ML20137A388
| ML20137A388 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/1995 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Catherine Haney, Marian Zobler NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20137A376 | List: |
| References | |
| FOIA-96-444 NUDOCS 9703200308 | |
| Download: ML20137A388 (1) | |
Text
(JAG)j6b From:
John A. Grobe Monday, March 1q3,,rvtNuTEobb,0 6 c.
CXH, MLz C Hew To:
Dates 1995 7:29 am Subjects FINAL Draft of Cleveland Letter
- Folks, As we discussed Friday, here is the final re-draft per your changes.
Jack CC:
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March 15, 1995 MEMORANDUM T0:
Materials Files FROM:
Michael F. Weber, Radiation Specialist THRU:
John A. Grobe, Chief, Nuclear Materials Inspection Section 2
SUBJECT:
ADVANCED MEDICAL SYSTEMS, INC.
LICENSE N0. 34-19089-01 i
DOCKET NO. 030-16055 On March 6-8, 1995, I performed an unannounced inspection at AMS. My activities included the following:
Overseeing the performance of daily and weekly radiological surveys
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and equipment checks by the health physics technician, Chris Reed.
Copies of the checklists used during the surveys and checks are attached.
No problems were identified.
Performing confirmatory surveys' of uncontrolled and controlled areas (excluding high radiation areas) on the first and second floors and roof of the building.
The background radiation level was approximately 20 uR/hr.
Readings above background are indicated on the attached maps. A small " hot particle" was found on the floor of the 1st floor uncontrolled equipment storage area.
(Initially, the inspector measured levels approaching 300 uR/hr in this area.
Then the RSO and inspector, using duct tape and a pancake probe, found the removable particle, and measured levels of 5 mrem /hr at I cm from the source.
The particle was subsequently disposed of in a radioactive waste drum.)
4 Performing confirmatory surveys of controlled and uncontrolled areas throughout the grounds outside of the building. Again, the background radiation level was approximately 20 uR/hr.
Readings above background are indicated on the attached map.
The radiation levels at the site boundary were at background levels.
Overseeing the replacement of malfunctioning valves on two water storage containers (a third valve was later replaced on March 8).
' Meters used: Ludlum Model 19 Micro R Meter, NRC tag 011021, S/N 21567, calibrated 9/13/94, and Bicron RS0-5, NRC tag 042651, S/N 8819G, calibrated 12/15/94. Wipe tests of the former low level waste storage room were also performed.
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i Interviewing workers (Bob Meschter, RS0; Steve Haddock, Isotope Handler; Chris Reed, HP technician) regarding the upcoming water removal and treatment projects, and many other topics.
No violations of NRC requirements were identified during the course of the inspection.
Tasks for the next inspection include performing a careful, systematic radiological survey of sewer and water pipes in the facility, and investigating further the source of the 200 uR/hr reading found near the pipes j
in the janitor's closet on the first floor (see attached map).
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AMS we11 counter S/N 4896 calibration due 7/5/95 Background 31 cpm efficiency 14.18%
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a Advanced Medical Systems ATTN: Mr. Robert Meschter i
Radiation Safety Officer 1020 London Road Cleveland, OH 44110
Dear Mr. Meschter:
Enclosed is Amendment No. 33 to your NRC Material License No. 34-19089-01 in accordance with your request.
Please review the enclosed document carefully and be sure that you understand all conditions.
If there are any errors or questions, please notify the U.S.
Nuclear Regulatory Commission, Region I!I office so that we can provide appropriate corrections and answers.
With this amendment, authorization is granted for AMS to utilize Lockheed Analytical Services for confirmatory analyses of treated water samples. Note that License. condition No. 20 has been amended to add Subitem I. which ties down your letters dated May 3 and May 17, 1995.
Please be advised that your license expires at the end of the day, in the month, and year stated in the license.
Unless your license has been terminated, you must conduct your program involving byproduct materials in accordance with the conditions of your NRC license, representations made in your license application, and NRC regulations.
In particular, note that you must:
1.
Operate in accordance with NRC regulations 10 CFR Part 19, " Notices, Instructions and Reports to Workers; Inspections," 10 CFR Part 20,
" Standards for Protection Against Radiation," and other applicable regulations.
2.
Notify NRC, in writing, within 30 days:
a.
When Radiation Safety Officer permanently discontinues performance of duties under the license or has a name change; or b.
When the licensee's mailing address changes (no fee is required if the location of byproduct material remains the same).
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Advanced Medical Systems.
3.
In accordance with 10 CFR 30.36(b) and/or license condition, notify NRC, promptly, in writing, and request termination of the license when you decide to terminate all activities involving materials authorized under the license.
4.
Request and obtain a license amendment before you:
a.
Change Radiation Safety Officers; b.
Order byproduct material in excess of the amount, or radionuclide, or form different than authorized on the license-l c.
Add or change the areas of use or address or addresses of use identified in the license application or on the license; or d.
Change ownership of your organization.
5.
Submit a complete renewal application with proper fee or termination request at least 30 days before the expiration date of your license.
You will receive a reminder notice approximately 90 days before the expiration date.
Possession of byproduct material after your license expires is a violation of NRC regulations. A license will not normally be renewed, except on a case-by-case basis, in instances where licensed material has never been possessed or used.
In addition, please note that NRC Form 313 requires the applicant, by his/her signature, to verify that the applicant understands that all statements contained in the application are true and correct to the best of the applicant's knowledge.
The signatory for the application should be the licensee or certifying official rather than a consultant.
You will be periodically inspected by NRC.
Failure to conduct your program in accordance with NRC regulations, license conditions, and representations made in your license application and supplemental correspondence with NRC will result in enforcement action against you.
This could include issuance of a notice of violation, or imposition of a civil penalty, or an order suspending, modifying or revoking your license as specified in the General Policy and Procedures for NRC Enforcement Actions, 10 CFR Part 2, Appendix C.
Since serious consequences to employees and the public can result from failure to comply with NRC requirements, prompt and vigorous enforcement action will be
Advanced Medical Systems.
taken when dealing with licensees who do not achieve the necessary meticulous attention to detail and the high standard of compliance which NRC expects of its licensees.
Sincerely, 1
Kevin G. Null Nuclear Materials Licensing Section License No.:
34-19089-01 Docket No.:
030-16055
Enclosure:
Amendment No. 33
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I JUN 141995 i
Advanced Medical Systems, Inc.
ATTN: David Cesar, Treasurer j
121 North Eagle Street j
Geneva, OH 44041 4
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Dear Mr. Cesar:
We have reviewed your March 22, 1995 amendment request as supplemented by your letter dated June 13, 1995, and find that we need additional. and clarifying information on each of your requests. Questions regarding your request to evaporate processed water will be provided under separate cover. Our concerns / questions associated with each of your other requests are provided as follows:
5 I.
Installation of a Samplina Device in the New Lateral Connection We have no objection to the installation of a composite water sampling device in the new lateral connection. However, the purpose of the sampling system is unclear. The water sampling device as currently j
proposed cannot be used to demonstrate compliance with 10 CFR Part 20.2003, since water samples are collected and analyzed after the release into the sewerage system has occurred.
f If your intent is to use the sampling system to show compliance with 10 CFR 20.2003, the system will need to be modified to detect the concentrations of radioactive material in the waste water effluent prior i
to or during its release and include an isolation capability to terminate the discharge if it exceeds 10 CFR 20 limits. Consequently, please provide the following information:
A.
Describe the purpose of the water sampling system.
i B.
Describe your proposed methods for demonstrating compliance with 10 CFR Part 20.2003 for disposal by release into the sanitary sewerage system, prior to a given discharge.
I If the composite sampler will be used to demonstrate compliance with 10 CFR Part 20.2003, or will be used to confirm results of other analyses, please respond to the following additional questionst C.
What modifications will be made to the proposed sampling system that will enable it to be used to evaluate discharges to the sewerage system orior to each discharge?
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l Advanced Medical Systems, Inc. JUN 141995 D.
.How is a sample collected during a given discharge? Specifically, 1s a sample aliquot collected from each discharge of water into the sewerage system? What is the volume of'the sample collected?
1 E.
If a sample aliquot is collected of a given discharge, what provisions will be implemented to ensure the aliquot is 1
representative of the total discharge?
F.
What is the percent (or relative volume) of the total discharge that will be sampled by the system (i.e., sample to sewerage system discharge ratio)?
G.
What will be the methods and equipment used to analyze the samples i
1 (e.g. contractor analysis using gama spectroscopy)? What will be j
the analysis equipment's minimum detectable activity? How do you plan to determine if the disch rge satisfies 10 CFR Part 20-f solubility criteria? If you propose to analyze the samples in house, you will need to describe the analysis equipment, its calibration and quality control check procedures.
H.
Supplement III of your March 22, 1995 submittal indicates that the Model 3710 sampler's operational temperature range is32-120 degrees F.
Consequently, verify that the sampling system will function properly during sub-freezing winter temperatures.
I.
Verify that the maximum rate of the Model 3240 flow rate meter is sufficient when sanitary discharges occur simultaneous with a rain storm or other significant precipitation event.
J.
What will be the location of the sampling system relative to the new manhole? If installed upstream or in the manhole itself, explain how the system will sample foundation drains (underdrains), surface, roof and sanitary discharges.
II.
Re-connection of the Foundation Underdrain and Sanitary Systems to the New Manhole / Lateral Before we authorize reconnection of the facility underdrain system to the new manhole / lateral, you must demonstrate that both the underdrain system is contamination free and that surrounding soils do not contain concentrations of radioactive materials in excess of unrestricted use soil release criteria (e.g., 8 pCi/gm for Co-60). As you know, the t
water problems your facility has experienced over the last several months may have contaminated the soil under the building and along the foundation walls in the vicinity of the underdrains. Therefore, you must evaluate the radiological condition of the underdrain system itself
i JUN 141995 Advanced Medical Systems, Inc..
and of the soils below the building's foundation and in the immediate vicinity of the underdrain system. Should soil contamination exist, we are concerned that movement of cobalt-60 via groundwater transport could contaminate a previously uncontaminated underdrain system.
Consequently, please provide the following information:
A.
What is the basis for proposing that.3,000 and 10,000 continuous gallons of water pumped from the foundation drainage system and from the newly installed manhole, respectively, and that contain no detectable cobalt-60, is conclusive evidence that the system has been flushed sufficiently?
B.
Define the term "no detectable cobalt-60," as discussed in your June 13, 1995 revised Supplement 4.
If these criteria will remain unchanged from that previously established (i.e., less than 20 pCi/l non-soluble cobalt-60 and less than 200 pC1/1 of soluble i
cobalt-60, as detennined by a contract analytical laboratory),
please adviso.
I C.
Provide the details of your planned sampling program to evaluate the radiological condition of the soils both under the building and in the vicinity of the underdrain system. Your description of the soil sampling program should include the sample locations, minimum number of samples, sample volume and soil analysis methods. NUREG/CR-5849 and Section 4 of Draft Branch Technical Position On Site Characterization For Decommissioning (enclosed),
provide guidance on soil sampling.
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(1)
Soil sample locations should address the depth of the samples and the horizontal distance from the outside of the building's walls with respect to the underdrain system.
(2)
Soil sampling should not be limited solely to excavated areas since other portions of the underdrain system may have been subjected to water inflow from the contaminated manhole / lateral. Therefore, the soil sampling program should be supplemented at a minimum, to include the extraction of soil samples at depths from the surface around the east and south perimeter regions of your building. Soil borings or equivalent techniques should be used for sampling at depths from the surface soils.
D.
We are concerned that over the last several months, backflow from the existing manhole may have contaminated the four-inch diameter
- cast iron sanitary discharge pipe in the innediate area where it connects into the manhole. Therefore, describe your plans to evaluate the radiological condition of the existing sanitary discharge line at its outfall into the contaminated manhole, prior to its reconnection to the proposed new manhole / lateral system.
a-i JUN 141995 Advanced Medical Systems, Inc. b
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E.
Supplement 4 of your March 22, 1995 submittal indicates that
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processed water meeting the release criteria will be pumped to the i
collapsible storage tanks for subsequent evaporation.
Footnote j
No. 3 to Supplement 4 further indicates that water that does not
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meet the release criteria will.be pumped into the above ground i
tanks and directly to the evaporator system.
It is our
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understanding that all water that accumulates in the drainage a
system during remediation activities will be pumped out of the sump pit or injection point in/near the existing sump pit, into 1
above ground tanks and processed.
Please confirm our understanding. Based on your statements in Supplement 4 of the March 22, 1995 letter, it is unclear if all water accumulated 4
during the excavation and grouting work will be processed to meet 4
the release criteria prior to evaporation.
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F.
Supplement 4 of rour March 22, 1995 submittal together *with the i
Neff & Associi n drawing appear to limit the length of foundation l
perimeter drains that will be excavated and removed or decontaminated. The extent of the pipe to be removed appears to j
be from the sump pit on the southeast corner of the building to e
the "Y" connection of the existing four-inch diameter pipe leading
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3 to the facility manhole. Provide the basis for the limits of your l
proposed excavation and pipe removal / decontamination. Also, I
provide details on the reconstructed foundation perimeter drainage i
system by including a cross-section of the installation showing l
the perforated pipe, filter provisions, and backfilling plans to include material gradation and compaction requirements.
l G.
Supplement 4 of your March 22, 1995 submittal together with the Neff & Associates drawing do not address the final disposition of surface water that originally flowed to three catch basins in
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front of the facility.
Specifically, only the perforated underdrains, sanitary drain and i
roof drains are noted as being connected to the proposed new j
lateral connection to the interceptor sewer.
It is assumed that i~
the " sealed" surface water drains depicted in the drawing would be j
removed, allowing flow through the new 15-foot section of 15-inch PVC pipe and into the new manhole.
Please clarify this issue.
H.
Additional information is necessary regarding your plans for
" grouting in" the existing service connection.
(1)
The cementitious material that is used to fill the existing service connection is referred to as a concrete.
Is the material to be a concrete with coarse aggregate or a grout consisting of cement and sand materials? Please define the limits of filling for the existing lateral, manhole and the section of severed four-inch diameter cast iron pipe.
d JUN 141995 Advanced Medical Systems, Inc. -
l Identify the extent of the fill procedure and indicate how complete filling of the volume will be accomplished and verified.
(2)
What plans exist for the compression plug previously inserted by the Northeast Ohio Regional Sewer District at the outfall of your facility's sewer lateral. Specifically, will the cementitious material be used to seal in the compression plug, or will the plug be removed and another 4
barrier placed at the lateral's outfall and sealed in place j
with the grout material?
3 III. Discharge of Ground. Surface and Waste Water into The Sanitary Sewerage-System 10 CFR Part 20.2003, " Disposal by Release into Sanitary Sewerage,"
authorizes the discharge of licensed material into the sanitary sewerage provided:
A.
The material is readily soluble (or is readily dispersible biological material) in water; and B.
The concentration of licensed material released into the sewer does not exceed that listed in Table 3 of Appendix B to 20.1001
- 20.2401 (e.g., Co-60 concentration of 3 E-5 microcuries/ml (30,000 pCi/1)).
Consequently, your request to discharge ground, surface and waste water that contains less than 200 pC1/1 of soluble cobalt-60, solubility as defined in NRC Information Notice #94-07, does not require an amendment since it is authorized by 10 CFR Part 20.
IV.
Miscellaneous Questions: Neff & Associates (February 24. 1994)
Engineering Drawing " Relocated Service Connection" A.
General note #9 on the drawing is unclear. Specifically, clarify what is meant by filling the existing service connection to within one foot of the casting. What and where is the casting?
B.
The drawing does not appear to detail the severance and reconnection of the existing four-inch diameter cast iron sanitary pipe at 1% grade, exiting from the front of the building to the proposed new four-inch diameter PVC pipe. The plan and profile of the new service connection appear to only indicate a double "Y" connection to the four-inch PVC from the two sides of the foundation perimeter drain piping. The drawing also does not
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JUN 141995 Advanced Medical Systems, Inc. -
t provide details regarding the limits on where the sections of perforated pipe begin and end, and where the non-perforated pipe begins. Please provide additional information to address these items.
C.
The drawing has not been " sealed" by a professional engineer; therefore, we q'Jestion if it is the final drawing approved for construction. The engineering seal attests to the correctness of the drawing and certification of the engineering firm.
We will continue our review of your application upon receipt of this-information. Please reply in duplicate, within 30 days, and refer to Control Number 98334..
If you have any questions or require clarification on any of the information stated above, you may contact us at (708) 829-9887.
Sincerely, Original Signed By John R. Madera, Chief Nuclear Materials Licensing Section License No. 34-19089-01 Docket No.
030-16055
Enclosures:
1.
Draft Branch Technical Position On Site Characterization for Decommissioning l
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