank prior to its discharge to the facility grounds.
. One sample taken from the loading dock as it was being discharged to the facility grounds.
.- Four samples collected from the basement of the facility.
--. One sample taken from each of the three bulk tanks used to store water pumped from the sewer manway (sewer collection i
tanks).
. Three samples collected from the sewer manway.
l -. One sample taken from a newly constructed sump pit located on the south end of the facility. ,!
As shown in Tables I and II (Attached), cobalt-60 concentrations ranging !
from 250-600 pCi/l were identified in two of the three sewer collection i tanks and in two of the three sewer manway samples. No cobalt-60 above minimum detectable activities were identified in one of the collection tanks and one of the manway samples. - Although the absence of cobalt in one of the sewer manway and one of the sewer collection tanks appears )
anomalous, it is not unexpected and attributed to the sporadic and !
unpredictable manner in which cobalt-60 apparently sloughs-off the sewer
( manway.and lateral piping surfaces. Similar unpredictable results have i
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' been previously identified, as documented in Inspection Report No.' 030-16055/94003(DRSS). Since the contents of the sewer collection tanks were not mixed prior to inspector sampling to ensure sample representativeness, additional samples from sewer collection tank # 1 i are necessary to conclude that the water is not contaminated with i cobalt-60. !
l Cobalt-60 was found in varying concentrations in all four basement i
flood water samples. Samples collected from the back basement showed significantly more activity than those from the front area, as expected, due to varying basement floor and wall surface contamination. Although the flood waters in the front and back basement areas communicate, they are relatively stagnant and no significant mixing of the waters has 4 occurred.
Remaining samples exhibited no detectable activity above counting system minimum detectable activities. Radiochemical sample analysis results are reported in Tables I and II.
Filtration studies were cor. ducted on the two samples (A and B) collected on December 12-13, 1994 from the sewer manway, in an attempt to estimate j the particle size and the solubility characteristics of the cobalt i
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,, contaminant. An unfiltered'500 milliliter aliquot of each of the two' samples was. analyzed for cobalt-60 content and compared to 500
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!. milliliter aliquots passed through a 0.45 micron filter. The analyses disclosed the filtrate activities to be consistent with the activity of the unfiltered material, indicating that the cobalt-60 had passed through the filter. No activity was detected on either filter. Upon i returning to the region III office, a second filtration experiment was conducted on the same samples using 0.22 micron filters. Specifically, filtrates which had passed through the 0.45 micron filter-were further filtered through 0.22 micron filters. As reported in Table III (Attached), the results were the same in that all cobalt also passed-through the 0.22 micron filter. As the filtration study was limited to only two samples which may not have been representative of the sewer manway's contents, no definitive conclusion can be drawn regarding the solubility of the cobalt-60 in the sewer. Additional samples taken over a period of time would be required to resolve the solubility question of the cobalt-60 contaminant in the sewer manway.
- 4. Waste Holduo Tank (WHUT) Room Radioloaical Assessment Between mid-November through mid-December 1994, a lic:msee contrar -
performed an on-site .'adiological assessment of the facility's MJ room. The assessment was conducted to evtluate the current rauogical conditions in the room, calculate its cobalt-60 source term and to determine the radiological impact of facility operations on the building's foundation and lub-surfaces. The results of the assessment, are required for the development of an adequate Decommissioning Funding.
. Plan (DFP). . Pursuant to 10.CFR 30.35 (c)(2), the licensee was required to submit a DFP and financial assurance mechanism with its license renewal application by December 1, 1594. The licensee's (DFP) submittal was delayed pending completion of the WHUT room assessment. '
The inspectors evaluated the radiological controls employed during the contractor's WHUT room analysis. Work and the project oversight provided by the licensee. No problems were noted. Pre-job surveys and briefings I
were conducted and job specific RWPs developed. Stripable paint was applied to floor surfaces to fix contamination and reduce airborne radioactivity. Worker breathing zone air samples and direct radiation surveys were conducted throughout the assessment work. A video camera was introduced through WHUT room wall penetrations to aid in remote visualization of the room's interior. Direct radiation measurements
. , were made across the room's interior with retractable pole mounted survey equipmer.t, inserted through wall penetrations. Sediment and water samples were also collected from within the room.
The licensee's contractor is currently evaluating the data collected during its assessment and compiling a report. The assessment findings -
and the licensee's DFP will be submitted to the NRC upon its completion.
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- 5. Exit Meetina
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The inspectors met with the licensee's Radiation Safety Officer on December 13, 1994 and summarized the purpose and scope of the l inspection. On January 18, 1995, Messrs. John Grobe and Jim Caldwell of the Region III staff met with David Cesar and other licensee )
representatives te discuss water management and control concerns and the licensee's plans to address them. The water sample and filtrat' ion study results were not discussed during either meeting because the results were not yet available.
l Attachments: (1) Tables I & II " Water Sample Analysis Results" (2) Table III " Filtration Experiment Results" r
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( WATER SAMPLE ANALYSIS RESULTS TABLE I SAMPLES COLLECTED DECEMBER 12-13, 1994 Sample Co" Concentration -i 2a l Location (pCi/1)
Loading Dock < 39 Rain Collection < 25 ;
Tank # 1 ,
Rain Collection < 23 Tank # 2 Rain Collection < 24
. Tank # 3 t Back 9.6 E + 5 i Basement Front 6.3 E + 3 %
Basement l
Sewer Manhole < 50
, Collection Tank # 1 Sewer Manhole 3.8 E + 2 i Sample # A Sewer Manhole 2.5 E + 2 Sample # B Note: The reported 2a uncertainty refers only to counting statistics. ,
The analytical results displaying the less than symbol, "<", indicate that no measurable activity was identified above the minimum detectable level derived ,
for that sample. '
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I WATER SAMPLE ANALYSIS RESULTS TABLE II SAMPLES COLLECTED JANUARY 18, 1995 1
Sample Co" Concentration 2a !
Location (pCi/1) :
-Back 1.7 E + 5 Basement Front 5.9 E + 3 Basement I l
. Sewer Manhole 3.0 E-+ 2 i Collection Tank # 2 I Sewer Manhole 6.0 E-+ 2 Collection Tank # 3 i Sewer Manhole < 18 Sample # C l Newly Constructed < 18 ,
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Sump Pit l . .
Note: The reported 2a uncertainty refers only to counting statistics. 1 The analytical results displaying the less than symbol, "<", indicate that no measurable activity was identified above the minimum detectable level derived ;
for that sample. .
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l FILTRATION EXPERIMENT RESULTS l
l TABLE III I
Manhole Sample # A Filter Type Co" Activity - Fi'lter (pci) i 2a Co" Concentration - Filtrate (pci/1) i 2a 0.45 Micron < 28 3.5 E + 2 l _ 0.22 Micron <6 3.2 E + 2 Manhole Sample # 8 Filter Type Co" Activity - Filter Co" Concentration - Filtrate (pCi) i 2a (pCi/l) i 2a j
0.45 Micron < 14 2.2 E + 2 0.22 Micron <5 2.2 E + 2 Note: The reported 2a uncertainty refers only to counting statistics.
The analytical results displaying the less than symbol, "<", indicate that no measurable activity was identified above the minimum detectable level derived for that sample.
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J ,u e 9/ Cw9 March 2, 1995 (A4/ / - -
NOTE FOR: C. Johnson, Section Leader
&,yG. - (bd)
T.
[ Materials Decommissioning Section Low-Level Waste and Decommissioning Projects Branch /DWM/NMSS FROM: M. (Sam) Nalluswami, Project Manager [0riginalsigned Materials Decommissioning Section by:]
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Low-Level Waste and Decommissioning Projects Branch /DWM/NMSS
SUBJECT:
NORTHEAST OHIO REGIONAL SEWER DISTRICT -
SUMMARY
OF MEETING ON FEBRUARY 27, 1995, ON EASTERLY PLANT ISSUES A summary of the discussions during the meeting on February 27, 1995, between the Northeast Ohio Regional Sewer District representatives and the NRC staff, is enclosed. If you have any questions on the summary, please let me know.
Docket No. 030-18276
Enclosure:
As stated TICKET:
7 DWM r/f ""x;;: JGreeves M9eM JAustin A 'TBUTION:
4er Central File JHsDoweek RJohnson NMSS r/f DWM t/f CPoland PUotic GShear JDeCicco RFonner CPaperiello Distribution List 1h?C6hedrr'5 hee 1816cQts1Ds MaEkl$nal'li6Boke6'^"6F6"'lisi~^inGri~C'= E C6Ve]r!nsiDiltlitistriAniC6pflPhiferesc's?' 1
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IG : YES NO / Delete file after distribution: Yes No /
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l NORTHEAST OHIO REGIONAL SEWER DISTRICT (NORSD)
SUMMARY
OF MEETING ON FEBRUARY 27. 1995. ON EASTERLY PLANT ISSUES A meeting was held on February 27, 1995, at 1 PM at NRC headquarters in Rockville, Maryland, between the representatives of the Northeast Ohio !
Regional Sewer District (NORSD) and the NRC staff. NRC Region III staff l participated via telephone as well as representatives from the Ohio Department '
of Health and the Cuyahoga County Board of Health. A list of attendees is attached.
After the introduction of the attendees, J. Greeves summarized the purpose of ,
the meeting to discuss controls on potentially contaminated subsurface soils l and backfill materials at the Easterly Plant site in Cleveland, Ohio. The i
discussions focussed on the efficacy of applying radiological controls, to ;
protect workers and the public, from Cobalt-60 contamination that is likely to l be present in subsurface soils and backfill materials at the Easterly Plant. l Previous sampling at the site indicated surface and subsurface contamination !
of the soils and backfill materials with Cobalt-60 up to 1600 pCi/gm. Surface I contamination has since been remediated. (NORSD's Southerly Plant is currently listed on NRC's SDMP for Cobalt-60 contamination.) NRC staff proposed an exchange of letters to seek NORSD's commitments to implement '
l appropriate control measures (restricting public access and worker protection) l in lieu of additional characterization of the subsurface, remediation and l possibly issuing a license for possession of the radioactive material.
( E. Odeal (Executive Director, NORSD) said that he is puzzled by the NRC's l position asking for further NORSD actions, even though NORSD performed the '
initial investigation that discovered the Cobalt-60 contamination. He said he is concerned and appalled that even after three NRC inspections, inspectors did not find contamination, and now NORSD is being asked to perform further actions.
During the course of the meeting, NORSD expressed several concerns about NRC's apparent inattention to NORSD's previous requests for regulatory actions. E.
Odeal indicated that there is a double standard being applied even though the NORSD spent over $2 million to fix the problem. According to him, NRC is closely regulating NORSD (non-licensee) and is taking a mom lax and "nevermind" approach towards licensees (i.e., Advanced Medical Systems). He said that he has a problem being regulated by the NRC, which has done such a poor job regulating its other licensees.
NORSD's representatives were particularly concerned about delays regarding two
$2.206 petitions, which have been under review by the NRC for the last two years. E. Odeal asked what is the status of their 52.206 petitions. He was disturbed that no decision has been reached in two years. R. Fonner indicated that it is being reviewed at levels above the NRC staff. E. Odeal asked why the 52.206 petition requesting remediation of the AMS lateral was being treated with the petition requesting the AMS be responsible for the remediation of the Southerly Plant. He indicated that he considered these petitions to be separable, and thought that NRC would be able to act quickly on the remediation of the AMS lateral. NORSD representatives urged separation
( of the contaminated sewer lateral issue from consideration of the larger issue associated with licensee liability for offsite contamination. The NORSD has l
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, , also been pursuing litigation to seek reimbursement from the alleged source of the Cobalt-60 contamination.
T. Lenhart asked if NRC staff has any additional information relating to the allegation of illegal disposal of materials from AMS. G. Shear indicated there was no additional information. G. Shear also indicated that Region III had reopened the allegation following the discovery of contamination at the Easterly Plant, but subsequently closed it out on November 18,.1994, when no additional information to support the allegation was discovered.
NORSD representatives asked whether NRC had looked at licensees operating prior to 1976 to see if the licensees might have released material into the sewer system. T. C. Johnson indicated that he would respond to this question.
The NORSD indicated that they would consider the NRC request to further document the implementation of the radiological controls that are now being applied to possible contamination et the Easterly Plant. T. C. Johnson indicated that in the NRC rest,onse, a statement would be made that no license for the Easterly Plant contamination would be required. John Greeves repeatedly emphasized and suggested that NORSD's consultant and the.NRC staff
' should work together to finalize the letter including the needed time to decay at the Easterly Plant. Although the NORSD agreed with the NRC's proposal for applying the controls at the Easterly Plant appeared reasonable and consistent with planned actions, they may delay submitting the requested commitments
- pending NRC action on the other matters.
( ACTION ITEMS ACTION RESPONSIBILITY DME
- 1. Contact OGC on s2.206 petition NMSS/ Petition 3-15-95 regarding release of Cobalt-60 Manager-JDeCicco j
- 2. Contact OGC on 52.206 petition NMSS/ Petition 3-10-95 regarding sewer lateral Manager-JDeCicco
- 3. Were there licensees operating T. C. Johnson /DWM 4-15-95 prior to 1976 who may have released Cobalt-60 into the sewers?
- 4. Send a copy of the 10-11-94 (0DOH already received a copy)
NRC inspection report to 000H.
i l At achment: List of Attendees 2
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J d6 PO. Box 50785 Knouvme, rN 37950 478s Integrated Endronrnental Manag<enent, Inc. gaagj8f5{5]1" g 1880 East Gode odve, Sulle aos Rockvile. MD 20850 Plevuv. (301) 7624 02 March 3,1995 m (a n n24sas Mr. John A. Grobe Nuclear Materials Inspection Section 2 United States Nuclear Regulatory Conunission 801 Warrenville Road Lisle, Illinois 60523 4351 1
Re: Supplement 2 to Application to Amend License No. 34-19089-01
Dear Mr. Grobe:
Mr. David Cesar recently sent you an application to amend the referenced license to permit water treatment and sewer remediation activities to proceed at the Advanced Medical Systems, Inc.
(AMS) factlity on London Road. This letter is Supplement 2 to that application. The following is a description of the procedures that will be implemented during the water treatment procese f Attachment 1- Diversified Technologics Services, Inc. (DTS) of Knoxville, Tennessee, has been contracted to provide water treatment services. A listing of similar pmjects and experience by DTS was submitted to you previously for your review.' DTS will implement a system of multi-stage tiltration and pressure vessels for application of ion exchange / activated carbon process media. If required, the same type of cobalt-scicctive ion eu.! ranger applied at nuclear power plants for cleanup of cobalt-bearing liquid waste will be utilized. The water processing protocols that will be followed by DTS were submitted to you previously.: Attachment I contains additional procedural steps to address spill control and staging of the equipment.
Attachment 2* Processed water will be stored, initially, in above-ground storage tanks. Samples will be collected from the tanks by the procedures submitted to you previously.3 (Sufficient sample to pemtit " splits" in volume with the USNRC will be collected.) The samples will be sent for confirmatory analysis to Quanteira, Inc., a conunercial analytical laboratory in St. Louis, Missouri. There the "Co Letter frum C. D. Berger to J. A, Grobe, Februsry 2.1995, Auachment 1.
3 Letter from C. D. Berger to J. A. Grobe. February 2. l'MS, Attachment 2 Letter from C. D. Berger to J. A. Grobe, t"cbruary 2.1995. Atuchn.cn; 3.
w swoe 6MM* MB
. -. . - ~ . - . - - -- - . - - - . - - - . - .. . -
concentra;.on will be determined by the methodology of gattutint spct.troscopy by the procedurcs submlued previously.' A minimum detection limit of 20 to 30 pCl per liter has been specified. The solubility of **Co in sampics containing
" detectable" activity, up to a nuutimum of 200 pCi per liter, will be demonstrated by the methodology of the American Public Health Association's Method 7110 "Grosa Alpha and Cross Octa Radioactivity (Total, Suspended, and Dissolved)" '
from Anandard Mattwk for the Rraminnelan of water and Wastewater. Once the analytical results have been received and validated, treated water in the above-ground storage tanks that meets the release criteria described in your letter to
{
David Cesar dated February 1,1995 will be pumped to collapsible storage j containers located in the AMS wanhousc. Attactmwn! 2 contidius a diawltig of time !
storage containers.
Attnehment t Water held in the collapsible storage tanks will be evaporated at a nominal rate of 300-700 gallons per 24-hour day using an industrial grado evaporator. Attachment 3 contains a description of one of the units currently under consideration. The evaporator will be installed in the AMS warehouse. . Solids removed from the evapontor pursuant to manufacturer's instructions will be screened 5 A standard operating procedure for monitoring and surveillance of tho ;
cvaporator will be prepared, nyiewed by the AMS Isotope Cotamittee, and 1 implemented shortly after lastallation is complete. Any permitting requittd by the City of Cleveland or pursuant to 40 CFR 61 will be secured once the system is
( purchased and riesign/ performance criterla are received.
l Pieaac contact me ut (301) 762-0502 If you have any questions or if I can provide you with additional technical information. ;Thank you in advance for your assistance and your prompt review of the AMS application. I am looking forward to timely mi sue.cessful completion of this project.
Sincerely,
-[
Carol D. Berger, C.ll.P.
C I.f cc: D. Cesar. AMS D. Miller, Esq., Scavole & Miller A. Duff, NRRPT, AWK Consulting Engineers File 94009 I.cuer from C. D. Berger to J. A. Omhe, Ikhmary 7.1995. Attxhnwn:t 4 and 5.
s it the M615 contain "r'n in cswontrations that exceed A pCi/ gram. they wl;t be retained at AMS. If the concentratinnt are lett than 8 pCi/g, the milijs will be disposed of purauant to the manufacturer's instructions.
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( ATTACHMENT 1 - WATER PROCESSING PROTOCOLS 4
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+ - t'AR-02-1995 ;3:17 FR&l DIV TECH 615 533 9M1 TO 1%t 319733 P.a3 i
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} D.T.S. SITE SPECFIC OPERATING PROCEDURE $
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I. PROCEDURE
S REV18tt)N 2
! 2/2a/es 1.0 PURPOSE '
{ This procedure provides guidance for prevention as wd as cleanup of spills and contaminadon in the Df8 liquid waste processing area.
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s.O REFERENCES i j 2.1 MFIX 01, Genwel Operating Procedure. i l
l 2.2 Radianon Work Permit. i i 3.0 CHECKLl8TS -
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- 3.1 DTS Vake Check +ff Ust.
l 4,0 PMEREQUISITES 4
41 DTS process system will be installed in a oiked/ curbed area.(MA4h* M^)
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4.1.1
! The dike must be able to conteln 1.6 times the volume of the tank or a diversion 4
route must exist for oxeees water to divert back lo tw contsminated waste holding area without operator Intervention, e.g. gravity drain from the dike back j to the basement, i
! 4.1.2 The dlke must t>e constructed of water resistant material cornpatble with the i Work envkonment.
1 j 4.2 All discharge process hoses, which may be subiect to pressurization, witi be fabricated of hign pressure (WP 325 psi) wire reinforced hosing and hydro tested to 226 poiin j ,accordance with B31.1 piping standards.
4.3 Prior to system start up, vwify that all cam-lok connections are properly connected and j that the ears are secured via an electrical tie wrap or other suitable securing device.
i 4.4 Prior to start up, a ayatem leak test shall be conducted at 100 pel for 15 minutes.
1 Acceptance criteria la 100% inspection of the hose, i:ttlngs and plumbirm wt'.h zero 4
Water leekage.
4.6 Entry into any areas for assessing or cleaning a spill shed not be done until a
- prailminary radiological survey has been perfonned.
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DT 10 96 I of 3 Rev: E l __8 pill Procedure 3/02/96_
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i 4.6 Clean.up activities must occur on the appropalate F1WP written for clearWp and decontamination.
t 4.7 NOTIFY Radletion Proi.ction prior to sampling manl /or Dreaching tie system.
4.8 ,
- Systun oporating preneure la Enisted to 100 pol (less'06% of design pressure and lesa l than 46% hydro test pressure). The total discharge head of any system pump, Including the cumulative houd for pumpe in series, may not exceed 100 pal. !
l 5,0 PRECAUTION 8 5.1 Prior to olsconnecting any hose (s), blow down hose (s) and piping with air and VEPFY !
zero pressure on system.
5.2 Prior to disconnecting any note (e), position a catch container under the connections to capture anyinadvertent leakage.
5.3 Afterends.
pipe disconnecting hose (s), drain excess water from hose (s), plug hose ends an 6.4 Spilled material must be treated as radioactive untilldentified as otherwies. '
5,5 Do not climb nnto/irito any equipmert or tanke without nodrying Radia#on Psotectiott .
A a Prior to the start of actMtlee occh day review the confirmuluty sunroy tnet Raola00n Protection has pefformed.
5.7 ff process hose (s) are in a walkway, *xientify hose with caution tape, post trip hazard
{ and construct bridge to prevent damage to hose (s) It in an area traneversed by heavy equipment.
5.8 A visualinspection of the DT8 process system should be conducted every hour when in service. This requirement is not necessary if in sku processing is occurring inside the tank itself with no water transferred outside the tank.
5,9 If pressurized discharge hoses are routed outside the facility, they must have doublo contaloment, e.g. eleeving, to aio in Itak detection and control.
e.01.lMITATIONS AND ACTIONS 6.1 NOTIFY 1.E.M. Supesvisor, Diversified Technologies Superv!sor, and Radiation Protection Technician IMMEDIATELY In the ovont of a leak or spill which muy, or has, resuhed in a potential release to the environment.
6.2 8ecure system processing until evaluation of the problem ls completed and app corrective actions aro takon.
DT 10 95 Spill Procedure 2 of 3 Rev.2 4/02/95
_ .. = , ..-. -~ - . .~ -
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Pt9R-024995 13:17 Fprt1 Diu TECH Gt5 539 9001 TC iM129GFM P.03 -
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( 7,0 PROCEOURE 7.1 NOTIFY 1.E.M. SupeMsor. Diversified Technologies Supervisor, and Radiation Protwollors Teotiniolan IMMEDIATELY In tne event of a leak or spHI which may, or has, resulted in a potential release to the environment.
7.2 DETERMINE what la spRied and how it was spuled.
7.3 CONSULT with Radiation Proteodon, prior to artering the area for surveys and assessment -
7.4 COMPLimii a pre-job plan for clean up and/or decontamination.
7.5 CLEAN UP and/or decontaminate pet pre-job plan.
7.6 DETERMINE oeuse of spil and correct prior to continuing with processing Equid i redoactive waste stream. !
7.7 OISPOSE of contaminate malertal por Radweste and'Radation Protection Superviolon.
8.0 LOOS 8.1 in the depylog, doournent datos, time, occurrenoce,actione taken and other pertinent Irdormation related to any spill, leak of spread of contem!naton which occurs in excess of the normal course of process operations.
(
1.AST PAGE END OF PROCEDURE DT 10-96 3 of 3
, Spill Proceduro Rey:2 l 3/M96 k .,
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Sisadard SpeclAcalions: %t Tube" E Series HT llent Ex.huges 55hedvh 40 pkt burner tube, ned nul, pketer cotting, fkirnen Power turett. niing to 950$0 BTU Electrt<ni tep r u""-"
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