ML20147H815
| ML20147H815 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1994 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Axelson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20147H788 | List: |
| References | |
| FOIA-96-444 NUDOCS 9704090082 | |
| Download: ML20147H815 (7) | |
Text
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(JAG) g M13( '0 MbY$d bb From: John A. Grobe
~
To:
WLA Date Thursday, December 8, 1994 7:13 am
Subject:
NEORSD Petition -Forwarded -Forwarded Forwarded mall received from: CH1:HMS3:IfAS1:TW4 TW8:C(U l
- Bill, The agency looks like a bunch of bumbling idiots regarding this issue. Why does it take months to redraft a document??? The only answer that could possibly be true is that it is not a priority and no one works on it.
What can we do to get this moving.....have Taylor himself call OGC7 Frustratingly Yours, j
Jack Filess meifESSAGE, m1 hESSAGE l
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.00CKE1 NO:
- 030-16055 TLICENSEE:
-Advanced Medical _ Systems. Inc.
Cleveland.10hio-
. SUBJECT.
-SAFETY EVALUATION REPORT: ' ADVANCED MEDICAL: SYSTEMS, INC.,
APPLICATION TO AMEND NRC LICENSE N0 34-19089-01' DATED JULY
- 1. 1996 The purpose of this memorandum is to document the' staff's Lsafety review of a license amendment application submitted by Advanced Medical. Systems (AMSL in a fletter of July,1.1996. -In that letter. AMS-requested that NRC amend License No. 34-19089-01.to allow it to implement Tasks.1 and 2 of the Building Recovery Plan whii AMS submitted in a. letter of June 10, 1996.
Task l' encompasses disposal of all accessible sealed cobalt-60 sources and all canisters of bulk cobalt-60 currently possessed at the licensee's London Road
. facility tat a commercial low-level radioactive waste disposal facility while
- Task 2 includes' disposal of dry solid waste currently stored at the facility.
r LThe effect of these tasks would be to reduce the inventory of cobalt-60 at the
- licensee's London Road facility by.approximately 52.000 curies.
In its July 1 letter. AMS also proposed to reduce its standby letter of credit from its current amount of $1.800,000 to $940.000 and thereby free up $860.000 to finance the cost of implementing Tasks 1 and 2.
These funds would be used solely-for the purpose of funding transfer / disposal of the bulk and sealed sources of cobalt-60 and low-level radioactive waste. AMS also agreed in this
-letter to submit by August 30. 1996 a revision to the " Conceptual Decommissioning Plan for the London Road Facility" that will reflect the reduced onsite source inventory, and by September 15, 1996, assuming approval of the revised conceptual Decommissioning Plan, a revised Decommissioning Funding Plan that will contain a description of a new decommissioning
' financial assurance instrument.
BACKGROUND From 1979 to 1989 AMS manufactured cobalt-60 sealed sources for teletherapy and radiography machines at its London Road facility.
Since May 1991, the licensee has not been authorized, nor does it now desire to manufacture sealed sources.
License No. 34-19089-01 currently authorizes possession of up to 300,000 curies of cobalt-60.-
At present, approximately 55,000 curies of cobalt-60 in the-form of bulk metal, sealed sources and dry solid waste are onsite at AMS' facility. (Of this inventory, approximately 3.000 curies is located in.a storage well behir.d the hot cell stuck plug and will not be removed as.part of Tasks.1 and 2.) This large quantity of cobalt-60 'is not needed for the limited operations _ currently authorized under the AMS license.
- 0n November.29. 1994. AMS submitted an application for license renewal.
As
-part-of the license renewal-process and in accordance with 10 CFR 30.35 (c)(2) and;(e), AMS~ submitted on January 27, 1995, an executed standby letter of
- credit _in the amount of $1.800.000, which was supposed to reflect its cost (estimate for decommissioning..By letter dated-March 30, 1995, NRC informed b
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'AMS that AMS had underestimated the cost of decommissioning the facility.
On October 11. 1995, in response to a' Demand for Information issued by NRC on
' September _ 17.-1995. AMS submitted ~a Strategic Plan to NRC for review.'This plan described a number of tasks needed to assure regulatory compliance as well as streamlined routine operations and assigned 3riorities of high. medium l
and low to those tasks, as appropriate.
One of the lighest priority. items in the AMS Strategic Plan is a reduction in the inventory of radioactive materials at the London Road facility.
l On October 20. 1995. AMS submitted a " Conceptual Decommissioning Plan for the London Road Facility" to NRC.
In this document. AMS estimated decommissioning costs to range between 5913.000 and $3.300.000 depending on decommissioning
)
methodology.
As noted above. AMS' January 27, 1995 standby letter of credit l
submitted in support of its license renewal application was executed in the amount of $1.800.000.
By letter dated March 20, 1996. NRC requested additional information from AMS regarding its decommissioning plan.
NRC has received'AMS' response and it is currently under staff review.
j 1
On June 10, 1996. AMS requested imC authorization to proceed on a i
comprehensive Building Recovery Project (BRP) at the AMS facility.
The BRP contained a twelve point scope of work.
AMS developed this plan because it is currently facing a number of extenuating regulatory, legal and financial circumstances that are hindering its efforts to remain a viable business entity.
Included in that letter was a request that NRC release a portion of the funds that AMS has committed for decommissioning the London Road facility to support the commercial disposal costs. AMS believes that once the project is complete. there will be a significantly-reduced radiological risk at the l
facility, license commitments will more accurately reflect AMS's on-going i
operational activities, compliance costs will be lower and routine personnel exposures will be lower.
As noted above, AMS submitted an amendment request on July 1. 1996 to, among other things, amend License No. 34-19089-01 to approve implementation of Tasks I
1 and 2 of the BRP.
DISCUSSION Task 1 of the BRP involves stabilization, transfer and dis)osal of approximately 52.000 curies of cobalt-60.
Under Task 1. t1e 1 censee and the contractor will stabilize the sources and bulk cobalt-60 (excepting those sources inside the hot cell stuck plug) with a disposal site stabilization agent that has been approved by the State of South Carolina. This stabilization will be performed inside shipping cask liners by AMS and the contractor.
AMS has committed to use remote handling capabilities to the greatest possible extent in order to minimize personnel ex)osures from handling and stabilization of the mater sis. Once the sta)ilization agent has cured sufficiently, the cask liner will be loaded by AMS and contractor aersonnel into a lead-shielded. Type B shipping cask for shipment to the low-
_evel Waste (LLW) disposal facility at Barnwell. South Carolina.
AMS antici)ates that this task will be accomplished in one or two shipments, based upon tle size of Type B cask that is used.
Under Task 2. approximately 2500 cubic. feet of dry solid radioactive waste (containing approximately 25 curies
.o:
1 of cobalt-60) will be inventoried by AMS. packaged in appropriate ship)ing containers by the contractor and shipped for disposal at the Barnwell
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' disposal facility. All onsite operations, including those of the contractor, will be conducted under the AMS license.
j NRC's Office of-Nuclear Material Safety and Safeguards (NMSS) and Region III have been interested in reducing the radioactive source inventory at the AMS London Road Facility since AMS amended its license in 1991 to limit authorized use of licensed materials to non-manufacturing purposes.
The highest priority j
concern listed in the staff's September 17. 1996 Demand for Information (DFI) i was "'.. removal of large quantities of radioactive material and low-level radioactive waste from the facility..."
While AMS' continued possession of E5.000 Curies of cobalt-60 in the form of bulk metal, sealed sources and dry solid waste Joses no imminent public health and safety risk, the staff noted
.in the DFI tlat continued possession of this material "... serves no useful pur)ose to AMS and poses avoidable risks to the workers and potential risk to mem)ers of the public." Staff believes that reduction in this inentory is consistent with the ALARA philosophy and will allow the licensee to focus on the remaining concerns expressed in the staff's September 17. 1995 DFI and the resultant AMS Strategic Plan.
Interest in decreasing source inventory has been heightened by recent legal and financial circumstances facing AMS that have the pctential to hinder AMS' i'
efforts to remain a viable business entity that can continue to provide control over activities at the London Road facility so as to protect public health and safety from radiological hazards.
Staff believes that AMS' plan to reduce source inventory is a positive step towards reducing any potential for significant repercussions that could impact public health and safety should AMS cease to be a viable entity.
AMS indicated in its June 10, 1996, letter that ap3roximately 40 curies of radioactive material that is stored onsite at the _ondon Road facility is in a pctentially dispersible form. This material consists primarily of dry solid waste, carbon granules and ion exchange resins stored in sealed 55-gallon
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drums or B-25 (steel) boxes.
Given that this material is potentially dispersible, staff is concerned that continued storage of material increases i
the long-term likelihood that radioactive material may be dispersed into areas j
outside AMS' control.
The request to reduce the amount of the present financial instrument, and use those funds to dispose of the bulk metal, sealed sources and dry radioactive waste is premised on:
o The importance of prompt action since the waste broker's proposal will be valid for a limited period of time.
If NRC does not proceed expeditiously to approve the licensee's proposal. AMS may not be in a position to initiate the project.
o The Licensee's operating funds are limited and are not sufficient to pay the costs of preparation. transfer and disposal of the material by the waste broker.
i ENVIRONMENTAL REVIEW
0 Issuance of license amendments to materials licensees such as AMS is covered by a categorical exclusion [10 CFR 51.22 (c)(14)(xvi)] from the requirement to prepare an environmental assessment or environmental impact statement.
CONCLUSION Based on information provided in this safety evaluation and in the licensee's June 10. 1996. and July 1,1996 letters, staff concludes that License No. 34-19089-01 should be amended to authorize the licensee to proceed with the actions described in its July 1. 1996 amendment request: i.e.. implementation of Tasks 1 and 2 of the BRP.
Although the onsite operations are to be conducted under the AMS license, this amendment will be conditioned to require that the contractor's radiological health and safety procedures be submitted for NRC review and approval before any work begins.
This approval is with the further understanding that any funds remaining, after Tasks 1 and 2 of the BRP have been ] aid, will be returned to Bank One for the purpose of increasing the value of 11e letter of credit.
The NRC staff acknowledges that the decommissioning funding instrument that will be in place. if AMS reduces the amount of, the letter of credit. will be significantly less than what the staff has estimated the decommissioning costs to be.
The NRC staff also notes, however, that by allowing AMS to take action to implement Tasks 1 and 2. the on:ite source inventory will be significantly reduced.
The licensee is attempting tc take advantage of a window of oaportunity 3rovided by a waste broker and disposal facility.
Staff believes t,at public lealth and safety will be served by AMS' proceeding with Tasks 1 and 2. even though implementation of those tasks will entail reduction of the line of credit, inasmuch as those tasks will result in removal of the great i
majority of the cobalt-60 inventory at the site.
This is with the understanding that AMS has committed in its July 1. 1996. letter to submit a revised Conceptual Decommissioning Plan and cost estimate by August 30, 1996.
This staff approval is without prejudice to the final NRC staff decision on the acceptability or adequacy of the current decommissioning cost estimate.
concur:
IMNS/DWM/0GC/ Rill l
- o1 i,
,c p0 Mr7 David Cesar
'Vice President:
' Advanced Medical Systems.'Inc.
121 North Eagle Street' Geneva. Ohio 44041-'
Dear Mr. Cesar:
During our May' 7. L1996, meeting.you described a proposal to dispose of.the majority-of your: bulk and sealed cobalt-60, and contaminated waste. We support -
your initiative to remove the majority of the bulk and sealed cobalt-60
- material and contaminated waste from AMS* London Road site.
However. we'have questions.regarding how you intend to fund this initiative in that active licensees; such as AMS that ' decommission portions of their facilities, typically doLso using funds from sources othe~r than those set aside in
. decommissioning financial assurance instruments.
Nevertheless, we are open to-any proposal 'that will improve ' conditions' at the' London Road facility and facilitate eventual decommissioning.
t During the May"7,1996 meeting, you indicated there are time constraints on
- signing a contract for disposal of the material. To facilitate NRC's timely
[
review of your proposal, we need the following information:
1, Other Sources of Fundino for Proposed Removal and Disoosal of Radioloaical Material.
Confirm and demonstrate that AMS has exhausted all reasonable means-to secure funding for the proposed radiological material removal and i'
' disposal other than means that would impact upon'the current decommissioning financial assurance instrument, j
4 2.
Precise Source of Fundino if Funds Set Aside for Decommissioninq are Jsed.
Provide details on the amount and precise source of funding AMS is proposing to use to fund the radiological material removal and disposal.
)
i If the source of funding proposed by AMS could affect the existing
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letter of credit, e.g., funds are proposed to be used whi& /esently i
serve as collateral for the letter of credit, describe how the i
instrument will be affected.
3.
Effect of Material Removal on Decommissionina Plan i
Provide an estimate of the impact on the current decommissioning plan,
-including funding, that will result from the disposal of the material.
If AMS proceeds in accordance with its proposal, it will be required to take
]
the:following actions' 1.
Revision to Decommissionino Plan and Cost Estimate j
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nud wa w,is a)lo to remove and dispose of the sealed sources, bulk
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If AMS ah...a u. i:u.
.m d m2ra w;s t.% freedom of Information
!AdNdtn;ticas 5-YO@
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l sources, and the packaged low-level waste as proposed, it must submit a revised " Conceptual Decommissioning Plan" for NRC approval (original j
plan dated October 20, 1996, is still being reviewed) detailing j
remaining radiological material and plans and costs for decommissioning the facility given the reduced radiological material.
j 2.
SAFSTOR and DECON y
3.
Submittal of "ew Decommissionino Financial Assurance Instrument If funds for the proposed materials removal and disposal are used such that the net value of the current letter of credit is reduced. AMS must submit a new letter of credit for NRC approval.
If AMS proceeds in accordance with its proposal, there will remain for resolution the matter of the acceptability of AMS' estimates of the costs for final decommissioning.
That matter will be addressed separately.
in accordance with 10 CFR 2.790, a copy of this letter and your response will j
j be placed in the NRC Public Document Room (PDR).
If AMS finds it necessary in 1
its response to provide any information that it considers to be 3roprietary under section 2.790(a)(4). it shall file an application for with1olding in accordance with section 2.790(b) and shall also file a non-proprietary version l
that can be placed in the PDR.
f Sincerely, Cynthia D. Pederson. Director i
Division of Nuclear Materials Safety l
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