ML20134H043
| ML20134H043 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1994 |
| From: | Berson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Cordes J, Crockett S, Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20127A948 | List: |
| References | |
| FOIA-96-444 NUDOCS 9702110131 | |
| Download: ML20134H043 (11) | |
Text
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From Bruce A. Berson (BAB1)jfl9 _
To: d///f JAG. JFC. SFC. WLA Date Friday. December 2. 1994 M /
12:36 pm h ,O4C.8bO C6 C, M/
BOA /CAJG/Lf I spoke to the AMS attorney. He will not be filing a Touhy request for the $
December 9 hearing. He may at a later date. ^
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l 9d 9702110131 970129 PDR FOIA ENGLISH96-444 ,PDR
.)
d December 6, 1994 l
Advanced Medical Systems, Inc.
ATTN: Mr. David Cesar, Treasurer 1020 London Road Cleveland, Ohio 44110
SUBJECT:
RESULTS OF NRC RADIOLOGICAL SURVEY AND SAMPLE ANALYSIS OF THE ADVANCED MEDICAL SYSTEMS, INC. (ANS) WASTE WATER PIPING l AND ITS OUTFALL INTO THE CITY OF CLEVELAND SEWER -(REPORT NO. 030-16055/94003(DRSS))
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Dear Mr. Cesar:
. This refers to the special inspection conducted by Messrs. Michael Kurth and
! Edward Kulzer of this office from August 17 through October 14, 1994. The special inspection was conducted to examine the radiological conditions of waste water exiting your facility through your waste water piping and into the City of Cleveland sewers in the vicinity of the sewage outfall from your facility. The inspection was prompted by the identification of exposure rates above background in the City of Cleveland sewer at the Advanced Medical Systems, Inc. (AMS) outfall. The results of this inspection were discussed with you at the conclusion of the inspection.
As described in the enclosed report, extensive radiation surveys and sampling of solid and liquid materials were conducted identifying cobalt-60 in the solid sediment from the city sewers and your waste water piping. Also, cobalt-60 was being carried in the waste water from the AMS cutfall into the l
city sewers. This appears to represent a violation of 10 CFR 20.2003 which permits only the discharge of soluble material or readily dispersible biological material in water. The cobalt-60 emanating from your lateral is neither soluble or readily dispersible biological material. ;
We plan to meet with you in the near future to discuss these inspection !
L findings. We will contact you at a later date to schedule this meeting. !
Following' our meeting, a decision will be made on the appropriate enforcement action regarding the apparent violation. As such, no Notice of Violation is being issued at this time. While no Notice is being issued and no written :
response is required, we expect that prompt action has been or will be taken to correct this apparent violation.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of !
this letter'and the enclosed inspection report will be placed in the NRC I Public Document Room.
i OPTIONAL FORM 99 (7W) e i FAX TR ANSMITT AL e oi mo > M
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gQ NSN 7540-41-317-7368 6099-101 Gl.NERAL $lRVICES ADMINiblHAllON hha OO'D ' 3 pps - - -. - -.
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Mr. David Cesar 1 l
We will gladly discuss any questions you have concerning this inspection. i l
Sincerely, ;
Original Signed By R. J. Caniano for W. L. Axelson, Director Division of Radiation Safety and Safeguards License No. 34-19089-01 -
I Docket No. 030-16055
Enclosure:
Inspection Report No.
030-16055/94003(DRSS) .
cc w/ enc 1: NE0RSD City of Cleveland i bec w/ enc 1: J. Turdici, OED0 ;
J. T. Greeves, HMSS '
E. W. Brach, NMSS J. H. Austin, NMSS T. C. Johnson, NMSS
, M. Nalluswami, NMSS C. G. Jones, NMSS R. L. Fonner, OGC PUBLIC (IE07) l 4
V DOCUMENT NAME: B:\AMS94003. DSS
- Concurrence via e-mail See Previous Concurrences q To escoive e copy of this document,6ndicate in the boa: 'C' s Copy without ettechment/ enclosure
- E* = Copy with ettschmer.1/ enclosure *N* a No copy 0FFICE RIII RIII RIII RIII l RIII RIII
- NAME Kurth Kulzer Slawinski Madera Grobe Shear DATE 12/ /94 12/ /94 12/ /94 12/ /94 12/ /94 12f /94
'FICE RIII NMSS
- DWM
- RIII O /
sME Berson Paperiello Knapp Chandler Axelson/;/f/A llDATE 12/ /94 12/ /94 12/ /94 12/ /94 12/ 6 (94 ~
[, .
i Advanced Medical Systems, Inc. 2 We will gladly discuss any questions you have concerning this inspection.
Sincerely, .
W. L. Axelson, Director Division of Radiation Safety and Safeguards License No. 34-19089-01 Docket No. 030-16055 l
Enclosure:
Inspection Report .
No. 030-16055
/94003(DRSS) cc w/ enc 1: NE0RSD ,
City of Cleveland I bec w/ enc 1: J. Turdici, OED0 I J. T. Greeves, NMSS l E. W. Brach, NMSS J. H. Austin, NHSS T. C. Johnson, NMSS M. Nalluswami, NMSS ,
C. G. Jones, NMSS R. L. Fonner, 0GC PUBLIC (IE07) 1 DOCUMENT NAME: B:\AMS3.ltr
- Concurrence via e-mail u ........ .... ... . m:.e . c.,, ~ .., ~ ,,.. . c . c.,, s. n ,.o. . . . u.....
OFFICE RIII R P E RIII M E RIII,A 6 RIII ,v/il6 RIII ,,glC RIII lW NAME Kurth KulzePd \,51aWski '
Made @ Grobd-.O Shhar AS TE 12/Js /94 12/5 /94 L12/ f /94 312/ 6 //94 12/ 6 /94 12/ 6 /94 0FFICE RIIIb) 6 NMSS/) W DWM (' Ki . * +0GC(M
- RIII OC(M 6 NAME BersW Papediello Knapp W 9 % Chandle d Agelson Lew'e .~_
DATE 12/ -4 /94 12/ t /94 12/ \'/9% fl!/ 7W94,712/ /94 # (Wa y y J ,r ypr
U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 030-16055/94003(DRSS)
License No. 34-19089-01 Organization: Advanced Medical Systems, Inc. (AMS) 1020 London Road Cleveland, Ohio Inspection At: City of Cleveland sewer interceptor (sewer interceptor)
Intersection of sewer interceptor under London Road, upstream and downstream manholes, and the AMS manhole Cleveland, Ohio Inspection Conducted: August 17 through October 14, 1994 Inspectors: _.Michbel Kurth tM th Dats I Radiation Sp ialist 3
Edwa'rd Kulzer bS 0 I $!W Dat'e' Radiation Specialist Reviewed b'y:
hn R. Madera, Chief fr)6Ye4 3 Date' '
aterials Licensing Section
/
Approved by: 17/ 44-
/fohn A. Grobe, Chief Datef /
VNuclear Materials Inspection Section 2 L Insoection Summary Inspection on Auaust 17 throuah October 14. 1994 (Report No. 030-16055 194003(DRSS))
Areas Inspected: This was a special inspection conducted to perform surveys '
of the City of Cleveland sewer interceptor in the location of the AMS facility, Cleveland, Ohio, and in the AMS manhole. The inspection was prompted by the identification of elevated exposure rates on the sewet interceptor surface below the AMS lateral in July 1994. Samples of sewer ,
l debris, water effluent, and a series of wipes were collected for analyses. ~
Results: The NRC inspectors, accompanied by the Northeast Ohio Regional Sewer District (NE0RSD), and NE0RSD contractors, B. Koh & Associates, Inc.,
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O identified four areas of elevated exposure rates. These areas are located:
(1) below the intarsection of the sewer interceptor and the AMS lateral; (2) within the processing drain line in the AMS sewer; (3) within the sanitary inlet into the AMS manhole; and (4).within the sanitary outlet from the AMS manhole into the sewer interceptor. The preliminary results of the sewer debris and wipe test analysis from the August 17, 1994 sampling identified positive cobalt-60 surface contamination levels ranging from 457 disintegrations per minute per 100 cm' (dpm/100 cm*) to 2.7 x 10' dpm/100 cm',
partial levels which exceed the 1,000 dpm/100 cm' limit found in NRC's guidance document, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Sources, or Special Nuclear Materials," dated August 1987. Also, between July 5 and October 10, 1994, cobalt-60 was identified, by the NRC and the NE0RSD, in the water effluent discharged from the AMS lateral into the sewer interceptor. The September 20, 1994 sampling analysis verified prior indications of cobalt-60 contamination. However, further water discharge samples taken from the location on September 20 and October 4,1994, did not identify the presence of cobalt-60.
One apparent violation was identified:
Apparent failure to dispose of licensed material into the sanitary sewerage system that is readily soluble or is readily dispersible biological material in water is an apparent violation of 10 CFR 20.2003, which has been a requirement for this licensee since January 1,1994 (Section 3. B. of this report).
Also, given that cobalt-60, which is not considered to be readily soluble or readily dispersible biological material in water, was identified in effluent discharged from the AMS lateral and, that cobalt-60 was deemed to be removable within the AMS lateral through the conduct of wipe sampling, the probability exists that future effluent discharges may develop into the disposal of licensed material into the sanitary sewerage system.
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DETAILS l
- 1. Persons Contacted Thomas Lenhart, Assistant General Counsel, NE0RSD !
- Lawrence English, Assistant General Counsel, NE0RSD ;
- Richard Connelly, Manager Water Quality, NE0RSD !
'* Len Jufko, NE0RSD '
- William Kasberg, net'4SD" '
- Theodore Adams, Vict President, B. Koh & Associates, Inc. !'
- 9 David Cesar, Treasu ar, Advanced Medical Systems, Inc. (AMS) 9 Joseph Michuta, P. dlation Safety Officer, AMS l 9 Robert Neschter, Senior Radiation Technician, AMS 9 Vincent Rocco, Radiation Technician, AMS
- Denotas those present at interceptor sewer survey conducted August 17, ,
and September 20, 1994.
90enotec those present at the sewer survey conducted September 20, 1994.
- Denotes those present during the exit interview conducted by telephone on October 14, 1994. I
- 2. Backaround l A. General History t
In 1959, the Atomic Energy Commission issued License No. 34-07225-09 to Picker X-Ray Corporation (Picker Corp.), for the operation of an '
isotope manufacturing facility located at 1020 London Road, Cleveland, Ohio. The Picker Corp. license authorized passession of ;
150,000 curies of cobalt-60 and 3,000 curies of iridism-192 in l solid metal form, and 40,000 curies and 100 curies of cesium-137 and thulium-170 respectively, as sealed sources. These licensed materials were authorized for: (1) processing incident to redistribution to authorized recipients; (2) radiation effects studies; and (3) research and development. The principal operation i
-conducted under this license was the manufacture of cobalt-60 sealed sources for medical teletherapy and industrial radiography units, and subsequent distribution of the sources to authorized recipients throughout the world.
In 1979, the Picker Corp. London Road facility was purchased by Advanced Medical Systems, Inc. (AMS). License No. 34-07225-09 was terminated on November 9, 1979, at which time all licensed material possessed was transferred to AMS.
The NRC issued License No. 34-19089-01 to AMS on November 2, 1979.
At this time, the licensed operations, facilities and equipment previously owned and operated by the Picker Corp. were assumed by AMS.
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l' l Both operations had released cobalt-60 through the London Road facility lateral into the sanitary sewer under the provisions of j 10 CFR 20.303, " Disposal by Release into Sanitary Sewerage Systems," which was in effect through December 31, 1993.- The NRC inspection in 1988 confirmed cobalt-60 contamination in the AMS
, sewer manhole on AMS property. At that time the radiation level ranged as high as 70 mil 11 roentgen per hour (mR/hr) at the bottom of the manhole adjacent to the discharge pipe from the AMS building. The contaminated area was partially decontaminated and i covered with a layer of concrete by the licensee. In May 1989, as stated in the NRC Inspection Report No. 030-16055/93002(DRSS),AMS discontinued the discharge of licensed' material into the sanitary sewerage system. Also, AMS has not generated liquid waste for several years due to changes in its decontamination methods'and l
! termination of source manufacturing operations. ,,
l i Beginning January 1,1994, NRC licensees were required to comply with the revised 10 CFR Part 20, which contains more restrictive requirements for sanitary sewer disposal of liquid radioactive waste than previously existed.
The revised 10 CFR 20 specifies, in part, in 20.2003, " Disposal by i Release into Sanitary Sewerage," that licensees may discharge l licensed material into the sanitary sewerage system only if the !
l material is readily soluble or is readily dispersible biological l material in water. j In 1993, as documented in NRC Inspection Report No. 999-90003
/93010(DRSS), an NRC inspector measured the exposure rates in the downstream manhole from the AMS facility in the London Road sewer interceptor. No detectable radiation exposure rates above background were identified. The location where the elevated exposure rate was identified in July 1994 by the NE0RSD was inaccessible at the time of the 1993 NRC inspection and the NRC was unaware, in 1993, of the manhole's existence.
B. Specific History Promotina this Soecial Inspection On July 5, 1994, surveys were conducted by the Northeast Ohio Regional Sewer District (NE0RSD) contractors, B. Koh & Associates,
- Inc., along the City of Cleveland's interceptor sewer (interceptor sewer) in an area connecting with the AMS lateral under London Road. Elevated exposure rate readings were identified below the AMS lateral on the sewer interceptor brick and iron rungs. The NE0RSD reported that the radiation exposure rate measured was approximately 7 mR/hr on contact. Residue deposits on the sewer interceptor brick and iron rungs below the AMS lateral were collected, resulting in the identification of cobalt-60 contamination ranging from 0.084 to 0.12 microcuries per gram.
Also, during the performance of the surveys, the NE0RSD di.scovered a manhole directly above the AMS lateral / sewer interceptor i
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- l intersection which was buried below the London Road surface. The NE0RSD has since raised the level of the manhole to the street surface.
Attachment No. I of this report illustrates the pathway and proximity of the AMS lateral in relation to the AMS facility. The approximate length of the lateral from the AMS manhole to the sewer interceptor is 40 feet (12 m). The lateral is made of 4 to 5 foot (122-152 cm) long sections of precast clay / ceramic piping butted together forming the lateral. The lateral is approximately 18 inches (46 cm) in diameter. Attachment No. 2 contains a photograph of the AMS lateral protruding into the City of Cleveland sewer interceptor (sewer interceptor). The sewer l interceptor is approximately 5 feet (1.5 m) in diameter and flows l to the Easterly Wastewater Treatment Plant. ;
- 3. Survey and Samole Analysis Results A. Survey Results .
On August 17 and September 20, 1994, the NRC inspectors, l accompanied by NE0RSD personnel and NE0RSD contractors, conducted a series of surveys in the sewer interceptor outside of the AMS facility under London Road. During those surveys there was a ,
significant flow rate of waste water emanating from the AMS '
lateral'into the interceptor. An assessment of the waste water ;
flow rates is contained in NRC Inspection Report No. 030-16055
/94004(DRSS) issued November 29, 1994. Also, on September 20, 1994, surveys were conducted in both manholes immediately upstream and downstream from the AMS facility along London Road, and in the AMS manhole. The survey instruments used were a Ludlum Model 19 ,
Micro R Meter, NRC Tag No. 014808, a Ludium Model 12 Count Ratemeter with attached pancake probe, NRC Tag No. 047068, a
'Bicron MicroRem, Serial No. B709J, and a 'Ludlum Medel No. 2221 Scaler Ratemeter (No Serial No. available) with attached pancake probe.
The background exposure rate measured at the London Road street surface above the AMS lateral / sewer interceptor intersection was 12 'microroentgen per hour ( R/hr). The surveys conducted in the sewer interceptor demonstrated elevated exposure rate readings.
A sewer interceptor surface area approximately 1.5 feet (46 cm) by 3 feet (91 cm) located directly below the AMS lateral showed l
elevated readings averaging 1.0 to 10 mR/hr on contact with the sewer interceptor brick. Attachment No. 2 of this report
'This instrument is owned and maintained by B. Koh & Associates, Inc.
'This instrument is owned and maintained by B. Koh & Associates,,Inc.
' Assume that I roentgen u 1 Rem.
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l illustrates the location of the elevated exposure rates in the sewer interceptor. One spot was identified between the iron rungs on the sewer interceptor brick sur' ace showing an exposure rate ranging from 20 to 25 mR/hr on contact. Also, a spot was identified on the rung below the AMS lateral showing an elevated exposure rate of 14 mR/hr on contact. An average exposure rate of 0.5 mR/hr was identified both 3 feet (91 cm) upstream and downstream from the AMS lateral in the center of the sewer interceptor. Also, an exposure rate ranging from 1.5 to 2.0 mR/hr was identified in the center of the sewer interceptor directly across (approximately 61 cm) from the elevated area below the AMS lateral. Attachment No. 3 of this report contains several j photographs of the sewer interceptor wall in the area of the AMS ;
lateral . j Surveys conducted of the first manholes immediately upstream and downstream from the AMS facility identified exposure rates ranging from 5 to 9 pR/hr on the surface of London Road next to the ;
i manholes. Exposure rates ranging from 14 to 19.5 pR/hr (includes !
l the background rate) were identified in the center of the sewer l interceptor and on contact with the interceptor brick in both l manholes. The slightly elevated exposure rates were attributed to ;
naturally occurring radioactive materials (NORM) in the sewer brick. (NORM, such as potassium-40, radium-226, and thorium-232, )
are found in very small quantities in brick.)
Elevated exposure rates were identified in the AMS manhole. ;
Exposure rates ranging from 2 to 3 mR/hr were identified, on '
contact, approximately 2 to 4 inches (5 to 10 cm) into the processing drain line, and the sanitary inlet and outlet in the l AMS manhole. A survey instrument was lowered into the AMS manhole demonstrating exposure rates of 0.5 to 1.0 mR/hr in the center of the AMS manhole.
B. Samolina Analysis Results On July 5,1994, the NE0RSD collected three sediment samples from the sewer interceptor in the location of the AMS lateral outfall.
Also, a water effluent sample was collected from waste water discharging from the AMS lateral. The analytical results of the l sediment samples identified positive cobalt-60 concentrations
! ranging from 0.084 to 0.12 microcuries per gram. The result of l the water sample identified a positive cobalt-60 concentration of 29 picocuries per liter (pCi/1).
The NRC collected numerous smears, sewage residues, and water samples on August 17 and September 20, 1994. Table No. 1 identifies the locations and analytical results of the smear and sewage residue samples collected on August 17, 1994. The samples i
were analyzed using the NRC Region III gamma spectroscopy, system.
. On August 17, 1994, a total 4 smears and 4 sewage residue samples i were collected.
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i As illustrated in Table No.1, the analysis of the sewage residue samples demonstrated cobalt-60 contamination ranging 'from 4.29 to 1,230 nanocuries. Two of the 4 smears collected identified cobalt-60 contamination ran disintegrations per 100 co'ging from 2,750 toEach 103,840 smear collected was assumed to cover a 100(dcu'ps/100 cm').
area. The acceptable surface contamination level for removable cobalt-60 is 1,000 dpm/100 cm', !
as stated in the NRC document, " Guidelines for Decontamination of l Facilities and Equipment Prior to Release for Unrestricted Use or i Termination of Licenses for Byproduct, Source, or Special Nuclear !
Material," dated August 1987, which is included as Attachment i No. 4 of this report. The water effluent sample collected !
demonstrated positive indications of cobalt-60 contamination of i 35 picocuries per liter (pci/1). :
Table No. 2 identifies the locations and analytical results of the l NRC smears collected on September 20, 1994. As illustrated in 4 Table No. 2, a smear result of 16,852 dpe/100 cu' removable cobalt-60 contamination was identified on the sewer interceptor wall below the AMS lateral. ;
On September 20, 1994, smears were also collected from the sewer interceptor walls in the areas of the first sewer interceptor :
manholes immediately upstream and downstream from the AMS facility !
along London Road, and the AMS manhole. As illustrated in Table !
No. 2, general smears of the sewer interceptor walls from the sewe* interceptor manholes located immediately upstream and ;
downstream from the AMS facility along London Road did not- '
identify removable cobalt-60 contamination. There was however, a
- surface contamination level of 97 dpm/100 cm' which was identified in the AMS manhole on the AMS lateral exiting into the sewer interceptor.
Table No. 3 identifies the dates, locations, and analytical results of the water effluent collected by the NRC and the NE0RSD.
As illustrated in Table No. 3, water effluent samples taken from the upstream and downstream manholes, and from the AMS manhole, did not demonstrate positive indications of cobalt-60. However, water effluent collected from the outfall of the AMS lateral into the sewer interceptor on July 5, August 17, September 28, October 1, and October 10, 1994, demonstrated positive concentrations of cobalt-60 ranging from 13 to 306 pCi/1. Given that removable cobalt-60 was identified on the surface of the AMS lateral. it appears that the water effluent flowina throuah the AMS lateral slouahed the cobalt-60 from the lateral causina the release of l licensed material into the sanitary seweraae system. The i discharae of licensed material. cobalt-60. which is not readily l soluble or is readily dispersible bioloaical material in water into the sanitary seweraae system is an apparent violation of i
10 CFR 20.2003 which has been a reauirement for this licensee since January 1. 1994.
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One apparent violation of NRC requirements was identified.
- 4. Exit Meetina During the performance of surveys and sample collecting, the preliminary findings were provided to those individuals present during the August 17 and September 20, 1994, on-site inspections, as identified in Section 1 of this report. A summary of the areas surveyed and the forthcoming letter were discussed. Also, on October 14, 1994, the results of this
! inspection were discussed in a telephone conversation between Mr. Cesar l and Mr. Cantano. The AMS and NE0RSD employees did not identify any l
information provided during the inspection as proprietary.
I Attachments: 1. Illustration of pathway of AMS lateral into sewer interceptor
- 2. Diagram of sewer interceptor
- 3. Series of photographs of sewer i
- 4. Guideline for the Decontamination of Facilities pnd Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source,or Special Nuclear Material t
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I TABLE NO. I NRC SEWER SAMPLE RESULTS SEWER SAMPLES FROM THE CITY OF CLEVELAND INTERCEPTOR IN THE IMMEDIATE AREA 0F THE AMS LATERAL ON LONDON RD SAMPLES TAKEN AUGUST 17, 1994 SAMPLE LOCATION '2a RESULT
- 1. Debris and sludge from left (upstream) of '4,290 pCi
- 32 pCi rungs below the AMS lateral
- 2. Black debris off of top rung below the AMS '434,000 pCi lateral 3,000 pCi
- 3. Black debris off of brick wall below the AMS '1,230,000 pCi
- lateral 7,000 pCi
- 4. Red debris off of rung above the AMS lateral '1,630 20 pCi
- 5. a. Smear: Rung immediately below the /MS less than 41 'dpm lateral
- 5. b. Smear: NE0RSD Sewer wall (sewer brick) 103,84i' @m
- 167 below the AMS lateral dpm l
- 5. c. Smear: NE0RSD Sewer wall (sewer brick) 2,750 dpm 52 dpm above the AMS lateral
- 5. d. Smear: Inside the AMS lateral 457 dpm i 138 dpm
- Note: The reported uncertainty refers only to counting statistics.
' Note: Additional analysis error will be introduced due to the unique geometry associated with the debris. The geometry error is estimated to be less than 10 percent.
' Note: disintegration per minute - dpm. Also, each smear result is estimated to be averaged over a 100 cm' area.
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TABLE NO. 2 NRC SMEAR RESULTS ;
SEWER SAMPLES FROM THE CITY OF CLEVELAND SEWER INTERCEPT 0R j IN THE AREA 0F THE ANS FACILITY ON LONDON ROAD '
i AND THE AMS SEWER !
SAMPLES TAKEN SEPTEMBER 20, 1994 i LOCATION RESULT * '2a 1 Smear: Iron Rung Directly Below the AMS '717
- 17 dpm i Lateral 2 Smear: Sewer Interceptor Brick Directly Below 16,852
- 264 dpm l the AMS Lateral (between lateral and I" rung 3 Smear: Sewer Interceptor Brick Directly Above < 16 dpm l the AMS Lateral j 4 Smear: Approximately 1 foot inside the AMS 56
- 4 dpm )
Lateral between the positions of 12:00 l and 3:00 5 Smear: Outer Surface of the AMS Lateral < 23 dpm between the positions of 12:00 and 3:00 j 6 Skipped No. 6 7 Smear: Outer Surface of the AMS Lateral at the 490 143 dpm 6:00 position 8 Smear: Inside the AMS Lateral Approximately 1 161 7 dpm foot at the 5:00 position (as close to water line as possible) 9 Smear: General' Wipe of Upstream Sewer < 13 dpm Interceptor 10 Smear: General Wipe of Downstream Sewer < 14 dpm Interceptor 11 Smear: AMS Sewer- Floor of AMS Sewer < 13 dpm 12 Smear: AMS Sewer- Outlet from Processing Drain < 16 dpm (East Drain near waterline) 13 Smear: AMS Sewer- General Wipe of Sewer Wall < 22 dpm 14 Smear: AMS Sewer- South Inlet to Manhole (near < 23 dpm waterline) ,
i 15 Smear: AMS Sewer- AMS Sewer Outlet to 97 i 6 dpm l Interceptor (near waterline) -
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' Note: . The reported uncertainty refers only. to counting statistics.
' Note: Disintegrations per minute - dps. Also, each result is estimated to l averaged over a 100 cm' area. '
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TABLE NO. 3 NRC AND THE NE0RSD WATER EFFLUENT SAMPLE RESULTS I SAMPLE DATE COLLECTED - LOCATION RESULT i '2cr 1 NE0RSD July 5,1994 - AMS lateral outflow to 29 pCi/l !
sewer interceptor 1 8
2 NRC August 17, 1994 - AMS lateral outflow 35 pCi/l !
to sewer interceptor 0.4 pCi/l 3 NE0RSD August 17, 1994 - AMS lateral outflow 33 pC1/1 to sewer interceptor 4 NRC September 20, 1994 - AMS lateral '
< 10.3 outflow to sewer interceptor pCi/l 5 NE0RSD September 20, 1994 - AMS lateral '
< 20 pC1/1 outflow to sewer interceptor 6 NRC September 20, 1994 - AMS manhole < 9.3 pCi/l 7 NRC September 20, 1994 - Upstream manhole < 8.9 pCi/l 8 NRC September 20, 1994 - Downstream < 9.1 pCi/l manhole 9 NE0RSD September 28, 1994 - AMS lateral 13 pCi/l outflow to sewer interceptor 10 NE0RSD October 1,1994 - AMS lateral outflow 86 pCi/l to sewer interceptor 11 NE0RSD October 4, 1994 - AMS lateral outflow *
< 0.1 pCi/l l to sewer interceptor 12 NE0RSD October 10, 1994 - AMS lateral 306 pCi/l outflow to sewer interceptor
' Note: The reported uncertainty refers only to counting statistics. l
' Note: The analytical results demonstrating the less than symbol, "<",
indicates that no measurable activity was identified below the minimum detectable level derived for that sample. The minimum detectable level for each sample in which no measurable activity was detected is recorded in the
" RESULT" column.
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'This sample was analyzed by the NRC. After conducting the analysis, the sample was provided to the NE0RSD for analysis (Sample Result No. 3 of this
- table). Therefore, Sample Nos. 2 and 3 were the same samples analyzed l independently.
I ATTACHMENT NO. 1 ILLUSTRATION OF PATHWAY OF AMS LATERAL INTO SEWER INTERCEPT 0R f
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9 ATTACHMENT NO. 2 DIAGRAM 0F SEWER INTERCEPTOR l
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ATTACHMENT NO. 3 1
SERIES OF PHOT 0 GRAPHS OF SEWER l i
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ATTACHMENT NO. 4 GUIDELINE FOR THE DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR MATERIAL !
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GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPM -
PRIOR'TO RELEASE FOR UNRESTRICTED USE i
OR TERMINATION OF LICENSES FOR 8YPRODUCT, SOURCE, i
! OR SPECIAL NUCLEAR MATERIAL l 1
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U.S. Nuclear Regulatory Cornission i Division of Industrial and Medical Nuclear Safety Washington, DC 20555 August 1987 -
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i The instructions in this guide, in conjunction with Table 1, specify the radionuclides and radiation exposure rate limits which should be used in decontamination and survey of surfaces or premises and equipment prior to j abandonment or release for unrestricted use. The limits in Table 1 do not apply to premises, equipment, or scrap containing induced radioactivity for -
, which the radiological considerations pertinent to their use may be different.
Thea release of such facilities or items from regulatory control is considered j on case-by-case basis.
- 1. l The licensee contamination. shall make a reasonable effort to eliminate residual 2.
Radioactivity on equipment or surfaces shall not be covered by paint plating, or other covering material unless contamination levels, as , ,
determined by a survey and documented, are bel' o w the limits specified in Table 1 prior to the application of the covering. A reasdnable effort must be made to minimize tte contamination prior to use of any covering.
3.
The radioactivity on the interior surfaces of pipes, drain lines, or !
ductwork shall be determined by making measurements at all traps, and '
- other appropriate access points, provided that contamination at these ; '
locations is likely.to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment,
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- or scrap which are likely to be contaminated but'are of such sizer i construction or location. as to make the surface inaccessible for surposes of measuremen,t shall be presumed to be contaminated in excess of tie limits.
l 4.
Upon request, the Consnission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having surfaces !
contaminated with materials in excess of the limits specified. This may l include, but would not be limited to, special circumstances such as razing !
of buildings, transfer of premises to another organization continuing work with radioactive materials, or conversion of facilities to a long-tern storage or standby status. Such requests must: *
- a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature *.xtent, '
and degree of residual surface contamination.
- b. Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, together with other ,
considerations such as prospective use of the premises, equipment, or scrap, are unlikely to result in an unreasonable risk to the health and {
safety of the public. l t
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ACCEPTABLE SURFACE C0iTAMINATION LEVELS .
NUCLIDESa AVERAGEbcf MAggggb d (
REMOVABLEbef U.nat. U-235. U-238, and associated decay produc'ts 5.000 dpm a/100 cm2 . 15.000 dpm e/100 cm2 1.000 dpa e/100 cm2 Transuranics. Ra-226. Ra-228 ,
Th-230. Th-228. Pa-231, 100 dpm/100 cm2 Ac-227. 1-125. 1-129 300 dpe/100 cm3 20 dpm/100 cm2 Th-na t. Th-232. Sr-90 .
Ra-22). Ra-224. U-232. I-126, 1000.dpe/100 cm2 1-131. 1-133 3000 dpm/100 cm2 200 dps/100 cm2 Deta-garrva emitters (nuclides .
with decay modes other than '
alpha emission or spontaneous 5000 dpm sy/100 cm2 fission) oxcept Sr-90 and 15.000 dpa sy/100 cm2 1000 dpk sy/100 cm2 others noted above.
aWhere surface nuclides should contamination apply independently. by both alpha- and beta-gamma-emitting nutildes exists, the limits -established for alpha and beta-garina-emitting '
b As used in this table, dpm (disintegrations per minute) means th'e rate of emission by radioactive material as determined ng the by co counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated .
with th Cneasurements of average contaminant should not be averaged over more than 1 square meter should be derived for each such object. .
For objects of less surface area, the average hhc maximum contamination level applies to an area of not more than 100 cm2, 0The amount of removable radioactlve material per 100 cm2 absorbent known efficiency.paper, applying moderate pressure, and assessing the amount of radioactive material ent on ofthe wipe When proportionally and the removable entire contamination surface should be wiped. on objects of less surface area is determined. the pertinent levels should be reduced 0.2 mrad /hr at I cm and 1.0 mrad /hr at I cm. respectively, measured through not more than 7 total absorber.
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Prior to release of premises for unrestricted use, the licensee shall i make a .the is within comprehensive limits specif. fed r'adiation in Table 1.survey'which establishes that contamin A copy of the survey report !
U. S. Nuclear Regulatory Commission. Washington. e- 4 Administrator of the NRC Regional Office having jurisdiction. The report The survey report shall:should be filed at least 30 days prior to the planned
- a. Identify the premises. :
b.
Show that reasonable contamination. effort has been made to eliminate residual i c.
Describe the scope of the survey and general procedures followed.
d.
State the findings of the survey in unit:s specified in the instruction. '
Following facilities toreview confimofthe thesurvey.
report, the NRC will consider visiting the "
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.s i cih fo30 hwxSu LEGAL. - .
. LCC 86 '94 FAX NO. 2168814407 P.02 ic 41Af1 B. KOH & ASSOCIA1L"5 *
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0: 00 Cons :---3;-ns (pCi/L)in Discharges Prem AM5 L.aeoral DATE _9USPENDED ~C-M W_Vis '
TOTAL ~
7/5/94
" 29.1
' a/17/94 20 ,
20
~ 8/17/94 33.4 33.3 9/16/94 3
MS/94 20 W2/94 20 Of2/94 ~
18.8
(/1/94 20 62,8_
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10/4/94 0.1, 10/10/94 106 85.6__ 106 10/16/84 121 164 186 10/10/N 366 103 466
_10/22/94 254 61.5 295.5 10/24/94 77.4 94.01
- 1 72 '
10/28/84 14'! 40 202 t
19(t_0/94 2 41 i 145 396 -
10/27/94 1 911 20 215 10/18/94 l 20 i 522 _
set 10/28/94 78.9 241t 119.9
_ 10/30/941 50,9 210i 260.0
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E December 7, 1994 ADVANCED MEDICAL SYSTEMS INC.
STATUS OF WORK ITEMS l
04 misted Inferustian is mudarlinee inspection lasues l
l Status of Temporary Bestraining order regarding sewer discharges Roof work completed 11/21-Warehouse roof drains to three 22,000 i gallon tanks, other roofs drain to Truck Dock.
l Will be sampling main tank and truck dock 11/28 and sending for analysis. First sample results showed no co-60.
- No plans now to discharge to sewer due to TRO.
- No undate.
Tao 12/9 Esaring - Berson has been in contact with AMS attorneys apd they will l
' request an affidavit. Have not yet received their request. They chartggd their minds and will not reauest an affidavit.
l Analysis of below floor cores of virgin soil (r. orth, south and east sides of l WHUT room) should be complete week of 11/28 (SEG). ! = lina ca=alete.
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l Angivsis onooina. One interestina issue--accroxis.atelv one foot below the floor, after enterina virain soil, and imaanitrable rock laver was hit in all three holes indicatino that this buildina was built rioht on too of a rock l ladoe.
l SEG drilling into WEUT room week of 11/28 and will survey and video inside of WHUT room. HP coverage adequate. Preliminary drillina/surveyina/videoina comolete vieldino substantially reduced dose rates f===. anorox. 300 R/hr).
Activities onooina.
Front plug milling - Aleron in week of 11/21 to plan job. AMS to access hot cell week of 12/5 to make specific measurements that Aleron needs to finalize proposal. Aleron subcontracting with Chicago based engineering firm who are familiar with nuclear work. Work delaved due to extension of WHUT room I
survey.
l GE 500 cask with 12,000 Ci of contaminated non-leak tested sources in limbo -
bolted and stored in overpack in secured warehouse. No update.
I Eot cell radiological conditions as of 11/28 - i Hot cell general area - 12 R/hr Front plug general area - 18 R/hr Several hot spots ranging from 10s of R/hr up to 200 R/hr contamination into the millions of dpm per 100 cm2 No update.
SEG will be submitting an unsolicited proposal as discussed with AMS t'o develop scenario for emergency drill. Not sure 12/31 is achievable with q a
everything else that is going on. We orovided Rea Guide on E,-p.lga g) t)
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I drills... work is oroaressina. '
slawinski Inspection report issued 11/29. ;
Meeting with AMS to discuss 11/94 and 12/94 Slawinski inspection results will be scheduled in December. Escackmc 19 or 20 look like the best days. We will l issue a daily staff note when the meetino occurs. l
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NRC structaral assessment of AMS ongoing. First sita visit 10/12. No significant issues identified. second site visit neceasexy, but not scheduled yet. En_undata.. ;
l Mamo to IICS regarding mannan allegation of illegal sewer discharges in final j typing - will be issued after inspection report. Will be issued this week. ;
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Letter from Cleveland regarding 11/94 Slawinski report findings - Slawinski drafting response. Will ao out 12/8.
10 CFR 2.206 Requests M.a.rch 1993 - AMS to Pay for Remediation - Finkelstien has*1ead and is drafting Commission options paper.
August 1994 - Sewer Discharge Radiation Monitor - Dicicco drafting recponse - Needs Picker files from 1974-1979 time frame - We are supporting.
No update.
Licensina lasues Renewal prepared and AMS to submit week of 11/28. DFP shculd be with renewal.
Not submitted vet . . < TRO hearina da=I nstina licensee =ma=------ .7t t i ==.
NEORSD and Effluent issues Kurth Report - In final concurrence in NMSS due 11/28. Concurrence in from OGC and NMSS/WN. Waiting for NMSS/IMNS. Outstanding question on solubility of cobalt-60 in wastewater. All issueu resolved, recort issued 12/6.
40 of 81 Southerly and Easterly samples counted as of 11/22. No Co-60 detected. 11 samples had either detectable I-131 (up to 1.45 pCi/g) or T1-201 (up to 65.7 Pci/g). Remainder of samples should be counted by 12/9. All samoles counted. NO cobalt-60.
Attempting to recover AMS affluent sample for assessment of solubility.
NEORSD has been recalcitrant in providing sample. Will discuss with Lenhart when he is in RIII en 12/2. Discussed with Lenhart...they will orovide us their results which included filterino the samole with 0.45 micron mudia. Co-60 was measured both oLipe filter media and in the filtrate.
FOIA follow up - NEORSD will be in RIII on 12/2 to review AMs and southerly I files. Pearson and Kurth expunging withholdable stuff and coordinating closely with HQ FOIA folks. pone,
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WBomps/ ARES Lawsuit - tentative date for first court action is mid-January '
1995. NRC/ Region III involvement not defined at this time. No update.
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!d TABLE NO. 1 ANALYTICAL RESULTS FROM EASTERLY AND S0t!THERLY SAMPLING SAMPLES COLLECTED NOVEMBER 1, 1994 LOCATION SAM DAY RESULT i 2a
( PLE (pCi/g)
Sou. Lagoon A 1 11/1 Co-60 <'MDA Sou. Gravity Thickener Primary 2 11/1 Co-60 <MDA Sludge I-131 0.8 0.2 Sou. Gravity Thickened Excess 3 11/1 Co-60 <MDA Activated Sludge l Sou. Gravity Belt Excess 4 11/1 Co-60 <MDA
- Activated Sludge
Sou. Thermal Conditioning 6 11/1 Co-60 <MDA Thickened Sludge Tank No. 4 Sou. Thermal Conditioning 7 11/1 Co-60 <MDA Influent I-131 1.3 0.3 Sou. Vacuum Filter Cake East 8 11/1 Co-60 <MDA Belt Sou. Vacuum Filter Cake West 9 11/1 Co-60 <MDA Belt I-131 1.4 0.3 Sou. Furnace No. 1 Ash 10 11/1 Co-60 <MDA l Be-7 13.8 4.0 T1-201 75.7 15.0 Ra-226 10.0 i 3.0 Sou. Furnace No. 2 Ash 11 11/1 Co-60 <MDA l Be-7 12.0 4.0 T1-201 64.0 i 17.0 Ra-226 6.0 i 2.0 Sou. Furnace No. 4 Ash 12 11/1 Co-60 <MDA Be-7 14.0 4.0 T1-201 58.0 15.0 Ra-226 10.0 2.0 l
Sou. Big Creek Interceptor 13 11/1 Co-60 <MDA Sou. Southwest Interceptor 14 11/1 Co-60 <MDA Sou. Southerly Interceptor 15 11/1 Co-60 <MDA Sou. Mill Creek Interceptor 16 11/1 Co-60 <MDA '
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I e I LOCATION SAM DAY RESULT i 2a 7
PLE (pCi/g) i e
Sou. Cuyahoga Interceptor 17 11/1 Co-60 <MDA Sou. Sludge Degrit No. 2 18 11/1 Co-60 <MDA Sou. Sludge Degrit No. 3 19 11/1 Co-60 <MDA Sou. Easterly Sludge Line 20 11/1 Co-60 <MDA I-131 1.0 i 0.3 )
Sou. Initial Grit 21 11/1 Co-60 <MDA l
East. Grit Classifier' 22 11/1 Co-60 <MDA ;
East. Easterly Inlet 23 11/1 Co-60 <MDA l
East. Collinwood Inlet 24 11/1 Co-60 <MDA East.' Heights Inlet 25 11/1 Co-60 <MDA East. Southerly Pumps 26 11/1 Co-60 <MDA East. Pump Building-Waste 27 11/1 Co-60 <MDA Activated Sludge
'The reported uncertainty refers only to counting statictics. !
'The calculated Minimum Detectable Activity (MDA) for cobalt-60 ranged from 0.1 to 0.6 picocuries per gram for all samples collected.
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l TABLE NO. 2 ANALYTICAL RESULTS FROM SOUTHERLY AND EAS1ERLY SAMPLING SAMPLES COLLECTED NOVEMBER 2, 1994 LOCATION SAM DAY RESULT ~2a !
i PLE (pCi/g) +
c Sou. Lagoon A 1 11/2 Co-60 <'MDA 1
, Sou. Gravity Thickener Primary 3 11/2 Co-60 <MDA j j Sludge Sou. Gravity Thickened Excess 2 11/2 Co-60 <MDA Activated Sludge Sou. Gravity Belt Excess NA Shut Down for Maintenance Activated Sludge on this day l Sou. Thermal Conditioning 4 11/2 Co-60 <MDA Thickened Sludge Tank No. I 1
l Sou. Thermal Conditioning 5 11/2 Co-60 <MDA i Thickened Sludge Tank No. 2 Sou. Thermal Conditioning 6 11/2 Co-60 <MDA
! Thickened Sludge Tank No. 4 l
l Sou. Thermal Conditioning 7 11/2 Co-60 <MDA Influent l Sou. Vacuum Filter Cake East 8 11/2 Co-60 <MDA i Belt l Sou. Vacuum Filter Cake West 9 11/2 Co-60 <MDA Belt Sou. Furnace No. 1 Ash 10 11/2 Co-60 <MDA Be-7 18.0
Sou. Furnace No. 4 Ash 12 11/2 Co-60 <MDA l Be-7 22.0 4.0 )
Ra-226 10.0 2.0 Sou. Big Creek Interceptor 20 11/2 Co-60 (MDA Sou. Southwest Interceptor 22 11/2 Co-60 <MDA l-Sou. Southerly Interceptor 21 11/2 Co-60 (MDA 1
i
- Sou. Mill Creek Interceptor 23 11/2 ! Co-60 <MDA a
s arm,-. u n, ww-,-- -, . - - .-a m. --- - e . ~ - - - - , - , , , - - - - ,. - - - - - - - - ,
s LOCATION SAM DAY RESULT *2o PLE (pCi/g)
Sou. Cuyahoga Interceptor 24 11/2 Co-60 <MDA Sou. Sludge Degrit No. I 16 11/2 Co-60 <MDA Sou. Sludge Degrit No. 2 17 11/2 Co-60 <MDA :
Sau. Sludge Degrit No. 4 18 11/2 Co-60 (MDA Sou. Easterly Sludge Line 19 11/2 Co-60 (MDA Sou. Initial Grit 25 11/2 Co-60 <MDA East. Grit Classifier 28 11/2 Co-60 <MDA East. Easterly Inlet 13 11/2 Co-60 <MDA East. Collinwood Inlet 15 11/2 Co-60 <MDA East. Heights Inlet 14 11/2 Co-60 <MDA Easterly-Southerly Pumps 26 11/2 Co-60 <MDA East. Pump Building-Waste 27 11/2 Co <MDA Activated Sludge u "The reported uncertainty refers only to counting statistics.
'The calculated Minimum Detectable Activity (MDA) for cobalt-60 ranged from 0.1 to 0.6 picocuries per gram for all samples collected.
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TABLE'NO. 3 I
ANALYTICAL RESULTS FROM EASTERLY AND SOUTHERLY SAMPLING SAMPLES COLLECTED NOVEMBER 3,1994 l
, i LOCATION SAM DAY RESULT i '2a PLE (pCi/g) !
Sou. Lagoon A 1 11/3 Co <*MDA Sou. Gravity Thickener Primary 3 11/3 Co-60 <MDA Sludge Sou. Gravity Thickened Excess 2 11/3 Co-60 <MDA Activated Sludge Sou. Gravity Belt Excess NA Shut Down for Maintenance Activated Sludge on this day l
l Sou. Thermal Conditioning 4 11/3 Co-60 <MDA
! . Thickened Sludge Tank No. 1 Sou. Thermal Conditioning 6 11/3 Co-60 <MDA Thickened Sludge Tank No. 2 Sou. Thermal Conditioning 5 11/3 Co-60 <MDA Thickened Sludge Tank No. 4 Sou. Thermal Conditioning 7 11/3 Co-60 <MDA Influuit Sou. Vacuum Filter Cake East 8 11/3 Co-60 <MDA l Belt Sou.. Vacuum Filter Cake West 9 11/3 Co-60 <MDA Belt l Sou. Furnace No. 1 Ash 10 11/3 Co-60 <MDA
)
Be-7 32.0 5.0 i T1-201 12.0 5.0 Ra-226 3.0 1.0 Sou. Furnace No. 2 Ash 11 11/3 Co-60 <MDA Be-7 32.0 1 5.0 T1-201 12.0 5.0 Ra-226 3.0 1.0 Sou. Furnace No. 4 Ash 12 11/3 Co-60 <MDA Be-7 32.0 5.0 T1-201 12.0 5.0 Ra-226 3.0 1.0 <
Sou. Big Creek Interceptor 16- 11/3 Co-60 <MDA .
( Sou. Southwest Interceptor 17 11/3 Co-60 <MDA i
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LOCATION SAM DAY RESULT '2cr PLE (pCi/g) i Sou. Southerly Interceptor 18 11/3 Co-60 <MDA l Sou. Mill Creek Interceptor 19 11/3 Co-60 <MDA Sou. Cuyahoga Interceptor 20 11/3 Co-60 <MDA Sou. Sludge Degrit No. I 13 11/3 Co-60 <MDA
! Sou. Sludge Degrit No. 4 14 11/3 Co-60 <MDA Sou. Easterly Sludge Line NA 11/3 Sample Not Obtainable -
Difficulty Getting Electric Switch To Work Sou. Initial Grit 15 11/3 Co-60 <MDA East. Grit Classifier 26 11/3 Co-60 <MDA East. Easterly Inlet l 24 11/3 Co-60 <MDA East. Collinwood Inlet 25 11/3 Co-60 <MDA East. Heights Inlet 23 11/3 Co-60 <MDA East. Southerly Pumps 21 11/3 Co-60 <MDA East. Pump Building-Waste 22 11/3 Co-60 <MDA l gctivatedSludge
'The reported uncertainty refers only to counting statistics.
1
'The calculated Minimum Detectable Activity (MDA) for cobalt-60 ranged from !
0.1 to 0.6 picocuries per gram for all samples collected. l k
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