ML20134G676

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Discusses Review of Proposed Contingency Plans in Event Advanced Medical Systems Either Abandons Facility or Declares Bankruptcy
ML20134G676
Person / Time
Issue date: 02/29/1996
From: Pederson C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Cool D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20127A948 List:
References
FOIA-96-444 NUDOCS 9702100506
Download: ML20134G676 (12)
v • d • e


Text

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    • % UNITED STATES i

g $*g NUCLEAR REGULATORY COMMISSION N o 5 I REGION m T, 801 WARRENVILLE ROAD '

USLE. ILUNOIS 60532-4351 z *...+ ,

. February 29, 1996 '

MEM0PANDUM TO: Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety, NMSS FROM: Cynthia D. Pederson, Director Division of Nuclear Materials ety, RIII O

SUBJECT:

CONTINGENCY PLANS ADDRESSING ADVANCED MEDICAL SYSTEMS, INC. (AMS) SCENARIOS  !

{

Our first response to the subject issue of this memorandum was sent to Margaret Federline, Acting Director, Division of Waste Management on February 22, 1996, in error. We apologize for this and the delay in our response to you. ,

We have reviewed the e-mail (attached) submitted to us by Kevin Ramsey of your

staff which discusses proposed contingency plans in the event AMS either abandons their facility or declares bankruptcy. We support the development of '

i contingency plans to deal with these possible scenarios, however we would like to take the opportunity to provide specific comments as noted below.

}

Our comments are organized to correspond to the items listed in Task Nos. 3

and 3A of the e-mail. As you will note from our comments, the Region  ;

recommends that headquarters take the lead in performing the tasks which  !

1 concern financial assurance / funding issues. To accomplish the majority of the i

tasks described in the e-mail will require legal and financial expertise, which currently resides in headquarters, not the Region.

, Task No. 3: Develoo Continoency Plan to Address Situation where AMS Abandons the Facility Item 1: We agree with this item in its entirety. Region III should 8

take the lead in dispatching an inspector to the site to verify that there is no immediate health and safety threat to the public.

However, immediately after an inspector is dispatched, notifications of local authorities (e.g., police and fire departments, etc.) should follow. Local authorities could provide valuable assistance in security of building, crowd and media control, etc. Also, if the facility is locked, they could provide assistance to the NRC in gaining access.

A listing of agencies and their contacts would be beneficial, and provide NRC the opportunity to make l expedient notifications. j CONTACT: John R. Madera 708/829-9834 U 9702100506 970129 kt 6-444 PDR

.i Donald A. Cool Item 2: We agree that an order should be issued to the licensee not to abandon the site. Region III would take the lead in drafting and issuing an order.

Item 3: We agree that a bankruptcy team should be established and be comprised of regional and headquarters staff. However, since there are legal issues associated with bankruptcy, we recommend that OGC take the lead.

Item 4: Item 4 deals with procedures to follow for drawing on the letter credit. Region III suggests that headquarters, since it has the expertise in dealing with financial assurance issues, take the lead.

Item 5: Regarding financial assurance / funding issues, Region III recommends that NMSS take the lead and direct the trustee to disburse funds from the trust, work with the trustee to prepare a Statement of Work, and solicit bids from contractors. As stated earlier, it is apparent that headquarters has the expertise to deal with these issues.

Item 6: The review of the remediation contractors decommissioning plan and cost estimate should be done at the Region with technical assistance from headquarters, if necessary.

However, any legal action against AMS due to a funding shortfall, should be handled by headquarters.

Item 7: The Region should take the lead in conducting inspections of remediation efforts.

1 i

Item 8: Approval of disbursements from the standby trust for

, maintenance of facility and remedial actions are financial 3 and legal matters. Therefore, the Region suggests that

( , these issues be handled by headquarters.

La,sk No. 3A: Continaency Plan to Address Situation where AMS Declares 5

Bankruotcy. but does not Abandon the Facility I

Item 1: The Region agrees that it should be responsible for contacting AMS to verify that they maintain control of the facility after they file for bankruptcy. The Region should also take the lead in drafting and issuing a CAL, with headquarters concurrence. However, since a CAL is issued for items that are expected to last less than 30 days, you may wish to consider issuing an order in this situation.

Item 2: As noted in our response to Item 1 of Task No. 3, we agree that a bankruptcy team should be formed; however, we .

recommend that headquarters take the lead in putting the team together.

i-l Donald A. Cool Item 3: As noted in Item 3 of Task No. 3 above, the Region suggests that headquarters take the lead in issues that involve drawing on the letter of credit.

t Item 4: This item discusses procedures concerning the disbursement of funds from the Standby Trust Account. We agree with Items 4.a. through 4.c.; however, the Region recommends that

headquarters take the lead in the review and approval of all l

financial documents dealing with the disbursement of funds.

Regarding Item 4.d., the Region suggests that headquarters certify the disbursement approval documents and ensure that '

certifications are authorized.

l Item 5: The Region agLin recommends that headquarters take the lead l in legal action against the licensee in the event of a i funding shortfall for decommissioning the facility. I Item 6: Our response to this item is the same as for Item 7 of Task 3 above.

Item 7: Our response to this Item is the same as for Item 8 of Task 3 above.

I cc: K. Ramsey, NMSS I

DOCUMENT NAME: A:\96-0072a.AIT

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OFFICE RQI N l4' RIII n lt RIII g# l RIII l NAME )(ffult:dh JMadeh(R% CPedersorl DATE (02/Jt?/96 02429/96 02/.f /96

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02/ /96 OFFICIAL RECORD COPY '

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State of Ohio Envimmnerital Protecti;n Agency Northeast District Offico 2110 E. Aurora Road Twinsburg. Ohio 440871969

  • 25-9171 George V.Voinevich Q 447-o769 Govamor March 6,1996 RE: Advanced Medical 4yuems NEORSD Pretreatment David Cesar Advanced Medical Systems 121 North Eagle Street Geneva, OH 44041 Dear Mr. Cesar.

Tbc Ohio EPA has recently discovered that Advanced Medical Systems (AMS)is proce>>ing wales poor to discharge to NEORSD. AMS is allowed to discharge water collected in tanks from the footer drain system provided the soluble Cobalt 60 concentration is less than 100 pCi/l. Analysis of a tank ofcollected water i revealed an incluble Cobalt-60 concentration. Recently.NEORSD was requested to approve the discharge of this same tank of water after the water had been treated in some undocumented manner.

The Ohio EPA, NRC, and NEORSD have agreed that while the NRC has authority to regulate radiological discharges, OEPA and NEORSD have the authority tu se;;ulate discharges if those discharges con result in l an interference of POTW operations. The Ohio EPA has also informed NRC and AMS that Perrnit to Install regulations found in OAC 3745 31 would be invoked if a pretreatment system was installed in order to ,

reduce Cobalt-60 concentratiens to a level that would not cause interference.  !

From the limited amount of information supplied to ehis office, it appears that AMS has constructed a pretreatment system that is in: ended to remove Cobalt 60 in order to prevent interference with NEORSD ,!

operations. AMS installed this system without firsti>btaining a Permit-to-install, which is a violation of i OAC 3745 31-02(A)(1) and ORC 6111 AS. Please provide a response to this office by March 15,1996 that provides a schedule for submittal of a Permit-to-Install to the Ohio EPA Northeast District Office.

If you have any questions or comments, please contact me at 216-963 1285.

Sincerely,

=

Post-It* Fax Note 7671 0** 3 M $ 6 lp U s> I Donna J.Kniss Environmental Engineer k h b v e lo/c ""T69 Wh3 Division ofSurface Water co g g g g co & pg -

Northeast Distnet Office Faz o ggg gg49ggq Faa e g gg Q DK:cth ec: Jimes Payne, AGO Richard Connelly, NtORSD .

Dwight A. Miller, Sizvole and Mille-

, Henry E. Billingsley, Arter and Hadden k John Madera. U. S. NRC Region III O--

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M Northeast Ohio Regional Sewer District

( 4747 East 49th Street Cuyahoga Heights, Ohio 44125-1011 216 641 6000 FAX:216 641 8118 March 7,1996 Mr. Robert Mechim Advanced Medical Systems 1020 London Road r Cleveland, Ohio 44110 I

Dear Mr. Mechim:

We have been informed by the Nuclear Regulatory Commission (NRC) that Advanced Medical Systems (AMS) has pretreated the water currently in Tank #880. As your are aware from the Ohio Environmental Protection Agency's (OEPA) letter of March 6,1996 to AMS, the installation and I use of a wastewater pretreatment system without prior approval of both OEPA and the local regulating POTW, in this case the District, is a violation of OEPA regulations. As of this date, the -

District has not received any design criteria for the installation and/or operations of this pretreatment system. Therefore, any discharge from Tank #880 or any pretreated water on the premises is neither

( authorized nor approved.

If you have any questions regarding this correspondence, please feel free to contact me at (216) 641-6000.

{

Sincerely, Richard N. Connelly, Manager Water Quality & Industrial Surveillance -

RNC:sar cc: Lany English, NEORSD Donna Kniss, OEPA J. Madera, U.S. NRC Region IIIL Dwight Miller, Stavole & Miller Harry E. Billingsley, Arter & Hadden gRlI NJ s 96090201/4 The mission of the Northeast Ohio RegionalSewerDistrictis to enhance public health and wettare through the esticient, cost-cliective conveyance and treatment of wastewater. This is accomplished by an organization dedicated to professionalism. v f.timess and consistency that anticipates and responds to the changing environmentalneeds of the community. L

. I ARTER & HADDEN Fax Cover Sheet CLEVELAND 1100 Huntington Building cimland, ohio 44115 216v696-1100 Fax 216/6962645

  • Celmembe DeAes Irvlee, CA 10 West Broad Sweet 1717 Mais Soest, suits 4100 2 Park Plaan, Suite 700 Colenbus, Ohio 43215 Dallas, Texas 75201 trvine,(phrarnia 92714 7 614/221-3135 214/761 2100 714/252 7500 i Enx614/2210479 Pas 214p417139 rea 714/s33-pood 14e Asesles San Freacines W9' 7 , D.C.-

100 sesikPlower Seest 201 California Swast 1801 K Beest.N.W.

IAs Angeles,Chlifcumis 90017 14thFloor Suite 400l( l 213/629 9300 SanFrummaco,Californis 94111 Washington D.C.20006  !

Fax 213/617-9255 415/912 3600 202/773 7100 Fax 413/912 3630 Pas 202/8374172

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pax NO. [70b SY)/zM ._

COMPANY:g8 N&6 bI TELEPHONE NO. fd #9" #44 ,

PROM: b 8- I DATE: 3'/b 94 TIME: a.m. o.m._

TOTAL NO. O AOES: CLIENTMATTERNo.: 4493/!877f -

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l STARTED: DATE: TIME: a.m. p.m.

COMPLLTED: DA'IE: 1TME: e.m. p.m.

COMMENTS:

Itis Arser & Hadden's guidingprinciple that every experience a client has with the Firm wlR meet orexceed that client's expectations as to outcome, quality and value.

If you have any problems reading this 'e=a mt-tm Please call the fax operator at (216) 6061100 ext. 2424 CONFIDENTIALITY NOI1CE

'Ihe documents ==j-%g this fax transmission contain confidential infortnation belonging to the sender which is legally privileged. The inicmnation is intended only for the use of the hidividual ur entity sameneJ abu,c. If you are uvt the intanded socipient, you are hereby notified that any disclosure, copying, distribution or tim taking of any action in reliance on the umscats of this famed informatice is strictly prohibited. If you lave received dJa faa in suu, ple e Leunediately notify us by telephone to arrange for retum of the original documents to ts.

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ARTER&HADDEN i ATTOANEYS AT law n ,

pa a IN3 cdemins 925 Euclid Avenue Irvine Delles 1100 Huntington Building ImAnoda

-"_ .D.C. Clotaland, Ohio 44115-H75 Sea Fransiseo  :

216/696-1100 peas, 216/696-264Auimur issner.s a uses asat a m er:

(21s) ses san i

l March 11, 1996 l l

BY FAE RED REGUL&R NhIL t

I Richard N. Connelly, Manager Water Quelity & Industrial surveillance Northeast Ohio Regional Sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 Re Advanced Medical systems, Inc.

our Files 62931/49779 i

Deer Mr. Connelly:

I refer to your letter of March 7, 1996 delivered by fax to Advanced Medical Systems.

You are, once again, misinformed. Advanced Medical Systems has not pretreated the water in tank No. 560 nor does AMS have any 1 intention of installing or operating a pretreatment system with l respect to this water. -

The water in tank 880 is not an " industrial waste" within the meaning of section 6111.45. It is, instead, surface and ground water that has been removed from the new foundation footer drain system located around the exterior of the building. This drain system, as you know, is completely isolated from the internal  ;

plumbing of the building. As you also know this water is pumped  !

from the foundation footer drain to a holding tank where it is held for sampling prior to discharge, in conformity with the consent Order recently issued by Judge White of the federal district court in Cleveland. *

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t ARTER&HADDEN
Richard N. Connelly, Manager j March 11, 1996 +

l Pege 2 1 l

! On one occasion tank 880 was cleaned to remove sludge from the bottom of the tank that had accumulated prior to the time that the tank was used as a holding tank for sampling by the NE0RSD. The [

I water in the tank was agitated to put the sludge into suspension.

j The sludge was then removed with a filter and retained. This was i not an operation that involved protreatment of the water for l discharge.

l As you also well know, there have been repeated discharges to

! NEORSD of the water accumulated from the foundation footer drains

! to the NE0RSD because it has been clear, from your testing, that i this water satisfies the release criteria set forth in the consent [

] order.

i For reasons that we now hope are obvious, AMS will not be

submitting "any design criteria for the installation and/or j operations [ sic) of this pretreatment systaa."

! If you have any questions please feel free to contact me at j (216) 696-2372.

I Very truly yours, i ARTER & DEN h * &^dZ Billngsley,[I Henry E -

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ARTER&HADDEN  ;

i Richard N. Connelly, Manager Narch 11, 1996 Page 3 I

i cca Larry English, Esq.

Assistant General Counsel Northeast Ohio Regional sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 Ms. Donna Kniss Environmental Engineer Division of Surface Water

  • Ohio EPA Northeast District Office 2110 E. Aurora Road Twinsburg, Ohio 44087-1969 Mr. John Madera United Statas Nuclear Regulatory conmainnion Region III )

801 Marrenville Road Lisle, Illinois 60532-4351 Dwight Miller, Esq.

stavole & Miller 55 Public Square Suite 1604 i Cleveland, Ohio 44113 i Mr. Robert Neschter R.S.O.

Advanced Medical systems  !

1020 London Road -i Cleveland, Ohio 44110 l

  • + TOTAL PACC.04 ++

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  • ARTER&HADDEN ATTORNEYS AT LAW

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' srnbus 925 Euclid Annue Irvine

.a s 1100 Huntington Building los Angeles

' Washington, D.C. Ciculand, Ohio 441151475 s San Francisco 216/6961100 pAone 216/6%-2645facimi/c w,te c.. Direct otal numbers (216) 696-2372 March 11, 1996 '

BY FAI AND REGUIAR MAIL e

Richard N. Connelly, Manager {

Water Quality & Industrial' Surveillance Northeast Ohio Regional Sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 Re: Advanced Medical Systems, Inc.

Our File: 62931/49779 -

i

Dear Mr. Connelly:

I refer to your letter of March 7, 1996 delivered by fax to Advanced Medical Systems.

You.are, once'again, misinformed. Advanced Medical Systems has not pretreated the water in tank No. 880 nor does AMS have any 1 intention of installing or operating a pretreatment system with respect to this water. -

Theofwater meaning Section in tank 880 is 6111.45. not an " industrial waste" within the It is, instead, surface and ground water that ham, been removed from the new foundation footer drain system located around the exterior of the building. This drain system, as you know, is completely isolated from the internal plumbing of the building. As you also know this water is pumped j from the foundation footer drain to a holding tank where it is held  !

for sampling prior to discharge, in conformity with the Consent i Order recently issued by Judge White of the federal district court in Cleveland. i g

ei.--- - i- -

- . - 1 ARTER&HADDEN i

k. Richard N. Connelly, Manager March 11, 1996 Page 2 l

1 on one occasion tank 880 was cleaned to remove sludge from the  !

bottom of the tank that had accumulated prior to the time that the tank was used as a holding tank for sampling by the NEORSD. The water in the tank was agitated to put the sludge into suspension. j) 3 The sludge was then removed with a filter and retained. This was not an operation that involved pretreatment of the water for discharge.

As you also well know, there have been repeated discharges to NEORSD of the water accumulated from the foundation footer drains l

to the NEORSD because it has been clear, from your testing, that d

this water Order. satisfies the release criteria set forth in the Consent {l For reasons that we now hope are obvious, AMS will not be submitting "any design criteria for the operations [ sic) of this pretreatment system."installation and/or

(

If you have any questions please feel free to contact me at (216) 696-2372.

f 1

Very truly yours, ARTER & HADDEN f - -

1 m2/b Henry E- Bill ngsley, I i

i i

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ARTER&HADDEN 4

( Richard N. Connelly, Manager

. March 11, 1996 Page 3 I

cc: Larry English, Esq.

Assistant General Counsel ,

Northeast Ohio Regional i Sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 )

Ms. Donna Kniss )

Environmental Engineer l Division of Surface Water -

I Ohio EPA

'i Northeast District Office '

2110 E. Aurora Road .

Twinsburg, Ohio 44087-1969 -

Mr. John Madera

( United States Nuclear Regulatory Commission l Region III 801 Warrenville Road Lisle, Illinois 60532-4351 .

Dwight Miller, Esq.

Stavole & Miller 55 Public Square Suit.e 1604 ~

Cleveland, Ohio 44113 Mr. Robert Meschter R.S.O. ,

Advanced Medical Systems 1020 London Road Cleveland, Ohio 44110 k

o

[Tl Advanced MedicalSystems,Inc.

1020 London Rd. l Cleveland, Ohio 44110

' 216-692-3270 l

March 8,19%

Ms. Cynthia D. Pederson, Director Division of Nuclear Materials Safety U. S. Nuclear Regulatory Commission 801 Warrenville Road ,

Lisle, Illinois 60532-4351 i Re: License No. 34-19089-01

Dear Ms. Pederson:

'Ihe purpose of this letter is to summarize recent actions regarding approximately 3,000 gallons of groundwater stored in Tank 880 at the Advanced Medical Systems, Inc. (AMS) facility. In your I3i letter to Dwight A. Miller, Esq. (dated February 16,19%), and again in Mr. Geoffrey C. Wright's j (USNRC)letterto me (dated February 22,1996), it was asserted that a non-representative samp of the contents of Tant 880 (collected and analyzed by the USNRC) contained detectable insoluble "Co. Subsequent representative samples from the same tank (collected by AMS and analyz;

[-

intW Analytical Laboratory) demonstrated that the tank contains no detectable insoluble "Co. '

'Ihe results of these analyses were forwarded to Mr. Mike Weber (USNRC). On March 7,1996, after reviewing.the.Lockheed analytical reports, Mr. John Madera (USNRC) confirmed that this tank volume was acceptable for discharge pursuant to 10 CFR 20.2003. If you have any questions I or ifI can provide you with additional information, please call me at (216) 692-3270.

Sincerely,

/

Robert Meschter, R.S.O. .

cc: David Cesar .

Dwight Miller- Stavole & Miller Carol Berger- EM John Madera - USNRC Re'gion M Mike Weber- USNRC Region M. -

Geoffrey._ Wright i USNRC Region m 5

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      • *% UNITED STATES y

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  • NUCLEAR REOULATORY COMMISSION REGION m U $ 801 WARRENVILLE ROAD

[ *g / USLE. lWNOIS 60532-4351

          • March 12,1996 -

Robert Meschter Radiation Safety Officer Advanced Medical Systems, Inc.

1020 London Road r Cleveland, OH 44110 i

SUBJECT:

NRC INSPECTION REPORT NO. 030-16055/95006(DNMS)

Dear Mr. Meschter:

This refers to the special inspection conducted by Robert E. Shewmaker, Engineering anC Geoscience Branch, Division of Waste Management, Office of Nuclear Materials Safety and Safeguards. The on-site inspection was conducted [

on October 11-12, 1994, February 1-2, 1995, and July 20-21, 1995, at Advanced Medical Systems' London Road, Cleveland, Ohio facility. The inspection's purpose was to evaluate (1) the impact of the basement flooding on the facility's structural integrity and (2) the facility's structural integrity relative to the containment and protection of the radioactive material stored

( there. The enclosed report discusses information obtained during the inspection. -

Based on observations made during the inspection we have concluded that the {

1994-1995 basement flooding had no observable impact on the 1958 building's structural integrity. The 1958 building includes all areas, with the exception of the isotope warehouse, where radioactive materials are used and/or stored. We have also concluded that the building's structural integrity appears adequate at this time to contain the radioactive material in AMS' possession; however, some questions regarding the structure's condition were identified.

Indications of structural distress in limited areas were evident. The impact of those indications on the structure's long term integrity and seismic stability were not assessed in the report. However, those indications of structural distress appear to conflict with the conclusions of your Emergency Plan's " Engineers Opinion Report." In order to complete our review of your Nrgency Plan, and to ensure an integrated assessment of your facility's N.egrity, you will need to address our report's findings, and the questions regarding seismic stability in our February 27, 1996 letter. The assessment should address the facility's ability to provide protective confinement of the radioactive materials over the facility's intended utilization period. The ,

assessment should include sufficient engineering detail to support its conclusions and plans, if necessary, for structural remediation. Plans for O

U

  • Robert Meschter f l

structural remediation, if identified, should include schedules with estimated completion dates for each action requiring remediation. The following items, discussed in the inspection report, should specifically be addressed:

1. The depth and extent of cracking, structural impact, and any measures I identified as necessary to repair the cracking identified in the load- ,

bearing masonry wall in the 1958 building's southeast corner. )

i Associated distress that could limit the facility's ability to continue 'l to provide protective confinement of the radioactive materials should j also be assessed and corrective actions identified as necessary. '

2. The depth and extent of cracking, structural impact, and any measures

, identified as necessary to repair the cracking identified in the 1958 building's north bay of the east masonry filler / curtain wall.

Associated distress, caused by the introduction of moisture and other waterborne contaminants, that could limit the facility's ability to continue to provide protective confinement should also be assessed and 'i I

corrective actions identified as necessary. 'i l

3. The precast concrete roof panels that in several areas exhibit corrosion l products on the visible surface. ]

( 4. The second floor concrete slab in the area where it forms the ceiling of the hallway in front of the hot cell and the radiography room, and exhibits the effects of previous fluid penetration through the slab from above.

5. The need to periodically inspect and evaluate the building's ability to I perform its defined functions over the utilization period. If a program l is deemed appropriate, it should include inspection frequencies and '

evaluation activities.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and .its enclosure will be placed in the NRC Public Document Room.

Please provide ycur plans and schedule for completing the assessment within 30 days of this 'etter's date. In your response to this letter, include an evaluation of the impact of the assessment described above, as well as an evaluation of the impact of any plans and schedules for structural remediation, on the long term priority plans you submitted in your letter of October 11, 1995.

9

u

Robert Meschter  ! l.

I We will gladly discuss any questions you have concerning this inspection.

Sincerely,

~

Original signed by Geoffrey C. Wright, Acting Deputy Director Divjsion of Nuclear Materials Safety ':

Docket No. 030-16055 License No. 34-19089-01

Enclosure:

Inspection Report j No. 030-16055/95006(DNMS) l See Attached Distribution 1

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  • j ,

Distribution Michael R. White, Mayor Lisa Mehringer City of Cleveland City of Cleveland Law Department 601 Lakeside Avenue 601 Lakeside Avenue, Room 106 Cleveland, OH 44114 Cleveland, OH 44114  ;

. Erwin J. Odeal, Executive Director Erv Ball, Deputy Director Northeast Ohio Regional Sewer District Cuyahoga County Board of Health 3826 Euclid Avenue 1375 Euclid Avenue, Suite 524 Cleveland, OH 44115 Cleveland, OH 44115 Michael Kalstrom, Secretary Jane Harf, Chairperson County of Cuyahoga Ohio State Emergency Response Cuyahoga Emergency Management Commission Assistance Center 1800 Watermark Drive 1255 Euclid Avenue, Room 102 P.O. Box 163669 Cleveland, OH 44115-1807 Columbus, OH 43216-3669 Robert E. Owen, Administrator Marian Zobler Department of Health U.S. Nuclear Regulatory Commission 246 North High Street, 3rd Floor Rockville, MD 20555 P.O. Box 118 Columbus, OH 43266 hG.G1 C. Jones, NMSS PUBLIC IE07 AMS File E-mail:

Bruce Berson (BAB1) Bill Brach (EWB) Joe DeCicco (JXDI)

Cynthia Jones (CGJ) Mike Stein (MHS) Jim Caldwell (JLCl)

Tim Johnson (TCJ) Mike Weber (MFWI) Fred Combs (FCC)

John Madera (JRM4) Marian Zobler (MLZ) Donald Cool (DAC)

Kevin Null (KGN) Bernie Bordenick (BMB) Steve Crockett (SFC)

Cindy Pederson (CDP 1) Josie Piccone (JMP1) Geoffrey Wright (GCW)

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December 20, 1995 U.S. NUCLEAR REGULATORY COMMISSION HEADQUARTERS Report No. 030-16055/95006(DNMS)

License No. 34-19089-01 (Current) Priority I -

Category B License No. 34-07225-09 (Former)

Docket No. 030-16055 (Current); None Specified (Former)

Licensees: Advanced Medical Systems, Inc (Current)

Picker Corporation (Former)

Facility: 1020 London Road Cleveland, OH 44110 Site Inspection and Interviews Conducted: October 11, 1994 through July 21, 1995 Inspector: h' k itkhuc of flobert E. Shewmaker, PE Date

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[SeniorStructuralEngineer l

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Accompanying Personnel: Wayne Slawinski -

Senior Radiation Specialist RIII ,

Reviewed By: 3/ i b/[I [ /L/

Richard Weller4 Section Leader

/v[%

Date Engineering and Materials Section Approved By:

Michael J. Be'll/ Chief' lb/w[f[

Date Engineering anJ Geosciences Branch

.)

Division of Waste Management '

Office of Nuclear Material Safety and Safeguards Insoection Summary: '

Inspections durino the oeriod of October 11. 1994 throuah July 21. 1995 (Report No. 030-16055/95006(DNMS))

Areas Reviewed: This series of special inspections consisted of three separate inspections relative to assessing the current and future structural integrity of certain specific areas within the Advanced Medical Systems, Inc.

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lj (AMS) facility at 1020 London Road, Cleveland, Ohio. Areas of main focus were j [ the hot cell, the waste hold-up tank (WHUT) room, the original radiography '

room (now known as the "high level" waste storage room), the source room, the front and back basements and the HEPA filter equipment room. In addition, the impact on the structural integrity of a water back-up condition that occurred l in the basement areas of the facility was also assessed.

Results: One area of distress in a load-bearing masonry wall, supporting the roof structural steel framing in conjunction with the wall of the HEPA filter i equipment room, was identified. This area also exhibited a breech in the building's waterproof envelope, leaving structural components exposed to a )

more rapid degradation rate than if protection were intact. One other area was found where the waterproof building envelope was not intact, however, any future structural distress resulting from this would not impact stored i

radioactive materials or wastes. Evidence of degradation in the form of rust  :

on the exterior of concrete elements that had formed over the current service life of the structures was also found. It was concluded that with repairs and continued monitoring, the structural integrity of the 1958 building could be maintained consistent with the original design conditions with monitoring on a 10-year cycle.

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i DETAILS

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1. Persons Contacted Mary Bennett, Administrative Assistant, Division of Building and Housing, City of Cleveland '

Carol Berger, Project Manager, Integrated Environmental Management, Inc.

- (IEM), AMS consultant -

David Ceasar, Treasurer and Chief Financial Officer, AMS John W. Denega, Project Engineer, Neff and Associates, AMS consultant Donald Jones, President, Quality Environmental Solutions, Inc. (QES),

AMS consultant Evans Matiatos, Environmental Chemist, Quality Environmental Solutions (QES), l.MS consultant Robert Meschter, Radiation Safety Officer, AMS William J. Muniak, Attorney, Arter and Hadden, legal counsel for AMS Vince Rocco, former Health Physics Technician, AMS

2. Purpose and SCoDe of InsDection This was a series of limited scope special inspections related to the structural integrity of the physical building facility at 1020 London Road in Cleveland, Ohio, including the specific elements such as the hot cell, the waste hold-up tank (WHUT) room, the original radiography room (now known as the "high level" waste storage room), the source garden, the front and back basements and the HEPA filter equipment room. The structural integrity of the building facility with areas of contamination, waste storage or source material storage needs to be assured for the expected future time period over which the radioactivity should be controlled, that includes during events that -

are addressed in the emergency response plan for the facility. Depending on various decisions that may be made by AMS management, this time period may extend as much as an additional 25 to 30 years or more beyond the current time. The original inspection scope was later expanded in the late fall and early winter of 1994/1995 to include the assessment of any impact on structural integrity caused by basement flooding that resulted from the deliberate plugging of the outfall lateral line of the combined sanitary and storm sewers by the Northeast Ohio Regional Sewer District at the street trunk line.

On-site inspections were conducted three times during this period based on the changing conditions at the facility and the gradual discovery and flow of 3

e

factual information related to the facility, the life of which to date has

( spanned nearly a forty-year period, with portions spanning over 60 years. The first site inspection was conducted from October 11 through October 13, 1994, addressing the general facility configuration, general construction materials, l general facility conditions, and the usage of the facility. The second site inspection was conducted on February 2,1995, during the time when there was water in the basement of the facility in order to observe any potential damage to the facility. The third site inspection was conducted from July 19 through July 21, 1995, in order to complete additional detailed observations and review of existing conditions of the building structures of the facility and to observe the corrective actions being made in the subsurface drainage system.

3. Backaround on the Develooment of the Facility The 1958 design, development and construction of the building facility for Phase I of the Picker X-Ray Corporation, that was subsequently acquired by AMS, encompassed the integration of a then existing warehouse / industrial building, with masonry load bearing walls and steel trusses as the roof framing steel, into the facility. That original building dating to at least 1934 (based on a City of Cleveland, Record of Permits Issued with an entry under " Electrical" and dated 12/3/34) was approximately 60 feet by 100 feet and 30 feet high. The 60 foot wide front portion of the warehouse / industrial building was enveloped by the construction of a new building with a front dimension of approximately 130 feet.in width. Of that 130 foot east wall building front, approximately 107.5 feet of it is load bearing masonry and

( 22.5 feet of it is a masonry curtain wall surrounded by a structural steel bay of framing at the north end for the lobby-stairwell area. The south and exterior west walls of the facility are also load bearing masonry. The north wall is a masonry curtain wall within the structural steel frame of the lobby-stairwell area. Phase II consisted of a two-story addition of classrooms, completed in 1963.

It should be noted that a relatively complete set of design drawings are available for the facility at 1020 London Road for those portions built in 1958 and 1963 and these were used in the inspection and evaluation process.

A listing of the design drawings used in the inspection and review process is attached as Appendix A. Other portions of the facility's building complex used by the licensee for handling radioactive materials, namely the isotope warehouse, were not included in any of the drawings or other records available at the site.

During the inspection and review process, the City of Cleveland, Division of Building and Housing, was contacted in order to review the records of permits associated with the 1020 London Road address. Appendix B lists the relevant permits issued against the address beginning with site clearing for the 1958 building construction. From these records it was determined that the building permit for the 1958 building was issued on 4/18/58 as Permit Number J46366 for the " Phase I Addition to Existing Brick and Block Warehouse." The permit for the addition that is known as the isotope warehouse was issued 5/4/62, under Permit Number K30250, for the L-shaped storage building 4

l

4 addition. A single sheet drawing was on file with the City of Cleveland for

[ this structure which contained minimal information.

4. Desian Bases of Buildino Facilities There has been no general building code reference found on any of the documents, including the drawings, so the City of Cleveland was contacted to ascertain what building code was in effect when the building permit was issued. It was learned that the City of Cleveland had adopted its own building code in 1951 that was in effect in the 1958 time frame when the building permit was issued. Archival copies of that document and the relevant revisions are available for review at the Cleveland City Hall, but the  !

document has not been reviewed.

The results of six (6) soil borings, made prior to the 1958 building construction for the foundation investigation, were summarized on the Site  ;

Development Plan (Dwg. SD-1) and indicated that the footings for the reinforced concrete (R/C) core of the 1958 building were founded in a grey to grey-brown shale above the normal water table. The Foundation Plan & Details (Dwg. F-1) indicated that the allowable bearing stress for those footings that were located below Elevation 640 feet was 5 T/sq. ft. Individual column '

footings for the interior steel frame portions of the 1958 building were founded in a hard, grey-brown shaley clay with Dwg. F-1 indicating an allowable bearing stress of 3 T/sq. ft. from Elevation 640 to 647 feet.

The design loadings for the 1958 building as specified on the concrete

( drawings for the R/C core were as indicated below, but no specific codes or 4 standards related to reinforced concrete (R/C) or masonry design were cited. I The general code for the design of reinforced concrete in effect at the time was the American Concrete Institute (ACI) Building Code for Concrete (ACI 318-56), dated 1956.

First floor of R/C core: Live Load (LL) - 500 psf; Dead Load (DL) = 175 psf Second floor of R/C core: LL - 150 psf DL = 90 psf The surrounding portion of the 1958 building's structural system is composed of a hybrid system containing load-bearing masonry walls, structural steel and reinforced concrete elements. The portions of the building envelope or exterior skin that are not formed as part of the structural system are masonry filler walls that act as curtain walls. The design loadings as specified on the structural steel drawings were as indicated below with a reference to the Specification for the Design, Fabrication and Erection of Structural Steel for Buildings, American Institute of Steel Construction (AISC), with no specific reference to the edition being used for the project. The particular edition of AISC in effect during this time frame was the 1949 edition.

First floor of remainder of bldg.: Ground supported slab Second floor of remainder of bldg.: LL = 150 psf DL = 70 psf 5

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Roof for entire complex : LL- 30 psf DL- 30 psf with 2.5K hanger- ,

( load at center of purlins l and beams  ;

All of the loadings identified on the drawings, as noted above, include only I vertical gravity loadings, with no indication of considerations made for l lateral loads from wind, tornado, seismic events, or other events creating ,

differential pressures or other loadings on the facility. -

r The specifications for materials used in the structural system were, in  !

9eneral, not available in the documents that were used in the inspection and  ;

evaluation process. Dwg. F-1 indicated that the concrete for the foundation j was to be 3000 psi concrete at 28 days, but no information was provided on the properties of the reinforcing steel. Other materials used in the structural 7 system were not identified by ASTM standards or by other numerical methods such as the identification of grade, strength or other specified properties. )

5. Field Observations and Structural Evaluation .

Based on experience in the design and construction of various types of facilities and structures with the various materials used in the civil engineering / building field, a general survey of the building's structural framing was performed. From this general survey critical areas of the structural system were reviewed and any areas of potential distress were identified.

( In general, the reinforced concrete core structure of the 1958 building that ,

forms the hot cell, the WHUT room, the original radiography room, the source i garden and the front and back basements was found to be in good condition based on a visual survey of the exposed externally visible surfaces, with the exception of one questionable area. In this area there is evidence of considerable amounts of water or other fluid apparently having penetrated on the second floor of the facility. The floor in that area is a 6-inch thick reinforced concrete slab. The underside of the second floor slab in this area forms the ceiling of the first floor. Evidence of the fluid that penetrated exists on the ceiling adjacent to the hot cell and in front of the radiography room and around the corner of the radiography room into a hallway at' the north side of the radiography room. It is not known what the source of this fluid was, but it could have been a source such as a ruptured pipe from freezing conditions or from the failure and leakage of exterior roof surfaces over the second floor. At the roof level in this general vicinity is the interface between the pre-1935 old warehouse building and the 1958 building. These interfaces are typically a source of leakage of roof water. Evidence of significant roof leakage can be seen on the suspended ceiling of the second floor in several areas of the building, but the period of time over which water was allowed to penetrate the building's originally waterproof envelope is unknown. In several areas such as in the southeast corner of the building and along the east front wall, there is evidence of water penetration of the roof deck structure. This structure is made up of haydite (lightweight) precast concrete roof panels, that exhibit corrosion products from the embedded reinforcina steel. The roof leakage apparently continued until 6

- ---My- m-, 9--e pm o i'--+- y m --sf--N

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October of 1994 when some major roof repairs were made. It was noted during-

!(.

the inspection of the roof that the sprayed foam coating appeared to be holding considerable moisture. No information was available on the material so it is unknown whether or not under freezing conditions there would be expansive forces created that would rupture the waterproof roof envelop again.

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Distress in the form of significant cracking in the southeast corner of the load-bearing masonry wall of the east front, near the second floor ~1evel, was identified as well as significant cracking in the north bay of the east masonry filler / curtain wall above the second floor elevation. Both these elements of the 1958 building serve to form part.of the building envelope.

The source garden, housed in the basement with access from the first floor, is located in the southwest corner of the 1958 building and is completely i surrounded by reinforced concrete structural elements. This portion of the 1958 building appears-to be in a condition that is adequate to meet the original design conditions although the visible portions of walls directly surrounding the source material are very limited.

The two areas of significant distress tend to indicate that the visible damage arose from the response of the structural system to a lateral load component that was parallel to the east wall which the structure was apparently not designed to resist. The most significant lateral load that could be identified that the building has experienced is the January 31, 1986, magnitude 5.2 earthquake that occurred in northeast Ohio although the observed distress and this event have not been clearly linked.

The distress at the southeast corner of the building associated with the east

( 3-wythe load-bearing brick masonry wall can be characterized as a saw-tooth crack extending horizontally 12 to 13-feet from the south building face and extending over approximately 4 feet vertically. The open crack, representing permanent displacement, indicates approximately a 5/8-inch horizontal differential displacement in the once continuous load bearing masonry wall that is 12 and 1/2-inches thick (Dwgs A-10 and P-2). The depth of the cracking into the 3-wythe wall is not known since the back side (inside the building) of the wall surface was not readily accessible. The face brick wythe is bonded to the two inner wythes with a header course each six courses of brick. Whether or not the wall was constructed with a mortared collar joint is unknown, but it is assumed the wall was constructed as a solid masonry bearing wall. The crack then appears to trace downward at the vertical joint between the corner stone return on the southeast corner and the -

east wall. The crack then shows as a fracture in the stone ledge of the east wall at the corner. Originally, the sections of stone were pinned together with brass dowels and the joints were mortared. At some of these joints there has been rotation and translation with rupture and mortar loss. Above the distressed region, the load-bearing wall supports the southern most roof structural steel purlin (P2) in a wall beam pocket on a 3/8" x 7" x 8" steel bearing plate. The purlin span is over 26-feet. On the inside of the 1958 building at this purlin bearing there is evidence of movement between the bearing wall and the purlin in the longitudinal direction of the purlin. It is not known at this time which structural element remains with the permanent movement; the east wall in the perpendicular direction or the purlin in its longitudinal direction. In addition to the cracking of the east wall, 7

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evidence of lateral loading was found at a point about 17-feet from the east wall in an area along the south wall that the purlin runs parallel to with its

( 26-foot span. At this area the purlin penetrates an interior non-load bearing concrete block masonry wall (Dwg P-3) that is perpendicular to the south wall.

Rupture of the joints of this wall where the masonry was fit around the purlin has occurred and there is a permanent opening of over 1-inch between the non-load bearing wall and the load bearing brick south wall indicating permanent differential movement.

The distress of the east wall near the northeast corner of the 1958 building i is associated with a rupture type failure that is evident on the inside of the building as a cracked and displaced concrete block filler or curtain wall.

This' wall section is within the region above the lobby area where the structural elements are steel framing as opposed to a load bearing type masonry wall. The rupture line is most pronounced in a vertical direction just adjacent to the northeast steel column of the building within the area from the second floor level to the roof. The rupture line extends over approximately 12-feet of the 14-foot story height and has approximately a 1 and 1/4-inch displacement out of plane at the maximum offset. This rupture surface is generally through every other course of concrete block and does not follow a saw-tooth pattern along the mortar joints. The concrete block in this curtain wall appears to be nominal 4-inch thick block (half block) that was made into a wall in which the concrete block portion is confined between the webs of the two columns (F1 and Dl, Dwgs. S-1, A-7 and A-10), the second floor concrete slab surface and the underside of the flange of the structural steel roof beam (RB3). It is possible to see through the ruptured concrete block of the inner wythe of the wall to the brick, but it was not possible to

(. determine the bond mechanism between the inner wythe of concrete block and the two outer wythes of brick. The outer two wythes of brick are supported between the columns (F1 and D1) by a lintel beam (Cl), at approximately 4'9" below the level of the second floor, that is part of the lobby entrance structural steel framing in this bay. The existing design drawings do not provide any information on the details of this wall section, but it is assumed the 3-wythe wall was intended to be bonded construction. At a level approximately two courses of concrete block above the second floor level, the rupture line turns horizontal and runs along the mortar joint between courses.

Approaching the next column (D1) along this joint rupture, the rupture becomes  !

a crack that then becomes invisible to the unaided eye. The interface between i the top of this wall and the structural steel framing is along a non-bonded, but tight joint on the underside of the bottom flange of structural steel roof beam (RB3). At the rupture surface intersection with this joint there is a 1 to 1 and 1/4-inch displacement of the top of the wall outward from under the l beam flange. This offset continues toward the next column (D1) that is approximately 22 feet away. The offset is not visible at the next column.

This distressed area represents an approximately 12'x 20' area of curtain wall (inner wythe) that is now free or ruptured on three of the four edges representing an " inner flap" in the wall. An inspection of the outer surface of this wall did not reveal any cracking when viewed from ground level. It did reveal that an outward bulge of the brick wall in the area directly '

opposite the " inner flap" now exists. In addition, the stone corner and stone return at this northeast corner of the 1958 building show displacement and rotation at the corner with failed joints. The distress was also reflected in 8

g- ,,y--- ---yw -- . , , - - - - . - , - . -

,--c.

__ _ _.____ _ _.___ __ _ _..~__._________ _ _ _

6:,

i -.

j

  • I 2 the displacement of the stone coping at the top of the walls as they intersect

.( at_ this northeast corner of the building. Differential movement of 2-1/2 to 3  ;

inches was found at this corner between the coping and the walls. Sighting I

I horizontally along the line formed by the corner of the coping stone on top of the east wall as well as vertically upward along the corner of the stone

, return at the north east corner of the building, it is obvious that there is a level of distress remaining in the elements described.

. The building permit for Phase II was issued 4/22/63 for an addition to the i north of Phase I and consisted of a steel-frame building approximately 160' in i

the N-S direction and 175' in the E-W direction. This was to be used as ,

l classrooms. No extensive inspection or evaluation efforts were made on this )

j addition since no known contamination exists in that addition and there are no ,;

known plans to allow storage of radioactive waste or soure ;
sterial in the  ;)

l Phase II addition.

l Based on the observations of the areas of distress of the two ends of the east j- front wall of the 1958 building, the interface of the 1963 Phase II building i and the 1958 building was an area that needed to be examined. This was based )

on the fact that under seismic loading the front portion of the 1958 building )

! would be expected to respond as a much stiffer building element in the 1 l structura than the 1963 structural steel building frame that did not appear to ,

j be a braced frame nor a rigid frame type design. The possibility exists that i

! the 1963 building could be more flexible, thus exhibiting a larger deflection

! Lnan the 1958 building and could have actually transferred additional lateral load into the 1958 building than would have occurred without the 1963

! building. It was noted in the review of the drawings for the 1963 building j- / that revisions had apparently been made in the framing of the 1963 building at

( the interface with the 1958 building along the original 1958 building north
wall. Drawings S-1 and S-2 in the preliminary verstons showed the structural i steel roof framing system purlins, designated P1, as framing into beam pockets t

cut into the masonry wall and seated on bearing plates, BP1, or as second l

floor structural steel framing system beams, designated 81, framing into '

similar beam pockets with bearing plates, BP2. The as-constructed conditions i

found in the field during the inspection revealed that the beam pockets in the i

masonry wall of the 1958 building had not been used to support the structural

steel framing of the roof and second floor framing, but additional columns and i beams had been erected. Drawing F-1, Revision 1, for the Phase II 1963 i building indicated the addition of Footing M on Column Line 2 as part of the i changes made in the framing system. This deliberate separation of the primary

! structural elements may have been as a result of the recognition of the  ;

! possibility of the different connecting phases of the building phases i responding to loads over time in a different manner. Whether the concern was l over what would be considered a more normal concern, related to differential  !

vertical movement, since the foundations were separate, rather than over l lateral'1oads is not known since no design calculations were available. In i the actual configuration, both the precast concrete roof panels as well as the i cast-in-place concrete slab on the steel frame of the second floor represent a j stiff diaphragm capable of transmitting considerable lateral load. Only a 1/2 )

< inch premolded expansion joint separated the two structures, probably

insufficient rattle space for the dynamic lateral response of the two 4 buildings. Such a loading could explain the observed distress.

9 I -

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As is discussed in Section 6 of this report, the basement slab underwent some

( uplift loadiag as a result of differential water pressures, so that once the basement was drained and dry, it was necessary to inspect the concrete structural elements to determine whether or not the basement flooding event had any impact on the structural integrity of the 1958 building. Cracks that were observed in the basement floor slab were judged by an NRC inspector to be cracks that probably existed previously, but which opened an additional amount during the basement flooding and allowed additional flow to occur into the basement. No additional signs of distress were noted by the inspector who had inspected the facility before and after the flooding event. While it is possible that contaminants that could increase the rate of corrosion of the reinforcing steel in the submerged reinforced concrete elements, could have been transported and deposited so et to attack the steel, at present, there is no visible evidence of such degrWion. Therefore, it is concluded that there was no observable significant impact on the structural integrity of the 1958 building as a result of the basement flooding event.

At this time, the design basis and condition of the isotope warehouse, built l in 1962, has not been fully assessed regarding its ability to protect stored source material. Source material contained in a certified shipping cask would potentially resist the collapse of the one story warehouse building. The onlv record found to exist for this 1962 addition that also modified the area  !

identified as the air lock was located in the public records maintained by the 1 City of Cleveland. These records were related to the issuance of the building I permit for the modification and addition. The record consists of a single i drawing providing some information on the addition. The structure is a  !

combination of structural steel columns, structural steel beams, open-web bar '

( joists, and load-bearing concrete block masonry walls. The drawing provides the geometry of the facility and the necessary details for the steel elements, but provides no information on the load-bearing concrete block walls regarding the block type, reinforcing and other construction details. No information l was found relative to the original design criteria for this addition.

6. Backaround on Subsurface Drainaae Another known condition that the facility has been subjected to is an artificially high water level outside the basement of the facility as a result of the deliberate closure of the combined sanitary and stormwater sewer system at the lateral discharge point into the public sanitary district mainline.

This resulted in the eventual backup flooding of the basement to a depth of over four feet with a portion of the initial quantity of water entering through an open 32-inch high standpipe and the remainder apparently entering via seepage paths.

During the period when the basement of the facility was covered with water as a result of the non-functioning subsurface drainage system, an inspection was performed on February 2, 1995. The main focus was the integrity of the basement floor slab under the uplift forces created by the differential water head between the inside and outside of the basement. Once the initial charge of water was introduced through a 32-inch high open standpipe, the water level in the basement continued to rise based on the head differential to the 10 e

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outside of the basement. No specific leakage paths had been found, but

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i indications of some cracks in the floor slab had been noted through the water.

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l-It was. not possible to determine whether the cracks we e new cracks or old-cracks that may have opened some additional amount as a result of the uplift '

pressure loads. During this time period some restrictions were placed on the diffe.rential water pressure to minimize the uplift on the floor slab. The

differential pressure could be controlled by pumping the basement water into i

! storage tanks.  !

In a letter dated March 22, 1995, AMS addressed,- in Item #3, the re-connection  !

' of the foundation underdrain system to a new manhole and lateral and then to  !

the main sewer line. As a result of issues raised related to this subject, I j NRC sent a letter to AMS dated June 14, 1995. The AMS response was contained l 1

in a letter that was discussed on a telephone conference call on July 18, 1995 l between NRC and AMS. At the time of that telephone conference call, AMS had

! made a sketch available to NRC, that presented in plan view, the status of the j work at the facility as of July 18, 1995. It was indicated on the sketch that the excavation and removal of the foundation drainage system perforated clay

tile in front of the facility had been completed and a new PVC perforated j drainage pipe had been completed in that same location. This system discharged in a new connector line to the new manhole. As of July 18, 1995, i

the new manhole had not been connected to the NE0RSD mainline and no outfall or discharge was available from the new manhole. It was noted that the wye l connection between the piping of the foundation drainage system and the 4-inch 3 diameter sanitary sewer line coming from the building under the east wall footing as shown on the drawings was not found. The 4-inch diameter sanitary 1 (\ line had been cut and apparently the cut upstream end grouted closed. The sketch indicated the same work had been completed around the SE corner of the l

4 facility and along the south wall to near the re-entrant corner at the south

stairwell. The open end of the new foundation drain pipe during the
construction process was shown at the end of the backfilled zone of the
excavated trench. The open excavation of the trench continued around the i perimeter of the building and around the SE corner of the rear stairwell
toward the SW corner of the building. The open trench extended only partially along the south wall of the stairwell since AMS had decided not to excavate in the vicinity of the source garden that is directly inside the basement walls at the SW corner of the 1958 building. In this region the sketch indicated that the existing foundation drain would be abandoned and a slurry wall installed around the abandoned pipe and the unexcavated soil mass. The slurry wall would continue around the SW corner of the building and past the northern extent of the source garden along the west wall and be continued to an area under the airlock slab and end adjacent to the west wall of the basement. The base of the slurry wall was to be cut into the very impervious shale material into which the building footings were founded. An impervious membrane cover was shown on the sketch that would then be attached to the exterior wall of the building and extended over the soil mass inside the slurry wall and then carried down to the top of the slurry wall and over its outside top corner so as to "shed" all precipitation outside the encircled volume. The new foundation drainage system would then be extended around the outside of the slurry wall. The remainder of the excavated trench was shown on the sketch as beginning against the west wall at a point just north of the northern extent of the source garden and the gas meter cover shed and continuing under the air 11 F a

i lock structure. It was also noted on the sketch that the existing foundation

'( drainage pipe on the west side in this area had been removed and a tee connection had been found with a 4-inch sanitary pipe that penetrated the west wall footing and flowed to the east, under the basement floor. It was noted that the 4-inch diameter line at the outflow end of the tee from the old foundation perimeter drain (upstream end of 4-inch line going through the footing) was to be grouted closed.

i

7. Field Observations of Reconstructed Subsurface Drainage Upon arrival at the site on the morning of July 19, 1995, the status of ,

, construction was as had been indicated in the sketch of July 18, 1995, except for the work that was underway that morning. Some additional trenching along the west wall, representing the trench for the slurry wall as it curved away from the northwest corner of the source garden area and the gas meter cover shed extending to the SW corner of the building, had been completed that morning. Work was underway in the trench by AMS contractors related to testing for contamination of soil / gravel and foundation material samples in the area along the west wall and under the airlock where the old existing foundation drainage system had ended and where the old foundation drain pipe had been removed. ,

On July 20, 1995, an AMS letter, dated July 19, 1995, was hand delivered at the site to an NRC inspector that summarized the July 18, 1995, telephone conference call and provided the status of the site as of July 18, 1995. AMS indicated that the 4-inch line the foundation drain system discharged into at

( the west wall would be grouted closed throughout the entire length (all under the beilding from the rear west wall to the front east wall). The material to be used in the pipe grouting procedure was identified in Attachment 2 of the submittal as AV-118 Duriflex, made by Avanti International, that is an acrylic resin based chemical grout. It is transferred to the grout location in a water solution prior to the time of catalyst reaction to form the gel state.

Included with the letter as Attachment I was the sketch of the plan view that had been the subject of the July 18, 1995, telephone conference call. In addition, Attachment 3 presented a cross-section view through the proposed reconstruction zone ~ adjacent to the source garden. This indicated a slurry

! wall was to be formed on one side that would be 6-inches thick and approximately 4-feet high within a 30-inch wide trench with no indication at what elevation the wall would begin or end with respect to the building -

footings except to indicate a bottom depth of 15-feet. The wall was apparently to be constructed with a grout material that had been recommended by the NE0RSD in a July 3,1995, letter to AMS. The grout would be a 50/50 cementitious material of Type I cement / Class F flyash with a local sand using an intrusion aid additive under the trade name of Hearl Foam. The grout formulation was to produce a 500 psi minimum strength material. The new 4-inch diameter perforated PVC foundation drainage system pipe was shown with gravel backfill, topped with a geotextile to act as a filter for the retention of fined-grained trench backfill soil material. A 20-mil geomembrane to perform as an impervious membrane was indicated for placement on the ground 4

surface with a 6-inch thick free draining protective material topping.

12 4

1

AMS provided technical information from the manufacturers of the two grouting

( materials in the July 19, 1995 letter and an NRC inspector, after a review of the submitted information, concluded that if used properly, the materials should perform as intended by the consultants in this application.

As work continued on July 20, 1995, to complete the excavation of the trench for the slurry wall around the SW corner of the building at a distance outside the south wall of the stairwell and to the intersection with the trench extended from alongside the east wall of the stairway, the AMS contractors discussed how the formed slurry wall would be constructed. The AMS site personnel and the contractors then proposed the construction of the wall without forming and placing normal ready-mix concrete into the full trench width, thus avoiding any formwork except for bulkheads in the trench at the end of wall placements, therefore, avoiding placement of personnel in the deep trench. The 4-inch diameter foundation drain pipe would then be placed in another trench excavated outside the slurry wall after the wall has been constructed. NRC inspectors agreed that this proposal was an acceptable alternative to the approach presented in the July 19, 1995, letter. A revised Attachment 3 to the letter was provided to the inspectors at the site on July 20, 1995.

On July 21, 1995, work on the construction of the slurry wall continued in the morning while the inspectors were on site. It was pointed out by the ,

inspectors that the loose shale material left in the bottom of the trench would prevent obtaining a " good seal" for water cutoff at the bottom of the slurry wall and the shale material. The AMS personnel and the contractors

{ were informed of this observation so that corrective action could be taken prior to the placement of the concrete wall.

Since there was no direct observation of the backfi[ ling of the foundation perimeter drainage system, discussions with AMS and the contractors indicated that no geotextile filter cloth was utilized along any of the new drainpipe and there was no placement of new, controlled gradation gravel around the foundation perimeter drainage system. Over the long term, it will be prudent to monitor the discharge from this system into the new manhole during periods where there is water infiltration into the ground and flow in the system in order to assure that migration of fines with clogging of the foundation drainage system does not occur.

8. Conclusions and Recommendations As a result of the review, inspection and evaluation activities, it is concluded that the subsurface drainage conditions that resulted from the j action to block the combined storm and sanitary systems, had no significant {

impact on the structural integrity of the 1958 built facility. While the '

structural integrity of the 1958 building system is probably at this time sufficient to withstand the original design loads (which apparently did not include any significant lateral loads), the building's waterproof envelope is not at this time intact as a result of the cracking and open joints in the building's exterior. This can lead to more rapid degradation rates of the  !

structural system than would be expected if the waterproof envelope were 13

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intact. The cracked bearing wall and the ruptured inside of a curtain wall

( section with the resulting outside distress that was induced, leaves the ends of the east (front) wall vulnerable to more rapid degradation with the entrance of water and freezing temperatures. Loss of the bearing wall which '

supports the roof system in the vicinity of the HEPA filter room could impact that contaminated enclosure on the second floor level. Loss of the curtain wall would not have any impact on radioactive material storage areas or contaminated areas. The hot cell,' the WHUT room, the original radiography room, the source garden and the front and back basements, and the HEPA filter room, except as noted above, should maintain their structural integrity relative to the original design conditions. It is recommended that if these structural elements are to be relied on in the future, that an inspection and ,

evaluation program be put into place. An interval of no more than ten years ,

between structural integrity inspections / evaluations and after major loading events should be provided for in the program.

Based on the distress that has been identified from limited visual inspection that focussed on obvious areas needing an evaluation, it is likely  !

that the structure has undergone a loading event outside the original design i envelope. This has left isolated portions of the building in a damaged i condition. Action needs to be taken to restore the building's waterproof envelope that is violated in the damaged areas and restore the local integrity of the structural system.

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The replacement of the subsurface drainage system based on the observations I made by an NRC inspector and the information provided by the licensee, appears

( to be acceptable, but until a new connection is made to the public sewer system, the drainage system will not function without active pumping.

Without additional investigation and evaluation by the licensee, including -

repairs of the areas of distress discussed in this report, one could not i conclude that the facility would remain intact for an additional 25 years.

Without repairs it is likely that sections of the exterior curtain wall could collapse due to degrading conditions. It is recommended that an assessment of the structural integrity of the facility be made by the licensee prior to the development of any repair program to address the distressed areas observed in this inspection so that if additional areas of distress are discovered they can be considered, if necessary, for incorporation to the repair program. The precast concrete roof panels in several areas exhibit corrosion products on the visible surfaces indicating the attack of the .

embedded reinforcing steel. Also a closer examination of the area of the underside of the second floor concrete slab in the area of the original radiography laboratory should be undertaken.

A loading condition that departs from the design conditions, such as may have occurred in the past, could also cause damage that could be considered to raise the level of concern about the structural integrity of the facility since the damage may be clearly visible. It should be noted that it may also become necessary to consider new loading conditions if the useful life is to be extended or credible events for the emergency plan are outside the original design envelope of the structures.

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APPENDIX A i!(

REFERENCE DESIGN DRAWINGS d

1958 Building

1. SD-1, Site Development Plan
2. F-1, Foundation Plan and Details
3. A-7, Elevations
4. A-10, Wall Sections 3-3 Thru 6-6
5. S-1, Roof Steel Framing Plan
6. S-2, Second Floor Steel Framing Plan
7. P-2, First and Second Floor Plumbing
8. P-3, First Floor Toilets, Showers and Riser Diagrams 1963 Building
9. F-1, Foundation Plan

{

10. S-1, Roof Framing Plan -
11. S-2, Second Floor Framing Plan 15

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i CONSTRUCTION SEQUENCE APPENDIX B f AMS FACILITY

, 1020 LONDON ROAD l CLEVELAND, OHIO December 15, 1995 CITY OF CLEVELAND DATE AMS CONTRACT PROJECT DESCRIPTION BLDG PERMIT NUMBER ,

NUM8ER J45739 3/24/58 635 Demolition of Frame Office Bldg J46366 4/18/58 635 Phase I-Addition to Existing Brick and Block Warehouse ,

(The 1958 Building) .

678 Completion of 2nd Floor (The 1958 8uilding)

K30250 5/4/62 Addition to Office and Lab of One Story L-Shaped Storage Bldg, 82'x 32.25' and 38'x 18' (Isotope Warehouse)

X40211 4/22/63 801 Phase II-Addition of Classrooms (The 1963 Building) 846 Office Remodelling L2485 5/12/67 Oae Story Masonry Storage Bldg, 16'x 16' (Small add-on by Truck Bay)

L28739 3/26/70 Addition for Storage i

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