View source for IA-97-253, Second & Final Response to FOIA Request for Records.Records in App B Available in Pdr.App C Records Encl & Being Placed in PDR

{{Adams
| number = ML20217N949
| issue date = 08/20/1997
| title = Second & Final Response to FOIA Request for Records.Records in App B Available in Pdr.App C Records Encl & Being Placed in PDR
| author name = Powell R
| author affiliation = NRC OFFICE OF ADMINISTRATION (ADM)
| addressee name = Cornett C
| addressee affiliation = External (Affiliation Not Assigned)
| docket = 
| license number = 
| contact person = 
| case reference number = FOIA-97-253
| document report number = NUDOCS 9708260392
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 4
}}

=Text=
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U s. NUCLE AR REZULAT;RY COfiMisslON NHc FOiu Heoutsi Nuvet Hist f"% A                                                                                                            FOIA 253 r.tspoNsE TYPE f) '                      kpb               RESPONSE TO FREEDOM OF                                                   xl''NAL        ( 2nd ) I I r^;it'A' INFORMATION ACT (FOIA) REQUEST g% ,                                                                                                               o^'t m,,,   ,, 0 _W t
DOCKL T NUMB 6 R($1 Mapp/> cable /
RE QUE ST E R C. Lawrence Cornetts Jr.
PART l.-.AoENCY nECORDS REEASED OR NOT LOCATED (See checArcf boAes)
N; agency records subject to the request have been located.
N) additional agency records subject to the request have been located.
Requested records are available through another public distribution program. see Comments section, y     Agency records subject to the request that are identified in Append x(es)      O                  are alret ly available for public inspection and copying et the NRC Public Document Room. 2120 L Street, N.W., Washington, DC.
Agency records subject to the request that are identified in Appendis(es)      C                 are being made available for public inspection and copying X    c: the NRC Public Document Room. 2120 L street, N.W., Washington, DC,in a folder under this FOI A number.
The nonproprietary version of the proposal (s) that you agreed to accept in a %Iephone conversation with a meniber of my staf f is now being made availab!e for public inspection and copying at t! t N RC Public Document Room,21:'o L street, N.W., Washington, DC,in a folder under this FOI A number.
Agency records subject to the request that are identified in Appendin(es)                   may be inspected and copied at the NRC Local Public Document Room identified in the Comments section.
Enclosed is inf ormation on how you may obtain access to and the charges for copying records located at the NRC Public Document Room,2120 L Street, X     N.W., Washington, DC.
X     Agency r( ords subject to the request are enclosed Appendix C Records subject to the request have been referred to another Federal agency (ies) for review and direct response to you.
X     Fees 4
X      You wHl be billed by the N RC for fees totaling s 35 Jh You will receive a refund from the N RC in the amount of s in view of N RC's response to this request, no further action is being taken on appeal letter dated                             , No.
PART 11. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certain Information in the requested records is being withheld from public disclosure pursuant to the exemptions described in and for the rea.ons stated in Part il, B, C, and D. Any released portions of the documer'ts for which ody part of the record is being withheld are being made avai' 'le for public inspection and copying in the NRC Public Document Room,2120 L Street, N.W., Washington, DC in a folder under this FOI A number, COMMENTS This confirms your conference call on July 15, 1997 with Ms. Mary Jean Pool of my staff and staff of NRC's Region III office.                              In that conference call you. narrowed the scope of your request, The re.:ords identified on Appendix B and C are subject to your request.
The fees for processing your request are:
Duplication of 275 pages 0 $0.20~per page (minus 100 free pages) = $35.00 This completes action on your request,                                                                                                                                     d
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RECORDS Al. READ         V)ht.dk  IN THE PDR W .97-253 v
      <<NUDOCS/AD>>             CON 2         Nuclear Regulatory Commission                                         Version 002.000
    =  Records 1             -
5 === Subject / Field / Boolean Results - Select Count                                                17 =
Accession #          Docket            Author Name             Affil         Issued    Microfiche Address 03016055
* NE R3        970508       92928-157/92928-164
  /f'9705150280 (TXT)        Insp rept 30-16055/97-02 on 970331-0401.No violations noted.
Major areas inspected: pump failure incident.
33 9703120002           03016055
* NE R3        970307       92078-161/92078-169 7-         (TXT)        Insp rept 30-16055/97-01 on 961113-1206.No violations noted.
Major arcas inspected: activities authorized by license.
  ]g9702110093            03016055 WEBER,M.F.                       NE R3        960520       91832-235/91832-256 s        (*)          Insp rept 30-36055/96-01 on 960515. Violation regional ltr issued. Major areas inspected: organization & scope of 9702100441         03016055 KURTH,M.                         NE R3        941118       91746-226/91746-248 (g?          (*)          Insp rept 30-16055/94'-01 on 940817-1014. Violations noted. Major areas inspected: City of Cleveland sewer interceptor in AMS
[)'9603140222           03016055 SHEWMAKER,R.E. NE R3                          951222       87467-032/87467-047 (ABS)        Insp rept 30-16055/95-06 on 941011-0721.No violations noted.
Major areas inspected: hot cell, waste hold-up tank room, original Arrows-Scroll, ENTER-Select, F10-Mark For Download, CTRL-F9-Continue Download.
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      <<NUDOCS/AD>>            CON 2          Nuclear Regulatory Commission                                         Version 002.000
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10 === Subject / Field / Boolean Results = Select Cvunt                                                 17 =
Accession #          Docket            Author Name             Affil         Issued    Microfiche Address b3bk6bbb        WhBbk,M F                  NE          9520b        86hkbb9/b6 9                                  b39 bh 9bkb$bbkkb(*)          Insp rept 30-16055/95-05 on 950403-1103.No violations noted.
Major areas inspected: determination of whether removal of 03016055
* NE R3       940831       8 5 6 31 - 10 C .'" 5 6 31 - 114
$h9509210351 (*)          Insp rept 30-16055/94-02 on 940706-07.Violatons noted. M. tor areas inspected: organization & scope of program, A 9509200008            03016055
* NE R3       930226       85630-058/85630-081
(*)          Insp rept 30-16055/93-01 on 930119-20.No violations noted. Major a                        areas inspected: organization, internal audits or
  'i 9505030047           03016055 GLINSKI,R.L.                      NE R3       950424       83720-118/83720-163 f'N           (ABS)        Insp rept 30-16055/95-04 on 950328 No violations noted. Major lQ                      areas. inspected: sample receipt & preparation,radioanalytical 9503080082         03016055 SLAWINSKI,W.                      NE R3        950302       82969-301/82969-310 (ABS)        Insp rept 30-16055/95-01 on 941212-13 & 950118.No violations noted. Major areas inspected: water flooding problems & licensee
* Arrow -Scroll, ENTER-Select, F10-Mark For Download, CTRL-F9-Continue Download.
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        = Records 11                                                                                    Version 002.000 15 === Subject / Field / Boolean Results = Select Count                      17 =
Accession #           Docket            Author Name         Affil Issued     Microfiche Address l])9412150013            03016055        KURTH,M.                NE R3    941205        82031-038/82031-060 (ABS)        Insp rept 30-16055/94-03 on 940817-1014. Apparent violations s                      being considered for enforcement actions. Major areas
      .)9412070037             03016055       SLAWINSKI,W.             NE R3    941129        81942-145/81942-153 (ABS)        Insp rept 30-16055/94-04 on 941011-12. Violation noted.Maior
  !:;,')9411160088 areas inspected: implementation of facility radiological 03016055        SLAWINSKI,W.             NE R3   941011 (ABS)                                                                       81746-238/81746-266 Insp rept 30-16055/93-03 on 930804-1214. Violations noted. Major areas inspected: employees involved in liquid radwaste effluent if9404270116             03016055        SLAWINSKI,W.            NE R3    940413        78995-311/78995-324
(*)          Insp rept 30-16055/94-01 on 940222-25 Violation noted. Major areas inspected: circumstances surrounding licensee reported ff,9308100033              03016055 SLAWINSKI,W.                   NE R3    930729        82711-252/82711-278
(*)          Insp rept 30-16055/93-02 on 930419 & 0524-28. Violations noted. Major areas inspected:physica' inventory & pre-inventory
_.,       -                                                                                                      ~
        <<NUDOCS/AD>>             CON 2           Nuclear Regulatory Commission                       Version 002.000
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17 === Subject / Field / Boolean Results = Select Count                       17 =
Accession #         Docket             Author Name          Affil     Issued     Microfiche Address N 9306300301               03016055 CANIANO,R.J.                     NRCZ    930520        75513-020/75513-021
(*)          Onsite Insp/ Survey Plan of Advanced Medical Sys on 930524-3                          28. Major areas inspected:AMS b1dg schematics or blueprints e 9303290130             03016055 SRENIAWSKI,D.J. NE R3                    930313        74374-021/74374-037
(*)          Assessment of license 34-19089-01 on 921027-1217.No concerns or violations noted. Major areas inspected:AMS procedures & records f
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Re    FOIA-97-253 APPENDIX C RECORDS BEING RELEASED IN THEIR ENTIRETY HQ2   DATE        DESCRIPTION /(PAGE COUNT)     _.,
: 1. 09/03/93      Letter C. Norelius to AMS re:      samples (2 pages)
: 2. 09/17/93      Letter C. Norelius to AMS re:      response to inspection report (8 pages)
: 3. 08/02/93      Letter C. Norelius to AMS re:      special safety inspection (23 pages)
: 4. 06/27/97     Letter S. Haddock to M. Weber re:       Emergency Exercise Re-scheduling (1 page)
: 5. 12/65        ORISE Final Report re: Evaluation of the operational Radiation Safety and Fire Protection Programs of AMS, London Road Facility (127 pages)
: 6. 04/89        ORISE Final Report re:     Radiation Survey, AMS London Road Facility (114 pages) 4

June 30,1997 F0WPAREQUEST US Nuclear Regulatory Commission                                   OsseNo:            v'7 - X5 Attn: FOIA/LPDR                                                    Date Rodd-        ''7-s2-99 Attn: Russell Powell                                                Ac60nOff:          Pot >'-
Washington DC 20555                                                 W08SO:           Op.- , M '? 7 4 T(-
Re:      Freedom ofInformation Restss_1

==Dear Mr. Powell:==

Lis is a request under the Freedom of Information Act ("FOIA"),5 U.S.C. Section 552.
Please provide available information about what is known and not known about the existing and potential current and future threats to human heath, property and the environment posed by the Advanced Mcdical Systems, Inc. (AMS) installation at 1020 London Rd, Cleveland, Ohio 44110 and associated:
          . Radiation
          . Padioactive and/or toxic materials and waste
          . Activities (including transportation of materials to and from the facility) and
          . Contamination (including that in the soil, sewers, etc. from previous releases)
          . Any other potentially associated environmental impact generators (including catastrophes such as train wrecks, tornadoes, etc.)
Please also provide this for calendar years 1995 and 1996.
His is also a request for available information on steps recently taken, steps underway, and steps planned by AMS, NRC, Ohio EPA, Cuyahoga County emergency preparedness organizations and other entities to help mimmize likel as well as potential environmental impacts, both under normal conditions and in event of an accident or catastrophe.
Available and upcoming opportunities for members of the general public to review draft submittals and permit conditions, cdl for heanngs, and to participate in activities such as emergency response exercises are also requested.
In addition, this is a request for available information on which individuals and institutions are financially responsible for AMS and for any damage to the surrounding community, the extent of their liability, and their ability to pay. In addition, please provide available information on individurls and institutions that would be considered to be potentially responsible parties if the site were to become under the jurisdiction of CERCLA / SARA Superfund programs, along with available information on the abdity of such entities to pay for associated studies, cleanup, damages, etc. This request includes the results of any credit checks and title searches conducted concerning AMS and associated entities, along with the general procedures used for such investigations.
064 Qff'

FOIA Request June 30,1997 Page 2 I
Please also provide available infonnation on the cost of damages that a catastrophe at AMS could cause and the extent of fmancial liability on the part of AMS and associated entities for such damages, along with the ability of associated organizations and institutions to pay for such damages.
Since this could change drastically if the site were under Superfund versus current regulations, please provide this information for both scenarios.
Unsubstantiated reports concerning the above matters alone are inadequate, and available proof concerning what is known and not known is needed. in order to focilitate an independent review and      I audit. This FOIA aquest is intended to help fulfill this purpose. Any summaries of how the specific documents provided could be used to provide such an understanding would be most helpful, along with the conclusions of others concerning these matters (and the reasons for their conclusions). Any documents not specifically requested that would increase such understanding are also requested, Your cooperation in this matter is greatly appreciated.
To help clarify the types of information requested concerning AMS in Cleveland and associated matters, please be sure to include the following:
: 1. Any existing and currently proposed Emergency Response Plans for responding to fire, explosion, train deraihnent, or other events that could result in a release of radioative material, along with any meeting notes or comments on the plans and dates by which comments or calls for hearings must be filed
: 2. He existing and proposed onsite Radiological Contingency Plan and any comments on the plau and dates by which comments or calls for hearings must be filed (if different from item 1)
: 3. The requirements for, plaru for, schedule for, results of, and comments on any proposed or actual exercises with offsite emergency response personnel since June 1994, and for associated audits -- along with the opportunities for public comment and participation in future exercises and associated plannmg and dates by which comments or calls for hearings must be filed (we understand that exercises are being planned for August 1997)
: 4. The requirements for, plans for, results of and comments on any proposed or actual reviews of -
emergency response programs and emergency plan procedures, training, equipment, and supplies since June 1994.
: 5. Any correspondence, meeting notes, etc, related to the possibility of AMS having a program involving:
                 . Continuous monitoring and automatic audible alarms (with repeaters inside nearby buildings when needed) in event of a dangerous release to the environment from AMS and
                 . Associated training programs to alert and train the community as to what to do if an alarm sounds (shut windows, turn of air intake vents, seal creks, etc., or evacuate),
Please take this as a request for inclusion of such a program in AMS's emergency response plans and associated programs and for them to be tested during the phnned exercises in August, if possible.

FOIA Request June 30,1997 Page 3 Also please prove any proposals, comments, contingency plans or other documents involving the possibility of AMS or any other associated entity notifying business and persons in the surrounding com nunity in event of an emergency at AMS and/or for providing appropriate training on how ausinesses and persons should respond.
: 6. Availabie information on recent (1995 and 1996), current and potential future impacts on public health and welfare and to the environment by AMS's past, current and potential future emissions of radiation and radionuclides to the environment. These rW should be stated in terms of cancer risks, potential radiation and/or radionuclide exposure, N idation of property values, and any other matters pertinent to the public health and welfare, the environment or business, and associated assumptions and resuhs (when available). This information should include details on the e dsting or possible future that could substantively influence the hazard (anticipated emissions, potential future catastrophic events, assurned weather, etc.). Please be sure to include available information on associated probabilities of occurrence, assumptions, models, uncertainties and comments on such studies and estimates.
The concept of current impacts should be taken with reasonable flexibly (it is not meant to mean at this instant, if that would unduly restrict access to pertinent information). When completely up to date information is unavailable, please include impacts for the most recent par for which appropriate data is available for a given parameter, with appropriate cavea.ts.
: 7. All available information concerning recent (since June,1994) activities, current activities, and taking place and those activities planned within the Advanced Medical Systems' London road site involving radioactive materials within the past year, and plans for the future.
: 8. All available information concerning the containment, pollution control, monitoring, and emergency response programs recently in place (since June 1994), currently in place and those planned to prevent or reduce contamination and/or emissions into the surrounding environment and to deal with any unexpected emissions should they occur -- along available information on their expected effectiveness and associated emissions, emission reductions, levels of potential caposure in the surrounding community, and human health, welfare and environmentalimpacts
: 9. The design and results of pertinent environmental monitoring and modeling programs associated with the aforementioned site and its recent (1994 and 1995), current (for the current calendar year, including the most recent data available) and projected future impacts on the surrounding environment. Please include where and when readings were taken or results modeled, the measurement or modeling protocols used, calibration records (or assumptions) and the precise type of units in which the measurements were taken or estimates made (committed effective dose equivalent exposure in mrem /yr, etc.) covering all radiation monitoring, exposure estimates, etc. performed and all associated assumptions. Please include all available comments and sununary reports on this monitoring and modeling.
: 10. All current permits, licenses, or other similar documents issued to the aforementioned facility and all associated permit, license, etc. conditions and requirements, along with all associated comments on those permits, licenses, etc. Please also include all associated proposals and submittals by Advanced Medical Systems, Inc. , as well as all requirements for future permits,

FOIA Request June 30,1997 Page 4 licenses, etc. and renewals and associated schedules, submittals by AMS, and opportunities for public comment, or deadlines for petitioning for hearings, etc.
I 1. All available data on the quantities of radioactive material and mrem /hr potential exposure recently (since June 1994) and currently at the advanced Medical Systems site, significant changes in the inventory or estimated inventory since June 1994, plans f r future changes in inventory (tncluding decontamination plans, etc.), types of containment and pellution controls, detailed design and condition of containment and pollution controls, effectiveness of containment and pollution controls against fire, sabotage train derailments, tornadoes, corrosion and other sources of degradation, monitoring programs to verify containment and effectiveness of pollution controls, etc.-with special emphasis on the Waste Holdup Tank Room (and associated floor sbb) and any other facilities containing substantial quantities of radioactive materials or activities having a potential to cause emissions into the environment (such as shot bhsting, steam cleaning, and other decontamination methods).
: 12. Any available information on why the water flooding the basement of the AMS facility in late 1994 and 1995 became radioactive, and the hazards posed by this water (before and after treatment) to workers and the surrounding community, along with the current location and degree of contamination of this water and associated cleanup resins, and associated hazards and estimates of associated existing or potential future hazards to workers and the public. Of particular concern would be the poter.tial for backwash from the flooded basement leading to the contaminated water that ended up in the basement and what that may imply concerning future hazards from surface water, ground water, sewer, etc. pathways. (Please include pertinent information on drainage (including sewers and ground water hydrogeology) associated with the AMS site and associated contamination, the integrity of the AMS floor slab, plans to descrmine its integrity, etc.
: 13. All information submitted by Advanced Medical Systems, Inc or other entities (Ohio EPA, etc.)
since June 1994 to the Nuclear Regulatory Commission pertinent to the aforementioned facility and/or its existing and potential environmentalimpacts
: 14. All information related to existing and potential financial liability for impacts on the surrounding community, including the identity of:
              . All past and current owners and investors in AMS and providers of their Cobalt 60 and other radioisotopes, along with
              .   'Ihc identity of others who were financially involved paying for operations, monitoring and clean-up While liability is currently limited under current Atomic Energy Act and NRC regulations, this request is broader than one just covering that legislation, although liabilities under current conditions are also requested.
* In addition to this, available information on the identity and financial condition of any individuals, institutions, companies, providers of Cobalt 60 or other entities associated with AMS throughout the entire history of AMS and prior owners that might be identified as potentially responsible parties. This information is to aid in an assessment of the situation if

FOIA Request June 30,1997 Page 5 AMS were to go bankrupt and the site fall under the EPA CERCLA / SARA regulations (Superfund) -- or if other circumstances (such as legislation) would put the site under Superfund. Of course, the individuals and institutions fmancially responsible for AMS activities and liabilities is also requested.. All documentation linking these individuals and organizations to AMS shouki also be provided, along with copies of any correspondence with such individuals or meeting notes concerning the AMS site and associated matters.
: 15. All existing and potential future opportunities for concerned members of the general public and the business community to have or to request opportunities to review and mmment or hearings on proposed orders, emergency response plans, permits, licenses, exercises, etc, any comments submitted, etc. Please provide a list of all such opportunities, and the actual or projected dates for those opportunities manifesting, where pertinent notification vJll take place, and the deadlines for submitting comments, requests for hearings, etc. This letter also requests routine notification when such opportunities manifest in the future. Please be sure to include in how interested members of the community can become involved in emergency response exercises planned for late . August 1997, the review of associated emergency response plans, etc.
: 16. Transcripts of hearings, and other correspondence concerning AMS etc. since June,1994
: 17. Any correspondence, transcripts, records, or other entities related to public relations, public panicipation, risk perception, or encouraging or discouraging participation by individuals, organizations or other entities in matters related to AMS and NRC's actions or jurisdiction over AMS.
: 18. The most recent ORISE report concerning the AMS site and any conunents and correspondence related to the report in NRC fdes
: 19. All pertinent inspection and environmental monitoring reports from June,1994 to the present and any risk assessments based on reports, or other information
: 20. Copics of all correspondence, m:eting notes, etc. with the City of Cleveland or other entities concerning any matter mentioned above since June 1994.
While all of the above may tecm very complex, and some of it repetitive, much of this detail is to avoid important gaps in the information received. The mtent of this request is to obtain a complete record of available infonnation concerning or related to:
       . The impacts and potential impacts (and associated probabilities) currently posed to the surrounding community by AMS, how those impacts or potential impacts may have changed in the very recent past (when absolutely current information is unavailable)
       . Plans to change those environmental impacts and potential environmental impacts in the future (and expected associated impacts)
       . Potentialimpacts in event of catastrophes and their probabilities
        . Possible methods of reducing those impacts (including financialimpacts)
        . Opportunities for concerned individuals and organizations to review associated documents, draft

FOIA Request                                                                                                4 June 30,1997 Page 6 permits, draft licenses, emergency retponse plans, etc. and to suggest or compel improvements to further reduce the impacts or potentialimpacts, and/or to petition for and participate in hearings etc.
Copies of any annotations based on this letter or checklists prepared to assure that the documents requested are provided are also requested. This FOIA request covers many key concerns related to AMS, and any notes concerning which documents or portions of documents relate to which questions would be greatly appreciated.
If you regard any of the documents as exempt from required disclosure under FOIA, I request that you disclose them nevertheless, as such disclosure would serve the public interest of educating citizens. Sec 10 C.F R. i 10N.1 (authorizing disclosure of documents exempt from FOIA disclosure where such disclosure is in the public interest).
If any of the requested documents include classified or restricted information and the volume of the l           material makes a lengthy declassification review necessary, I request the prompt release of all portions of the document marked Unclassified, For Ofiicial Use Only, or Declassified. In addition, I request that the remaining classified portions undergo a careful review for the purpose of declassification, in whole or in part, and that you release to us all reasonably segregable portions of the classified record, except those portions that could reasonably damage national security.
As you know, an agency cannot rely simply on the markings of a document to deny its release. For a document to be withheld under Exemption 1 of FOIA, it must be reviewed and found to be in fact properly classified pursuant to both procedural and substantive criteria found in the governing executive order 5 U.S.C. 6 552(b)(1)(B). See also L2sar v. U.S. Dep't of Justice. 636 F.2d 472, 483 (D.C. Cir.1980); Southam News v. INS,674 F. Supp. 881,884 (D.D.C.1987). This requires an actual, substantive review of the materials and their classification markings.
Should you decide to invoke a FOIA exemption, please includei n your full or partial denial letter sufficient information for me to appeal the denial. To comport with legal requirements this information must include, inter alia:
: 1. Basic factual material about each withheld item, including the originator, date, length, general subject matter, and location of each item.
: 2. Explanations and justifications for denial, including the identification of the category within the goveming executive order or statutory provision under which the withheld document (or portion thereof) was found to be subject to classification; at what level the entire document was ultimately classified and the nature and variety of the document's portion-marking; and, most importantly, explanations of how each exemption fits the withheld material.
The information requested is to be released to an investor concerned about the safety of his employees, neighbors, investments and potentialinvestments in the Collinwood area and to the Earth Day Coalition, and the Collinwood flomeowners and Tenants Association, which are reportedly non-1 9

FOIA Request June 30,1997 Page 7 profit, tax-exemp public-education, research and environmental organizations. It is expected that the information dialosed pursuant to this request will be made available by these organizations to the public and others engaged in policy analysis and research, including historians, area specialists, and journalists. Three copies of the requested files should be provided, if possible, so that the aforementioned organizations and associated consultants can study them simultaneously.
FOIA permits the waiver of search and copy fees where the release of information is in the public interest. 5 U.S.C. i 552(a)(4)(A)(iii). See also 10 C.F.R. 610N.9(a)(8). Release of the documents requested here would contribute significantly to public understanding of these matters. The information is to be made available to the public through the methods specified above. For these reasons, this request qualifies for a fee waiver, and I ask that you waive all fees in connection with i         tids request.
I appreciate your help in obtaining this information. As provided in FOIA, I will expect a reply
:         within ten working days. If you need further information about this request, please contact me by l          phone at (216) 247-5021 in order to speed consideration of this matter.
Sincerely, C. W~ %4},
C. Lawrence Comett, Jr.
cc:
Mr Roy Caniano Acting Director, Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission, Region III 801 Warrensville Rd.
Lisle, Illinois 60532-4361 John Madero Chief, Nuclear Materials Branch U.S. Nuclear Regulatory Commission, Region III 801 Warrensville Rd.
Lisle, Illinois 60532-4361 Ken Schultz Environmental Manager Ohio EPA Division of Emergency and Remedial Response 1800 Watermark Drive Columbus, Ohio' 43216 1
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SEP 0 31993                                   !
t Advanced Medical Systems, Inc.
ATTH: Ms. Sherry Stein                                  License No. 34-19089-01      !
Docket No. 030-16055         !
Director of Regulatory Affairs                                               '
1020 London Road Cleveland, OH 44110

==Dear Ms. Stein:==

This responds to your {{letter dated|date=August 12, 1993|text=letter dated August 12, 1993}}, regarding radioanalytical         l measurements that were made on samples taken from the sewer manholes, catch basins and sewage treatment facilities serving the area around your London l
Road facility. Those measurements were documented in our Inspection Report            l No. 99990003/93010(ORSS) issued August 2, 1993.                                      '
You specifically indicated in your {{letter dated|date=August 12, 1993|text=August 12, 1993, letter}} that: (1) you were curious to note the findings of cesium-137 in manholes- and catch basins, and at the Easterly Wastewater Treatment Plant; and:(2) the levels of cesium-137 and _ cobalt-60 found at the Easterly Wastewater Treatment Plant indicate a source of discharge of that material other than your facility.
As my staff discussed with you and Mark Loeser of your staff during a
    . telephone conversation on September 1,- 1993, there was no cobalt-60 or cesium-137 identified in the sludge and soil samples collected at the Easterly Wastewater Treatment Plant. The numbers recorded in Table 11 for the Easterly samplos are the lower limits of detection for that material in the sample being counted and the counting results of all Easterly samples were less than the lower limit of detection. This was not clearly stated in Table II of our inspection report, and we regret.any confusion this may have caused  .
Cesium-137 was identified in one manhole sample (ladder rung scrapings from Manhole #1) and one catch basin sample (Mandalay Avenue and London Road). As you can see from Table 1 attached to our inspection report, the background levels of cesium-137 in soil samples taken in the areas' surrounding your London Road facility range from 0.22 picocuries of cesium-137 per gram of soil to 1.34 picoeuries of cesium-137 per gram of soil. .These background levels of cesium-137 are caused by past nuclear weapons testing around the world. The cesium identified in the manhole and catch basin cannot be differentiated from background levels and, consequently, this data is not helpful in determining -
the source' of cobalt-60 contamination identified at the Southerly Wastewater Treatment Plant.
A ge93 M N 99-J\

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1 Advanced Medical Systems, Inc.            2 SEP 0 31993 We would be glad to address any further questions you may have regarding our inspection- report and we will be issuing a, separate inspection repcrt of our continuing review of-gs1 Advanced Medical Systems, Inc. and Picker licensed material discharges to th,e-sanitary sewers. Since your letter addressed a matter discussed in our inspection report, we are sending copies of this letter to the recipients of the inspection report.
Sincerely, ORIGINAt SIGNED BY CHARLES E. N0ltEllVS Charles E. Norelius, Director Division of Radiation Safety
                                                         .and Safeguards cc: Michael White, Mayor, City of Cleveland Roosevelt Coats, Councilman, Ward 10, City of Cleveland Michael Polensek, Counctiman. .
Ward 11, City of Cleveland Michael Konicek, Department of Public Utilities, City of Cleveland Lisa Mehringer, Department of Law, City of Cleveland Erwin Odeal, Northeast Ohio Regional Sewer District Robert Owen, Ohio Department of liealth-Erv- Ball, cuyahoga County                                                              ;
Board of Health bec:    PUBLIC W. Slawinski, Rlli J. Turdici, OED0
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_OAuAbd SEP 171993 Advanced Medical Systems, Inc.
ATTN: Ms. Sherry Stein                                 License No. 34-19089-01 Docket No. 030-16055 Director of Regulatory Affairs 121 North Eagle Street Geneva, OH 44041

==Dear Ms. Stein:==

==SUBJECT:==
RESPONSE TO INSPECTION REPORT NO. 030-16055/93002(DRSS)
This acknowledges receipt of your letters dated August 10 and 11,1993, in response to our {{letter dated|date=August 2, 1993|text=letter dated August 2,1993}}, transmitting Ins'iaction Reports No. 030-16055/93002(DRSS) and No. 99990003/93010(DRSS).
We have reviewed the corrective actions described in your letter dated l
l August 10, 1993, and find adequate your response to concerns No I and 4, pertaining to the compression plug in the basement floor drain and the failure to identify and control potentially contaminated waste water. With respect to your response to our second concern regarding surveys to identify changing radiological conditions, you will also need to conduct radiation measurements on the outside walls of the facility if radiation levels-inside
!       exceed 10 CFR 20.105 limits. Your response to this concern indicates that i       only the inside wall will be surveyed. In regard to your response to our third concern, it is our understanding, based upon a discussion with Mr. Mark Loeser, that in addition to improvements in your survey documentation, you have also expanded the area surveys to include overhead        ,
piping, wall penetrations and other locations which could exhibit elevated rattiation levels. These corrective actions will be examined during a future inspection.                                             .
Regarding your intent to contact the Regiot. III Office 24-hours prior to any release of radioactive liquids to the sanitary sewer system, the Region III contacts are Roy Capiano and/or John Madera. Messrs Caniano and Madera can be contacted Monday th , ugh Friday during normal working hours at (708) 790-5500.
Should you plan tn release radioactive liquids during off-hours or on weekends, please contact the NRC Operations Center at (301) 951-0550, and request that either Mr. Caniano or Madera be contacted.
Your {{letter dated|date=August 11, 1993|text=August 11, 1993 letter}} alerted us to an error in Inspection Report No. 030-16055/93002(DRSS) relating to sanitary sewer discharges for 1986. The error you describe appears to exist and was promulgated by an erroneous and partially illegible entry in your sanitary sewer discharge log for 1986. The discharge log appears to show that the final discharge made to the sanitary gM
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4 Advanced Medical Systems, Inc.                                  ~SEP 171933   )
sewer system in 1986 occurred following an October 6, 1986 release, and that the cumulative total of cobalt-60 released in 1986 was 51.157 mil 11 curies.
NRC Inspection Report No. 030-16055/87001(DRSS), issued on March 4,1987, also indicates that a total of 51.157 millicuriet was discharged to the sanitary sewer system in 1986. However, based on Mr. Slawinski's recent telephone conversation with Mark LO:ser of your staff, it appears that the finkl log entry for 1986 was in reality the first sanitary sewer discharge for 1987.
The first sanitary sewer discharge for 1987 was accurately recorded as a 1987 release; however, it was also mistakenly listed in your log as a 1986 discharge. Consequently, the correct amount of cobalt-60 listed in your discharge log as released to the sanitary sewer system in 1986 should be 35.6 mil 11 curies, not 51.2 millicuries as previously reported. To correct this error, we have attached a revised Figure-I for Inspection Report No. 030-16055/93002(DRSS),
If you have any questions, please contact Mr. Caniano or Madera of my staff.
Sincerely, ORIGig sicuto BY CN L NM '
Charles E. Norelius, Director l                                                 Division of Radiation Safety 1                                                   and Safeguards

==Attachment:==
Revised Figure I cc w/ attachment:
Michael White, Mayor, City of Cleveland Roosevelt Coats, Councilman, f-           Ward 10, City of Cleveland Michael Polensek, Councilman, Public Utilities, City of Cleveland Lisa Mehringer, Department of Law, City of Cleveland                                                '
Erwin Odeal, Northeast Ohio Regional Sewer District Robert Owen, Ohio Department of Health Erv Ball, cuyahoga County Board of Health Michael Konicek, Dept. of Public Utilities, City of Cleveland bec w/ attachment and w/1trs dtd 08/10/93 and 8/11/93:
J. Glenn, HMSS/IMAB F. Combs, NMSS/IMAB                               '
C. Jones, NMSS/IM0B G. Shear, Rill N
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REVISED Sept (193                        .
g,    ,g ADVANCED MEDICAL SYSTEMS Cumulative Sanitary Sewer Release Activity vs. Year
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Advanced Medical Systems,Inc.
121    North Eagle Street . Geneva. Ohio 44041                                             ,u.
216)4664671 , TWX 4332135 ATC UI FAX (216) 466-0186                                     *;
d; l.lCENSE Fil.E        l 3Y
                                                                                       / 9o 3 9_of August 11, 1993 Mr. John Madera U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:      Inspection Report No.
Shown in Figure 1           030-16055/93002(DRSS); Error in AMS' 1986 Discharge

==Dear Mr. Madera:==

Please beofadvised discharge        51.2 mCl. that Figure 1 attached to the above Inspection Report shows a discharge, without correcting for delay factors,The                  correct amount was 35.602 mCl, m 209.217 mCl, rather than 225 mci.
Mr. Mark Loeser has discussed this error with Mr. Wayne Slawinski of your office.
Your assistance in correcting this error is most appreciated.
Sincerely,                                                                       '
SHERRY J.           IN SJS/cs cc: J. Grobe - USNRC
                                                           /
lL If'                             AUG 16199)

Adv'anced Medical Systems,Inc.
  ;
* 121 North Eagle Street .' Geneva, Ohio 44041                                              h *^
                                                                                               ,i (213<66-4671- 1W)(4332-135 ATC UI ' FAX (216) 4664186 0-,                                     ,   ,
Au gust _10,1993 Mr. John Madera U. S. Nuclear Regulatory Commission
              . Region III 799 Rcosevelt Road Glen Ellyn. Illinois 60137 RE:     AMS Byproduct Material License No. 34-19089-01; Docket No. 030-16055;
;                       Inspection Report Nos. 99990003/93010(DRSS); 030-16055/93002(DRSS)
P I               

==Dear Mr. Madera:==

l              _ This letter addresses the four concerns identified by NRC Region III in your {{letter dated|date=August 2, 1993|text=letter dated August 2,1993}}. In addition to the four issues of concern Advanced Medical Systems, Inc. will also address additional actions taken to date as well as our
;               current status. We did wish to point out the fact that AMS has never been licensed for, nor utilized either T-232 or K-40. Further, the only C-137 AMS has ever been licensed for is in the form of sealed sources. AMS has never fabricated C-137
,                sources. _ Thus, the cesium found at the Northeast Ohio Regional Sewer District
                ,Wastewater Treatment Plant was not discharged by AMS.
(1)    Back Basement Floor plun Drain plun The first concern addressed is the reliability of 'the removable compression plug in the back basement floor drain. Following receipt and review of the inspection report No. 030-16055/93002(DRSS) on August 3,1993, un evaluation of the back basement floor drain, which has the floor drain that is of concern and a ten inch capped stand pipe, was conducted the morning of August 4,1993. The cap on the stand pipe is loose fitting to allow a pressure buildup to be released but will prevent water discharge in the event the basement is flooded above this level. . The inspection of the floor drain revealed that due to its construction, a replacement compression type floor drain plug would not alleviate the concerns expressed by the NRC Region III.
Following t discussion with Mr. Ed Svigel, AMS's Engineering Manager, and Mr. Roy Cantano of your office, it was decided by AMS to permanently seal the back basement floor drain. This action would prevent any uncontrolled release of liquid from the floor-drain and still provide over-pressure protection of the drainage system via the capped standpipe. On the morning of August 5,1993, the back basement floor drain _ was filled with approximately a fourteen inch column of concrete. To prevent a loss of concrete through the drainage system, a bottom support was constructed to support the weight of the concrete until it sol!dified. AMS believes- this action adequately addresses the concern of the reliability of the back basement floor drain.
RECEIVED c
pa#W                                                        AUG 131993 REGION 2N131993   -

                                                                                                               $,p.
t' 3 Mr. John Madera                             2.                       August 10, 1993 (2)   Dutside Surveys of AMS' Fenced-in properiy                                       !
The second concern addressed by the inspection was elevated radiation levels on a small portion of the west wall and a small area of the south wall adjacent to the low level waste storage area and isotope warehouse respectively. This situation was corrected at the time of inspection. I would like to emphasize that the entire facility is posted as a restricted area and this includes the fenced-in area surrounding the north, west, and south sides of the building. Your inspection revealed the fence was in good condition and was not compromL .i in any fashion. The inspection also noted that radiation levels at the fence line were at background levels and pose no health and safety concern to the general public. Ilowever, to eliminate this concern, AMS has implemented a more conservative approach. Whenever radioactive material is moved within the facility, a radial. ion measurement on the inside wall is conducted to ensure the regulations are met. This approach will remain in effect until AMS revises its procedures to l                                         comply with the new requirements of 10 CFR 20 later this year.
L                                   (3)'  Specific Identification on Survey Documentation of Localized Areas of l
Elgvated Radiation Within the Pacilit.I The third area of concern was the lack of specific documentation of localized hot spots during radiation surveys of restricted areas. Let me state that AMS personnel are keenly aware of these hot spots, and I can appreciate the NRC's concern for the lack of documentation for trend analysis, Therefore, upon learning of the NRC concern at the th of the inspection, AMS immediately implemented a documentation procedure for general area radiation levels which now includes identification radiation hot spot 'ocation and radiation level measurements. In addition to this docun.entation, AMS has also worked, and coatinues to work, toward reducing the overall radiation levels of the facility and the areas of elevated radiation.
(4)    Identification and Control of potentially Contaminated Wastewater from Floor Moppinses The final concern expressed in the inspection was potentially contaminated wastewater from unrestricted area clean up. While I cannot address what occurred before my arrival at AMS, I can discuss-what procedures were implemented after I became RSO. Regarding unrestricted area clean up, a process was implemented to ensure there was no contamination outside restricted areas. This process includes periodic clean up of occupied unrestricted areas. This periodic clean

- - - - - - - - - - - - - - - ~ ~                                                ~
i_                           .
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                                                               .,                                                     y9,x a
Mr.- John Madera                               %
3.
August 10,1993 up ;ir.volves three steps: -(1) The area la swept, and the floor sweepings are checked for contamination; (2) Each c.ection is swept again using masselin cleaning cloths which are again checked for contamination (these first two steps ensure there 18 no contamination in unrestricted areAsi; (3) Following confirmation that the areas are free from any contamination, each area is then damp mopped.            I feel that this procedure edequately prevents the possibility of potential contamination of wastewater.
In addition, the following actions have been taken with respect to the hot cell sink was verified shut and tagged The                             not to be operated. p valve value. was also seal wired to prevent inadvertent operation of this During a visit by Mr. Wayne Slavinski of your office on the afternoon     of August 3,1993, we also clarified some potential ambiguity of ISP-12, Liquid Waste Discharge Procedure.
intention of changing +hia procedure at this time for two reasons:AMS,     (1) however, has no AMS does not generate liquid waste at this time and has no intention of generating and/or discharging radioactive liquid waste in the fut.ure, and (2) upon implementation of the revised 10 CFR 20, we will not useddischarge         radioactive liquid due to the composttion of the isotope at this facility.
Ilowever, to ensure there is no misunderstanding regarding ISP-12 in the unforeseen event AMS is required to conduct a radioactive liquid
{
discharge, to  radioactiveAMS li   will voluntarily notify NRC Region III 24 hours prior other licensees. quid discharge even though this is not required of any tank for at least five minutes prior to sampling.Further, Tank agitation will       regarding Section continue until the sample la drawn.
                                           ' be drawn off using a standard water column sampling             -
                                                                                                                      . The probeSection 5.2.2 state water column sampling probe is approximately three feet long and requires the 200 gallon blue batch / sampling tank to be at least half full and then only the top of the tank would be sampled. AMS will use a large beaker to draw approximately 1,000 mi sample. A subsample of -
50 ml will be withdrawn-from the 1,000 m1 sample. Finally, a 5 m1 semple will be withdrawn from the 50 m1 subsample.
These will all be done will take within place.a five minute time frame to' ensure no settling out         S  of Co '
The rest of the procedure will be followed verbatim.
Also note that during Mr. Slawinski and Mr. Walker's visit on August 3,1993, it was determined that based on their observation, the five minute agi'ation is sufficient to ensure adequate mixing of the water in the batch / sampling tank. FinaHy, the "New Cell" computer program appears adequate for determining the number of ganons that may be discharged per day given the specific activity of the liquid to be discharged.

I      '
                    .o t\, , .
                            .,                                                                        e a
Mr. John Madera                           t' 4.
August 10,1993 General progress Lastly, in keeping with AMS's practice to provide continuing written updates to the NRC of our progress, we subett tt.e following: We have spent much of the past two weeks for J. L.prepar!ng Shepherd a& shipmuni, Associates.of eight Co'' sources to Southwest Research Institute ship these sources.                       We are currently awaiting the authorization to August 18, 1993.           It isanticipated   the shipment will take place on or about J. L. Shepherd & Associates airo said they would approach Southwcet Research lurtitute concerning expansion of tLe license limits to allow shipment of our sonces in a more timely manner.
response to date on this request.                                  We have had no further Associates.                               We are still negotiating with J. L. Shepherd &-
remainder of outRegarding    the 10,000+   curies 8
of bulk Co'' In the GE 500 cash and the                   '
!                    arrangements soon-      old picker /AMS Co ' sources, we hope to complete these
[                    Intone Inventory _hgnLEhtg I
With respect to the - isotope inventory, we anticipate having the hot cell-decontaminated August     20, 1993      above and- below the table top by the end of work on Friday, L                 ,
of    the front floor plug la successfulin dislodging the plug from its rece will keep you updated as to our progress.
As    always, should you have any additional questions, please do not hesitate to contact toe at 216/692-3269.
liecpectfully i
MARK W. LOESER MWL/cs f
i                                                                __-

AUG 0 21993 Advanced Medical Systems, Inc.                               License No. 34-19039-01 ATTN: Ms. Sherry Stein                                       Docket No. 030-16055 Director of Regulatory Affairs 1020 London Road Cleveland, OH 44110

==Dear Ms. Stein:==

This refers to the special saftty inspection conducted at the Advanced Medical Systems, Inc. (AMS) London Road facility by Messrs. Wayne Slawinski and Kevin Null on April 19, 1993, to review your physical inventory and pre-inventory hot cell decontamination projects. This also refers to the special dafety inspection conducted in and around your facility and neighboring areas by Messrs. Slawinski, Donald Sreniawski, Raymant Glinski, Robert Hays and Keith Andre of the NRC Region Ill staff on May 24-28, 1993, and continuing with analysis in our office through June 18, 1993. Assistance during this inspection was provided by Ms. Cynthia Jones of the NRC Headquarters Office l           and representatives from the Ohio Department of Health. The latter inspection l           was conducted in response to Cleveland City Council concerns, and to assemble        :
l            information to assist the NRC staff in evaluating a 10 CFR 2.206 petition from the Northeast Ohio Regional Sewer District. The inspection consisted of a review of your effluent management and control program, and included radiological surveys and collection of various environmental samples at both your London Road facility and in surrounding neighborhood areas.                      -
On May 27, 1993, the preliminary findings of the onsite portion of the inspection were discussed with you and Mr. Loeser of your staff. These findings were further discussed with you and Mr. Roy Caniano and others of my staff in a telecon on July 29, 1993.       In addition, on May 28, 1993, a public meeting was held at Holy Redeemar Catholic Church on Kipling Avenue in the Collinwood area, to discuss your facility operations and the findings of the onsite and offsite (surrounding neighborhood) surveys.
* The enclosed copy of our inspection reports identify areas examined during these inspections. Within these areas, the inspections consisted of a selective examination of procedures and representative records, extensive independent measurements, and interviews with current and former AMS personnel. Inspection Report No. 9999003/93010(DRSS), provides the results of the offsite surveys. Report No. 030-16055/93002(DRSS) describes the onsite inspection efforts and survey results.
      ~.
Based on the results of the inspections, a violation for failure to completc a physical inventory in accordance with license requirements was identified and is being considered for enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1993). However, no Notice of Violation is presently being issued for these inspection findings. You will be notified by separate correspondence regarding our proposed enforcement action.
ewer                                                                      4

Advanced Medical Systems, Inc.               2                    Atjg 0 21993
                                                                                                                            )
i In addition to the violation, the inspections identified concerns in the              I following areas:
(1)       Reliability of removable compression plug in the back basement floor drain to prevent an unmonitored release of liquid radwaste.
(2)      Failure to conduct surveys outside your facility, but within your fenced property, to characterize changing radiological conditions.
(3)      Failure to document localized areas of elevated radiation in internal facility area survey records and include overhead piping, floor drains and wall penetrations while conducting these surveys.
(4)     Failure to identify and control pote itially contaminated waste. water generated from floor moppings.
No response to the violation is required at this time. However, we request a response to all of the above stated concerns, describing your plans to l                                       strengthen your program and practices to preclude recurrence of the identified weaknesses.
Although we understand that no further liquid discharges tc the sanitary sewer system are planned, a sewer backup and resultant floud or an uncontrolled release of water into the facility (i.e. water pipe break) could occur and produce a large volume of contaminated water in the basement of your facility.
To ensure all future releases that may be made to the sanitary sewer system
(
are properly analyzed, we desire the opportunity to collect a split sample prior to any discharge. Consequently, we request that you notify the NRC Region 111 office at least 24-hours prior to any future discharges of radwaste to the sanitary sewer system.
We plan to meet with you in the near future to further discuss these inspection findings and our plans to conduct a hazard assessment of your facility pursuant to 10 CFR 30.34(e), to better evaluate potential ' facility vulnerabilities from internal and external hazards. We will contact you at a later date to schedule this meeting.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosed inspection reports and your response to this letter will be placed in the NRC Public Document Room.
The response directed by this letter is not subject to the clearance procedures of the office of management and budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

[ ,,              ,
r 4
Advanced Medical Systems, Inc.          3 Aus o 21993 1
We will gladly discuss any questions you have concerning these inspections.
Sincerely,
                                                         " Original Signed by W. L. Axelson Charles E. Norelius, Director Division of Radiation Safety and Safeguards

==Enclosures:==

l                       1. Inspection Report No. 99990003/93010(DRSS)
: 2. Inspection Report No. 030-16055/93002(DRSS) cc w/ enclosures:
i                      Michael White, Mayor, City of Cleveland Roosevelt Coats, Councilman, Ward 10, City of Cleveland Michael Polensek, Councilman, Ward -11, City of Cleveland Michael Konicek, Department of Public Utilities, City of Cleveland Lisa Mehringer, Department of Law, City of Cleveland Erwin Odeal, Northeast Ohio Regional Sewer District Robert Owen, Ohio Department of Health Erv Ball, Cuyahoga County Board of Health bec w/ enclosures:
PUBLIC-RIII                 -
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U. S. NUCLEAR REGULATORY COMMISSION Region 111 Report No.
99990003/93010(DRSS)
Docket No. 99990003                                                                           I Facility:     Advanced Medical Systems, Inc.
1120 London Road Cleveland, OH Inspection At:             Residential, Public and Commercial Premises in the Vicinity of Advanced Medical Systems, Inc.                    '
Inspection Conducted:                    ay 24 - 28, 1993 Inspectors:
Donald (S. Sreniawski 4%                       7-9%-93 Date Senior Health Physicist
                           . $44$ad Raif>'antL.'Glinski,Jr.
hr    ~
                                                                      > V-Date l*~A hN Radiation Specialist i         -
l           Accompanying Personnel: Keith Andre
(
Physical Science Technician NRC RIII Carl Heller Ohio Department of Health Dwain Baer Ohio Department of Health Harvey Brugger Ohio Department of Health Approved:
J
[
A. Grobe 7 1 3 Date ef, Fuel Cycle and Decommissioning Branch Inspection Summary inspection Areas      of May 24 through 28. 1993 (Report No. 99990003/93010(DRSS))
inspected:
This was a radiological survey conducted at the residential, public, and commercial properties surrounding the Advanced Medical Systems, Inc.(AMS) facility on London Road in Cleveland, OH; and in the public sewer system that services the AMS facility. This inspection included the measurement of direct radiation; the collection of smear, soil, sediment and water samples; and the subsequent analysis of these samples by the Region III Hobile Laboratory and in the Region III Radiological Laboratory.
Nff'

Results: The NRC inspectors did not identify any radiation levels or any radioactive contamination off the AMS property that would present a radiological health and safety concern to any members of the public.
l l
l 1
2

s                                                                                 .
DETAILS j
: 1. Persons Contacted Councilman Michael Polensik, Cleveland City Council Councilman Roosevelt Coats, Cleveland City Council Tom Marsalis, Department of Water Pollution Control Micheal' Marcellino, Office of the Mayor Micheal Konicek, Director of Public Utilities Caroline Arnold, Sen. Glenn Staff Janice McCourt, Sen. Metzenbaum Staff Mark Loeser, Radiation Safety Officer, Advanced Medical Systems, Inc.
(AME}                    -
Sherry Stein, Director of Regulatory Affairr, AMS Robert Owen, Ohio Department of Health Richard Connelly, Northeast Ohio Regional Sewer District, (NE0RSD)
Leonard Jufko, NE0RSD

===2. Background===
'           Advanced Medical Systems, Inc. (AMS) of Cleveland, OH, is the holder of Byproduct Material License No. 34-19089-01 issued by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 30. The license authorizes AMS to possess and use up to 150 kiloCuries of cobalt-60 as solid metal,150 kiloCuries of cobalt-60 in sealed sources and 40 kilocuries of cesium-137 in the manufacture, installation and servicir.g of teletherapy units. The teletherapy units are used in medical facilities to treat cancer patients. The NRC first issued a licer.se to AMS in November 1979 following a review of their application by NRL
[
'           Headquarters, and from 1979 to the latter 1980's AMS actively manufactured sealed sources for distribution to medical licensees.
Radiological surveys performed by the Oak Ridge Associated Universities (0RAU) in 1985 and then by the NRC in 1986 found that contamination levels at the London Road facility represented an unacceptable safety hazard. On October 30, 1987, the NRC issued a " Confirmatory Order Modifying License, Effective immediately", which required AMS to complete decontamination of the London Road facility by April 1988. The NRC Region III office then contracted with ORAU to perform another radiological survey that included all of the AMS property at the London Road facility. This survey was conducted on November 14-17, 1988.
Other than along f.he outside of the AMS facility south wall that faces the railroad tracks, no elevated radiation levels were found. Another portion of the ORAU survey included the collection of 12 soil samples from the AMS property. The results-of the soil analyses revealed slight levels of contamination with a maximum level of 2.5 picoCuries per gram-of cobalt-60 in the soil. This is below the 8 picoCuries per gram allowed by the NRC for release for unrestricted use. The levels of cesium-137 detected were consistent with radioactive fallout from atmospheric weapons testing (UNSCEAR, 1982). This area is fenced to prevent access by the general public.
Y 3

The Mayor of Cleveland and a U.S. Congressional Delegation, led by                   !
Senator Metzenbaum, expressed concern for Cleveland residents living                 l near AMS in letters to the NRC dated April 8 and 28, 1993. The Cleveland City Council requested that the NRC perform a radiological survey of the neighborhcod in the vicinity of the AMS facility to ensure that there are no health and safety concerns incident to the activities conducted at AMS.
1 Although surveys had been completed over the AMS property on previous                '
occasions, surveys had not beca conducted in the neighborhood and industrial areas around the AMS facility. In response to the request                ,
made by Cleveland City Councilmen, the NRC Region III office, in conjunction with the Councilmen and City of Cleveland staff, developed a radiologicsl survey plan for the immediate vicinity of the AMS London Road facility. The Northeast Ohio Regional Sewer District (NE0RSD) and the Ohio Department of Heahh assisted with the planning and the survey.
: 3.                              Survey Conducted A)     Direct radiation surveys were performed over the following areas:
(refer to map on page 6 of 6 in Attachment D) i                                                        1. At two locations approximately 0.5 miles west of AMS to establish an area background. These locations were the front yard of Collinwood High School and an area just south of the railroad bridge at the intersection of Ivanhoe Road &
Enoch Road.
: 2. Along London Road approximately 0.25 miles north and south
}                                                               of the AMS facility, and along the railroad tracks approximately 0.25 miles east and west of AMS.
: 3. Along the streets of Wickford Court, Wayside Road, and Roseland Road east to the park.
: 4. Over the grounds, on the roofs, and at the gutter downspouts of residential properties within 500 feet of the AMS hot cell. Three other residents requested that their property be surveyed and one other residence was added during the course of the survey. A total of 12 residences were surveyed. A list of the actual addresses is presented in Attachment F and is not subject to public disclosure, in accordance with 10 CFR 2.790.
: 5. Over the grounds, on the roofs, in the gutters, and at the gutter downspouts of six commercial properties in the vicinity of AMS. The following is a list of commercial properties surveyed:
: 1) 1001 London Road
: 2) 1700 London Road
: 3) 1700 London Avenue, North Building
: 4) 1725 London Road 4

I ', '
5 1636 Wayside Road 6 16626 Mandalay A fenue
: 6.      Over the grounds of the Mark Tromba Park located on Mandalay Avenue west of AMS, to include the baseball field, the         i basketball court, the tennis courts, the playground, and the diatomaceous earth filters used at the swimming pool. A map of the entire area surveyed is presented in Attachment A.
: 7.      In the sewer lines immediately downstream of the AMS
,                          facility and in storm water catch basins immediately around
            /7             the facility.
: 8.      At the Easterly Sewerage Treatment Plant in areas determined to be collection points for solid material,                   i j            B) The following s m as were collected and analyzed:
l
: 1.      Fourteen soil samples were collected from the residential, industrial, and public areas surveyed in the neighborhood j                           surrounding the AMS facility.
: 2.      To establish background levels for the soil from this area   i of Cleveland, two soil samples were coller.ted ap3roximately 0.5 miles west of the AMS facility. A copy of tae soil sample collection fonn is presented in Attachment B.
: 3.      Nine samples consisting of water, sediment, and scrapings were collected from the sewer lires immediately downstream l                          and the catch basins in the vicinity of thu AMS facility (See Attachment E). Four samples of sludge and landfill soil were collected from the Easterly Plant. A copy of this collection form is presented in Attachment C.
C) Changes from the original survey plan.
The two catch basins on London Road south of AMS and the catch basin at Rudyard Road and Mandalay Avenue were not surveyed or l                  sampled because the surveys of London Road and catch basins closer to the luiS site showed no contamination. Subst auent analysis of sedimut samples from offsite catch basins closer to AMS showed no signifiant cobalt-60 contamination. A copy of the original survey plan developed by the NRC Region 111 staff is presented in Attachnient D.
: 4. List of Instruments Used for the Survey 1
  .                   1)      Portable Gamma Spectroscopy Multichannel Analyzer Unit interfaced with sodium iodide detector.
: 2)      Victoreen 190 with pancake GM probe, calibrated on 1/22/93. NRC Tag No. 42445.
  )                                                 5

4 c
1 i
l l                                               3)  Victoreen 190 with pancake GM probe, calibrated on 6/29/92.
NRC Tag No. 40520.
4                                                             ,
: 4)  Ludlum Model 19 pR meter, calibrated on 5/15/93.                  I NRC Tag No. 14808.
t
: 5)  Ludlum Model 19 R meter, calibrated on 2/9/93.
1 NRC Tag W.10617.
: 6)  Ludlum Model 19 pR meter, calibrated on 2/9/93.
NRC Tag No. 14809.
: 7)  Ludlum Model 19 pR meter, calibrated on 5/8/93.
NRC Tag No. 11021.
: 8)  Bicron MicroAnalyst used by the Ohio Department of 4
4 Health staff.                                              -
: 9)  Ortec High Purity Germanium detector interfaced with a personal computer (PC)-based Multichannel Analyzer in the l                                                   Region Ill mobile laboratory.
: 10) Princeton Gamma Tech High Purity Germanium detector
'                                                   interfaced with a PC-based Multichannel Analzer in the Region III radiological laboratory.
: 5.           Results of the Radioloaical Survey l
The radiation levels detected along London Road and the railroad tracks were consistent with the local baciground of 10-15 microRoentgen per hour. Slightly elevated readings below the NRC requirements for i
unrestricted areas were detected at the brushline between the railroad tracks and the AMS-property line, with the radiation levels ranging from 18-22 microRoentgen per hour. Waist level and ground level surveys in this area were identical, indicating that the elevated readings were attributable to direct radiation from the AMS facility and not
* 3                                   contamination of the ground from radioactive effluents. A soil sample 4
was collected and analyzed, confirming the absence of soil contamination.
A total of 16 . oil ;amples were collected and analyzed for gamma emitting isoto)es by the Region Ill Mobile Laboratory. The samples
.                                   consisted of tie following; (1) two soil samples as control to establish the local background, (2) seven samples from residential properties.-(3) four samples. from commercial grounds, and (4) three samples from public areas. The results of the soil analyses are presented in Table I,              No cobalt-60 was detected in any of the soil samples; however, some of the residential soil samples possessed elevated levels of thorium-232 in equilibrium with its progeny. This phenomenon is discussed in Paragraph 6.
6

The radiation levels found on the roofs, in the gutters, at the downspouts, and on the grounds of all the commercial properties were indistinguishable from the background level of 10-15 microRoentgen per hour. Only one of the industrial buildings possessed an air intake unit on its roof. Smear samples were taken on the air handling unit to determine whether contaminated air was being drawn into the building.        4 No cobalt-60 was detected on the two smears taken from this air handling     l unit.
The radiations levels found in the catch basins and sewer lines were N       consistent with the local background. In addition to determining the radiation levels in the sewer lines and catch basins, samples were collected for gamma spectrometry analysis. No significant levels of j cobalt-60 were found in these samples, except for approximately 1,800        '
s picoeuries of cobalt-60 found on several small pebbles weighing 36.5 grams collected from manhole #1, the nearest manhole downstream.of AMS.
Based on the nature of this sample, which appeared to be mortar, it is believed that the cobalt-60 in this sample is adhering to the surface of the material. Table 11 presents the results of these analyses. The I           table is organized such that the sampling location closest to the AMS I
facility is listed first and the furthest sampling location is placed last. A map of the sampling points from the sewer lines and catch basins is also provided as Attachment E.
No health and safety concerns were identified.
: 6. Elevated Thorium levels at Two Residences The radiation levels detected on the roofs, at the gutter downspouts and over the grounds of the residential properties were all consistent with background levels, except for areas of elevated radiation found at two residences. The backyard fenceline shared by these residences contained an area of approximately 12 square feet that had radiation levels that ranged from 70 - 350 microRoentgen per hour at ground level. The maximum reading at one meter above the ground was 60 microRoentgen per hour. One residence also had an area in the front yard shrubbery with levels of 30-50 microRoentgen per hour.
Soil samples were taken from these areas and subsequent gamma spectrometry analysis revealed the presence of elevated levels of up to 90 picoCuries per gram of thorium-232 in equilibrium with its progeny.
Although this level of thorium is unusual for the Cleveland area, there are certain places in the western United States that have equivalent radiation levels. Thorium is a material found naturally in the earth's crust and is also a chemical used in certain industrial processes. The NCRP Report No. 94, entitled " Exposure of the Population in the United States and Canada from Na'. ural Background Radiation", indicates that the average amount of thorium in soil is approximately 1 picocurie per gram.
Thorium levels in the other soil samples collected during this survey ranged from 1.2-2.2 picoCuries per gram.
The inspectors questioned the residents regarding the areas with elevated thorium levels. The residents stated that they had occupied those premises since the middle of the 1950's, though they thought that 7

e the houses had been built in the 1920's. These individuals also indicated that they had not added any soil or fill to these areas. On one side of the fence, a flower garden is present, while on the other side of the fence the resident regularly applies a herbicide. The inspectors placed a GM pancake probe against the commercial herbicide container and did not detect any radiation above background. The NRC and the Ohio Department of Health have evaluated the thorium soil levels at these residences and concluded that they do not pose a health and safety concern. At this time, no determination has been made regarding the origin of the thorium and this remains an open issue. No action is recommended concerning the soil, 1
No health and safety concerns were identified.
: 7. Exit Meetina An NRC Region 111 management representative, members of the inspe'ction team and NRC's regional public and government affairs staff conducted a public exit meeting at the Holy Redeemer Roman Catholic Church on           ,d r
Hay 28, 1993. The purpose of the meeting was to: (1) discuss the preliminary findings of the onsite inspection, an described in
* Inspection Report No. 030-16055/93002(DRSS)1 (2) describe the results of      "
surveys conducted by the inspection team in neighborhood areas                l' surrounding the AMS facility, as described in Inspection Report               -
No. 99990003/93010(DRSS); and (3) respond to questions from elected officials and the public,
                                                                                         .g
                                                                                           .r The public meeting was attended by state and local government officials,    z licensee representatives, several media representatives and a) proximately 25 members of the public that reside in the vicinity of tie AMS facility, idbles:
: 1. Soil Analysis Results
: 11. Analysis Results of Sewer Line and Catch Basin Samples Attachments:
A. Map of Entire Survey area                                                --
B. Soil Sample Collection Form C. Sewer Line/ Catch Basin Sample Collection form D. Original Survey Plan E. Map of Sewer Line and Catch Basin Survey Locations F. List of Residences Surveyed
                                            .      8

)*
Table 1. Soil Analysis Resylts All results are in picoCuries per gram of wet
        ~
weight. The uncertainties reported are two standard deviations.
Location                 _
Co-60     Cs-137    Th-232     K-40 London Road, 93-398                   <0.16    0.82      1 90        20.6
                                                          +/-0.16   +/-0.48    +/-2.0 London Road, 93-397                   <0.15    0.65      1.96        19.6
                                                          +/-0.12   +/-0.40     +/-l.9 Alhambra Road, 93-395                 <0.15    1.0       1.68        17.6
                                                          +/-0.14   +/-0.36     +/-l.8 Alhambra Road, 93-396                <0.14    0.83       2.17       20.5
                                                          +/-0.16   +/ 0.40     +/-2.0 Alhambra Road, front                 <0.26    0.53       34.4       27.4 yard near shrubs, 93-415                      +/-0.25    +/-l.72     +/-3.2 Alhambra Road, #1 along              <0,31     <0.43    91.4        31.9      ''
backyard fence, 93-399                                  +/-3.0      +/-4.0
  )
Alhambra Road, #2 along              <0.29    0.47      84.6        27.4 backyard fence, 93-422                       +/-0.30    4/-2.88    +/-4.4 Superior Die Casting, along         <0.19    1.34       1.56       23.4 London Road                                  +/-0.19    +/-0.30    +/-2.8 Superior Die Casting, Office        <0.20    1.53         <l.42     17.3 Building                                     +/-0.24               +/-2.9 Tribco Parking lot                  <0.17    0.54        1.51       7.2
                                                           +/-0.16    +/-0.66     +/-1.9 Atlas Sewer and Pipe               <0.17      0.24       1.56       15.7 4
Cleaning, Grape Area                          +/-0.11    +/-0.58    +/-2.6 y==--..    .
                                    ,  x   -- =         --.-         --
                                                                               .- =      ;
Between AMS fence and               <0.18    0.47        <0.71      10.6 Railroad Tracks                              +/-0.16               +/-l.8
  )                                                     9

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Mark Tromba field, backstop              <0.08       0.22         1.17       16.0
                                                                          +/-0.08      +/-0.30
                                                                                                  +/-).58 Mark 1romba field, left field            <0.10       0.51         1.52       19.5
                             , , _ _                                      4/-0.08      +/-0.40    +/-l.74 Collinwood High School,                   <0.10      0.85         1.90       18.6 background                                           +/-0.14      +/-0.34    +/-l.6 Ivanhoe Road and Enoch Road,               <0.08     0.69         1.16       15.5 background                                           +/-0.11      +/-0.31    +/-l.54 L
F                                                                                                  .
10

l                         Lable 11.             Analysis Results of Sewer line and Catch flasin Sample.
;                          LT1 results are presented as picoturies per gram of wet weight unless otherwise indicated. The uncertainties reported are two standard deviations.
;                          ND indicates None Detected. A specific lower limit of detection (LLD) was not assigned to these measurements due either to unique geometry contraints or the
.                          LLD value was not recorded.
5 Location                                                                   Co-60           Cs-137 f
Manhole #1 - Water                                                                   1.17           ND
             .                                                                                                      +/-0.14 1                              Minhole #1 - Rung Scrappings                                                         ND             1.00 ND             ND
!                              Manhole #1 - Benchwall Manhole #1 - Pebbles off Bottom                                                Appox.1800         ND       -
_picoCuries*
l                                 Manhole #3 - Sediment / Water                                                     0.69           ND
',                                                                                                                  +/-0.14 Manhole #3 - Rung Scrappings                                                      ND              ND Catch Basin Sediment - Mandalay Avenue                                           <0.06            0.06 l
4 and London Avenue                                                                                 +/-0.04 Catch Basin Sediment - Mandalay Avenue                                             ND             0.15 4                                 and Alhambra Road                                                                                 +/- 0.16
                                  $4anhole #13 - Sediment                                                            ND             ND NE0RSD Easterly Plant - Dewatering Unit                                          <0.15           <0.14 2                                 #2 NE0RSD Easterly Plant - Sludge                                                    <0.10          <0.08 NE0RSD Easterly Plant I.andfill Soil #1                                           <0.23          <0.22 NE0RSD Easterly Plant landfill Soil #2 __                                         <0.14          <.10 '
j                              __
* This sample appeared to be mortar with cobalt-60 adhering to the surface.
l 4
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A*ITACIIMENT C nas I or.L uces

Y'  .
Iinal Itadiological Survey Plan May 21, 1993 AMS and Surrounding Areas
: 1. Purpose                                                                              '
The purpose of this radiological survey is to determine whether there exists any contamination from AMS operations that would pose a health and safety concern outside of the AMS facility.
: 11. Coordination Meetings have been conducted with concerned Cleveland elected officials, Cleveland City staff and Northeast Ohio Regional Sewer District staff to discuss the AMS facility, review the survey plans and obtain their input. Their input has been incorporated into this plan.
Assistance has been secured from Northeast Ohio Regional Sewer District and Cleveland City personnel to gain access to sewers, basins and sewage treatment facilities and to assist in performing surveys and sampling those areas.
The AMS Radiation Safety Officer will provide access to areas under AMS' control and any necessary radiation protection measures for access to those areas.
The Cleveland Public Services, Water Pollution Control and Public Utilities Departments will assist the survey team with access to industrial facilities and roofs, and residential buildings and roofs, and provide secure facilities to support the Mobile laboratory, federal, State and local elected officials will be notified of the survey and close out meeting plans. Coordination has occurred with the City of Cleveland (elected officials and staff), cuyahoga County Ocpartment of Health, Ohio Ocpartment of Ilealth, and Northeast Ohio Regional Sewer District. Region til Public Affairs and Government t.iaison staff will assure appropriate notifications are made, federal elected officials will be notified through the Office of Congressional Affairs.
A notification to local residents and businesses will be delivered door
'             to door by Cleveland City personnel to assure that the local neighborhoods are aware of the NRC activities.       Region III has reviewed that notification. A press release will be issued by Region 111 announcing the time and location of the close out meeting for the surveys.
ATTACIIMENT D nce I a. 6 nats

              .                                                                                                             }
l i,
Il 2
May 21, 1993 J
111. personnel
;                 The personnel conducting the survey will consist of two inspectors and one technician from the Region !!! staff. In addition to NRC personnel,                                       i the Ohio Department of llealth (ODH) has committed staff support to the                                       '
survey team.
A separate inspection effort by two other inspectors will be concurrently conducted (See Attachment) within the AMS facility to evaluate release pathways and radiological conditions. That effort will be assisted by an NHSS Section Leader.
A Region 111 Branch Chief will conduct the pubile close out meeting.
1
            -IV. Equipment The Region !!! .) bile Laboratory will be used for the counting of soil / sludge /wate ' samples collected during this inspection. MicroR meters, Na! crys' als, and pancake GM probes will be used for direct 4                 radiation surveys Sampling supplies will be obtained from the Region III lab. Any app. ratus necessary to sample sewers will be provided by the NE0RSO and Cleuland City staff.
Radiological Surveys V.
A.
* Direct radiation surveys will be conducted over the following
 ;                              areas:
;                                           1. At two locations approximately 0.5 mile west of AMS to establish a local background. This will include Collinwood liigh School and one other location ideritified by the City of Cleveland.                                                        .
: 2. Along Lonoon Road 1/4 mile north and south of the AMS Tacility.
: 3. Along the railroad tracks 1/4 mile east and west of the AMS facility.
4 Along Wickforo Court, along Wayside Road between Wickford Co0rt and Roseland Road, and along Roseland Road b: tween Wayside Road and Avalon Road.
: 5. Over the on-site grounds of the AMS facility, and at all gutter downspouts. Particular attention will be paid to the external surfaces of the AMS facility to assure that they will be in compliance with the revised 10 CFR Part 20 (100 mrem /y, ear in untestricted areas),
i A*ITACHMENT D NY*       ""     -

0,'      .
May 21, 1993
: 6. Over the grounds and at the gutter downspouts of g
representative industrial and residential properties within l                    500 feet of the M5 hot cell location. This will include residences north of Handalay Avenue on Lcndon                I Road, Alhambra Road ind Rudyard Road. in addition, the grounds of the following residences will be survevq:                           ;
London Ro'd a     .
Alhambra Road
                                                       ' SPECIFIC ADDRESSES WITHHELD Alhambra Road Alhambra Road         IN ACCORDANCE WITH     -
Rudyard Road
]                                                        10 CFR 2.790
: 7. On representative industrial roofs within 500 feet of the MS hot cell location including any air intake housings.
: 8. On representative residential roofs and gutters with'in l                     500 feet of the MS hot cell location.
: 9. Over the grounds of the park, the swimming pool, the
}                     tennis courts, the pirk facilities, and the baseball field west of MS on Handalay Road.
: 10. In the manhole and sewer lines on-site at AMS and in the manholes, road way gutter basins, and sewer lines off-site and downstream of MS. This will include two road way gutter basins along London Road north of the railroad tracks, two road way gutter basins along London Road south of the rrilroad tracks, road way gutter basins at the corner j                      of Alhambra Road and Handalay Avenue and at the corner of Rudyard Road and Handalay Avenue, and three manholes to the London Road sewers downstream (north) of the MS outfall,
: 11. At the Easterly Plant in areas that the NE0RSD identifies as solids collection points.
Any detected cobalt-60 off the MS property will result in a revision of the survey plan to address the scope and nature of k               that finding.
Most surveys will be conducted using microR meters or Hal crystals. _ However, GM pancake probes will be employed in those circumstances in which they would be significantly easier to handle: The GM probes may also be used for confirmation of any arets giving elevated readings with microR meters.
B. Sample Collection - At this time it is estimated that, as a minimum, the following samples will be collected and counted in the Mobile Lab. Preliminary tests show that a one hour count of a 500 ml geometry will generate a minimum detectable activity of <1 pC1/ gram.: The NRC safe release level for cobalt-60 in soll is 8 pCi/ gram.*
ATTACllM11NT D PAGE 0 of. 2.PAGES

l , .. ..
May 21, 1993
: 1.      Two soll samples from the locations approximately 0.5 mile west of AMS identified by the City.of Cleveland to establish a local background. These will be the same locations where background surveys are performed pursuant to 1. above.
: 2.      Sludge samples from the basins, manholes, sewers, and sewage treatment systems, at locations described in
: 10. and 11. above.        .
: 3.      Several soil samples consisting of on-site samples,                     !
residential samples and samples from the bordering                      i ir.dustrial sites. Samples will also be taken at any l
location that yields elevated readings on the survey equipment,                                                ,
l                                 4.      A water sample will be taken from the public swimming i                                         pool, if it is filled.      If it exists, used swimming I
pool filter media will be obtained and analyzed. A soil sample will be taken from the public baseball field.
Approved:_               -
{p61CycleandDecommissioning

==Attachment:==
Advanced Medical Systems Onsite inspection / Survey Plan 4
4 4
4 NITACHMENT D PAGE  of b;PAGES

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Advanced Medical Systems,Inc.
1020 London Road Cleveland. Ohio 44110 (210)092 3270 FCx (216) 692 3149 Jusw 27,1997 kit, kl. havl F. Wdwr Nuclear h!sterials Liceming 11rarwh R S. Nucisar Regulatory Comrnission                                                                           i I
801 Warrensille Road Lhic,!!!inois 60$32-4351 Re Fanergency Eservise Rewbedukag l
I)<ar Air. Wehrt:                                                                                             l l
bi A ''lintergency Plan for the tenen Koed facilit)" (Revision 1. February 23.1997). Sour                     !
              .wtynis,ti..n i ii t d as a lient rempinder lie 6criain typsn of cmcrueiwiss that enight veeur at Ads arwcd h1.did Sptava, he. (Ah1S). As requblin that Pimit, Ah!S must preper for and conduct an emen gmiy excrei : ones every two years.
In a pcdous cottununiention. I annoutwed that tlw next excreise was whedulso for Wedrw6 day, August 27.1997. Ikeauw certain Ley first retonders esprenwd neheduling dEcultics, the exerciw has been patponed until January 25,1998. sonw tinw 1xtuceu Gw hours of 6:30 a m. ml 9.30 pm In the vwry near ibture )ou uill tw provided with a selwdule, a linting ol'the drill's objectives, and irstnetitsw to participaus IW your review and comment 'the seenario will be kept eurdiderdial, but will I
              .be dc=lgned to tc61 the on. and olf. mite organsosilon to the lhlls6t extens practienb!c Onec again, your netive nrd enthitstic pu1icipation in the planning as well as the csceution stage of the eweine will not only be appr'ceist i h) / hts. but will erwre optimum protection of ficilities, the environment and the publie in the unlarly ennu of a real emergeney at or London Road 'neility.
If you cleet not to participw in the exereig on this date, please call me at (216) 692 3270. If!do not lear San you witisi iwo (2) weeks of tlw date of this letter. I will assume that >vu intend to participtc.
hi am event. please call me ifI can amwer any qucutions or provide you with additional infortnation on tiiin impwtan: maner.
Sirwcacly, Stephen J. IlmL L. R.S.O.
cc:      E. Svigel D. h1 iller, Esq. . Stavolc & hiiller C. lkrsce, C.ltP. . LEh!
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                                                                                                              )
                           \ _ _\ L I                                                          EVALUATION OF THE Prepared by Oak Ridge Associated
.I.
;                    Universities                     OPERATIONAL RADIATION SAFETY AND l
h''S [uctear                         FIRE PROTECTON PROGRAMS l['
Regulatory Commission's 4
Region lli Of fice OF TE j'
supported by Safeguards and                     ADVANCED MEDIC AL SYSTEMS, INC.
Materials Program Branch;                                 LONDON ROAD FACILITY Division of inspection Programs:
Of fice of                                   CLEVELAND, OHIO f                inspection and a                Enforcement r-
[                                                                G.L. MURPHY rL
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U                                                   Radiological Site Assessment Program Manpower Education, Research, and Training Division n                                                                '
A                      FINAL REPORT 02 8 kIg   >
                                                    '                  DECEMBER 1985                  1 u                                                                                               -

o       a                                                                                                                             f ll             il=                                                                                                                                       l 1
.                                                                                                                                                        l, EVALUATION OF THE OPERATIONAL RADIATION SAFETf AND FIRE PROTECTION PROGRAMS OF THE                                                                     j ADVANCED MEDICAL SYSTEMS, INC.                                                             l LOFDON ROAD FACILITY                                                                i CLEVELAND, OHIO                                                                 l l
t i
Prapared by                                                                  (
G.L. Murphy Radiological Site Assessment Program                                                           t Manpower Education, Research, and Training Division                                                  i Oak Ridge Associated Universities Oak Ridge, Tennessee            37831-0117                                                   !
Project Staf f J.D. Berger                    H.E. Goranson**
* R.9. Condra                    A.S. Masvidal E.D. Darden*                   T.J. Sowell E.J. Deming                    C.F. Weaver
                         -                                  D.A. Gibson i
4 Prepared for                                                                   j of fice of Inspection and Enforcement
.                                                          U.S. Nuclear Regulatory Commission Region III Office                                                                ,
4 FINAL REPORT                                                                  l December 1985                                                                 :
This report is based on work performed under Interagency . Agreement DOE' No. 40-816-83 NRC Fin.. No._ A-9076 be tween the U.S. Nuclear Reguistory Commission and the. U.S. Department of Energy.                           Oak Ridge Associated Universities: -performs            complementary . work             'under   contract              numbe r                ;
           .y.-                 DE-AC05-760R00033 with the U.S. - Department of Energy.                                                                  t t
1 i
* Radiation Safety Of ficer 0SH/0RAU i                             ** Professional Loss' Control, Inc., Oak Ridge, TN i
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    . . - - ~ , . . .-       --   ---      - . . . .           :.,.._,.._-,...,--.--...u..,-.~,..---,..n           . . , . . - , _ , - . , . - - - - - -
* i
     .I                                                                                             J i
i a
TABLE OF CONTENTS i
i i                                                                                            fagg   ,
List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . iii i
List of Tables    ...........................                                      iv 1.0 Executive Summary     .......................                                  1   !
 <                                                                                                  t 2.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . .               5 2.1 Pu rpose and S co pe . . . . . . . . . . . . . . . . . . . . .            5   ,
 ,                2.2 Site Description .....................                                    6 2.3 Administration and Organization . . . . . . . . . . . . . .               7 2.4 Policies and Procedure s . . . . . . . . . . . . . . . . . .              7 2.5 Environmental Surveillance Program . . . . . . . . . . . . -16
$            3.0 Staffing / Training   .......................                                 17 4.0 Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . .              19 j            5.0 Equipment    ...........................                                      24   i 5.1 Portable ' Monitoring Instrumentation . . . . . . . . . . . .            24 5.2 Personal Dosimeters . . . . . . . . . .      ..........                  26 5.3 Fi xed I n s tru me n t a t i on . . . . . . . . . . . . . . . . . . . 27 l                 5.4 Air Monitoring     ...................... 29 4
6.0 Haterial Accountability     .._,.................                             32
,            7.0 Security . . . . . . . . . . . . . . . . . . . . . . . . . . . .              33 8.0 Fire Protection     ....-....................                                 35 4            9.0 Emergency Planning . . . . . . . . . .-e ............                         37 i           10.0 Waste Management ........................ 41 11.0 Site Survey    .......................... 45                                       ;
4
:           Appendices Appendix A     Audit Team Bibliographies                                           l r
Appendix B:    Scope of- Work
;                Appendix C     Radiation Protection Training Courses Appendix D: List of Decontamination Firms 3
1 l
!   ---                                                1 lI'

e
     .8 Appendicies (Continued):
Appendix E    U.S. Nuclear Regulatory Comission Regulatory Guide 8.15 Acceptable Program for Respiratory Protection Appendix F:   An Evaluation of Fire Protection at Advanced Medical Systems, Inc., London Road Facility, Cleveland, Ohio Appendix G    Analytical Equipment and Procedures                       l l
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LIST OF FIGURES
:                                                                                    L*L*
FIGURE 2-11    Cleveland. Ohio, Area Indicativg the Location of the AMS Fa c i l i t y . . . . . . . . . . . . . . . . . . . . . 50 l
[           FIGURE 2-2: General Layout of the AMS Froperty . . . . . . . . . .             51-FIGURE 2-3: AMS, Inc., organizational Chart           ...........              52
   ,,,      FIGURE 4-1: AMS Facility - 1st Floor (partial) . . . . . . . . . .             53 FIGURE 4-2: AMS Facility - 2nd Floor (partial) . . . . . . . . . .             54 FIGURE 4-3: AMS Facility - Basement         . . .............                  55 FIGURE 5-1: Air Sampling Station:        Schematic Diagram .     ......        56 FIGURE 5-2:    Stack Air Sampling Systems       Schematic Diagram     .... 57
   ~'
FIGURE 11-1: _I!ot Cell Exposure-Rate Survey Locations.       .......          58 FIGURE ll-2: _ Second Floor Exposure-Rate Survey Loc 4tions. . . . . .         59 FIGURE 11-3:   First Floor Exposure-Rate Survey Locations . . . . . .          60 FIGURE 11-4    Basement Exposure-Rate Survey Locations        .......          61 FIGURE 11-5:   Second Floor Smear Locations      .............
62 FIGURE 11-6    First Floor Smear Locations       .............                 63 FIGURE 11-7 8- Basement Smea r Loca tions . . . . . . . . . . .       .... 64 FIGURE 11-88 AMS Environmental Sample Locations . . .         .......          65 FIGURE 11-9:   AMG Offsite Sample Locations . . . . . . .......
                                                                                          -66 FIGURE 11-101. Facility Radiation Leakage Locations _ . .      .. .....        67
:s.
E                                                    iii' l

   .I LIST OF TABLES
                                                                                            .P,a,gg TABLE 11- 1: Ilot Cell Exposure-Rate Measurements . .         . . . . . . . .      68 TABLE 11- 2: Second Floor Exposure-Rate !kasureuentu          . . . . . . . .      69 TABLE 11- 3: First Floor Exposure-Rate Measurements           . . . . . . . .      70 TABLE 11- 4: Ba sement Exposure-Rate Measurements . .        . . . . . . . .      72
   ..         TABLE 11- 5: Second Floor Smear Measurements . . . .         . . . . . . . .      73 TABLE 11- 6: First Floor Smear Measurements      . . . . . . . . . . . 4          74 TABLE 11- 7: Basement Smear Measurements . . .      . . . . . . . . . . .         75 TABLE 11- 8: Radionuclide Concentrations / Activity in Hiscellaneous Media .  . .......................                                  76 TABLE 11- 9: Radionuclide Activity on Type H Air Filter Canister . .              77 TABLE 11-10: Radionuclide Concentrations in Sediment          . . . . . . . . 78 TABLE 11-!!: Radionuclide Concentrations in Soil . . . . . . . . . .              79 TABLE 11-12: Radionuclide Concentrations in Vegetation . . . . . . .             80
   ^-
TABLE 11-13: Radionuclide Concentrations in Water         . . . . . . . . .       81 9
II                                                  iv 1
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       .8 1.0 EXECUTIVE SUHHA1(Y At the reques t of Nuclear Materials Safety and Safeguards, Nuclear Regulatory Commission (NRC) Region III, Glen Ellyn, IL, the Radiological Site Assessment Program (RSAP) of Oak Ridge Associated Universities (ORAU) performed a comprehensive evaluation of the fire protection and operational radiation safety programs at the Advanced Medical Systems Inc., (AMS) facility on London Road, in Cleveland, Ohio.                     The evaluation addressed policies, procedures and i
radiological conditions related tot organization, training, ALARA program, l                              emergency planning, fire protection, security, facilities, equipment, waste
!                              management, material accountability, and hot cell entry / accessibility.
l This section summarizes findings and reconenendations as they relate to specific program areas.                   It should be noted that certain of the recommendations provide only one suggested approach and that there may be alternative approaches
            ~
which would be acceptable. The - short and long term recommendations serve only td emphasize specific concerns, and should not be considered a comprehensive listing of all recommendations.
The AMS staff was very cooperative, and demonstrated a receptive attitude for the recommendations discussed during the audit.
SHORT TERM RECOMENDAfl0NS (to be accomplished within approximately six months)
Policies and Procedures Implement the use of a Radiation Work Permit- (RWP) system which will require the Radiation Safety Officer (RS0) to authorize the work request and be present to monitor the work activity.
e, Implement    -a    respiratory    protection           program    consistant      with        NRC guidelines.
              -                                                                          1

O
  .8 Staffing / Training i
Improve the professional health physics capabilities by augmenting the i
staff or providing in-depth trainin",.
Provide formal Radiation Protection Training for all employees.
Facilities e.,
Perform a complete decontamination of the hot cell and duct sva: tem. This may best be performed by a professional decontamination firm.
Increase the single HEPA filter on the hot cell to a two stage series llEPA filter system.-
   ~~
Provide improved illumination in the hot cell.
Upgrade ventilation system pre-filters and holders.
Plug the basement floor drain to minimize the discharge of radionuclides to the sanitary sewer system.
Equipment Supplement the high range measurement capabilities with an additional ins t rument.
Install a new f risker system in the change room.
Redesign and install a new exhaust stack sampling system.
Fire Protection L.
Develop and -implement a fire pre plan with the Cleveland Fire Department.
2 T                            ,

}. 6 Provide automatic fire suppression systems throaghout the facility (hot cell excluded).
Emergency Planning i
l             Review and upgrade ISP-1, Emergency Action Procedures.
             -Initiate preliminary emergency action plans for all agencies listed in
   ,,         Section 1.4 of ISP-1.
Waste Management Package and dispose of the current inventory of dry waste.
1
             -Decontaminate-the--dry waste storage area.                                       ,
Decontaminate the liquid _ waste area, the batch tank, the holding tank, and associated piping.        This may best    be performed by       a- professional decontamination firm.
LONG TERM RECOMMENDATIONS Policies and Procedg e_s, s
Impleme nt the specific recommendations contained in Section 2.4, Policies and Procedures.
o Facilities Redesign the illumination system in the hot _ cell co f acilitate remote bulb change.
Upgrade the _ remote manipulators to provide access to all areas of the hot cell.
     --                                           3

  ,t Equi pment 4
Calibrate-all portable survey instruments semi-annually; repair or dispose of non-repairable instrumentation.
Calibrate all rotameters semi-annually.
Material Accountability e,
Develop a new program or modify the existing material accountability program to include radioactive waste as an inventory item.
E,mergency Planning Establish' written procedures for hate   : a potential radiation emergency.
Waste Management 4
Redesign the holding tank to add a level guage.
Develop continger.cy plans for liquid releases to the sanitary sewer.
system.
. y.s u

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==2.0 INTRODUCTION==

==2.1 Purpose and Scope==

At the request of Nuclear Materials Safety and Safeguards, Nuclear                      1 Regulatory Commission (NRC) Region III, Glen Ellyn, IL, the Radiological S",te Assessment Program (RS AP) of Oak Ridge Associated Universities (0RAU) performed an evaluation of the fire },rotection and operational radiation safety programs at the Advanced Medical Sys tems Inc.,                 (AMS) facility on London Road, in Clevelano, Ohio.                     This evaluation was performed October 21-24, 1985 by an audit team (see Appendix A) composed oft J.D. Berger     - Certified Health Physicist, Program Manager, RSAP/ORAU
   ~
E.B. Darden     - Radiation Safety Officer, OSH/ORAU E.J. Deming     - Health Physics Team Leader, RSAP/0RAU l
!                     H.E. Goranson - Sr. Fire Protection Engineer, Professional
                                .        Loss Control Inc.
G.L. Murphy     - Health Physicist, Assistant Program Manager, RSAP/ORAU The NRC was represented at the evaluation by Mr. William Axelson, Chief ,
Nuclear Materials Safety and Safeguards and Mr. Robert Burgin, Senior Radiation Specialist.
Appendix B contains the scope of work issued by .NRC for this assessment.
The evaluation addressed policies, procedures, and radiological conditions related to:      organization, training, ALARA program, emergency planning, fire   protection,     security,      facilities,     equipment,    waste  management, material    accountability,       and   hot      cell  entry / access. Confirmatory measurements, onsite and offsite sampling were performed to determine the a,
radiological status of the site and the immediate environment.               The scope of work did not include evaluation for compliance with federal, state and/or local requirements, r~.                                                5
                                                              .w-

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The ORAU review- incorporated appraisal methods utilized by the NRC (NUREG-0855 dated 12/81), Department of the Navy (NAVENENVSAINST 5100.1 t-               dated 5/B3), and internal health physics audit procedures developed by ORAU. The rev.tw utilized analytical " risk trees" with related questions         I to guide the evaluation team.
AHS personnel contacted during the review included:
l
        ...                S.S. Stein, Ph.D; General Manager                                             l H.R. Irwin; Corporate Compliance Manager (Radiation Safety Officer)           I D. Murray; Consultant W. Turbett; Technician M. Baruffa; Electronics Technician Items of concern noted during the review were brought to the immediate attention of the f acility personnel.          A brief close-out presentation was j                   made by Mr. Murphy on the afternoon of October 24, identifying those areas
              ,     where major deficiencies or potential problems were felt to exist.
2.2  Site Description Advanced Medical Systems,       Inc.,   at 1020 London Road (Figure 2-1),        is located in an industrial / residential area of Cleveland, Ohio, and occupies the former Picker Cobalt Teletherapy facility.
AMS    occupies    three   floors   on    the    southeastern   end  of  a    large
        ,           warehouse / manufacturing building (Figure 2-2).           The main floor includes an of fice area, an isotope shop area, a hot cell, a shielded work room, a storage area _ and miscellaneous unoccupied areas.           The basement includes dry and liquid waste storage facilities, air sampling equipment and other unoccupied space.        The second floor includes additional office space (unoccupied), exhaust ventilation equipment room, and a mecFenical equipment room.        AMS - occupies approximately 25% (21,000 ft2) of the total building space (approximately 85,000 f t2),
I                                                 6

5 AMS is licensed by the NRC to possess up to 300 kC1 of Co-60, 40 kCi of Cs-137 and 9,000 pounds of depleted uranium. License number 34-19089-01 authorizes AMS to perform research, development, and processing of sealed sources for distribution to authorized recipients; to install, dismantle, service and maintain Picke r Corporation and AMS teletherapy units, and Picker radiography units; to remove, install or exchange sources in Picker Corporation, AMS     Inc.,  and Keleket Barnes teletherapy equipment; to develop and demonstrate equipment containing sealed sources; and to leak test sealed sources installed in Picker Corporation and AMS, Inc. devices.
2.3 Administration and Organization Management of the AMS Lonoon Road facility is under the di rec t iim of S.S. Stein, Ph.D, General Manager (Figure 2-3).       Mr. H.R. Irwin is the Corporate Compliance Manager (Radiation Safety Officer), and reports directly   to    the General Manager.       Other  full-time   employees  are B. Turbett, technician and J. Powell, secretary. Other AMS - Geneva ,
l             Onto,   employees may visit      the London Road    facility as    necessary.
(Reference to the AMS facility in this report will refer to the London Road site, unless specifically noted otherwise.)
2.4 Policies and Procedures Policies and procedures are documented in the AMS Operating Procedures Manual (OPM) (Rev: 8/1/85). Many of these procedures have been adopted from Picker, Inc., the facility predecessor.      Chapter 1, Emergency Action Procedures, of AMS OPM is reviewed in section 9.0, Emergency Planning, of this report. Chapter 2, Description of the Isotope Facility, is reviewed in section   4.0,  Facilities, of this report. Chapters 3 through 8 and Appendix A are reviewed in this section on an individual item basis.
Recommendations Chapter 3    " Safety and Health" Items 3.1.1.a (restricted working air sample), c.        (hot cell air sample), d. (shipping container wet smear), and e. (personal body 7

  ,I, contamination check) do not refer to the apecific procedure for performing tests, surveys, or checks.              These abould reference     j specific procedures,       i.e. ISP  2, ISP 15, etc., in the operating procedures manual.
3.1.2.a       Personal dosimeters should be read at numerous intervals throughout the day, to minimize the possibility of an off-scale reading.
3.1.5.d      The wrist badge should be replaced with a finger ring, and the ring should be worn continuously within the plant.
3.1. 7 . a    All survey instruments should % calibrated at inte rvals not to exceed six months.
3.2.3     Bioassy - Whole body counting for internal exposure should be related to actual work time and air concentrations in correlation with radiation protection guides.          The f requency can be formulated and presented to the NRC for concurrence.             There is no obvious correlation between whole body exposure and need for whole body counting.
l 3.2.5       Air Sampling Ins t rume nta tion  -
Redesign the entire air sampling system per the recommendation from section 5.0, Equipment.
Chapter 4      " Procedures for Handling Radioisotopes" 4.2.2.b      Entering the liquid waste storage room - Use a calibrated high range ion chamber for surveying (minimum 20 R/h recommended).
4.3.2.a      Cell and Decontamination Room - Complete anti-contamination dressout (disposable jump-suit, gloves, boots, and head gear) should
    ..            be required.       All open seams or junctions (glove / sleeve) should be taped off. Full-face respirators should be utilized.
8

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4.3.2.b      Liquid Waste    Storage  & Processing Reom -- Complete anti-contamination dressout (disposable jump-suit, gloves, boots, and head gear) should be required.        All open seams or junctions (glove / sleeve) should be taped off. Full-face respirators should ha utilized.
Chapter 5    " Storage of Isotopes"
   *+              No recommendations.
Chapter 6    " Transportation of Isotopes" No recommendations.
Chapter 7    " Monitoring" Personnel monitoring is provided by whole body film badge changed
           ,       weekly, and wrist film badges changed monthly.
7.2.b   Change the wrist badge to a finger ring and require it to be worn et all times within the facility.
7.2.c    Implement the use of an RWP system, which will. require the RSO to authorize the work request and . provide health physics surveillance. The RSO should not engage in _the work activity, but should monitor / manage the work. The RWP would require complete
  .m                pre planning of the operation, pre-operation monitoring of.1) dose ates, 2) contamination levels, and 3) air concentrations, time estimation for work, _ projected dose to individuals, a review of the operation to reduce the dose, and         a- review of the completed ope ration and dose records to determine if ALARA conditions were met.
Chapter 8    " Contamination Control & Waste Disposal" 8.1.1    Action in the event of a spill - This should be amended to require that a leak or spill be confined if possible.
9

o
,8 8.1.3.a     Area Decontamination - Non-Expendable Equipment - Redefine the wipe area to be the " standard" 100 cm 2        (approximately 15.5 in.2), and adjust the action level to the appropriate value.             I ISP-2 Revision A      " Meter Survey Procedure" ISP-2A Should be revised to include the action level for each area listed (occupied vs. non-occupied). The reverse side of the form could be used to note any corrective action taken, and the survey results of the action.
ISP-3 Revision A      " Wipe Survey Procedures" 5.1.2    The wipe are a should be 100 cm2 (approximately 15.5 in,2) instead of I ft.2 5.2.1   Action limits should be set in terms of disintegrations per
       ,        minute (DPM) and re f erenced to specific criteria.         For example, 50,000 cpm on 1 ft.2 corresponds to 5,555 cpm on 100 cm2 . Using the efficiency and background of the isotope shop area (ISA) well counter this would correspond to approximately 100,000 dpm, which is considered excessive by the audit team for any area in the ISA.
5.2.2   Uncontrolled Areas - Same general principle as above.       The action limite should be re-evaluated and submitted to NRC for approval.
t ISP-4 Revision A      "Well Counting Procedures" 5.4 and 5.6     Determine the minimum detectable activity (MDA) needed to ensure that the guidelines or criteria have been met, then select
,,               the appropriate counting time for the sample.
5.7 The activity calculation should also include, as a minimum, the associated error based on counting statistics.
10

o el ISP-5 Revision A       " Daily Check List" No recommendations.
ISP-6_- Revision A     " Semi-itonthly Checklist" No recommendations.
  '*.       ~ISP-7 Revision B         " Monthly Checklist" i
No recommendations.
!               ISP-8 Revision A      " Air Monitor System Check" 5.6.2   Use the new flow rate as prescribed by the new stack sampling system.
          ,            Calculate the MDA for the system based on the counting time needed to - mee t. the NRC air concentration release limits. Calculate the associated error based on counting statistics.      Report either FWA, or the calculated concentration and its associated error based on counting statistics.
ISP-9 Revision    A.-  " Air Monitor Calibration" No recommendations.
               - ISP Revision A     " Hot Cell- Air Samples" The same calculation recommendations in ISP-8 apply.
   ,,            ISP-11 Revision B       "ISP Air Samples" 5.2    Based on a one month sample period, the background and-efficiency f rom the ISA well- counter (10/22/85), the sample would II                                                  11

o
    ,a have to be counted for 71.8 minutes to determine if the not activity exceeded 9 x 10-9 pCi/cc of air. This counter should be used to screen the sample, then forward it to the well counter in the unrestricted area for final analysis.
i 5.3     This section refers to " discharged air".         This procedure calculates the air concentration for the ISA over a given period of time and does not directly reflect the concentrations of the
    ..              " discharged air".
ISP-12 Revision A      -
                                        " Release of Liquid Waste into the Sanitary Sewage System" 5.3 Modify this section to require continual agitation of the water during the disposal process, otherwise settling may occur and Co-60 may buildup in the batch tank.
         ,   ISP-13 Revision B        " Emergency Generator Battery Check" I
No recommendations.
ISP-14 Revision B       " Entering the Hot Cell" No recommendations.
ISP-16 Revision C
* Radioisotope Container Receiving Procedure" Change ISP-6A to reflect the contamination check area as the
                     " standard" 100 cm2 instead of I sq. ft.
ISP-17     "ALARA Program Revision" w.
Item 5.d. suggests that when necessary, a new higher action level'II can be e nact e d.      This is not in accordance with good ALARA 4
12

l . e, .
practice. Action levels should be realistically de te rmined for
                  . general situations, and should not be allowed to fluctuate based on the need to expose an individual.      This item should be eliminated from the ALARA Program.
A functional . ALARA Program should work ' to reduce high radiation areas, excessive surf ace and airborne contamination -and - potential for release of radionuuides to the environment. Several practical l
steps could be taken (reduce solid and liquid waste volume, reduce l-                 HEPA   filter    contamination,   decontaminate   the   hot cell   and decentamination room,- etc.) to establish a sound functional ALARA Program.
ISP-18 Revision 0     " Radiation Exposure Level Evaluation" 3.0    Change wrist badge to finger ring, because the fingers are of ten exposed to higher radiation levels than the wrist.
4.1    Air samples   should also be taken separately as the work is performed.
ISP-19 Revision A     " Cobalt 60 'rcapsulation" 5.1.1    The worksheet identified as " attached" should be given an ISP-19 Number.
      ,     ISP-20 Revision A     " Preparation of Used Sources for Resale" No recommendations.
ISP-21 thru 27 - Not defined in Appendix A.
ISP-28 Revision _ B   " Packaging & Labeling Depleted Uranium"
                  -No recommendations.
4-13

GI 6
ISP-29 thru.1001 - Not defined in Appendix A.
l 1                   ISP-1002 Revision- A                  " Leak Test for Sources Installed in Teletherapy and Industrial Radiography Systems" 4
5.3         ISP-1 does not specifically address leaking sealed sources.
This specific item (Leak Testing of Sealed Sources) should be added as part of Chapter 1 under a separate heading.
i ISP-1003 Revision A                   "Packesing & Labeling Depleted Uranium"                                  '
a 4
All sections of this ISP are identical to ISP-28 Revision B, dated 10/23/84, except items 5.5.1 and 5.5.2.                     Either ISP-1003 Rev. A or ISP-28 'kiv. B. should be deleted; f rom the manual.
The following ISP procedures were reviewed as a part of the November 1984 license renewal application; they were not provided as a part of the OPM.
ISP-26 Revision A               " Depleted Uranium Handling Procedure" ( Attachment 10.4 of 1984 license renewal application)
P No recommendations.-
ISP-27-Revision A               " Emergency Procedures for Depleted Uranium"
                             -This procedure should be modified to note that Uranium metal is' L                          pyrophoric and. can be extinguished                         only  with   type.      D-       fire extinguisher or equivalent equipment.
ISP-30 Revision 0              " Instructions to Drivers When Transporting Radioactive Materials" i.
Nc recommendations.
    ~-
14
                         ~       - -                         _.       ...,m .-        -.m.  -. .

o 0  .I ISP-31 Revision D      " Calibrating Radiation Detection Instruments" 7.1    The instructions for selecting appropriate distances for using the TECH /0PS calibrator should be incorporated into this section of ISP-31.
8.0    Procedures for the use of the commercially available personal dosimeter calibrator should be incorporated into this section of
   , , ,        ISP-31.
Miscellaneous Findings Several procedures refer to the use of respirators (half-face dual cartridge were available) as required equipment. AMS does not have an approved respirator use prograu in effect, nor is there a written policy statement on respiratory usage.
A respirator hanging in the ISA was f ound to be contaminated. The two typq H cartridges were returned to the RSAP lab for analysis.
Although significant surface contamination was present, the filter media was also contaminated.         (S'e Results in section 11.0, Site Survey).
Recommendations AMS should establish a respiratory protection program consistant
      .         with NRC guidelines. USNRC Regulatory Guide 8.15 (October 1976) (or ANSI    Standard   Z88.2-1980)    outlines    acceptable   programs  for respiratory protection (see Appendix E).             The program should address, as a minimum, the following elements:
: 1. A strong management committment to respirator usage;
: 2. Identification of the individual responsible for the program; I-                                          15

e il d
i                              3 A method for evaluating program ef fectiveness;
: 4. A. program to ensure proper respiratory equipment fitting;
: 5. Prepara       in        of.       procedures       . covering                equipment,            issuance,
;-                                 maintenat.ce, use, training, and qualification; and
!                                                                                                                                               i i                              6. A       maintenance              program      for     inspection,                       testing,-     repair,
     ,,                            decontamination, and disinfection of respirators.
:                2.5. Environmental Surveillance Program l-l
;                      Findings No environmental surveillance program is in operation.
i Air and liquid effluent- releases are routinely ' monitored at the f
point or discharge.
l             ,
Environmental exposure-rates are not . routinely measured.
J''
Environmental exposure-retes were . measured at several locations around the facility. (See Section 11.0, Site Survey-for results).
    .s Recommendations
       ,,              Quarterly exposure-rate measurements on the roof and inside the fence line should be performed.                                                                                                     ,
No environmental surveillence program is recommended at thic time.
v.
              ,1 t
       "*                                                                16 u

o e l-3.0 STAFFING / TRAINING Findings The AMS f acility had. on1) two full-time personnel on staf f at the ti.ne of the audit._ The secretary had no background or training in radiation prottetion or int.;ustrial safety; the technician (employed less than two months) has a mechanical background and an eight weeks 1
    ,-.,                       electronics course.          The technician had no foraal training or experience in radiation protection or industrial safety.
1
    +:
AMS utilizes the services of a consultant on an as-needed basis for hot cell and other relateC work requirements.           The consultant, a previous Picker employee at this facility, has at least 15 years expe rience in hot cell work, saaled source fabrication, ' source exchange and other radiation related projects.         The consultant has some formalized training in radiation protection f rom previous employment.
AMS provides a radiation protection training session as a part of the field engineer training course.
The RSO is- located in Pittsburgh, PA and visits the AMS London Road      )
f acility weekly.-   The RSO has a B.S. in Chemistry from Carnegie Mellon Ins titute (Pittsburgh, FA), but hati no formal training and       ;
minimal experience in radiation protection.
i Other personnel f rom the AMS Geneva facility have been utilized on an as-needed basis for hot cell entries, decontamination work, high radiation - area entry, waste handling, etc. These personnel have attended in-house - training sessions on radiation protection, and have passed written exams.
v.
Example:    Sr. Electronics Technician - Two year Associate r',egree in' electronics. Approximately two days formal in-house training in radiation safety procedures,        instrumentation,   and   ALARA practices.
_17_

      'O .
  .'p There is . currently no employee of AMS qualified to perform radiation protection training.
The RSO appears to have an open, receptive attitude, and an
                   . ea ge rnes s to increase basic . knowledge and improve health physics practices where appropriate.
Recommendations All. full-ti me employees and- occasional       or consultant    labor  should participate in a formalized Radiation Protection Training Course.           Tne L            training should be documented and re-training should be provided on an annual basis.       The training program should be implemented as soon as I            possible. A list of possible training courses is provided in Appendix C.
Improve the professional health physics capabilities by augmenting the existing staff, or providing in-depth training for the RSO (basic and
(          ,  advanced course).
The RSO should be required to be present at the site to monitor any activity requiring an RWP:
l
: a. entry into a "high radiation area";
: b. hot cell entry;
: c. HEPA filter change out;                                              !
: d. radioactive waste packaging;
: e. radioactive waste shipment.                                          ;
: 6. ,
[~                                          18

o I , l' 4.0 FACIL.ITIES Findings (Figures 4-1 through 4-3)
The licensee has designated restricted / unrestricted areas; however. -
the NRC designates the entire f acility as a restricted area, since all access is limited 24 hours a day by lock and key.              The restricted areas in the f acility are adequately marked and secured l
l   ,,                         to prevent unauthorized entry.
t Exposure-rate levels in the licensee designated areas were generally _
less than 1.0 mR/h, with a maximum of 220 mR/h (see Section 11.0 l
l Site Survey for results).      Twenty-nine of 41 areas were less than 1.0 mR/h, 6 areas were between 1.0 and 2.0 mR/h, and 6 areas exceeded 2.0 mR/h.
Traffic patterns are designed to minimize entry into the restricted areas.
Entry into the airlock is controlled by key and door lock out-system. If the ISA doors are open, the warehouse or hallway doors cannot be opened ' or vice versa.        This isdesigned to minimize introducing potentially contaminated air into the unrestricted areas.
The ISA is maintained under negative pressure with respect to the unrestricted areas, by supplying more air to the unrestricted areas, than is removed.
The hot cell .is naintained under negative pressure with respect to the ISA and the unrestricted areas, and measured 0.11 inches of water on the manometer.
: c. .
All drains within the restricted area (with the expection of the toilets and basement - floor drain) are piped into the liquid waste collection system.
7                                                        19

  .e
  ,I The hot cell is 6 feet square inside with a height of approximately 10 feet, and has 5 1/2 feet thick concrete walls and 4 feet thick concrete floors and ceiling.          The floor pan is stainless steel and the walls are lined with 1/4" steel , late to a height of 11 feet.
The cell is accessed at the rear thro gh a 42 ton hinged door. Cell observation is provided by a 5 foot glass and zine bromide solution window.           Remote operations are possible using a pair of Model 8       l manipulators and a two-ton overhead crane.          Normal cell operations e                                                                    do not require entry into the hot cell.
The Model 8 manipulators can reach most of the cell area, but not the cell floor.
The cell is illuminated by 3 glass-enclosed, mercury vapor lamps.
Two bulbs are burned out, and the other is very dim, significantly
!                                                                       reducing the illumination level.
                           ,                                            Portable spotlights are presently being used in the cell, but are suscepttble to breakage.
Access to the hot cell from the ISA is via two straight-thru ports in the coil wall.           The only other access is through the 42 ton hinge r',    door which surves as the rear (west) wall of the cell. The limited size of the access ports do not permit the exchange of equipment, filters, waste, etc.; this restriction requires opening the cell door to exchange any object over 4' in diameter.
The cell door is interlocked by a switch located at the door, and a second switch located at the cell controls.             Release of either switch stops the door movement.            The dual switch system limits single person entry into the hot cell, and requires an individual in the cell control area to assist in cell door opening.
Storage facilities within the cell are provided by two lead containers inserted in steel sleeves in the floor.
20
                                             ^
                    \\                                                                                                                             .-

e
[;5-Radiation      levels  in - the  hot   cell  due   to   unsealed   sources (coutamination and loose pellets) are high, resulting in excessive personnel' exposure during cell entry.
Two exhaust - ducts in the hot cell are connected to a _HEPA filter system.-     One duct was pre-filtered using a regular furnace-type filter, the other duct did not contain a pre-filter.
The hot cell pre-filter is - held in place by screws which require cell entry for change-out.
The ISA and the hot cell have once through airflow directed to a HEPA filter system.      The air flow pattern is from the unrestricted l                    areas     through the ISA to the- HEPA system,           and  through the l
l                    decontamination room through the hot cell to the HEPA system.
The doors to the decontamination room are interlocked such that,
             ,       opening the doors increases the hot cell f an speed, and diverts tho the decontamination room supply air to the ISA.
The blowers and' HEPA filter system are located on the second floor directly above the hot cell.
The hot cell is exhausted through a single HEPA filter into a common exhaust stack. The ISA exhausts through a "2 x 2 array" of HEPA filters into a common exhaust stack.
The exposure-rate outside the restricted area exhaust ventillation room' exceeds 80 mR/h in some areas, due to contamination on the HEPA filter. During the audit the exposure-rate at the hot - cell filter was 3.0 R/h. These exposure-rates are excessive, 'and severely limit j
    .'                the    time accessibility to      this   room for    routine   maintencnce
                     -_(generator, battery checks,-_etc.).
The exhaust stack for restricted areas of the facility extends approximately 15 feet above the roof line, directly above the exhaust ventilation room.
    ~
21

o
  .I
* The radiation level on the roof, in the vicinity of the stack ranges from approximately 30 mR/h at waist height to a maximum of 300 mR/h directly over the small HEPA filter.
The radiation levels in the vicinity of the exhaust maintenance room increase as the contamination on the HEPA filter increases.
The rooftop exhaust stack area is placarded as a "High Radiation
  ,.                Area" but the physical boundaries are not clearly defined.
Recommendations Changing the pre-filters used in the ISA and hot cell to a dry and spun glass filter, will reduce the contamination of the HEPA systems.
These pre-filters will remove a larger percentage of smaller diameter
   ~
particulate material. Changing these filters more frequently will reduce i
personnel exposure, and should increase the useful lifetime of the HEPA system.
Redesigning the pre-filter holders in the hot cell to permit manipulator replacement of the pre-filters will reduce personnel exposure during filter change.
Install a pre-filter over the open duct in the hot cell, until the filter holder design can be changed. This will reduce contamination of the hot cell HEPA filter, increase its useful lifetime, and reduce personnel
    .         exposures during filter system maintenance, emergency battery test, or other activities in the surrounding area.
Improve hot cell illumination by replacing the burned-out bulbs.       Also, change the bulb assembly design to permit remote changing of bulbs.
v.
Upgrade the remote manipulators to provide access to all areas of the cell.
     ~
22 l

   = 'o
-l   ;g:
t Perform '.. a -- complete . decontamination of the hot cell and duct work.-to
              -reduce the exposure levels as low as reasonably achievable for-futur'      e hot cell  entry.-     This -work- may best     be performed by a professional           -
decontamination firm.
l Changing - the single : HEPA'- filter on the hot cell to a two-stage, series HEPA -filter system'will reduce the risk of of f-site releases in the event of filter rupture.
              -On an annual. basis, perform a smoke-test throughout the facility to verify proper air flow patterns are in etfect.
I m
9 I
go4 T
W' 23

), ;cB 5.0 EQUIPMENT 5.1   Portable Monitoring Instrumentation                                            :I a
               ' Findings i
The following portable monitoring / surveying / detecting ins t rumenta-  )
tion was operationni and calibrated on the dates of the audits            I 5-Victoreen model 491 w/30 mg/cm 2 CM detectors (range 100 mR/h)
(Serial #1851 - had low battery indication) 1-Eberline Radtad (Chirper) 1-Victoreen Digital Chirper 1-Eberline PIC 6A Ion Chamber (range 1000 R/h) 1-Nuclear Associates Mini-monitor II (range 1 R/h)
The following portable monitoring / surveying / detecting ins trumenta-tion was operational but out of calibration:
2-Nuclear Associates Mini-monitor II (range i R/h)
The following portable monitoring / surveying / detecting instrucenta-tion was non-operational:
5-Victoreen codel 491 with or without-detectors 2-Victoreen Thyac 11 A4 4-Victoreen Model 592-B 2-Victoreen Thyac I
['                                                24

3
    .e 3-DCA digital alarming dosimeters model 1888 (range 10 R) 1-Eberline E-510G (internal GM tube) (range 1 R/h) 1-Nuclear Associates Mini-monitor II (range 1 R/h) l-Eberline Radtad (chirper) i Jr                 Several portable instruments were in field use at the time of the B                      audit. Their operational state and calibration accuracy were not verified by the audit team.
Instrument calibration for GM survey me ters and ion chambers are performed at six month intervals, or prior to use if the calibration date has been exceeded.
GM meters are calibrated with a 2 mg Ra-226 source.          Ion chambers are calibrated using a Tech /0Pd Co-60 calibrated reference source.         l Ra-226 2.02 mg U.S. Radium Corporation Co-60 15 mC1- 7/31/78 Tech /0PS Ra-226 approximately 2.0 mg Picker Model 540 The instrument calibration room has storage areas - set aside for calibrated instruments, non-calibrated inst rument s , functional and non-functional instruments. This appears to be an ef fective system to - monitor instrument status.
Several ins trument calibration stickers had inaccurate calibration due dates. These were noted and corrected immediately.
      .+                The instrument calibration sheets were reviewed. All current sheets appear complete, and were signed and dated.
l l
[*                                             25

   .8 Recommendations Change the instrument calibration requirement to semi-annual regardless of use history.        If the instrument is operational, it should be calibrated.
This will prevent an individual from " grabbing" a functional instrument which may not be calibrated.
Repair. all non-functioning instrumentation or dispose of non-repairable
  .o,           ite ms .
Calibrate all portable ins trumentation with the Tech /0PS Co-60 source.
I Add a second Eberline PIC 6A or other high range ionization instrument fur backup when the current unit is out for calibration or down for repair.
5.2 Personal Dosimeters Findings The following dosimeter chargers operated properly:
7-Victoreen model 561-A 2-DCA chargers
                         .The following pocket dosimeters were operating properly and within calibration:
3-Victoreen SR Chambe rs 5-Victoreen IR Chambers 4-Victoreen 200 mR Chambers 6
A DCA- dosimeter calibrator was stored in a cabinet in the cell control area. This unit contains a nominal 10 pCi Cs-137 source calibrated 2/26/85.
r-i---
26

a ISP 31-C section    8.0, in the Operating Procedures Manual, gives three acceptable methods for pocket dosimeter calibration.      Item I references outside vendor; item 2 references commercial dosimeter calibrator; and item 3 utilizes procedure 8.1 through 8.5.             l Racommendations                                                              l Expand section   8.0,   ISP 31-C to include procedures for use of the i-                                                          commercial dosimeter calibrator.
5.3                     Fixed Instrumentation Findings The ISA uses a Picker Spectroscaler IIIA with a NaI(TI) well
(                                                                   detector for smear and other sample analysis. The scaler is located in the cell control area but is visible from the ISA, while the well
                   ,                                                detector in located in the l!.A. The start count function can be operated from the ISA. The detector is shielded on the bottom and sides by 4" lead. Functional tests performed during the audit:
HV - 1100 volts Background - 7352 counts /5 min = 1470 cpm Co-60 standard - 9902 cpm Co-60 activity - 2.54 ES Y/ min Efficiency - 3.31%
A Picker Spectroscaler 4 with a NaI(il) well detector is used to count smears and other samples in the unrestricted area of the facility.
  ,,                                                                 Functional tests performed during the audit:
HV - 1200 volts Background - 77 ces/5 min = 15.4 cpm Co-60 standard - 3261 cpm
   ~
   .-                                                                                           27

  .5 Co-60 activity - 2.32 E5 y's/ min Efficiency - 1.40%
* A Picker 600049 Labmeter with a 30 mg/cm 2 GM tube is used as a f risker for exiting the 1SA.
A Victoreen model 500 electrometer with a 0.33 cm 3 chamher is used for monitoring hot cell operations. The range of this instrument is
  ,,                                                      0-2000 R/ min. The instru.nent was operational and calibrated at the time of the audit.
A Victoreen model 500 electrometer with a 3.33 cm 3 dosimeter calibrated for Co-60 was used by the audit team to survey the hot cell and evaluate the calibration of the AMS unit. The cross check data indicated the AMS unit was within 4% of the ORAU unit. This is t
considered satisfactory.
Tech /0PS model    492 Gamma Alar ms are used as area radiation I
monitora. The units in the second floor equipment room and the cell control area are set to alarm if the exposure rate exceeds 2 mR/h.
The units in the ISA and the shielded work room are set to alarm if the esposure rate exceeds 5 mR/h. The Tech /0PS area radiation monitor in the shielded work room was turned off at the time of the audit, because the exposure rate in thia room exceeded 5 mR/h. The room is temporarily being used as a vaste storage area. The alarm set points an each unit are checked monthly using a Ra-226 source.
The records were checked for the current calendar year, and appear to be complete.
The exhaust stack air sampling station, located in the basement uses a Picker 600049 Labmeter with GM detector to monitor the air filter.
v, Recommendations The ISA well counter should be used as a screening device only. The high backgrounds in the ISA give a minimum detectable activity of 5444 dpm using the counting procedures described in ISP-3 (i.e. a 1 minute count).
28

  *B s
Replace the Picker frisker used in the change room, with an audible alarming, AC operated, battery back-up ratemeter, with a thin window, pancake style GM detector.                                     New models available provide more dependable operation, and                                      the thin window GM tube will improve sensitivity.       A backup scaler and detector should also be purchased.
Make arrangements with Victoreen to provide secondary instrument support for the model 500 electrometer during re-calibration or down time for
  ,.          repair, in the event cell operations are ongoing.
5.4   Air Monitoring Findings l
Two fixed, general aret., air sampling stations are located in the ISA (Figure 5-1).                      The vacuum for these stations is supplied by a common pump shared with the exhaust stack air sampling station in I                                   the basement.
Each station flow rate is individually monitored by a rotameter.
The prescribed rotameter settings are 10 1pm.                       Both rotameters were within 0.5 1pm of the prescribbed setting.
The rotameters are not being calibrated on a regular schedule.
The re are no records from recent history to denote any rotameter calibrations.
An open-end filter holder has been mounted on a semi-flexible copper tube for remote air sampling of the cell, decontamination room, or other areas as needed.
e.
The stack sampling system (Figure 5-2) is composed of a stack probe, sample line, flow meter, filter system and pump.
The existing drawings indicate at least 70' of sample line from the probe on the roof to the filter paper in the basement.                     The sample y                                                                             29 i.
w

  .a line changes from 1" to 3/4" pipe during the piping run; the sample line contains a minimum of 8 right-angle bends between the probe and the filter. The flow meter is placed in the line between the probe and the filter. The flow meter is measuring the flow from the fixed        i I
air stations in the ISA as well as the stack sample flow.
l The stack probe design is not compatible with ANSI stack sampling recommendations, and the air is not isokinetically sampled f rom the
! n.                                          stack.
The prescribed stack sample flow rate was 5 cfm and the indicated flow rate was 6 cfm at the time of the audit; however, this includes the flow rate from the two ISA fixed stations.
The stack is sampled continuously, with a monthly filter change.
The filter loading has oeen assumed to be negligible.
      ,                                       Air samples were collected f rom the stack, hot cell, decon room and ISA; the. results are reported in Section 11.0, Site Survey.
Recommendations Calibrate all air sampling flow meters semi-annually.
The    stack     sampling system and     procedure   should  be  redesigned  to incorporate the following:
: 1. Design and install an isokinetic sampling probe.       Refer to the ANSI Stack Sampling Guide for proper sample probe selection and installation.
: 2. Mount the filter paper holder as close to the stack as possible.
: 3. Mount the rotameter as close to the filter holder as possible.
: 4. Install separate vacuum pumps and flow meter set-ups for the ISA stations and the stack sampling system.
h 30

l              .
: 5. Change the filter paper sample media to 0.8 um millipore paper.
Monitor the filter loading by change in rotameter flow.
: 6. Record beginning and ending flow rate to document filter loading and change out fr'quency.
4
                  ~
I
                   .L.
P*
                    "                                                31 i

o =-
}   it-6.0 MATERIAL ACCOUNTABILITY Findings Radioactive material       inventory    is maintained on a      time-share computer.
Whenever on inventory request is made           the printout reflects the activity on hand corrected for decay to the current date.
The radioactive material on hand is in the form of solid metal Co-60 1                       (pellet form), or manufactured Co-60 sealed sources (wafer, customer-owned, competitor owned, or pellet form), cesium-137 sealed sources, and depleted uranium.
The radioactive material inventory does not include waste materials.
* Inventory as of 10/01/85:
On Hand     License Limits s
Co-60                175414 Ci     300000 C1 Cs-137                 6403 Ci-     40000.Ci-Depleted Uranium       3682 #        9000 #
Recommendations
               - Modify the computer program to - include radioactive waste in all forms (liquid, solid, contamination, packaged _ (ready for shipment), etc.), or-         ,
J
               ' develop a separate program to track radioact!va waste inventories.
6e W
       -                                              32 T

o 41 7.0 SECURITY Findings l              Building security is provided by ADT Security lystems, Cleveland, Ohio.
Inspection of the active security system was difficult, b3cause 4
outdated wiring and detection devices _ are still in place.
Monitoring of unauthorized building entry is provided by security tape on glass, magnetic door sensors, ultrasonic motion monitors, and inf ra-red photoelectric beam systems. TripH ng any of the above devices results- in an alarm at- ADT Secur'        ervices, as -well as visual 'and audible alarms on the control panel           in the cell operations area.
An alarm at ADT Security Services initiates the follcwing actions
: 1. Notify police of alarm and probable cause (unauthorized entry, fire, etc.)
: 2. Dispatch an ADT security- team to the site.
: 3. Notif y AMS personnel on the Emergency Call list.
ADT - Security : Services have been inattucted not to _ enter the AMS facility unless accompanied by AMS personnel.
Six safety / monitoring devices    installed by ADT, are connected to-the cell operations master alarm panel.          These devices, which g;,-           provide redundancy, are
: 1. Cell temperature alarm - if temperature in cell drops below 42'F or rises above .85'F.
I                                          33

                        .e
: 2. Cell exhaust fan alarm                     -
fan shut down; sudden pressure drop across HEPA filter (filter rupture): improper filter pressure (broken belt, clogged filter, etc.); 3xcessive radiation detected in stack air filter.
: 3. ISA exhaust f an alarm - f an shutdown; sudden pressure drop across itEPA filter ( rupture)I improper filter pressure (broken belts, clogged filter);            excessive radiation detected in stack air
                       ,,                                            filter.
: 4. Stack filter monitor alarm - excessive radiation on filter paper or monitoring equipment inoperative.
: 5. Supply air fan alarm                    -
a thermostat in the air intake will trigger an alarm if the duct temperature sensed after the l
heaters, drops below $0'F.
: 6. Emergency generator alarm - signal given on power failure.
At a maximum of thtee years, or at the request of AMS, ADT Security Services performs a comprehensive factitty review and recommends l
appropriate modifications to the existing security plcn.                     The last AUT review was approximately July 1984.
ADT inspects the burglar alarm system every one to two years.
* AMS personnel are not familiar with the type of burglar alarm system l
currently in operation.
Recommendations None s                         r~
,4 34 g

il 8.0 FIRE PROTECTION Findings
* The review of the . AMS Fire Protection program was conducted by tiarvey Goranson, P.E., with Professional 1.oss Control, Inc., Oak Ridge, TN. The evaluation is presented in Appendix F, o            The     Cleveland   Fire    Department  lacks basic knowledge of    the operations of the AMS facility, and the potentisi risks associated with responding to an incident.
The hot cell contains no form of fire suppression system.
* Several areas of the facility are not covered by fire detection devices.
* deviation from NFPA standards and good
    ,        Other areas of                                                    fire protection practices are documented in the attached report.
Recommendations
* AMS should develop a fire pre plan with the Cleveland Fire Department.
Automatic fire suppression should be provided throughout the facility (hot cell excluded). Acceptable suppression systems would include:
: 1. W t pipe spJinkler system;
: 2. Pteaction sprinkler system with heat detector activation
: 3. Wet pipo eystem utilizing "on-off" sprinklers which will stop the flow of varer buk u a. prescribed temperaturel
: 4. Total flooding halon 1301 extinguishing system.               *
[                                           35

  >   I flot cell fire suppression can be provided through a home line from the cell faucet, or an open can of dry chemical. Either system could be manipulated using the remote manipulator arms.
I Separate the presently occupied areas of the facility from unoccupied         l areas by three hour rated barriers.
Require ADT Security Systems to inspect, repair, and replace loose or
  .                  painted heat detectors or looso pneumatic tubing: and, extend the heat detection system to second floor offices and mechanical equipment room.
Removal all oil spillage from the basement floor.           Relocate and/or redesign the vacuum pump system in the basement.      An oil collection pan with absorbant should be used to trap pump exhaust.
Relocate the naturai gas line to the second floor emergency generator to the outside of the building, and the natural gas line through the airlock to the warehouse.
Upgrade the safety features on the mechanical room boiler to NFPA '85A standards. (Actual specifics addressed in Appendix F.)
Provide llalon or type B/C portable extinguishers in the ISA and the first 4
floor office area.
The recommendations for the balance of the plant areas are addressed in section 5.0 of Appendix F.
i  ,
n
       "                                               36

4
    .a 9.0 LMERGENCY PLANNING Findings The organisation chart (Figure 2-3) does not designate personnel to be notified in case of emergency.             However,   ISP-l. Chapter 1 addresses emergency action procedures and personnel notification.
    . .           Radiation hazards are addressed to Howard Irwin, Radiation Safety Officer Seymour Stein, General Manager ISP-1 also addresses general fire or explosion precautions and actions.
l l                 The emergency action plans do not give adequate guidance for
         ,        contacting the appropriate agency or institution in the event of
: 1. Fire
: 2. Explosion
: 3. Burglary
: 4. Personnel contamination with or without injury.
: 5. Possible ingestion or inhalation of radioactive materials.
The following agencies,           listed in section    1.4  of  ISP-1 were
    ,,,           contacted to determine the status of emergency action plans:
Agency / Institution         Individual Contacted              Status Cleveland Police Dept.       Patrolman Healy                Plan in effect for (Badge #593)                   Police / Fire / Utilities (216) 623-5005                 Emergeacy Medical
    "                                   11/12/85                       Services. Contents of plan & issue date were classified, and were not released.
37

    .I                                           ,
J l             Agency / Ins titution       Individual Contacted                         Status Cleveland Police Dept.         Sgtt Regete                             Ne knowledge of any (Local London Road                      plan.
District) 11/12/85
;         Cleveland Fire Dept.           Cpt. J. Esper                           No knowledge of any l                                       10/22/8$                                plan.
i j         Hillcrest Hospital             Gail Bassick                            No knowledge of any j                                        Director of Legal Affairs               plan.
11/12/85 i  ,                                                                                                                           i i         fluron Rd. Hospital            Jeff Hoebius                            No knowledge of any Assistant Vice President                plan.
t
 !                                       11/12/85
!                                                                                                                             l The phone number for the Huron Road Hospital is incorrectly listed                                          f as reads:- 761-6111                                                                                         :
should read        761-3300                                                                                 i The emergency action procedures do- not clearly outline steps to                                            ,
evaluate   ,
contamination nor dose                 rates arising   from emergency situations.
* There is no established check point where radiation survey equipment can be readily accessed in the event a fire or explosion renders the AMS building inaccessible.
Recommehdations Review and upgrade ISP-1 to present explicit instructions on who' to contact in the event of an emergency, what action to take, what equipment should be accessible, . etc. Emergency planning information can be obtained from
    ..      Robert C. Ricks, Program Director Radiation Emergency Assistance Center / Training Site (REACTS)
ORAU/MHSD 150 E. Vance Road Oak Ridge, TN 37830 (615) 576-3130
    ,"*                                            38

e          :9 4
4 1                                                                                                                                                                                  1
  ;                                     Department of Emergency Preparedness                                                                                                        ,
Perry Nuclear Plant                                                                                                                        I l                                     Cleveland Electric 111uminatird                                                                                                           i 1                                      10 Center Road
,'                                      North ';rry, Ohio 44081 j                                      Initiate preliminary contacts / arrangements with all agencies listed in 4
]                                       ISP-1          section 1.4,                to advise them of the potential hazards associated
 !                                      with the AMS facility, general procedures for responding to an emergency                                                                  1 l
1 i                                       at the facility, and who to contact at AMS if they are asked to respond to                                                                ,
an emergency at the facility.
  !                                                                                                                                                                               i 4
:                                       Establish                 definitive              procedures             for  handling a              potential                 radiation i emergency.                 For examplet                                                                                                    f l
1 I
}
j'                                                  !. Take immediate action to protect life and property.
4
: 2. Report the emergency tot 1                                                                                                                                                                                 j
                                -                                   Name                                   Phone #                  llome Phone                                   I
: 3. Contact appropriate outside emergency' groups i                                                                                                                                                                                 !
Agency                                                   Person to Contact                            Telephone #       j I                                                         Fire l                                                         Police                                                                                                                  3 Emergency Hedical Services f                                                                                                                                                                             _,
;                                                         Hospital Nate                                                                                                           l i
: 4. Contact outside consultant if available.                                                                                   ;
I-                                      The - individual. making the call should be able to - clearly and concisely f-define the scope of the emergency:
i          .
: 1. Location:
4
: 2. Type of-emergency (Fire, Explosion, etc.);
i r,-                                                                                               39
+          c n .- ,,.      ~~,,,,,----,#,    +_. ...-  m ,.r,.-.,   ~~_,.-m,        -,,.-_..r,...--.._,,.~._,~,.,.w._             .,,.r..-,..,-..m         ,._,,._-.,,,.---..--r~.

         . B
: 3. Radiation levels;
: 4. Contamination present
: 5. Contaminated   victims  present   (internal, external,  potential hazard to medical personnel, etc.):
: 6. Possibility of airborne contamination!
l
: 7. Monitoring instrumentation is/is not avai?chle at the site, etc. l Establish a set of monitoring equipment available at a nearby, but remote location, to assist in monitoring the site or personnel, in the event access to the equipment located in the building is limited or impossible.
4 0
4 a
9
        -                                                                              40

l +9                                         ,
1 l
i 10.0 WASTE MANAGEMENT Findings
* The responsibility for waste management is assigned to Howard Irwin, Radiation Safety Officer.
* The waste management program has been neglected for a period of
  ...             time, allowing dry waste to accumulate to excessive volumes - with associated high radiation levels.
Low level dry waste, generated in the ISA _ is compacted using a home-type trash compactor.
Radioactive waste is stored in the basement beneath the ISA/ hot cell area. The waste is not stored in proper packaging or clean tight containers. HEPA filters from past changeouts are still stored in the basement area.
* AMS is packaging the dry waste for shipment to Chem-Nuclear Systems, Barnwell, SC. Two shipments were planned; November 1985 and at a later date.
The dry waste storage area contains high levels of removable contamination.
                 ' Liquid waste _ f rom the hot cell, decontamination room, ISA, laundry, change room (showers, sinks, etc.) are all piped into a 600 gallon stainless steel - holding tank, located in' a ~ shielded maze in the basement.
* Floor drains in the basement: are connected to the sanitary sewer system.
41
[

it
        '   Some drains to the holding tank have screens in place to prevent solids 1 see or larger f rom passing to the tank. (The drain in the hot cell could not be examined. The sink in the ISA did not have an obvious filter in place.)
* The Itquid waste room has a 9 to 12 inch i;urbed bara to act as spill basin for the holding tank.       The curbed floor area has a stated capacity of 2400 gallons.
* The floor area could not be inspected for cracks or fissures due to standing water and high exposure rates.
Disposal of liquid waste to the sanitary sewer system is by batch process. Water is drawn off the top of the holding tank, gross filtered and transferred to a 55 gallon drum.       The batch tank is agitated by electric motor for $ minutes. A simple is drawn off and counted in the well counter and the release quantity (number of gallons) is calculated. The batch is released if tlw total activity does not exceed the limits of 10CFR20.303. Records maintained are Date of discharge cpm standard cpm sample Gallons discharged pCi/mi of standard 9C1 discharged Total 9C1 discharged to date.
No procedure has been developed to handle disposition of the batch liquid if the limits of 10CFR20.303 are exceeded.
No procedures have been - - developed for- decontaminating the liquid L
waste storage area, the batch tank,        the holding tank or the associated plumbing.
7                                        42

[    .
9 .s                                                                                      l l
i No provisions are available for controlling discharges to the              I sanitary sewer system in sitt'ations such as:
: 1. Pipe breakage which flood the basement;
: 2. Fire which triggers sprinkler system, or where large quantities of water are used to extinguish a fire.
  .,           Either of these situations could lead to discharges to the sanitary sewer system well in excess of the limits specified in 10CFR20.303.
Recommendations Continue to package and remove the current inventory of dry waste.         Make future periodic shipments to prevent a buildup of waste.
Decontaminate the dry waste storage area. A suggested mothod would be the application of a strippable coating, such as Imperial Coatings #1146 ALARA Decon Yellow., to re move the majority of the contamination.        This area should be maintained to as great a degree possible as a non-contaminated zone.
Decontaminate the liquid waste area, the batch tank, the holding tank, and associated piping.        This may best be performed by a professional decontamination     firm.      Appendix  D   contains   a   partial   list   of decontamination firms.      Check the cleaned floor for cracks or fissures, and seal.
Redesign the holding tank to add a level gauge.       Monitor the liquid level and make batch sewer disposals or commercial disposals when the tank reaches a pre-set level.
o.
Develop procedures to address disposition of batch liquide which exceed the disposal     limits of    10CFR20.303.    (For example    -
contract   for 43 t.

b .5 commarcial filtration, ion exchange resin or other method, which results in final commercial disposal and sanitary sewer release.)
Develop contingency plans for controlling liquid releases to the sanitary sewer system through basement drains in the event of a major spill into the basement.   ( AMS could monitor discharges to the sanitary sewer system and place a servo-controlled valve in the basement floor drains to shut-off flow to the sanitary sewer if a prescribed radiation level is exceeded; or, temporarily seal the floor drains, so that releases to the sanitary sewer can be monitored and controlled.)
4 4
f Le
: r. '.
44

5 11.0 SITE SURVEY During the audit, random f acility and environmental (on and off site) samples were collected and returned to the ORAU laboratory for analysis.                                                                                       The facility survey consisted of exposure-rate me as u reme n t s , smears, sir, miscellaneous samples, liquid (floor of holding tank area), and miscellaneLus samples. The environmental samples consisted of soil, vegetation, standing liquid (storm irains, roof, etc), sediment (sower and storm drains), sewer discharge, and
  ,,     other miscellaneous samples. Direct radiation measurements were also perfo med.
The analytical procedur*u and equipment used are listed in Appendix Gs Findings Facilitten Ilot cell - Exposure-rate measurements were made in the hot cell at the table level and three foot above the table.                                                                                      A few Co-60 pellets were placed in a known position at the rear of the cell (Figure 11-1). Table 11-1 presents the survey results. Although there were no obviously visible pellets in the vicinity of areas 5 and 6, a substantial source of activity was present.                                                                                          The maximum reading at the table level was 35 R/m (2100 R/h), and at the f.hree foot level was 1.7 R/m (102 R/h).
The average exposure-rate in the cell at the table level was 6.5 t                        R/m (390 R/h) and at the three foot level was 1.4 R/m (84 R/h).
This     indicateu         considerable                                                cell                               contamination,    with   a probabilitv of loose pellets under the table.
NOTE:    The licensee has des'.gnated restricted / unrestricted areas based on contamination or radiation levels. The NRC views the entire facility as a restricted area per 10CFR20, since the f acilita' is operated as 24 hour controlled access by lock and key.                                                                                  The following references to e-                                                                45
* l F is i
                    -restricted / unrestricted    areas    are    based  on  licensee designation, not NRC designation.
2nd Floor    -
The second floor exposure-rate measurements are sunnarized in Tabic 11-2.         It should be noted that radiation levels in several unrestricted areas exceeded the action levels specified in ISP-2.
 ....        First Floor     -
The first floor exposure-rate measurements are summarized in Table 11-3.       Several locations in the unrestricted areas exceed the action levels in ISP-2.                                        l Basement - The basement exposure-rate measurements are summarized in Table 11-4.      The present ef fort to redure the dry waste volume         !
will reduce the high exposure rates in this area.                 Several      ;
locations, in the unrestricted areas exceed the action levels in ISP-2.
4 Smear Survey Measurements - Tables !!-5 thru 11-7 present the smear survey results. f rom the second, first and basement floors.
The results are within acceptable limits for the individual area designation, except the floor of the isodose-curve storage room and the miscellaneous storage room (basement).
Air Samples - Three f acility air samples were collected in the hot cell, decontamination room, and the ISA.                 During each
     ;       sampling period, no activities were conducted in the area which would resuspend particulate materials.            The air concentrations were Hot Cell                  1.24 + 0.01 E-08 pC1/mi Decontamination Room 3.35 + 0.01 E-09 pCi/ml
     ~
ISA                       1.42 + 0.01 E-09 pC1/mi The cobalt-60 ' insoluble air concentration for occupationally exposed individuals is _9 _x 10'9 pCi/ml. Note: These results
  .w                                   46
  -9,

l  .a are based on no activities which will resuspend particulate matter;   the air concentrations during work operations would undoubtably be higher.        This data, dependent upon stay time,       I could    support the establishment of a respiratory protection program, consistant with NRC guidelines.
l A single stack air sample was collected over a period of 48 hours. The stack air concentration was 1.64 + 0.03 E-13 pCi/mi which is considerably less than 3 E-10 pCi/ml, froin Table 11, Appendix B, 10CFR20.
Miscellaneous    Samples    -
Several   miscellaneous     samp1ss were analyzed for radionuclide concentration or total rahonuclide content. The data is presented in table           11-8. Cobalt-60 contamination in a roof gravel sample (#3519) indicates previous stack releases have occurred.          The sampling direction chosen (North of the stack) correlated to the actual wind direction on that date; for a definitive study, the sampling locations should be chosen based on site micro-meteorology. The sediment from the loading dock drain (#3516) contains a low but detectable amount of Co-60.      A water sample from the liquid waste room floor contained 1.75 E05 pCi/l of Co-60.           This water needs to be disposed of as soon as possible; and, the entire waste storage area should te decontaminated.
During the audit, an exposure rate of 20 mR/h was measured on a
     ,      half-f ace respirator which was available for use in the ISA. The cartridges   were   r1 turned   to  ORAU    and   analyzed   by   gamma spectroscopy to determine if the contamination was f rom handling the cartridge, or Co-60 on the filter media. Table 11-9 presents the cartridge data. There is considerable surface contamination w
on the cartridge, but there also is significant Co-60 on the filter media itself.         This also supports       the need for a respiratory protection program, consistant with NRC guidelines.
[                                  47

l   .I Environment Table 11-10 thru 11-14 presents the radionuclide concentrations in sediment, soil, vegetation, and water.            No detectable offsite cobalt-60 concent rations were found; however a f ew sediment, soil, and vegetation samples        displayed   detectable  significant   Co-60 ;
concentrations in the south to southeast regions of the plant property. This data suggests that contamination is being released e-             through the stack, or being transf erred outside the building from the restricted areas.      Sedime nt collected f rom storm drains at the loading dock and east of the butiding contain low, but detectable, Co-60. Standing liquid collected f rom the roof, storm drains, and sewer    outfall    contained    no   detectable Co-60.        The  Co-60 concentrations detected pose no hazard to the public or environment.
Figure 11-10 depicts three locations where radiation leakage occurs f rom the building. Area 1 measured 0.6 mR/h and is located opposite the access ports from the hot cell.        Area 2 occurs in a narrowly defined, beam approximately six feet off the ground, and measured 0.5 mR/h at the fence line.         This beam originates from the    cell exhaust HEPA filter room on the second floor. Area 3 occurs          in a
.                  wide flat beam sttaaming along the top edge of the Hot Cell door.
This beam is only detectable on the roof and measured 6 mR/h at the location indicated.
* Areas I and 3 will vary in intensity depending on the activity present in the hot cell.       Area 2 will increase as the HEPA filter contamination increases n th time.
Recommendations Quarterly exposure-rate measurements on the roof and inside the fence should be performed.         These measurements may indicate areas where additional shielding can reduce external exposure rates.       (i.e. The Area 2 exposure rate could be reduced by adding a solid concrete block wall on P                                         48

i
.I the southwest corner of the facility where the second floor access door is located. Also, action to improve the pre-filter media, and reduce the cont ainination on the HEPA filters, will reduce the direct radiation      i levels.)
e, t
L  F
 ==
49

7                 .                      1                                                       - -
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                               @                   k
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                               /                                                 -
e                                                              A
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Roan RAILRDAD
        /                                                                     e   FACILITY LOCATim i
r?GURE 2-1: CLEVELAND, OHID, AREA INDICATING THE LOCATION OF THE AMS FACILITY 4
_ -_ _ . -__________m

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                                  .                                           LONDON ROAD u        u              .
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M FENCE NOT TD SCALE W PRESENT OCCUPIED SPACE                                                                                                                                                  "
a t m                                                         /\                         m FIGURE 2-2 General Layout of AMS Property
             ~
51
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r:1                                 e ADVANCED E DICAL SYSIDtS. INC. - ORGANIZATION O Wti' T9 Fast /S ES - 0 B. B R ILG& N                                                                                                   AtmIntST8Af t%E AMI5TAssi - Ol'euaA ELT oonTesst11R - FSAsst EtmArt                                              LFu p A8.
* tam.La a - est. 5.5. sit t s                 Sas1Tv/utotFtATuat Ate Atas - seesbAasp taktas FtsetIC RE!AT3OseS - taClLLE a8curtase                                                                                            ittasseIL AL SarrreserT - hl4.1t Art ayAzS tipspen(1 - MAFILYS ZUSAL
          . ' stets                                       Itam EftsC                                             FIBIA SERTICE                   resteCT10ER and samT*LS CouTest w rt/n.E.                  SALES W ra              EXPORT                              ACTIE ftAMALES - F. CARANI                                 MA%AbFB - P. CA&Amt
               -E. SVICEL                 -3. AmeAnAff            ADMimISTRATOR
                                                                  -M. JUDO                                ADMIp. CLEst - C. austmSom                              >ttanfatt - J. esuovte ELECT. TECM.               MIDWEST REClow
             .-et. SAatfrFA               SA!IS MANAGER           19f7ERNATIonAL ASST.
                                          -J. 9s175               -E. EJERPE                                                                   COLL 8MATUS ASST.                   tenr./MAI*LS.
BRAFT$etEN                                                                             SERYlCE TECMS.          taum0ER 83.      -J. MILtJ8
               -g. OtAFFEE                DUME5 TIC ASSISTANT                                         -M. CLIPSTDW                             -J. ERAnatAS                        SUF1pftSOR
               -C. CtstTIS                4. CosLETT                                                  -M. otD                 !$0TOFE TELNS.                                       -J. FAREER
                                                                                                      -W. SALTENIS           -U. TUesETT       ELECTEICAL ASST.
TEta. WALTER                DOMESTIC SALES                                              -c. JotDAss            -J. PoutLL     -S. factAts                        SatFFtNC
              -T. CAAPEsfTES              C00RSinATOR                                                 -J. CDCNeuwl                             -]. petuar                          -S. VisscEnf
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- N                                       SALES BEF.                                                                                           -J. timLtt SUPEuvison                  -0. SUSSMAN                                                 BFt.tt*AstEs           scTim
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aEftSas: oCT. Isas FIGURE 2-3: Advanced Med cal Systems, Inc. Organization Chart I

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                                                           .                                                                                      *j AMS5 i
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Instrument Calibration                                                                                                              ;
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i as s                                                                  I                   l 4                                  L.                                                  I i                                                       .
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A                                                                      1 i           Shielded r             Work                                                           Office 1             Room                                    l Warehouse             f
                                       . k U                                           L      U                   ,
Hot                     Cell Decon                                                           DGVN T Cell __r-               Control                                      ,
Room                                                        ''
s                                                                                          Area                                 I       ;
t                                                                                       p q;                          l                   .t i
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I Isotope Shop Area                                               I
                                                                                                        ! Laundry / Change              {
Rooms t
                                                         ~
NOT TO SCALE
                                            ._        y.                           - - AREA VITHIN THIS BOUNDARY IS DESIGNATED AS A RESTRICTED AREA NY THE LICENSEE I
FIGURE 4-1: AMS Facility--First Floor (PartiaD

                              - . .       ~._ _ _            _ - - _ _ - _ _ _ _ _ _ .                   -          _ - _ _ _ . _ _ _ _ _ _ _                                     . _ .      .-     -                                                                  _
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Outs ide Roof Area                                                                                                                                                                     l
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r Unoccupied Office                              Unoccupied                                                                 ;
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;                                                                                                                                                                                Space                                                                                                     o u                                                                                                                                                                                                  Space
* NOT TO ICALE                                                                                                                         y
                            - - AREA VITHIN THIS BDUNDARY                                                                                                                                                                                                                                  I 1
f II DESIGNATED AS A RESTRICTED .                                                                                                   *                                                                                              .
AREA BY THE LICENSEE                                                                                                                 ____
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i                                                                                                                                                                                                                                                                                         i II i
i FIGURE 4-2: . AMS Facility--Second Floor (PartlaD                                                                                                                                            l 1
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Liquid Waste              Air Sampling Room Holding Tank                                                        4 IIIIIiiiiIIIIi!IIIiiIi1                         ,
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                                                                             !                                                Isodose Curve Unoccupied                 Storage Room Dry Waste Storage Room                                       Area
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PAR 11AL CONCRETE BLOCK VALL
                                                                                 .   . . 12' VALL (ACTS AD DVERFLOV BASIN FUR HCLDING TANK)
AREA VITHIN THIS BOUNDARY IS DESIGNATED AS A RESTRICTED AREA BY THE LICENSEE FIGURE 4-3: AMS Facility--Basenent

1           !                                     !
AMS4 FILTER HDLDER
                                                                        & RADIATICTN MONITOR EXHAUST RDTAMETER STACK SAMPLE r
ISA         RDTAMETER
                                                      ~
VACUUM FILTER HOLDER                                             UMP      EXHAUST w
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ISA         RDTAMETER FILTER HDLDER L
FIGURE 5-1: Air Sampling Station: Schenatic Diagran

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                    @ Location of pellets an stardess steel clish FIGURE 11-1: Hot Cell Exposure-Rate Sur vey Locations.
Refer to Table 11-1.

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                                                                       !                            [                                     ;o AMS10m 28       I 29 30       27 g              26              16                                        I            7                     8 g                                 L                                                     1           9 24                                                                    8 to         ,
L IL                            7-y 21                                                                     6 18     EC 1
13 17                                     _
D                                                                                          5 12                g4 22                   _.,                                       -
19                                                                          #
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8 DfjVN    UF 46            43                                                        15 1
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47                  '                       '                   31        '
: v.                                     '
32 50 40     39 44               43                                38      6 35 42 41    37              34 49                                                                     i DOVN-48                                     NOT TD SCALE IJP-.                                 AREA VITHIN THIS BOUNDARY IS
                                                                     ,                       DESIGNATED AS A RESTRICTED AREA BY THE UCENSEE FIGURE 11-3: First Floor Exposure-Rate Survey Locations.
Refer to Table 11-3.
                                                                                                                                , , _ _ _    W

Tl          !                                             P
                                                                             ~
l                      I                   Y.
AMS2 1   I 14 ii1l l 1iIi1111IIIiiiiiIi                                                                              13e            W i
5
                                                                                                                    /         10 15 8(FLOOR Vt'                                                i
                                                                       ..A                                   16 2                                            3 7    9                                  214 4 --                                     17 L_        l 20 6   19                              2, 18                 12 g
1 NOT TO SCALE UP -)                                           PARTIAL CONCRETE BLOCK VALL 12" VALL (SERVES AS DVERFLOV BASIN FOR HOLDING TANK)
                                                                                          -            AREA VITHIN THIS BOUNDARY IS DESIGNATED AS A RESTRICTED AREA BY THE LTCENSEE FIGURE 11-4: Basement Exposure-Rate Survey Locations Refer to Table 11 - 4.
1                  _ _ _ _ _ _ _ _ _ _ _ _ _

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                                      .                            . , . ~. - 17                       ,.               * .', .. , . . .
                                    .. ..                      . ..           ..l     .                           5
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                                  ...                       _ . _ . _ , _                   {4 15 b             [14 10 18 11         3                                  1 I          12 6
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NOT TO SCALE
                                                                                                              -        1I SECOND TLODR
             .. RDOF AREA                                                                                   -                   +-
I                                                                      19
_ _      AREA VITHIN THIS BOUNDARY IS DESIGNATED AS A RESTRICTED AREA BY THE LICENSEE FIGURE 11-5: Second Floor ' Smear Locations.
Refer to Table 11-5.

  "1.          1      F'
* 1 L_
AMS10 42             I 40 41                                                                                                                                                         !
43 .                                i
                                                                                            ' 23                24 L                                              l 1
27                                          '
47 l,               -
44                                                                  21 26        _
25               29                 22 m      46                       -
_L,          U                                                            ,    ,
                                                                       ~
DQVN29 UF 48                     57                                             20 1                           -
65 Ws                   I                I'
                                                              ' 52      49          !        M 53 56             55             54        51   59       I      62 3
60 50                              61 DOVNw
                                              .                    NOT TD SCALE UP-.            -- AREA VITHIN THIS BOUNDARY IS g             DESIGNATED AS A RESTRICTED AREA BY THE LICENSEE FIGURE 11-6 First Floor Snear Locations.
Refer to Table 11-6.                                                                                                                   !
r s
                                                                                                                         - _ _ r'~-_- -a     __-___ . - _ _ _ _ _ _ . _ _

;rg        ;              L                                           '                    ~
AMS2a O   I l
34 iiiiIIIIIIIIiiiiiiiii    i                                    35                            i 30 I                    36      31      8 66 i                                          /
68    l                                     /
67            --
l 39 32 3/
38 33
                   ~
e F
* NOT TO SCALE y          __                          l l l l I PARTIAL CONCRETE BLDCK VALL
                                                                      - 12' VALL (SERVES AS DVERFLOV BASIN FDR HDLDING TANK)
_                   AREA VITHIN THIS BOUNDARY IS DESIGNATED AS A RESTRICTED AREA BY THE LICENSEE FIGURE 11-7: Basement Smear Locations Refer to Table 11-7.

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TABLE 11-1
                       !!OT CELL EXPOSURE-RATE MEASUREMENTS              ,
l i
R/m Location #          Table Level         Three Foot Above 13ble 1                    2.1                       1.2 2                    5.0                       1.4
: a.            3                    2.0                       1.1 4                    2.0                      1.3 5                    6.7                       1.6 6                   35.0                       1.4 7                    2.2                       1.6 8                    1.3                       1.7 9                    2.0                       1.4 See Figure 11-1.
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         - . - - - . .   - - . - . . - - - - _ - . -                             . - . - -  . ~ . . - - - . - . - - - - . - _ - . . . . - - .
1     --J B A
I                                                                         TABLE 11-2                                                                l I
SECUND FLOOR EXPOSURE-RATE HEASUKEMENTS V      .
                                                        -Location            mR/h                   Comments-
+
I 1R               1.9-                      W 2R               1.3        W near hot water tank A
3R               0.8        W near boiler
!      ..                                                      4R               9.2                       W 5R            25.0                         H 6R            83.0          H near service panels-25.0                         W                                         '
7R               3.0                       H 18.0                         W
:                                                              8R            25.0                         H 9R               2.0
                                                                                                         .W i                                                             10 R              4.0                       W l                                                             11 R           35.0                         W 3
12 R          120.0          W door closed
[ --
;-                                                            13 R' 157.0 660.0 W door open Large HEPA contact 14 R         3000.0          Small HEPA contact
                       -                                      15                1.6                       W
                                                         . 16                0.7                       W i                                                             17                1.5        H at surface i                                                                             -3.0                        W i                                                             18                4.6        W at surface i
19                0.7                       W l                                                             20                1.6                        W l                                                             21                0.1                        W 22               19.0        W door closed
;.                                                                           25.0          W door open
,                                                             23                1.0                        W 2-                                                            24                0.4                        W-
;                                                             25                0.7                        W 26                0.1                        W
                                                            ' 27                2.0        W door open                                             u
,                                                             28                0.2                        W l-                                                            29                0.2                        W Refer to-Figure 11-2.
1                                                    H     Head Height-
      ...                                            R - Restricted area as ' defined by the ' licensee; by 10CFR20 i                                                         definition, the entire facility is a restricted area W - Waist-Height i-a 69
     .r-i,

w i9 TABLE 11-3 FIRST FLOOR EXPOSURE-RATE MEASUREMENTS Location          mR/h              Comments 1              0.6                W 2              0.6                W
: 3.             0.6                W
  , , .,           4              0.8                W
     .             5              0.5                W 6              0.3                W 7              0.6                W 8              0.7                W 9              0.8                W 10              0.6                W 11              0.6                W 12             28.0                W 13            220.0                W 14              0.5                W 15              0.3                W 16              0.6                W 17 R           20.0      near-old hot cell window
          .-      18 R            1.5                W 19 R            4.5                W 20 R           30.0                W 21 R         1300.0      near old hot cell window - floor 22              4.3                W 23              1.7                W 24              0.3                W 25              0.4                W 26              0.3                W 27              0.2                W 28              0.2              -W-29              0.1                W-30 R            0.2                W
  ,~'
                .31 R             0.2.               W
                 -32 R            0.4               li-33 R            0.6                W 34 R-           0.8                W 35 R            0.5                W 36 R            1.0                W 37 R            0.8                W 38 R'           l.7'               W
  ~~
39 R            1.9               -W 40 R            4.0                W 41 R            3.0                W 42 R           10.0                W 43 R            9.0                W 44 R           18.0                W 45-R           54.0                 W l
P'.
u 70                                       )

c il l
TABLE 11-3 (Continued)
FIRST FLOOR EXPOSURE-RATE MEASUREMENTS i
Location          mR/h             Comments 46 R            50.0               W 47 R           440.0      Floor - dumb waiter 48 R             3.0               W
: e.            49 R             5.0               W 50 R            30.0      Square or round hot cell access port Refer to Figure 11-3.
R - Restricted area as defined by the licensee; by 10CFR20 definition, the entire facility is a restricted area.
W - Waist Height e
J.
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4
     !.           i4:                                                                                                                                                                          ;
I p                                                                                                                                                                                               -
t L                                                                                                                                       . TABLE 11-4 I
j                                                                                                                          BASEMENT EXPOSURE-RATE MEASUREMENTS                                 l i
Location                 mR/h               Comments                        i i
i                                                                                                                          1R               820                    W i                                                                                                                          2R               525                    W 3R              2600                    W                           .
i                 ,,                                                                                                       4R              1500                    W 5R              3000                    W 6R                65                    W                             '
.                                                                                                                          7R               880                    W i                                                                                                                          8R           >20000          Near floor vac/HEPA box s                                                                                                                          9R              4000         Floor level near water-i                                                                                                                                                       surface j                                                                                                                         10                   1.3                 W j                                                                                                                         11 R                 1.0                 W 12 R                 1.1                 W                           '
13 R                 1.5                 W 14 R                 1.0                 W 15 R               15.5                  W 16 R                 5.5                 W
* 17 R               10.0                  W
                                                                                                                  ..-     18 R               20.0                  W                            t 19 R               20.8                  W 20 R               17.3                  W                           '
                                                                                                                      -21 R                    2.6                 W Refer to Figure 11-4.
R  -     Restricted area as; _ defined by the licensee;                by 10CFR20 definition, the entire f acility is a restricted area.                            .
W - Waist Height
                  ,a ,
W:
72

N TABLE ll-5 SECOND FLOOR SMEAR MEASUREMENTS Location #         Room                Description-         dpm/100 cm 2
                               .1 R -     Equipment          Floor                         4 f; 4a 2R        Equipment          Boiler                        5 j; 4 3R        Equipment          Electrical Panels             '<2 M+                        4R         Equipment         Door                           (2 5K         Equipment         Exhaust Duct                  7+4 6          Bathroom          Wall                           <2 7          Office            Door                           <2 8         Office             Floor                         8+5 9     _
Office            Floor                         73[4 10 R        HEPA Room         Srall Filter Housing      5.67 + 0.59 E3 11 R        HEPA Room         Floor                     3.74][0.16E4 12 R        HEPA Room         Large Filter Housing        78' j; 12 13 R        HEPA Room         Floor                     1.84-+ 0.11 E4
        ~'
14 R'       HEPA Room.        Floor of Landing            $2 7 10 15 R        HEPA Room         Floor foot of Stairs-         73[4 16 R        HEPA Room        . Stair-rail                   5+4 17         > Roof _           Drain.                       '53[4 18          Office            Floor                          <2 19           office           Floor                           <2
* T Refer to Figure 11-5.
aErrors are 20 based on counting statistics.
R - Restricted area as defined by the licensee; by 10CFR20 definition, the entire facility is a restricted area.
ds
   ' W9 E'                                                        73 L

7   :s J . ;3 -
TABLE 11-6                                               ,
FIRST FLOOR SMEAR MEASUREMENTS Location #          Room                    Description           .dpm/100 cm 2 18         Cell Control Area         Manipulator Controls            11 j; 5a
               -19         Cell Control Area         Door Knob to Control Area       15 j; 6               ,
20         Cell Control-Area         Floor                           11 f; 5 o,          21-        Office                    Floor                            8+5 22         office                    Desk Top                         3E3 23         Cof fee Room              Counter Top                       <2 24         Cof fee Room              Equipment Hood                  26 f; 7 25       -Shie7ded Work Room         Floor                            9+5 26         Shielded Work Room        Floor                             <7-27         Shielded Work Room        Door                             3+3 28 29 Cer Control Area Celt Control Area Counter Top Entrance Door 4[4 5+4 40         Calibration Room          Floor                           1516 Floor 41         Calibration Rcom                                            <2 42         Calibration Room          Floor                            5 j; 4 43 R       Air Lock              '
Door                             5+4 Floor 44 R      ' Air Lock                                                 96[13 45'R       Air Lock                  Door                            26 + 7 46         barehouse                 Floor                            313 47         Warehouse                 Floor                             <2 48         Warehcuse                 Floor                             <2 49 R       Isotope' Shop Area        Work Bench                     542 f; 30 50 R       Isotope Shop Area         Work Bench                     102 j; 13 51 R       Isotope Shop Area         Fume Hood Sash             1.83 j; 0.03 E5 52 R       Isotope Shop Area         Hot Cell Square Access-    2.05 j; 0.04 ES -
Port 53 R       Isotope Shop Area         Hot Cell Round Access      1.51 j; 0.02 E6 Port
               -54 R       Isotope Shop Area         Floor                      2.15 f; 0.12 E4 55 R       Isotope Shop Area         Floor                      2.05 f; 0.11 E4 a,         56 R       Isotope Shop Area         Floor at Air Intake Vent    1.57 j; 0.10 - E4 57 R       Isotope-Shop Area          Floor at Decon Room      - 9.61 j; 0.24 E4 58'R       Laundry Room              Washing; Machine Drain     7.73 -j; 0.71 E3 59 R       Laundry Room              Floor                           42 j; 9 60 R       Laundry Room             . Floor                          48 j; 9
               '61 R-      Shower Room                Sink                       2.52 + 0.38 E3 62LR       Shower Room'               Floor                          67[11 63 R       Shower Room              ' Shower Floor                  119 j; 14 o-         64-R       Locker Room                Floor                           18 j; 6 65 R       Locker Room                Door                           31 j; 8 Refer to Figure 11-6.
aErrors are 20 based on counting statistics.
R - Restricted area as designated by the licensee; by 10CFR20, the entire facility is a restricted area.
L[                                                 74

o II                                                              .
TABLE 11-7 BASEMENT SMEAR MEASUREMENTS Location #        Room                Description            dpm/100 cm2 30       Stairwell            Door                          33 + 8a 31 K     Isodose Curve        Floor                       1.28 + 0.28 E3 32 R     Isodose Curve        Floor                         22[7
..         33 R     Isodose Curve        Sink                          27 + 7 34 R     Air Sampling         Bench Top                       (7 35 R     Air Sampling         Drain to Liquid Waste Tank   148 + 16 36 R     Air Sampling         Floor                        352124 37 R     Miscellaneous        Floor                       4.02 + 0.45 E5 38 R     Miscellaneous        Door                          55110 39 R     Miscellaneous        Counter Top                   $5 + 10 66 R     Waste Area           Floor                       8.68[0.75E3 67 R     Waste Area           Floor                       4.50 + 0.09 E5 68 R     Waste Area           Floor                       3.36[0.15E4 Refer to Figure 11-7.
aErrors are 20 based on counting statistics.
      -  R- Restricted area as designated by the licensee; by 10CFh20 definition, the entire f acility is a restricted area.
a.
ev 75

o is TABLE 11-8 RADIONUCLIDE CONCENTRATIONS / ACTIVITY IN MISCELLANEOUS MEDIA Sample              Location                     Radionuclide Concentration No.                                            Co-60               Cs-137 (pCi/g)             (pCi/g)
... 3517     Roof Gravel - Lower Roof                <0.04           1.11 +~
0.21 (Northern Corner) 3518     Roof Gravel Approximately 225 feet      <0.03           0.74 j;0.14 Northwest of Stack 3519     Roof Gravel Approximately 12 Feet     .08 j; .06         1.86 j;0.23 North of Stack 3520    Roof Gravel Approximately 90 Feet       <0.05           0.48 f;0.11 North of Stack Co-60                Co-60
    -                                                   (pCi/1)             (pC1/ml) 3530    Water from Liquid Waste Floor        1.75 f; 0.08 E05    1.75 f; 0.08 E-04 Radionuclide Activity Co-60 (pCi) 3527 R Paint Sample South Wall Isotope       7.37 j; 0.22 E04 Shop Area 3527 S Paint Sample Floor Isotope Shop       2.81 f; 0.13 E04 3,
Area 3528     Dryer Lint                          3.31 f; 0.10 E04 Refer to Figures 11-8 and 11-9.
aErrors are 20 based on counting statistics.
76
[*

e e  I i
l l
TABLE 11-9                              I RADIONUCLIDE ACTIVITY ON TYPE H AIR FILTER CANISTER Sample        Location              Radionuclide Activity (pCi)
No.                                           Co-60 4
3525     Filtec & Cartridga               7.97 + 0.44 E05a
**             3525A    Filter Media                     2.18 + 0.25 EOS 3525B    Cartridge Container only         5.68[0.39E05 3526     Filter & Cartridge               3.01 + 0.07 E07 3526A    Filter Media                      1.59 7 0.21 E05 3526B    Cartridge Container only         2.41[0.06E07 aErrors are 20 based on counting statistics.
e ha  E pe
{                                            77

it-l
                                                 . TABLE 11                                        ,
RADIONUCLIDE CONCENTRATIONS IN SEDIHENT 4
Sample            Location                         Radionuclide Concentration (pCi/g)a   ,
No.                                                    Co-60              Cs-137 3512    Approximately 50 m South of Site                <0.05          0.12 j; 0.07 a;            3513    Storm drain at Loading Dock                 1.78 3; 0.35       1.00 j; 0.32 3514    Storm Drain Approximately 25~m                  <0.04         .0.89 j;0.14 Northeast Corner of Building 3515-  _ Storm Drain Approximately 35 m             0.08 j; 0.02       4.06 j; 0.35 Northeast Corner of Building-3516    Sediment in Loading Dock Basin               1.72 j; 0.36      0.48 j; 0.23 Refer.to Figure 11-8.
aErrors are 20 basedlon counting statistics.
e 4
4        4 Je
[                                                     78

e I              ti-1; i
TABLE 11-11                                                      '
1
 ,                                                                                                                                    RADIONUCLIDE CONCENTRATIONS IN SOIL
!                                                                                    Sample                                       Location               Radionuclide Concentration (pCi/g)a 1
No.                                                                  Co-60                 Cs-137 3506                             Approximately 10 m South of         0.41 f;0.23        1.59 j; 0.24 Paint Room 3507                             Approximately 10 m South of          1.40 f; 0.27      0.53 j; 0.13 H.V. Transformers                                                                           ,
;                               .4 j                                                                                      3508                            Approximately 10 m South of           .07 f; .05       0.33j;0.10                           ?
Basement Stairwell 1-j-                                                                                    3509                             Approximately 15 m Southwest        0.05 j; 0.04       0.25 j; U.09
;-                                                                                                                     London Road (on RR Spur) 4
                     ~
3510-                           Approximately 10 m Northeast AMS-        <0.05         0.61 j;0.17
: j.                                                                                                                     vs 75 m from RR Tracks on London Rd.
1
!                                                                                      3511                          .Approximately 10 m Northeast AMS          <0.09         1.34 + 0.27           -
l vs 30 m from RR Tracks on London Rd.
l                                                                                                                                 -
 ,                                                                                -3504                                200 m North                              <0.07         1.51 + 0.28 i                 ,
3503                            200 m Northeast                          <0.06         1.21 f;0.28
+
3502                           .200 m East                               (0.04                   <0.04 1
3501                            200 m South                              < 0.03        0.85 3;0.22 3500                            200 m Southwest (Baseball field)         <0.06          1.54 f;0.23.
!                                                                                      3499                            200 m West (Mandaley Road)               <0.04         0.27 j; 0.09 e                                                                                      3505                            200 m Northwest                          (0.06         0.24 j; 0.09 L
'                                                                                       Refer to Figures 11-8 and 11-9..
aErrors are 20' based-on counting statistics.
}                                                                                                                                               .
4 i
}
4 E                                                                                                                                 79-
_     , . _                     . , ,,c.,

I o
i l TABLE 11-12 RADIONUCLIDE CONCENTRATIONS IN VECETATION Sample            Location               Radionuclide Concentration (pC1/gl,a No.                                           Co-60              Cs-137 F
3531    200 m West of Site                     <0.24              <0.16 (Mandalay Road) 3532    200 m South of Site                    <0.09          0.33 + 0.19 3533    200 m East of Site                     <0.20              <0.22 3534    200 m North of Site                    <0.29              <0.30 (Hadison Street) 3535    Southeast Corner at HV Unit         0.31 + 0.14
                                                                            <0.05
   ~
3536    5 m Northeast of Building              <0.21              <0.20 Refer to Figures 11-8 and 11-9.
aErrors are 20 based on counting statistics.
b  4 ewn
((                                           80 J

1 4                                                                                         [
les                                                                                           '
                                              ' TABLE 11-13 l
RADIONUCLIDE CONCENTRATIONS IN WATER I
          -Samplo              Location                Radionuclide Concentration (pCi/ml)
No.                                                       Co-60 3537         50 m South of Building                     <5.67 E-09
:.!         3538         Standing Water 100' North                  (8.55 E-09 of Stack 3539         Roof over Basement Stairwell               <5.67 E-09 3540         Drain at Loading Dock                      <5.12 E-09 3541         Sewer Outfall London Road                  <4.91 E-09 3542         Storm Drain 25 m from Northeast            <4.70 E-09             <
Corner of Building                                                  l 3543         Storm Drain 35 m from Northeast            <5.59 E-09 Cornce of Building 3544         Storm, Drain 65 m from Northeast           <5.40 E-09 Corner of Building Refer to Figure 11-8.-
          - For' comparison, the NRC criteria for Co-60 discharge to the sanitary ~ sewer system -is   1.0 E-03 pCi/m1,- and the Co-60 concentration in water in an unrestricted is 3.0 E-05 pCi/ml.
 . _6 .
VA 81
 -[I                                          ,

.        4 4I APPENDIX A AUDIT TEAM BIBLIOGRAPHIES e
st.
m
{ --

1       ,
l;i l s
                                                            -BIOGRAPHICAL SKETCH
-!                                                              James D. Berger Oak Ridge Associated Universities Oak Ridge, Tennessee 4
                   . Manager, Radiological Site Assessment Program at ORAU from 1980 to present.
Main duties include technical- assistance to DOE and NRC in areas of radiological        environmental         surveys    and   evaluation of effluent  and
-     i..           environmental monitoring programs. Prior positions at ORAU include Department
 !                  Head, Health and Safety Of fice, 1975 to 1980; Radiation and . Chemical Saf ety Officer, 1970 to 1975; and health physicist, 1967 to 1970.                Also, Health .;
Physics Team Leader for the ORAU Radiation- Emergency Assistance Center from
'                    1975 to 1985.- Additional professional experience as industrial hygienist' at l                    Bettis Atomic Power Laboratory, 1963 to 1966, and ins t rument developtrent physicist with the Bureau of Radiological Health,1960 to 1963.
Education B.S. in Physics f rom Bowling Green State University,1960.
M.S. in Radiological Health from Northwestern University, 1968.
* Professional Society Affiliations
-                         Health Physics Society American Industrial Hygiene Association s
Certified by American Board of Health Physics t
l                    Publications Author or co-author of approximately 10 - published reports, guidebooks, and book chapters in various' areas of health physics.
l.
Author of numerous unpublished (internal use only) reports describing findings or results of technical assistance for DOE and NRC.
[                                                             A-1

K
          --it   -
4 B10CRAPHICAL SKETCH                                   -
4 Edgar B. Darden Oak Ridge Associated' Universities                             y Oak Ridge , Tennessee -                                    J j
Currently Radiation Safety 0f ficer in the Of fice of Safety and Health.          Prior work history includes Head, Radiation Safety and Dosimetry Group, Comparative Animal and Research Laboratory 1973-1981; biologist ORNL 1949-1955 and
: u.              1956-1973;.. Physicists Aide, Navy Department 1941.
Education B.S. Chemistry, College of William and Mary 1941 H.S. Physics,. University of North Carolina 1950 Ph.D.. Zoology, University of Tennessee 1957 Professional Society Af filiations Health Physica Society Southeastern Section American Physical Society Sigma X1, The Scientific Research Society Publications Author Ror co-author of publications               in radiological  physics     and radiobiology, including dosimetry of              cyclotron  and  nuclear     bomb g;                  radiations,       radiation sterilization of insects, electrophysiological ef fects of radiation, and f ast neutron and high energy particle mammalian radiation - biology; also publications in gerontology, electron microscopy and-bioelectricity in plants.
f~                                                         A-2
   =,.

1
[ ,,                                                                                               i l
BIOGRAPillCAL SKETCH                                  i Elizabeth J. Deming
                                       -Oak Ridge Associated Universities                           i Oak Ridge, Tennessee Currently Health Physics Team Leader, Radiological Site Assessment Program at Oak Ridge Associated Universities to provide assistance to program manager for 1 technical- assistance to DOE and NRC in. radiological environmental surveys and
   , , ,      direct team of 2-10 health physics technicians in conducting these surveys at sites throughout the U.S.      Prior wor'; history including Radiological Health Specialist with the Salt Lake City County Health Department from 1980-1982 and Radiological- Protection Technologist at the University of Utah from 1978 to 1980.
Education B.S. in Medical Technology from California State University 1978 M.S. in Radiation Ecology from Colorado State University-1984 Professional Registration and Af filiations W
Nationally Registered Radiation Protection Technologist - 1980 Health Physics Society Publications-                                                                        >
Co-author on a paper discussing the leachability of - Ra-226 f rom soil and subsequent plant uptake currently being reviewed for publication in- the       ,
                   -Journal of Environmental Quality
                                                     ^-3
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II-BIOGRAPHICAL SKETCH Glenn L. Murphy Oak Ridge Associated Universities Oak- Ridge , Tennessee Currently the Assistant Program Maneger, Radiological Site A=cessment Program at ORAU to provide techr.ical assistance to DOE and NRC 4n the areas of radiological     environmental   surveys     and   evaluation of     effluent    and
  ..         environmental monitoring programs. Prior work history includes Senior Health Physics - Consultant with Phoenix Technology Corporation from 1983 to 1985.
Research Coordinator / Health Physicist, Center for Applied Isotope Studies, University of Georgia from 1981-1985 and 1978-1980.       Radiation Safety Officer, University of North Carolina at Chapel Hill and North - Carolina Memorial Hospital, 1981. Radiation Safety Officer, University of Georgia 1975-1978.
Edacation
           .       B.S. in Mathematics Education from Virginia Polytechnic Institute, 1971.
M.S. in Applied- Nuclear Science from Georgia Institute of Technology, 1975.
Professional Society-Affiliations Health Physics Society Publications-m Author or co-author of publications on decommissioning of a luminous dial painting - f acility and comparative analytical methods for environmental gamna ray dose rate assessments.
Author o'' unpublished '(int'ernal use only) reports ' describing findings of results of technical assistance for DOE, NRC, and EPA.
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             * -*   2  A e      a _,   a 4
[h APPENDIX B SCOPE OF WORK A
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:9                                                                                              l UNITE 3 STATES                             f
                 $a asog''                                                                          I
             /           .,                   NUCLEAR CEGULATCRY COMMISSION
{;              g                               RE010N lli sie noosevatt moao
             *           ,.,7 OLEN ELLYN, ILUNoll 6013 OCT 9 - 1985 Oak Ridge Associated Universities Radiological Site Assessment Program ATTN: Mr. Glen Murphy 4
Post Office Box 117 Oak Ridge, TN 37831 1
Gentlemen:
This refers to the telephone conversation between Mr. Glen Murphy and Mr. Robert E. Burgin of this office on October 8, 1985, concerning the operational and radiological safety assessment scheduled for October 20-25, 1985, at the Advanced Medical Systems, Inc. facility in Cleveland, Ohio.
Tha following are the general areas we request be addressed during the audit:
: 1. Organization
    -             2. Training
: 3. Security
: 4. Instrumentation
: 5. Facilities / Equipment
               ,  6. Effluent Monitoring                                                        ,
: 7. Confirmatory Measurements
: a. Air / Stack Tilters
: b. Waste
: c. Effluents
: d. Area Surveys                                                        4
: 8. ALARA Program
: 9. In-Cell Decontamination Procedures
: 10. Material Accountability
: 11. Fire Protection
: 12. Emergency Planning
: 13. Calibration Procedures We realize that licensee scheduling problems have resulted in severe time
   -"'            constraints on our advanced preparation for this assessment; however, we would appreciate your proposed audit plan prior to our meeting with the ORAU team on October 20, 1985. We can, at this time, discuss the specific areas of concern in greater detail.
Should you have questions concerning this request prior to our meeting, please contactMr.Burginat(FTS) 388-5622.
Since ly,                ,.
                                                                            /         c.
Pu W. L. Axei     -
Chief M 1 ear Materials Safety ano M eguards p                                                           B-1

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1 1
APPENDIX C RADIAT10N PROTECTION TRAINING COURSES b .h .
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APPENDIX C              f RADIATION PROTECTION TRAINING COURSES     ,
3                              Basic Radiological Health                                         i Balittore/ Washington Chapter Health Physics Society              l P. O. Box 7532                                                    !
Silver Spring, MD 20907                                          l Howard Hering (301) 427-5104                                     ;
Radiation Protection Technology (1 week)                          :
Pacific Radiation Corporation                                     L
       ,,,                     9827 Daines Drive                                                [
Temple City, CA 91780                                            :
                             . Dan Go11 nick (Bib) 286-8222                                     i Fundatoentals of Radiation Protection (2 days)
Radiation Safety-Associates, Inc.
P..O. Box 107                                                    i Hebron, CT_                                                      '
Paul Steinmeyer (203) 228-0487 Safe Use of Radionuclides (1 week)
Applied Health Physics (5 weeks)                                 .
Oak Ridge Associated Universities P. 0.. Box 117 4
Oak Ridge, TN 37831-0!!7                                         :
Jo Tipton (800) 362-5555                                         l Basic Radiation Protection (1 or 2 w 4k)                         ;
i                            ' Nuclear Engineering / Health Physics Program Georgia Institute of Technology.
Atlanta. . GA 30332 Dr. Melvin Carter (404) 894-3745                                 :
Basic Radiological Health Physics (1 week)                       !
l                              Advanced Radiological Health Physics (1 week)                    !
University of Lowell Department .of Pt.jsics and Applied Physics l University Avenue Lowell, MA 01854 l;                            .Kenneth Skrable (617) 453-1045 or-(617) 256-8282                 ;
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_ _ . _ _ _ _ _ _ _.. _ _ _ _ ._..                                                        _a

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i APPENDIX D                                              !
LIST OF DECONTAMINATION FIRMS 9
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P9

il APPENDIX D 1,1STS OF DECONTAMINATION FIFJtS Equipment Systems International, Inc.
          - 2250 Chestnut Springs Boulevard Sutte 200 Harietta, GA 30062 Terry Holland, President (404) 973-4921 Radiation Hanagement Corporation
: i.       3440 Harket Street, Suite 320                                          ;
Philadelphia, PA 19104                                                 i (215) 243-2950                                                         4 Chem-Nuclear Services 220 Stoneridge, Suite 100 Columbia, SC 29210 (803) 256-0450
  ~
Applied llealth Physics 2986 Industrial Boulevard Bethel Park, PA 15102 (412) 563-2242 The inclusion of this list does not imply an endorsement of the listed companies, nor the qualit-/ of their work.
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ATPENDIX E REGULATORY GUIDE 8.15 ACCEPTABLE PROGRAMS FOR RESP 1kATORY PROTECTION l
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D44 t-

ii U.S. NUCLEAR MEOULATORY COMMISSION
                                                                                                                                                         ~ ""
REGULATORYGU DE OmCE OF STANDARDS DEVELOPMENT REGULATORY OUIDE 8.4 ACCEPTABLE PROGRAMS FOR RESPIRATORY PROTECTION A. INTRODUCTION                                         menspment backing is considered essential to an adequate respiratory protection propam. Techniques a e Section 20.103," Exposure of individuals to concen.                           to be provided and masaures taken to ensure that trations of radioactive materials in air Art restricted                            manspraant pohey la carned out. Subjects to be covered ueu," of 10 CFR Part 20. " Standards in: Protection                                by the pokey statement belude the une of practicable Against Radieuon," permits licenaces % re u s*'owance                              eneneering controls instaad of respirators;routme, non.
for the toe of respiratory protectie %M in                                         routine, and emerpney dtuations; and periods of esumsting exposures of indjviduals to teWt t;dio-                                  respirator uw and rehef from respirator une active materials pronded the protecuve equip.,cnt is                               (NURECr0041. Secuons 2. 3.2.12.1).
used u stipulated in this guide, which describes the elements of respiratory protection propams acceptal,le                                  2. Raspiratory protective equipment is to be wiected to the NRC staff.
to provide a protection factor pester than the multiple by which peak concentrations of radioactive materials E DISCUS $10N                                       are espected to exceed the values specified in Table I, Column I of Appendix B to 10 CFR Part 20. The This guide specifies elements of acceptable respira.                          equiprnent wiected is to be used so that the average
._           tory protection propams. More detailed advice,                                    concentration of radioacuve material in the air that is including technical needs and backpound information,                              inhaled during any period of uninterrupted use in an may be found in NUREG.0041," Manual of Respiratory                                airbome radioactivity area, on any day, by any indl.
Protection Against Airbome Radioactive Materials."e                               vidual unng the equipment, will not exceed the values sections of which are referenced and keyed to                                      specified in Table I, Column 1 of Appendix B to 10 appropriste portions of this guide.                                               CFR Part 20. For the purpous of this guide, the concentration of rsdioactive material in the air that is The NRC staff will use information in NUREG.0041                              inhaled when respirators are worn may be initially in assesung the adequacy of respiratory protecuon pro.                           estimated by dmding the ambient concentration in air pams pursuant to the guidance provided herein                                     by the protection factor specified in Table 1. If a (NURECr004), Section 3t                                                            respirator user's intake of radioactive materials is later determined by other measurements to have been C. REGULATORY POSITION                                         pester than that expected from initial estimates of radioactive matenals in the air the user inhales, the Punuant to $20.103 of 10 CFR Part 20. a bcensee                               pester quantity is to be used in evaluating exposures, may make allowance for the use of respiratory                                     if it is less than that initially estimated, the leuer protective equipment tn estimating exposures of                                   quanuty may be used in evaluating exposures indmduals to airborne radioacove materials if the equip.                          (NURECr0041, Section 5,6).
ment is und according to the following guidance:
: 3. The bcenace is to advise each respirator user that
: l. A written pobey statement on respirator usage is                           he may leave the area at any time for relief from to be lasued from a high management level. Strong                                 respirator use in the event of equipment malfunction, physical or psycholopeal distress, procedural or communication failure, significant deterioration of
              *NUREG.004) ts available from the Neuonal Techrucal infor.                        operating conditions, or any odier condition that mahon servur, $pruiafwW, Virgmu 22161.                                           might require such relief (NUREC4041, Section 2.2).
usNnc mtoutATORv ousois                                        c                    w    mi   i..s=    n .i. c..     . vs n
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: 4. The hoensee b 13 maintain and impleme:t a                         of whe7 there b n3 ealetir,8 ochedule for approval cf respiratory protecuon program that includes, as a                        certain equipment, such equipnent is not to be uend mirdmum, the following items (NUREG0041, Section                         without spedfle authoriaauon by the Commlasion. Aa 3.1.5);                                                                  apphcotion for such authortuuan la espected to include a demonstration by tuting or on the baass of
: a. Air sampling and other surveys sufficient to                  reliable test information that the me,erial and pet.
idenufy the hasard, to evaluate individual esposures,                    formance charactenstics of the equiptrent att capable and to permit proper selection of respiratory protecuve                  of providing an acceptable degree of protocuon under equipment (NUREG0041 Sections 4,5.1I),                                   antidpated conditions of use,
: 7. Unlew otherwise authortaed by the Commission, j                         b. Written procedures to ensure proper selection,                the licensee is not to asugn protection factors in supervision, and trairung of personnel using such                         esceu of those specified in Table I in selecting and l
protecuve equipment (NUREGC041.Secuon 8,i2).                              using tespiratory protecuve equipment.' The Comtrus.
aion may authortre a licensee to use higher protecuon
: c. %,ntten procedures to ensure the adequate                      factors on receipt of an application (a) ducribing the individual fitting of respirators, as weu as euch proce.                  situeuon for which a need esists for higher protecuon 4         ,,
dures to ensure the testing of resptratory protecove                      futors and (b) demonstrating that the respiratorv
 !                  equiptrwnt for operability immediately pnot to each                       protective equipment will provide such higher proteh
!                    use (NUREG0041, Sections 7,8,12),                                        don factors under the proposed conditions of use,
: d. Written procedures for maintenance to ensure                         8. As a minimum, the following additional technical full effectivenen of respiratory protecuve                   %rnent, items are to be observed:
,                    meluding procedures for cleanmg arid                      v       m.
decon tamination, inspection, reptu, ,                        e tre                a. Respitable air of approved quality and                                      l
.                    (NUREG0041, Section 9,10).                                               quanuty is to be provided and osygen delictency is to be avoided (NUREG0041, Secuons 4.1,1,5.1.2,5.1.3, l
: e. Written operauonal and administraus proce.                     5.2.4.1, 5.2.4.1.1, 5.2.4.1.4, 9.8).
          ~
dures for control, tasuance, proper use, and return of respiratory protective equipment, including provtuons                              b. There in to be a standby rescue person 3                   for planned hmitaucna on duration of respirator use                       equipped with self. contained brtathing apparatus and for any individual u necessitated by operadonal condi.                    communications equipment when supplied.als suits are
                    ,uons (NUREG0041, Secuons 2, 9. 10, 12),                                   used (NUREG0041, Section 5.1.3).
: f. Bloassays and other surveys, as approprtate, to                         c. No credit is to be taken for use of sorbents evaluate individual esposures and to assess protection                     against radioactive materials (NUREG0041, Sections actually provided (NUREG0041 Seetion 4. II).                               5.2.2, 5.2.2.2, 5.2.3.5, 5.6.6).
: s. Records sufficient to pertrut penodic evalua,                           d. Filter media in air. purifying respirators are to tion of the adequuy of the respiratory protection                         be of the hiprefficiency type (NUREG0041, Sectioni
,                     program (NUREG0041, Secuon 12).                                           5.2.2.1, 5.2.2.3, 5.2.3.2, 5.6.1).
: h. Determination prior to auignment of any                                 e. Alepurifying resptrators are not to be used in individual to tasks requatng the use of respirators that                  on) pen. deficient atmospheres (NUREG0041, Sections such an individual is physicauy able to perform the                        4.1.1, 4.2.3, 5.2.3.1 ).
-                     work and use the respiratory protective equipment. A physician is to determme what health and physical                                  f. Adequate skin protection is to be provided
: a.          conditions are perunent. The medical status of each                       (NUREG0041, Secuons 1.2, 5.2.3.2).
respirator user is to be reviewed at leut anttunUy (NUREG4041.Section 7.4),                                                           s. Air. purifying respirators are not to be used in atmospheres immediately haurdous to hfe or health
: 5. The licensee is to use equipment approved under                     INUREG0041, Section 5.2.3.4).
appropriate Approval Schedules in 30 CFR Part 11 of the    U.S. Bureau of Mines / National Institute for Occupational Safety and Health and as ut forth in
          **                                                                                      *The factors tuted are Latended as eundes for selection sad use of respirstors in protecuen agatast rad 6oacuve materwis.
: 5. %here no equipment of a particular type hu                            Addmonal precautiors must be taken as necessary to protect been approved under the schedules in 30 CFR Part 11                          anstasi concurreni huards other than redisoon.
8.152                                                                                      ,
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I     ii
: h. Canisters and cartrtdys are not to be und                          n. Appropriate equipment with propt womat.
commuruc4: son, and other special capabihtws u to be beyond wrvice.hfe kmitsuons (NUREG4041, Section i,             .
Pronded (NUREG4041, Secdons 7.1,13).
5.2.3.6).
: i. Facelets are not to be und (NUREG4041, Sectam 5.?. 3.6).                                                                        D. IMPl.tMENTATION                                  f' J. Oxypn and breathLng air are not to be used
        '          in the same apparatus (NUREG.0041, Sections 5.2.4.1,                        The purpose of this wetion is to provide informs.
t
-                   5.2.4.1.4, 5.2.4.2 ).                                                  tion to appbcanu and licennes regarding the NRC staff's plans for using this regulatory guide,
: k. Proper 8ttiny are to be und with suppl 6ed air equipment (NUREG.0041, Sections $.2.4.1.1                                  Tids guide reflecu current NRC staff practice.
!                                                                                          Therefore, eacept in thou caws in which the licenwe 5.2.4.1.2, $.2.4.1.3).
or appucant propous an acceptable attemative method
: l. Equipment is to be used within umitations for               for complying with specified portions of the Commis.
sion's reguistions, the erwthods described herein are type and mode of une (NUREG4041, Sections 5.2.3,                                                                                            j being and wGl continue to be used in the evaluation of 5.2.4).                                                                 the respiratory protection programs of licenant who                 1 are subject to the requirements of $20,103 of 10 CFR                i
: m. Only specified equipment is to be und as                                                                                        '
Part 20 until this guide is revind as a result of sugys-emerpncy devices (NUREG4041, Sections 5.2.4.1.4, tions from the public or additional staff review.
                     $.2.4.2.1, $.2.4.2.4, 5.5),
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0  .a TARLt1 PROTECTION F ACTORS FOR RESPIRATOR 88 pgtonCHON                        BELECDON OF TESTtD
* FACTOR $d                      & CERTIFIED EQUIPMENT PARTKV.            FARDCU.             RUREAU OF MINE&lN AT10N AL LATES         LATT4,CA$tj           INfilTUTE FOR OCCUP ATION AL DESCRIPT10Nb                                 wopg$t ONL Y               & VAPOR 5'         SAFETY AND MEALTH APPROYAL5
: 1. AIR PURIFYING Rf3PIR ATORS F aceptent, hallesakI                       NP           10 Facept es. fuU       .
NP           $0                                    30 CTR Part 11 Subpart K Ine ..ce half mask,fuu, of hood             PP        1000
: 11. ATMOSPHIRE !LfPPt VING Rf SPIR ATOR$
: 1. Air kne respuator Fwepiece, halfeask                          CF                           1000      i Fuepwce, helleaak                            D                              10 Fwepine, fuu                                CF                           2000
: o.               Fuepace, fuu                                 D                              $0                 30 CFR Part il Subpart J Fuepwce, ruu                                PD                           2000 Hood                                       CF                           20008 l                      i Suit                                       CF                               h   i j
2.Self contained breathmg appararus (SCB Al F acepine, fuu                               D                             $0 l
Fuepwce, fuu                               PD                         10.000)                 30 CFR Part 11 Subpart H Facepuce, fun                                R                             $0 lit. COMBINATlON Rf SMRATOR Any combinsuon of au purifying                     Protection factor for l                    and atmosphere-supplytng                           type and modt of operation                  30 CFR Part il l ll.6)(b) respuators                                         as lated above nFor um in the wlection of respuntor) protective devices to be         2. The protecuon sectors apply:
uwd where the contammant has been identtfwd and the concentrauon (or possibW concentrauoni is known,                        (a) Only for trained individuals wearms properly ntted respuntors und and mamtained under supervison in a bOnly for shawn faces and where nothing interferes with the                wou planned respuntory protecuve program, seal of lightfitting facepwces against the skin, (Hoods and
:            suit 6 are encepted.)                                                   (b) For au puttfying respuntors only when high efficanc>
paruculate futers (abow 99.97'% removal efficwncy b)
CThe mode symbols are defined as fouous:                                  thermauy generated 0.3 mm dioctyl phthalate (DOP) testi are used an atmospheres not deficient in onyren and not CF e continuous flos                                                 contauung radioacuve gas or vapor respuntory hasards.
D = demand NP= negauve pressure (i.e., twssuve phase dunns mhala.               (c) For atmosphere supplytng respuators only when uont                                                        supphed with adequate respueble air.
PD = pressure demand (i.e., always posuve pressurel PP e possuie pressure                                           'Encluding radioactive contaminants that prewnt an absorpuon R= demand, recarculatmg (clomd cucuit)                            or submerson hazard. For tnuum oude, appronunately one half of tlw intake occurs by absorpuon throu6h th* skin so
   .6.      d l, The protocuon factor is a sweeure of ttw degree of protec.        that an overaU protocuon factor of less than 2 ts appropriate non afforded by a respirator, denned as the rat 6o of the        when atmosphere-supplying respuntors are used to protect consentranon of airborne radioacuve maternal outside the         against tnuum cande; for example:
respuetor7 Protective equipment to that knende the equip.
ment (usuauy made the facepwcel under condiuons of use.18 to apphed to the ambant suborne concentrauon to             if the protuuon factor             FF owrau for triuum estimate the concentreuen inhaled by the wearer ac.                      for a device ts:                     oude ts:
cordag to the louowing formula:
10                            1.82 concentrauon Inhaled . Ambwnt Abborne Concentradon                                100                            1,98 Protocuon Factor                              1,000                            1.99 s
(Continued) 8.15 4
   ~                                                                  E-4

   .E co.e edl                                                            be *woome it e enori up.me eninauen to un h d a were under e eset or powtalla Other lesnaistsome spostrand by Alt-puttfykts toepusters are not suitable for protection          t opprMal egenry meet be conadored belon unsg a hood agaanet wouum s tade. See also lootnote e concerning              an senaan tyMs of atmospbres teme footnote bl. Weavise.
                                                 "          **' 8"'I'                                               turoes femmmended pressure settands lot the att supply cannot ahess be teled on to ensure a minimum 6 cfm air I Undseeken type only. The type of respuetor is not eeuafsc.         b' h8'P'nent must be operated m o menews thei ensures proper be tous are maintasend,                                  l tory for see where it might be poemble led . if an secadens et unstgene) were to occuti lor the arnbie nt suborne               h concentropon to reach nastantaneous values paeter than 10           Apporreste protocuon factors must be determissed, takary into account the design of the suit and its permemb6kty to the tames the pertinent values an Table 1. Column I of Append 64       apatamanant under condit6ons of vet.
3 to 10 CTit part 20. " Standards for protection Against Radasuon " Thas typ of toepusior is not suitable for protec. 6 tion esaanst plutotuum or other harh.totocity materna16 T he       No approval schedules are currently evelleble fot this equip.
pnent. hulpment is to be tvaluated by testtag or on the been maak as to be tested for fit with erritant smoke, pnot to use, of rehable test Litformation-each tame it a donned khts type of respirator may provide greater protection and be ST he design of the supphed4tr hood or helmet (with a                used as an emergency dersce in unknown concentre4cns for mmamum flow of 6 c.fm of av) me) determine its ovetaU              protection assanst inhalation hasards. Laternal tednauon        l e!Donocy and the protocuan et provides For esemple, some           hasards and other hmitsuons to permstted esposure such as l ',f '                                          hoods sepuste coolemanated au nnto the breathing sone when                                                                         l l
skin absorption must be taken into account in such eucum.      i the wester works with hands + vet head. Such espitsuon may         stances.
Note 1: protection factors for respuators as met be approved       respiratots for such circumstances should take into account by the U.S. Itureau of Mines / National Institute fot Occupa.      appluabk opprovals of the U.5, Burosu of M6rws/NIOSH.
tsonal Safety and Health (NIOSHI accordmg to appbcable approvals for respirators to protect agamst suborne radio.
auchdet, may be und to the entent that they do not etceed          Note 2: Radsosctive contaminants for wl.6ch the concentration
* values in Table I of Appendit 8 to 10 CT R part 20 are bawd the protection factors bsted in this table The protection          on anternal dose due to inhaleuon may, an oddauon, present I
factors beted an than table mas not be appropriate to clicum.      etternal enposure hasarda at highet concenuttsons. Urder such stantes where chemical or other tespirator) hdards ttist in       cucumstances, hmitabons on occupency may have to be addauon to radioactive hazasds. The selection and use of           governed by enternal dow limits 6
4k4 8.15S 7.,                                                                                                       E-5 n                                         .      .

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APPENDIX r AN EVALUATION OF FIRE PROTECTION AT ADVANCED MEDICAL SYSTEMS, INC.
LONDON ROAD FACILITY CLEVELAND, OHIO w
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smenoposeWNAL LE3ee COMWoOL. WWC.
AN EVALVATION OF FIRE PROTECTION l                                                   AT ADVANCED MEDICAL SYSTEMS, INC.
LONDON ROAD FACILITY CLEVELAND, OHIO a
Submitted: November 8, 1985           Prepared by:  bb Harvey E. Goranson, P.E.
Reviewed by:  hkI David S. 'Mowi'er(P.E.
P. O. Box 446 e Oak Ridge. Tenneme 37831 e (616) 482 3541
[
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;-                                                                                                                 TABLE OF CONTENTS 1                                                                                                                                                                                                                        1 i
i                                         Section-                                                                                                                                                                  M     l
                                                                                                                                                                                                                           )
t i
1.0       Description of                                   Facility.................................                                                                        1   !
:                                          2.0 Existing Fire Protection................................                                                                                                                7   :
3.9       Conclusions.............................................                                                                                                          9
 ;                                         4.0 Reconnend ati ons - Hot Cel l Area. . . . . . . . . . . . . . . . . . . . . . . .                                                                                      14 5.0 Reconnendations - Bal ance of Plant . . . . . . . . . . . . . . . . . . . . .
17   ,
1 J        ..
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I 1
k a
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e-                                                                                                                              F-2 i       1

  ,I AN EVALVATION OF FIRE PROTECTION AT ADVANCED MEDICAL SYSTEMS, INC.
LONDON ROAD FACILITY CLEVELAND, OHIO

==1.0 DESCRIPTION==
OF FACILITY Advanced Medical Systems, Inc. operates a radioactive isotope handling        ;
facility at 1020 London Road, C16 Wland, Ohio. (also known as the Lon-        {
don Road Facility). At this location, the cobalt-60 radiation sources used in medical instruments are manufactured and stored. Completed sources are sent to the company's Geneva, Ohio, location for installa-tion in the heads of X-ray equipment. Field installation of sources is also conducted.
On October 22, 1985, an inspection of the London Road Facility was conducted to evaluate the protection of the facility against fire haz-ards. Present during this inspection were Jim Berger, Glenn Murphy, and Ed Darden of Oak Ridge Associated Universities (0RAU), Robert E.
Burgin of the U.S. Nuclear Regulatory Comission - Region 111 (NRC),
Harvey Goranson, P.E., of Professional Loss Control, Inc. (PLC), and Dr. Sam Stein and Howard Erwin of Advanced Medical Systems.
Construction and Occupancy      - The building may be considered as form-ing five areas:       a vacant manuf acturing f acility on the north, the original structure in the center, vacant offices on the east, a ware-house and shipping area on the southwest, and the hot cell f acility on the southeast. The construction date of the original structure is un-known, but in 1958 it was substantially remodeled, with the east of fices, hot cell f acility and warehouse added,        in 1960 the north addition was built and used to manuf acture the X-ray equipment.
   ~~
The original structure is a brick-walled two-story building with a wood plank on unprotected steel bowstring truss roof.       Dimensions are 1
r F-3

         ,l'
:                                      approximately 58' x 96', for a ground floor area of $568 square feet, i
During the 1958 remodeling, the wood floors were removed and replaced i-                                     with concrete on unprotected steel forms, beams, and columns. Floor
:                                       openings are unprotected.                                 The second floor and attic space are vacant; only a portion of the first floor offices, storage area, and restrooms is utilized.
The north addition is a two-story building having hollow concrete I
block walls (partially brick-f aced) and concrete on steel floors and roof,             Dimensions are approximately 160' x 176' for a ground floor area of 28,160 square feet. Stairways are enclosed, but doors are not
;                                         listed for Class 'B' openings. Manufacturing operations were moved
 !                                       several years ago and this area is vacant.
 ;                                       The east office area is a two-story building with brick-faced hollow block walls and concrete on steel floors and roef. Dimensions are approximately 28' x 58' and the ground floor area is 1624 square feet. This area is vacant, although some of the office space is util-ized.
1 The southwest warehouse and loading dock is irregularly shaped and one story in height. The ground floor area is approximately 3600 square feet. This area contains x ray machine heads and source containers.
The addition on the west is vacant, but was once used for spray paint-
;                                         ing witn small amounts of flamable liquids still stored in the area.
 !                                       The hot cell facility is one and two stories high, with a part base-
 ,- a ment. The first floor is approximately 3550 square feet, the second approximately 2400 square feet, and the basement approximately 2400 square feet. Construction is concrete-protected structural steel with                          '
some exterior t<all of solid brick. Interior walls around the hot cell are 5-1/2 foot- concrete with cell windows of 2-inch glass filled with a zinc bromide solution. Stairways are enclosed; 1-1/2 hour doors are provided on the east stairway only. It could not be determ-
},                                        ined if fire dampers are installed in high-radiation ventilation ducts 2
[                                                                                            F-4
             .-            . --                    - .               .       -            ~     . __        .- -_-.      -     -   -.

0 . e*
between the first and second floors. The second floor contains a boiler, HVAC equipment, emergency generator, high-rad ventilation equipment, and vacant offices. The first floor contains the hot cell work area, offices, clothing change areas, isotope shop area, waste storage, air lock, and decontamination room. Tne basement contains the air sample pump, miscellaneous storage, and high-radiation dry and liquid waste storage.
UL-listed 3-hour fire doors are provided in several areas, but due to their erratic locations, the f acility is considered a single fire division. Also, at least one fire door was found blocked open with the fusible link missing. The vacant portions of the building are for lease.
Hazards - The north addition is vacant and there are no significant quantities of combustibles remaining in the area. A 2.56 million Btu /hr. output boiler is installed.
    ~
The natural gas supply line to this boiler is provided with a manual shutoff valve, unvented reguia-tor, safety shutof f valve, and a second manual shutoff valve. High and low gas, pressure switches and a second safety shutoff valve are not provided.
The east office addition presents no unusual hazards.
The attic of the original structure contains several combustible boxes, probably left over f rom prior plant operations.      The vacant second floor presents no unusual f eatu res. A portion of the first floor storage area is used to store two pallet loads of combustible roof coating liquid in ordinary 5-gallon containers. This material is segregated by open space f rom other materials, in the southwest warehouse addition, there is a paint spray booth located in an 11' x 16' ' room. This booth was used to touch up x-ray machine heads, but reportedly. has not been used since 1982. Although the room is sprinklered, the booth is not.       Electric lights on the 3
p                                         F-5

                        .I booth are standard, but an ordinary enclosed lighting fixture is 5' f rom the bootn f ace. Booth filters are in poor condition. A 3 hour door to this room is held open by a chain.
Outside the paint spray room is a flamable liquid ''.orage area. This room contains a standard flamable liquids cabinet, a self-closing rag can, and 3 LPG cylinders chained to the wall. The cabinet contains old paint and thinner previously used in the paint spraying opera.
tion. The LPG cylinders are used to fuel a fork lift truck in the
                      ,,,                         warehouse area.
l The source exchange containers in the warehouse are of a heavy con-      !
struction. They were stated to be tested to withstand extremes of heat (1475'F for 10 minutes) and water spray in accordance- with NRC requirements.
                         ~
Cobalt pellets are shipped to the Oak Ridge National Laboratory (ORNL) for conversion to the Cobalt-60 isotopes. This highly radioactive
                                              ,    material is returned to this facility in special shipping containers.
Approximately once every 3 months, the 40-ton, 5-1/2 foot thick con-crete door to the hot cell is opened.      The cobalt-60 and other re-quired materials are placed within the cell, and finished materials and waste are removed.
During the next three months, colbalt-60 pellets are placed in small containers using remote manipulator arms. The tops of these contain-ers are welded shut, the container is placed within another container, and that larger container is sealed by welding. This is the finished product used in the x-ray machine.
The only combustibles located within the not cell are wiping cloths, and a small plastic trash bag used for trash collection. The welding process is electric, using argon gas. The welding procedure is pre-scribed so that sparks or splatter of molten metal should not occur.
The cobalt source can become self-heated and personnel 'are advised by 4
I:                                                        F-6 i

st procedure not to allow this material to contact combustibles for more than a few seconds. A water faucet is ' located within the cell.
Personnel who must enter the hot call or isotope shop areas do so through a locker room and change area in the southeast corner of this area.      A laundry f acility, using dnmentic-type washer and electric dryer machines, is located at the entral.ce to the isotope shop area.
l           in tnt. Southwest corner of the isotope shop, there is a storage garden containing old radioactive sources. These sources are stored 9 feet below the ground.      in the west area there is a gas line from the out-side meter to the second floor emergency generator. Also in this area is a hatch to the basement. The shop contains a relatively light loading of combustible materials.
There is an airlock connecting the l'sotope shop, warehouse, and origi.
  ~
nel structure areas. Some' combustible boxes are stored in this area.
A natural gas supply line travels from the outside meter, through this area, to the original building.
The shielded work area contains depleted uranium, check sources (for instrument calibration) and approximately 20 metal drums of radio-active waste (considered combustible). This room is surrounded by 3 foot thick-concrete walls, but is not cut off by fire doors.
4 On the second floor, the ventilation exhaust equipment is located in a concrete block-walled room with a 1-1/2 hour fire door installed on the opening. Ventilation air travels f rom the outside, to the isotope shop area, through the decontamination room to the hot cell, and up to this exhaust equipment.- Roughing and HEPA filters are installed to remove airborne radioactive particulates prior to air discharge through a roof stack.      This room also contains the emergency genera-
  ~
tor, with air intake located inside the room and exhausting outside.
This room is a radioactively contaminated area.
5
{                                             F-7 m

s el Also on the second floor, in a separate room, is a 1.512 million 8tu/
!           hr. boiler with a manual gas shutoff valve, hydramotor valve, unvented l           regulator, and a safety shutoff valve.        No high/ low gas pressure switches or second safety shutoff valve were in evidence. The boiler is roped off as contaminated equipment. Normal HVAC equipment is also located in this area.
In the " clean" area of the basement, paper materials are stored on one metal shelf in a small room. in another room, the air sample pump is located. This pump is lubricated using motor oil, and 121-quart cans of oil are stored nearby.       A S-gallon open can is used to collect waste oil. Minor oil spillage exists on the floor, i
The basement area also includes wet and dry radioactive waste. Radia-  l tion levels are high in these areas. The dry waste includes used fil .
ters in cardboard boxes.
Exposure - This f acility is located in an industrial neighborhood. I There are no significant exposing buildings within 100 feet. Railroad ,
tracks are located 'along the south side of the property. A second building on the plant property, located over 100 feet west, is occu-pied by a plumbing supply company.
Wd4 e*
6
: p.                                          T-8

  , s' 2.0 EllSTING FIRE PROTECTION Existing fire protection consists of extinguishers, sprinklers, detec-tion, alarm systems, and response from the municipal fire department.
Spr_i,nklers - Two wet pipe sprinkler systems are installed at this facility. The entire plant is protected with the exception of'the hot cell facility, the east office addition, and scattered of fice areas throughout the building where sprinklers either were never installed, or drop ceilings obstruct the existing heads. There is an antif reeze     l loop for the LPG cylinder room and heat tape is attached to the l                   sprinkler line in the paint spray room. The ..,mbustible attic space      l
!                    is sprinklered.
Sprinkler systems appear to be designed using ordinary hazard (2-3-5) pipe schedule. Sprinklers are 1/2-inch orifice with a 165'F rating. -
l                    The north manuf acturing area has center feed branch lines, six heads per line, and 125 square feet per head. The attic of the original building has side feed sprinklers with 2 and 3 neads per line.
A booster pump is installed in a separate building on the property.
The Fairbanks-Morse fire pur.:p is rated at 750 gpm at 70 psi and 1750 rpm. Tne jockey pump maintains system pressures at about 140 psi .
The exterior condition of the pump indicates it is not very well main-tained.
Fire Detection - ADT fire detection systems are installed in the hot cell f acility and portions of the nonsprinklered offices. Offices both within the hot cell f acility and in other plant areas have ADT 4205 rate-of-rise thermal detectors installed. The radiation areas of the hot cell facility are protected by a combination of pneumatic hol-low tubing and ADT B4103 compertment units. These B4103 units are marked with a blue dot and, according to the 1985 UL Fire Protection Equipment Directory, have a 45-foot coverage area.       All detection equipment is UL-listed.
7 p                                                   F -9

.I The hot cell it equipped with a temperature sensor which sounds an alarm if the temp. ature goes below 40'F, or exceeds 85'F. This sen-sor could not be viewed and VL-listing information is unknown.
Alarms - All fire detection alarms are transmitted to the ADT central station. Also included are burglar alarms, sprinkler valve tamper switches (on most valves), sprinkler waterflow, ventilation system shutdown, a manual pull a' inn (located outside of the airlock in the original structure), fire pump operation, and fire pump power failure.
The maintenance of these systems was confirmed by a call to ADT.
Extinguisheri - Both carbon dioxide (typically 10BC) and dry chemical (typically 4A40BC) extinguishers are located throughout the f acility.
Minor deficiencies exist in their distribution in vacant areas, but due to lack of combustible occupancy, this is considered acceptable.
The travel distance to an A-rated extinguisher from the first floor isotope shop and basement dry waste storage areas exceeds 75 feet.
All extinguishers have current inspection tags.
Fire Department Response - A call to Captain James Esper of the Cleve-land Fire Department revealed there is no preplan for fighting a fire at this facility.
The previous owners of tnis facility (Picker) developed a Radiation Procedures Manual which describes the fire protection systems and mea-sures to take in the event of a fire.       Advanced Medical Systems is said to be following these procedures, and several present employees were hired by the original owner. However, with a neximum of five people at the f acility during the day and none at night, it is unknown how closely any of these older procedures are still followed, particu-larly with respect to maintenance.
8 p                                           F-10

e it 3.0 CONCLtlS10NS The primary fire protection concern in this f acility is that any pos-tulated fire cannot result in the uncontrolled release of radioactive material. Secondary concerns include limiting fire and water damage to an acceptable level, and compliance with applicable codes and standards.
Some of the conclusions and recommendations of this report are based on information contained in " Fire Prevention and Protection in Hot Cells and Canyons" by Arthur J. Hill, Jr., dated April,1971. Also i                used as references are the following standards published by the National Fire Protection Association (NFPA):
NFPA 10-1984       Standard for Portable fire Extinguishers NFPA 13-1985       Standard for the -Installation of Sprinkler Sys-tems NFPA 85A-1982      Standard for Prevention of Furnace Explosion in Fuel Oil- and Natural Gas-Fired Single Burner Boiler-Furnaces 4
3.1 Lack of knowledge by the Cleveland Fire Department of the nature of operations at this f acility presents a severe possibility of radioactive release in the event of a fire. Without such Know-ledge, responding fire fighters may attack a fire with large quantities of water, which could release radioactive materials to the environment. Also, clean-up operations may spread contami-nants,   it will be necessary for the fire department to complete-ly pre-plan a response to this f acility.
3.2 To limit the possibility of radioactive release to the environ.
ment from fire department operations, some form of fire suppres-sion system should be installed in the hot cell f acility. This is recommended in Hill's paper and is also standard procedure in DOE facilities, such as ORNL. Due to the low quantities of com-bustibles within the cell and its small size, fire suppression 9
p                                               F-11

il may be omitted in this area. The postulated fire within the cell should not release quantities of smoke that will be large enough to clog the HEPA filters, resulting in a back pressure release of radioactivity. Some means of exhaust duct protection (such as a water curtain) is recomended to limit fire spread from the hot cell to the second floor, i
Acceptable forms of automatic fire extinguishment would include a wet pipe sprinkler system, a self-restoring wet pipe or preaction sprinkler system, or a Halon 1301 extinguishing system. Halon 1301 is expensive, but there is virtually no cleanup problem to deal with following actuation. Sprinkler systems are less expen-sive, but the water release may result in costly cleanup proce-dures later. Preaction or self-restoring systems will result in less water release and also reduce the possibility of accidental (non-fire) water release.
Carbon dioxide extinguishing sys; ems were not considered due to the life safety hazards to personnel from a major CO2 release.
Ory chemical systems are unacceptable due to cleanup problems associated with system discharge.
3.3 The hot cell facility presently comunicates with all other por-tions of the building. This introduces the potential for fire spread among the various building areas with the attendant possi-ble spread of radioactivity. Also, should a tenant move into the vacant areas, a serious exposure problem may result. The hot
    ,           cell f acility should be separated from other areas by 3-hour fire barriers to limit fire spread. Also, suitable curbs are neces-sary to direct fire fighting water to the basement 50 that dis-charge of radioactive water can be controlled.
To sum up, Sections 3.2 and 3.3 reflect the philosophy that any fire should be contained and automatically extinguished, with cleanup operations limited to within building boundaries.
10 p                                     F-12

     .I 3.4 Some minor instances of a lack of detection system maintenance were noted. This includes loose pneumatic tubing and ADT 84103 detectors, and painted ADT 4205 detectors.
3.5 Several areas of the hot cell facility are not covered by the fire detection system, principally the second floor mechanical equipment room and several offices.
3.6 To limit fire spread within the hot cell facility itself measures need to be taken to sepsrate the basement, first, and second floors. This would include installation of 1-1/2 hour rated doors on the south stairwell and heat-actuated fire dampers in the ventilation ducts where they pierce floors, particularly from  1 tre hot cell itself.
l 3.7 Fire hazards in the hot cell facility can be significantly l
reduced by the removal of unnecessary combustibles and proper     l housekeeping. Toward this end, it is recomended that oil spil-lage in the basement in the vicinity of the air sample pump be cleaned up, and that oil cans be stored in a detached location (such as the existing flamable liquids storage cabinet in the warehouse section). Also, it would be advisable to relocate the gas line in the first floor isotope shop to the outside of the building, and the gas line in the first floor airlock to another area outside of the hot cell facility. This will reduce the pos-sibility of mechanical injury to the gas piping within the high radiation areas.
a 3.2 NFPA 85A, Appendix M. illustrates a typical gas supply line to a boiler similar to the two boilers installed at this property.
Comparing this illustration with plant conditions reveal; the following equipment is missing -(see_ also IRI recomendation 83-
    ~
1):
: 1)   High and low gas pressure switches
: 2)   A second safety shutoff valve (SSOV) 11
    ,-                                      F-13 n

in
: 3)    A vent line located between two $50V's. This vent line would bleed off any natural gas that could leak past a f aulty SSOV. It should be provided with a vent valve which de-energizes in the open position. The vent line should terminate above the roof and the outlet should not be located near any ignition source, especially the boiler exhaust stack.
: 4)   A vent line from the top of the regulator to a safe lo-cation, preferably outside, to discharge any gas leak-I                             ing past the regulator diaphraps. (This is not spe.
cifically shown in Appendix M to hFPA 85A).
3.9 Excessive travel distances to a 2A-rated extinguisher in the iso-tope shop area and basement waste storage areas could allow a small fire to expand before it could be extinguished manually.
(There is a carbon dioxide extinguisher in the isotope shop - not an A-rated extinguisher). However, extinguishers should be loca.
ted in uncontaminated areas to facilitate periodic servicing.
NFPA 10 limits travel distance for a 2A-rated extinguisher to a
      ,          maximum of 75 feet. The best -locations from which the isotope shop can be served would be the clothing locker room and imedi-ately beyond the airlock in either the warehouse or the original structure.
The basement area poses a problem in extinguisher location due to high levels of radioactivity and potential contamination. A door to the clean area of the basement may be locked which would- pre-    ;
vent access to the extinguisher in the east stairway. The best alternative available for this area would be to locate an extin-guisher in a secure box on the exterior of the building at the first floor emergency e'xit from the south stairway. This extin-guisher could also be available for use in the isotope shop area.
12                    *
{                                              F-14

l a' The type of extinguisher recomended is a Halon 1301 or 1211 type with at least a 2A-rating.       This type of extinguisher is useful on all types of fires (except combustible metals), whereas carbon dioxide is not recomended for Class A (ordinary solid combusti-ble) fires. Also, the Halon 1301 extinguisher leaves no residue (unlike water or dry cherical ertinguishers) which will reduce the cleanup of contaminated waste.
\
The uncontrolled access area of the hot cell facility contains only two carbon dioxide extinguishers of 8BC and SBC ratings. An A-rated extinguisher is recomended for these areas as well.
3.10 Remaining areas of the plant property exhibit several deviations f rom NFPA standards and good fire protection practices which should be addressed. Many of these have been documented by the insurance carrier in the IRI Loss Prevention Survey of January 9,
.-           1985. Most of these recomendations will not be repeated here.        '
Additional deficiencies observed include: installation of drop ceilings beneath detectors and/or sprinklers, upright sprinklers instalied in the pendent position, blocked fire doors, and use of
.            an unlisted fork lift truck within the building.
L.
13 p-                                      F-15                                      '

i t' 4.0 RECOMMENDATIONS - HOT CELL AREA 4.1 Advanced Medical . Systems should work with the Cleveland Fire Department to develop a suitable fire pre-plan for this facili-ty. Such a pre-plan should include such aspects as breathing apparatus for fire department personnel, evacuation of surround-ing areas, rotation and monitoring of exposed personnel, response of hazardous materials specialists, warning signs, diagrams of the locations of radioactive materials, etc.
4.2 Automatic fire suppression should be provided throughout the hot l
I'                 cell facility (the hot cell itself may be omitted).         The pro-tected area would include any office or other areas not detached from the f acility by 3 ..sur barriers (see Recomendation 4.3).
Necessary protection would include a water spray system within the high rad exhaust duct, upstream of the filtration unit.
Acceptable suppression systems would include:
                            -   Wet pipe sprinkler system.
                            -   Preaction sprinkler system with heat detector actuation.
                              , Wet pipe system utilizing "on-off" sprinklers which will stop the flow of water below a prescribed temperature.
Total-flooding Halon 1301 extinguishing system.
4.3- Since fire suppression systems can be omitted from the test cell, it would be advisable to place a small open can of dry chemical powder or hose line f rom the faucet for use in extinguishing small fires within the cell.        Such extinguishment would take place manually using the remote manipulator arms.
4.4 Separate the hot cell facility from other areas by 3-hour rated barriers. This will necessitate the installation of new fire walls, or an upgrading of existing walls and floors to the required rating through the installation of UL-listed 3-hour fire
   ~~
doors and dampers, and suitable sealing of all other fire wall penetrations. Suitable curbs and/or drainage should be present 14 F-16

il l
l to direct fire water release down the stairwells to the basement for later removal / decontamination action.
1 4.5 Painted heat detectors should be replaced.                             Loose detectors and pneumatic tubing should be reattached.
4.6 Extend the ADT neat detection system to the second floor of fices and mechanical equipment room.
,                      4.7        Provide self-closing UL-listed 1-1/2 hour fire doors on all stairway openings.       Install heat actuated automatic closing. UL-
;                                 listed fire dampers having at least a 1-1/2 hour rating in all l                                 HVAC ducts which go through the first or second floor. This is particularly important for the ventilation duct from the hot cell itself, and a 3-hour fire damper is recomended at the second                                    .
floor opening for this duct.               'Any other unnecessary penetrations
     ~
should be sealed to meet a 3. hour fire endurance.
4.8 Remove all oil spillage from the basement floor near the air sam-Relocate oil cans outside of 'the hot cell facility, pie pump.
preferably to tne flamable liquids storage cabinet.
4.9 The gas line to tne second floor emergency generator should be relocated to the outside of the building.                      The gas line in the airlock should be relocated, preferably - to the southwest ware-house area.
4.10 In accordance with NFPA BSA, provide the following equipment on the 1.512 million Btu /hr. boiler located in the second floor mechanical equipment room:                                                               '
: 1) A low gas pressure switch, located upstream of the first safety shutoff valve.
15 F-17

In
: 2) A second safety. shutoff valve located downstream of the existing SSOV.             '
: 3) A vent line located between the SSOV's and terminating above the roof, away f rom the boiler vent stack. A vent valve should be provided which de-energizes in the open positton.
: 4) A high gas pressure switch, located downstream of the second safety shutoff valve.
: 5) A vent line from the top of the regulator, terminating outside of the building.
   .4 4.11 Provide Halon extinguishers having at least a 2A-rating to pro-tect the contaminated area of tne hot cell facility. The travel
!               distance to an extinguisher should not exceed 75 feet f rom any l               location within this area. Suggested extinguisher locations in-clude:
: 1) In a weatherproof secure box outside the first floor landing'of the south stairway.
: 2) Outside the north and west doorways from the airlock.
: 3) Within the clothing change area near the red - step-of f line.
Also, an extinguisher of. any. type having at least a 2A rating snould be provic'01 near the first floor office area.      Considera-tion should -be given to providing, a Halon eatinguisher on the--
second floor at the entrance to the machinery room to reduce the potential for radioactive waste cleanup, although dry chemical extinguishers present meet the intent of NFPA 10.
4.12 All major design changes should be reviewed by a registered fire protection engineer prior to implementation.
  . r-16
  +                                          F-18

le' 5.0 REC (MMENDATIONS - BALANCE OF PLANT 5.1  In accordance with NFPA 85A, provide the following equipment on the 2.560 million Btu /hr. boiler iocated in the northwest corner of the old manufacturing facility (first floor):                      I
                         .1) A low gas pressure switch located upstream of the first safety shutoff valve.
: 2) A second safety shutoff valve located downstream of the existing SSOV.
: 3) A vent line locatee setween the SS0V's and terminating above the roof, away from the boiler vent stack. A vent
                              -valve should be provided which de-energizes in the open position.
: 4) A high gas pressure switch, located downstream of the second safety shutoff valve.
: 5) A vent line f rom the top of the regulator. terminating outside of the building.                          '
5.2 Sprinkler protection should be extended to all balance of plant nonsprinklered areas, particularly below any drop ceilings.
:nstallation should be in accordance with NFPA 13.
5.3 Unused paint and thinner kept in the west storage area should be removed from the premises.
5.4 Fork lift trucks used inside the building should be UL or FM-         4 listed for use in ordinary occup:c.cy areas.
5.5 Two upright sprinklers are installed in .the pendent position beneath tha drop ceiling on the first floor in the original structure.      These sprinklers should be replaced with listed pen-dent sprinklers.
17
[                                                F 19 i
l

It 5.6 Fire doors in a first floor _ corridor between the original build-ing and the east offices are blocked open. These doors should be      ,
i allowed lto _ operate freely and fusible links, required- for auto-
     ,                       matic closure,- provided as - required.
i l
i-              ,
L File Ref:   AMS-16-01-53 18
[~                                                   F-20

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O 9
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l e.
s APPENDIX G ANALYTICAL EQUIPMENT AND PROCEDURES l
i e
h w
t F
a            .                                                                                                                      .. . ..              .

l'it-Appendix G Analytical Equipment & Procedures The display or description of a specific- product is not to be construed as an endorsement of that product or its manuf acturer by the authors or their employer.
A. Eberline PRM-6 i-                    Portable Ratemeter
!         *           (Eberline, Santa Fe, NM)
Eberline " RASCAL" PRS-1 Portable Scaler /Ratemeter (Eberline, Santa Fe,- NM)
Eberline llP-260 & HP-270 GM Detectors (Eberline,. Santa Fe, NM)
       ~~
Victoreen Na1. Gamma -Scintillation- Detector Model 489-55 (Victoreen, Inc., Cleveland, OH)
Keithley Model 36100 Ionization Chsaber (Keithley,- Cleveland, OH)
B. Air Sampling
                     ; Stack sampling nozzles (NuTech Corp., Durham, NC)
Rotameters, 0-100 cfh (Dwyer Corporation)            ,
Gast Vacuum Pumps 115v/60Hz Cat. #P8400 L.              (American Scientific Products,-Stone Mountain, GA)
Velometer - Type 6000 (all purpose set)
( Alnor -Instrument Co. , Niles , IL)
                -C. Laboratory Analysis
                     ' Automatic low-background Alpha-Beta Counter
        .- :           Model LB5110-2080
                     . (Tennelec,- Inc. , Oak Ridge, TN)
High Purity Germanium Detector
_ Model GMX-23195-S,'23% Efficiency (EG&G Ortec, Oak Ridge,. TN) 6.
b$
            ~

o ta l
l l
l ND-66/ND-680 System (Nuclear Data, Inc., Schaumburg, IL)
D. A brief description of the analytical procedures used is provided below.
Soil / Sediment / Vegetation Sample Analysis Gamma Spectrometry Soil / Sediment / Vegetation sampics were dried, mixed, and a portion placed in a 0.5 liter Marinelli beaker.       The quantity placed in each beaker was chosen to reproduce the calibrated counting geometry and varied in weight based on sample type.        Net weights were determined and the samples counted using an intrinsic germanium detector and a Nuclear Data Model ND-680 pulse height analyzer system.         Background and    Compton  stripping,   peak   search,    peak  identification,   and concentration    calculations    were   performed   using   the   computer capabilities inherent in the analyzer system.
Water Sample Analysis Water samples were rough-filtered through Whatman No.            2 filter paper.      Remaining suspended solids were removed by subsequent filtration through 0.45 um membrane filters. The filtrace and filter samples were counted by gamma spectrometry using the system denoted above.
Paint Sample Analysis a.
Paint chips are counted in a filter paper geometry using the gamma spectrometry system denoted above.
Air Sample Analysis Air sample filters are cour.ted in a filter paper geometry using the gamma spectrometry system denoted above.
[*                                             G-2

  ' II Smear Sample Analysis Smear samples were counted for gross beta using a Tennelec Model LB-5110 low background proportional counter.
Errors and Detection Limits                                                                    !
The uncertainties associated with the analytical data, presented in                        :
    ,,       the tables of t' te re port , represent the 95% (20) confidence levels I
based only on counting statistics. Other sources of error associated with the sample analysis introduce an additional uncertainity of +/-
6 to 10% in the results.
I Calibration and Quality Assurance
;            Laboratory and field survey procedures are documented in manuals l            developed       specifically            for   Oak  Ridge    Associated    Universities;
       ,     Radiological Site Assessment Program.
With the exception of the measurements conducted with the portable gamma scintillation survey meters, instruments were calibrated with NBS-traceable standards. The calibration procedures for the portable gamma instruments are performed by comparison with an NBS traceable pressurized ionization chamber.
Quality       control            procedures   on  all   ins t ruments   included   daily L        background       and            check-source   measurements     to   confirn equipment operation within acceptable statistical fluctuations.                          The ORAU laboratory participates in the EPA Cross Check and EML Quality Assurance Programs.
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    'I 3                                                                                                               ORAU 89/B 145 I'
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    ,                   a Prepared by
* Oak Ridge Associated
    ,; Unkersities
     -    Prepared for RADIATION SURVEY U.S. Nuclear Regulatory OFTHE
     ,    c:mmission s                         ADVANCED MEDICAL SYSTEMS, INC.
Region lli Office Supported by LONDON ROAD FACILITY Dwision oi                                       CLEVELAND, OHIO l    "
Industrialand Medical Nuclear
     -    Safety                                       P. R. COTTEN and G. L. MURPHY J
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A                                                       Radiological Site Assessment Program J                                                     Energy / Environment Systems Dkision m                                                               FINAL DEPORT APRll1989                                              .
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RADIATION SURVEY OF THE ADVANCED MEDICAL-SYSTEMS, INC.
LONDON ROAD FACILITY
* CLEVELAND, OHIO Prepared by-i-
P. R. Cotten and G. L. Murphy.
Radiological Site Assessment Program Energy / Environment Systems Division Oak Ridge Associated Universities
: j.                                      Oak Ridge, Tennessee 37831-0117 Project Staff S.F. Barnett         T.J. Sowell J.D. Berger           C.F. Weaver C.H. Searcy Prepared for Division of' Industrial and Medical Nuclear Safety U.S. Nuclear Regulatory Commission Region III Office FINAL REPORT APRIL 1989 s
This report is based on work performed under. an Interagency Agreement (NRC Fin. No. A-9076) between the U.S. Nuclear Regulatory Commission and the U.S. Department uof Ener gy.     ,0ak Ridge Associated Universities performs complementary- work .under contract number DE-AC05-760R00033 with the U.S. Department of Energy.
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i                                                                                       TABLE OF CONTENTS Page
                     -List of Figures .                       . .         ..... .-. . .. . .. . . . . . .. .                                     11 q                      List of Tables                      . . . . . . . . . . .. ... , , , , . . . .                                .-.. .       y
;.                    . Introduction                   . . - , . . .-. .... . .. . . . . . . . . , ,. .                                           1                      ,
4 Site Description                        . . .. ..., . . . . . . . . . .. . . . . .                                         I r                      Procedures                  . . . . . . . . .......... .. . . . . . . . .                                                 2 Survey Results_                    , . . . . . . ... .. . .. . .. . . . . . . . .                                         5-
                      -Radiation Safety Evaluation .                                   . . . . . . . . .. . . . . . . . . .                      10 I
i-                      Summary . . . . . .                        .-. . . . .. . . ... . . . . .. . . ., .                                      20                     !
                      -References                   . . . . ... .... ... . . . . . . . . . . . .. .                                              88
                      . Appendices:
I j                                 Appendix A: NRC Scope of Work Appendix B: Radiation Co racterization Survey Plan.
Appendix C: Major Sampling and Analytical Equipment Appendix D: -Measurement and Analytical' Procedures s-i e+   -
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                                                                                                           )
LIST OF FIGURES                                     i i
l Page FIGURE 1:  Cleveland, Oil, Area Indicating the Location of the AMS Facility . . . . . . . . . . . . .              . . . . . . . . .      22 FIGURE 2: Advanced Medical Systems Facility Layout                . . . . . . . . 23  I l
FIGURE 3:  Partial Floor Plan of the AMS Occupied Area on the
   ,,                       First Floor     . . . . . . . . . . . . . . . . . . . . . .                24 FIGURE 4:   Partial Floor Plan of the AMS Occupied Area on the                            4 l                            First Floor    , . . . , . . . . . . . . . . . . . . . . .                25  !
;                FIGURE 5:   Floor Plan of the AMS Occupied Area on the Second l
Floor . . . . . . . . . . . . . . . . . . . . . .                  . . . 26 FIGURE 6:   Floor Plan of the AMS Occupied Area on the Basement Floor . . . .       . . . . .. . . . . . . . . . . .             27 FIGURE 7:   Layout of Cell Control Area, First Floor, Indicating Measurement Locations.        . . . . . . . . . . . . . . . . .            28 FIGURE 8:    Layout of Front Office, First Floor. Indicating Measurement Locations.       . . . . . . . . . . . . . . . . .            29 FIGURE 9:    Layout of Chemistry Laboratory, First Floor, Indicating Measurement Locations.       . . . . .. . . . . . . . . . . .             30 FIGURE 10: Layout of Main Stairwell, First Floor, Indicating Measurement Locations        . . . . . .. . . . . . . . . . .             31 FIGURE 11: Layout of Instrument Calibration Room, First Floor.
Indicating Measurement Locations . . . . . . .. . . . .                  32-FIGURE 12: Layout of Airlock and Hallway off Instrument Calibration
  ,,                         Room. First Floor, Indicating Measurement Locations . .                    33 FIGURE 13: Layout of Laundry Room, First Floor, Indicating
                           -Measurement Locations         . . . . . .. . . . . . . . . . .              34 FIGURE 14: Layout of Change Room and Hallway, First Floor, Indicating Measurement Locations . . . . . . .. . .            . .        35 FIGURE 15: Layout of Stairwell at Main Entrance, Second Floor, Indicating Measurement Locations . . . . . . . . . . . .                  36 FIGURE 16: Layout of Room 1, Unoccupied Office Space, Second Floor.
Indicating Measurement Locations . . . . . . . . . . . .                  37 11

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                                        -LIST OF FIGURES (Continued)
P, age FIGURE 17: Layout of Room 2. Unoccupied Office Space, Second Floor.
Indicating Measurement Loc:tions . . . . . . . . ....                      38     i l
FIGURE 18: Layout of Room 3, Unoccupied Office Space, Second Floor.
Indicating Measurement Locations . . . . .                     . . .... 39 FIGURE 19: Layout of Room 4, Unoccupied Office Space, Second Floor,
  ><                   Indicating Measurement Locations . . . . . . . . . ...                     40 FIGURE 20: Layout of Room 5 Unoccupied Office Space, Second Floor, Indicating Measurement Locations . . . . . . . .. ...                     41 FIGURE 21: Layout of Equipment Room, Second Floor, Indicating Measurement Locations.     . . . . . . . . . . . . . .                  ,, 42 l             FIGURE 22: Layout of Entrance to HEPA Filter Room, Second Floor.
l Indicating Measurement Locations . . . . . . . . ....                     43
\
FIGURE 23: Layout of Women's Restroom, Second Floor, Indicating Measurement Locations     . . . . . . . . . . . . . ....                  44 FIGURE 24: Layout of Men's Restroom, Second Floor, Indicating Measurement Locations     . . . . .. . . . . . . . ....                   45 FIGURE 25: Layout of Air Sampling Room, Basement Floor Indicating Measurement Locations.    . . . . . . . . . . ... ....                    46 FIGURE 26: Layout of Isodose Curve Storage Room, Basement Floor, Indicating Measurement Locations . . . . . .. . ....                       47 FIGURE 27: Layout of Unoccupied Room and Hallway, Basemen: Floor, Indicatin5 Measurement Locations . . . . . . . . ....                     48 FIGURE 28: Layout of Main-Stairwell, Basement Floor Indicating a                    Measurement Locations. .      . . . . . . . . . , . . ....                 49 FIGURE 29: Layout of Isotope Shop Area, First Floor, Indicating Measurement Locations      . . . . . . . . . . .. . ....                   50
             . FIGURE 30: Layout of Stairwell Off Isotope Shop Area, First' Floor, Indicating Measurement _ Locations .            . . . . .. . ....         51 FIGURE 31: Airlock to Isotope Shop Area, First Floor, Indicating Measurement Locations.    . .. . . . . . . . . . . ....                    52 FIGURE _32: Laycut of Wasta Storage Area in Main Warehouse, First Floor, Indicating Measurement Locations. . . . . ....                      53
_                                                        iii f    4

t LIST OF FIGURES (Continued)
Page FIGURE 33: Layout of DU Storage Area, First Floor. Indicating Measurement Locations      . . . . . . . . . . - . . . . . . .        54 FIGURE 34: Layout'of Waste Storage Area Across from Front Office, First Floor. Indicating Measurement Locations. . . . . .             55
    ,,        FIGURE 35: Layout of Warehouse, First Floor, Indicating Measurement Locations. - ,. . . .. . . . . .. . . . . . . . . . . .              56 y
FIGURE 36: Layout of HEPA Filter Room, Second Floor, Indicating Measurement Locations.    . . . . . . . . . . . . .. . . . .         57 FIGURE 37: 1 Layout of Dry. Waste Storage Room, Basement Floor, Indicating Measurement Locations .         . .. . . . . . . . .      58 FIGURE 38: Hot Cell Exposure Rate Measurement Locations at Table Top Level. . . . . . . . . . . . . . . . . . . . . . . . . .             59 FIGURE'39: Hot cell Exposure Rate Measurement Locations at 1 m above the Table Top. . . . . . . . . .. . .. . . . . . . . .               60' FIGURE 40:-Roof Area Survey Locations .       . . . . . . . . . . . . . .       61 FIGURE 41: Soil Sampling and Exposure Rate Measurement Locations.             . 62 FIGURE 42: Water and Sediment Sampling Locations.          . , , . . . . . . 63
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  ,I LIST OF TABLES Page TABLE 1: Results of Surface Contamination Measurements Non-Restricted Areas. . . . . . . . . . . . . . . . . .            . .                   64 TABLE 2: Results of Surface Contaminatica Measurements Restricted Areas .   . . . . . . . . . . . . . . . . . . . . . . . . . .                            68
  ">        TABLE 3: Gamma Exposure Rate and Beta Gamma Dose Rate Measurements Non Restricted Areas - First Floor.            . . . . . . . . . . . .                   71 TABLE 4:   "amma Exposure Rate and Beta-Camma Dose Rate Measurements
                       '4on Restricted Areas       Second Floor .       . . . . . . . . . . .                  73 TABLE 5: Gamma Exposure Rate and Beta-Camma Dose Rate Measurements Non Restricted Areas - Basement Floor .              . . . . . . . . . ,                75 TABLE 6: Gamma Exposure Rate and Beta Gamma Dose Rate Measurements Restricted Areas - First Floor.         . . . . . . . . . . . . . .                      76 TABLE 7 : Gamma Exposure Rate and Beta Gamma Dose Rate Measurements l         ,
Restricted Areas-- Second Floor .          . . . . . . . . . .                      . . 79 t
TABLE 8: Gamma Exposure Rate and Beta-Gamma Dose Rate Measurements Restricted Areas - Basement Floor . .            . . . . . . . . . . .                  80 TABLE 9: Gamma Exposure Rate Measurements in the Hot Cell.                          . . . . .      81 TABLE 10: Gamma Exposure Rate Measurements on the Roof.                      . . . . . . .         62 TABLE 11: Outdcor Gamma Exposure Rates.        . . . . . . . . . . . . . . .                        83 TABLE 12: Radionuclide Concentrations in Surface Soil .                      . . . . . . .          84
     -       TABLE 13: Radionuclide Concentrations in Water.              . . . . . . . . . . .                  86 a.
TABLE 14: Radionuclide Concentrations in Sediment               . . . . . . . . . .                 87 9
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RADIATION SURVEY OF THE i'                                                         ADVANCED MEDICAL SYSTEMS, INC.
1DNDON ROAD FACILITY f
CLEVE1AND, OHIO 4
INTRODUCTION Advanced Medical- Systems, Inc. (AMS)~of Cleveland, Ohio, manufactures and
{                      fabricates sealed sources of Cobalt 60 and Cesium 137 for *eletherapy and le                     radiography machines, under Nuclear Regulatory Commission (NRC) license number I
34 19089 01.            The license authorizes possession of up to 300 kCi of Co 60 and
                      -40 kCi of Cs 137 in any form, for manufacture, installation and servicing of sealed -sources.            Based on a survey performed by Oak Ridge Associated Universities (ORAU) -in October 1985 and an NRC follow up in August 1986, contamination at the London Road facility wcs found to be excessive and l                      increasing.           On July 23, 1987, the NRC issued an " Order Modifying the License, Effective Immediately", -which required AMS to initiate decontamination of the facility. no later than August 31, 1987, in accordance with a decontamination plan submitted to the NRC on September 10 1986, On October-30, 1987, the NRC 2
j                      issued a " Confirmatory Order Modifying the License, Effective Immediately",
i s-requiring that AMS initiate decontamination no later than August 31, 1987, and l                      complete the decontamination project no later than April 1988, in accordance with a revised decontamination plan submitted by AMS on October 20.-1967.
At the request of the Nuclear Regulatory Commission, Region III Office, the a
Radiological Site Assessment Program of Oak Ridge A:eociated Universities                                                   -
performed           a  radiological survey -of                  the facility and a review of the 1
a              implementation status of recommendations made during the ORAU survey of October 19851 .       This survey was performed November 14 - 17, 1988. Procedures and results-of this survey are presented in this report.
SITE DESCRIPTION-
                            -Advanced'        Medical         Systems         is      located in an industrial / residential.
f                      nei5hborhood at: 1020 London Road, on the east side of Cleveland, (Figure 1).
      ~
The facility: is -in tha- northeastern end of a large warehouse / manufacturing building,        formerly occupied by the Picker Corporation, which used it for similar activities as those being conducted by AMS.                                      Figure 2 is a plot plan of i
i:

          .I 2
the property.         AMS occupies approximately 25% (1925       m ) of the total building floor space of 8000 m ;2 the remainder of the building is not currently being used.        There are three floors in the facility.      The main floor (Figures 3 and
: 4)   includes an office area, an Isotope Shop Area, a Hot Cell, a Shielded Work Room, a storage area, and miscellaneous unoccupied areas. The second floor N          (Figure 5) includes additional unoccupied office space, a Mechanical Equipment Room,      and the Exhaust Ventilation Equipment Room. The basement (Figure 6) includes a former Dry Waste Storage Area,                a Liquid Waste Handling Room, cdditional unoccupied space, and a former Liquid Waste Holdup Tank Room. AMS has received permission from the NRC to seal and monitor the holdup tank room, until the radiation levels are low enough to facilitate further decontamination of the area.           On the south side of the warehouse area, AMS has established a temporary dry waste storage area. The waste is stored in a locked room, and i                     rope barriers have been installed delineating the restricted area.
l               -
PROCEDURES Obiectives l                           The scope of work for this task, as develcpcd by the URC's R~ gt.oh        e    111 Office, is included as Appendix A of this report. In accordance with this task assignment, the objectives oi the survey were to perform a radiological survey to determine the current radiolo8 cal       1  conditions at the AMS London Road facility and to review the current status of implementing the recommendations outlined in the Executive Summary of the 1985 ORAU report entitled " Evaluation sa of the Operational Radiation Safety and Fire Protection Programs of the Advanced Medical Systems,          Incorporated,    London Road Facility,       Cleveland, Ohio"1        Appendix B is the survey plan, prepared by ORAU to accomplish these objectives. Radiological data to be acquired during this survey included:
: 1. Samma exposure and dose rate measurements in general areas of the facility (indoor and outdoor);
: 2. direct measurement of fixed contamination and smears for remosable contamination levels within the building; 2
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: 3. an evaluation of the contamination and exposure rate levels in the sewer drain line exiting the building; 4    an assessment of the exposure rate levels inside the Hot Cell; and,
: 5. an assessment of the exposure levels surrounding the isolated Liquid Waste Holdup Tank room.
Document Review                        .
A review of the licensee's decontamination status report, modifying orders and scope of work (prepared by the NRC), and additional supporting documents were reviewed by ORAU.      Information submitted in these documents were compared to the previous survey results and program review performed by ORAU and to current NRC licensee requirements.
l                                       Building Survey i
Surface scans f
Beta-gamma and gamma scans were performed in locations where the ambient radiation levels were low enough to discern gross changes in instrumer.t response.      Because of elevated ambient levels, such scans were limited to unrestricted areas of the facility.            Floor surfaces were scanned using a large-area     gas-proportional detector and NaI(TI)         scintillation detectors coupled to audible indicating ratemeter/ scalers. Lower walls, ceilings, beams, ducts, and miscellaneous equipment surfaces were scanned using " pancake" CM detectors.      Locations of elevated radiation levels were noted for further evaluation.
Surface Contamination Measurements Direct measurements for total contamination and contact dose rate and smears    for removable contamination were performed at randomly selected locations on floors,      lower -walls, and miscellaneous surfaces throughout the facility.
                          ,_                                                       3

a f
At ~ many of the locations, measurements were also performed with the detector shielded against beta radiation to differentiate between the beta and gamma                          ;
contributions.
Exposure Rate Measurements Gamma exposure rates were measured throughout the facility, using primarily
   ,,   ionization    chambers     and compensated GM detectors.          Nineteen of these measurements were performed inside the Hot Gell using dedicated in cell j       monitoring instrumentation.
l l       Outdoor Survey Surface Scanning Scans were conducted throughout the AMS facility property using NaI(TI) gamma scintillation detectors coupled to racemeters with audible indicators.
Areas with elevated radiation levels were noted for further investigation.
Exposure Rate Measurements Gamma exposure rates were measured at surface contact and one meter above the- surface at 12 locations around the facility.        Exposure-rate measurements were. made with NaI(TI) detectors, cross calibrated on site with a pressurized ionization chamber. In addition, exposure rates were measured at 40 locations on the building roof, u
Soil Sampling Surface soil samples       (0 - 15 cm) were collected at 12 randomly selected locations around the AMS facility. Sampling was conducted only in areas where exposed soil surfaces were available.
                       +
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       .4 Lt.
                . Water and Sediment Sampling 4
Three -water samples _ and three sediment samples were collected from storm                             J drains located on the AMS property.
Sanitary Sewer Survey
 .,,                  In January,- 1988, elevated radiation levels and Co.60 concentrations were                            _I identified in the -main sewer line from the AMS facility. Decontamination of                                I the sewer line and associated manhole access area have reduced radiation levels. AMS maintains the manhole as a limited access area, by locking a steel ~
_ grate in place over the opening. A limited gamma scan was performed, and gamma exposure rate < measurements were performed in the manhole access area, using a Victoreen portable ' ion _ chamber.       One water and one sediment sample were collected from the open-trench area at the bottom of the manhole access site.
The- sampling. location was approximately 3 meters from the discharge point into=
the City of' Cleveland sanitary sewer system.
Sample Analyses and Interpretation of Results Samples were returned to the ORAU laboratory in Oak Ridge -TN for analyses.-
All-water, soil, and sediment samples were= analyzed by gamma spectroscopy. The radionuclides- of interest were Co 60 and Cs-137. Spectra were also reviewed.
for the~ presence of' other significant photopeaks. . Cross beta analyses was performed- on water samples- and smear samples.                         Additional information
{            concerning analytical' equipment. and procedures is presented in Appendices _C Land D.
SURVEY RESULTS Document Review A-review of the October 1988' milestone report 2 and more recent survey data, developed by_AMS, indicates that actions by the licensee have been effective in significantly reducing contamination and direct radiation levels in most areas.
Monitoring data is available for both indoor and outdoor locations.- Current
=r.                                                            5

o iI radiological information is being posted in restricted areas.                                        Progress'in implementing other recommendations is discussed in the following section
                  " RADIATION SAFETY EVALUATION".
Building Survtv
{
Surface Scans o
Scans of unrestricted aren surfaces identified only one area of definable                                                i surface contamination; this area was on the carpeting at the entrance to the Instrument Calibration Room. A small portion of the carpeting was immediately removed by AMS personnel, thereby eliminating the contamination. Elevated beta gamma levels were also noted in a duct in the Laundry / Change Room and in
   ~
the airlock; however, because of thstr proximity to restricted areas it was i
impossible to delinea*e the sources of the elevated measurements. No areas of significant surface contamination were noted in other unrestricted portions of l                 the facility.
{
Surface Contamination Measurements Non restricted areas Surface cont ..                             -
1 measurements in non-restricted areas are tabulated in Table         1. Total                       >
                                                                           ' ,n levels ranged from <710 to 2,800,000 dpm/100 cm2 on the first floc                                           .ne highest level was on an old cell window in the a
airlock.            Other locations of significant contamination on the first floor were under shelves,                          in the shower stall, and on a table top in the Laundry / Change Room.             Removable beta gamma contamination on the first floor ranged from <6 to 49 dpa/100 cm2 .
On the second floor,                                   total beta-gamma contamination ranged from <710 to 370,000 dpm/100                             cm2 . Most areas of contamination were in the Equipment Room and the entry hall to-the HEPA Filter Room; however, there were two areas above 5000 dpm/100 cm2 in the Men's Restroom. Removable contamination levels in these areas ranged from <6 to 110 dpm/100 cm2.
6

       .I I The basement also- had locations of beta gamma contamination in the Air Sampling- Room,- Isodose curve Room ,-- unoccupied room adjacent to Dry Waste Storage Area, and the hallway. Levels of total contamination ranged from <710 to 700,000 dpa/100 cm2 ; the range of removable contamination was <6 to 510 dpm/100 cm2 .
Restricted areas n
Table 2 contains the results of surface contamination measurements in restricted areas of the AMS facility.               At locations of high ambient gamma radiation,    direct measurements were influenced by this arbient radiation and should therefore be considered as only approximate values. First floor areas with highest total levels were the Isotope Shop Area (up to l
950,000 dpm/100 cm2 ), Airlock (up to 210,000 dpm/100 cm 2), Depleted Uranium           l p '"
        ~
Storage     (up   to   400,000      dpm/100    cm2 ),    and   the    Warehouse (up _to
!-                   840,000     dpm/100   cm2 ).        Removable    contamination ranged from- <6       to 2
38,000 dpm/100 cm ; highest levels were noted in the Isotope Shop Area.
In the second floor cell HEPA Filter Room the-direct measurements ranged up to    550,000    dpm/100     cm2 ,   and    the, removable       levels   ranged up to 13,000 dps/100 cm2 ,
The Dry. Waste Storage Area' contained a large number of locations with high total contamination.         Levels ranged up to 21,000,000 dpm/100 cm2 on a table top. Removable contamination ranged from <6 to 14,000 dpm/100 cm2 ,
u.
                    . Exposure Rate Measurements Exposure rates -in non-restricted areas are tabulated in Tables 3 to 5.
With ene exception of 20 mR/h_ in the- Airlock / Hallway, all exposure rate measurements' for- the first floor areas were 2.5 mR/h or less; many were less that~ 0.1 mR/h._ The highest readings on the second floor were in the Equipment Room (52 mR/h) and the entry hall to the HEPA Filter Room (8 mR/h and 6 mR/h).
As with the first floor, all other measurements were 2.5 mR/h or less with many below 0.2 mR/h.
           -                                                        7 69 9

ll l
Generally higher levels were present in non restricted areas of the basement, with exposure rates ranging from 0.6 to 11 mR/h; highest levels occurred in the
                                                                                                          )
room leading to the Dry Waste Storage Room.
Tables 6 to 8 present the exposure levels measured in restricted areas of the facility.       Highest levels measured were in the Waste Storage Area across from the front office on the first floor. The maximum exposure rate was 7 R/h;
 ,,          several other locations in this area had levels from 2 to 5 R/h. On the second floor one location in the Cell HEPA Filter Room measured 1.1 R/h. Exposure rates in the basement ranged from 4.4 to 28 mR/h.
Exposure rates measured inside the Hot Call ranged from 0.5 to > 20 R/ min at the tablotop surface and from 0.1 to 0.8 R/ min at 1 meter above the table (refer to Table 9). The radiation level on the tabletop surface exceeded the upper scale limitation of the in cell instrumentation.
Beta-Gamma Dose Rate Measurements Tables 3 to 8 also present the results of measurements of beta-gamma dose rates.      At most locations, dose rates were the same or only slightly higher than exposure rates.      Locations where substantial differences were noted were those with high levels of surface contamination.       In non restricted areas the maximum dose rate      (58 mrad /h) was measured at location 8 in the second floor Equipment- Room.      Other non restricted area locations with dose-rates above
            .10 mrad /h were in the Isodose Curve Room (18 mrad /h at location 4) and the u
unoccupied room leading to the Dry Waste Storage Area (11 mrad /h at location 2); both of these locations were on the basement floor. In restricted areas of the facility, the gamma exposure rates dominated.           The highest dose rate measured was 450 mrad /h in the Isotope Shop Area; however, no attempts were made to measure dose rates separately at some locations of high ambient gamma radiation, such as the Waste Storage Area across from the front office, e
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I II Outdoor Survey l
Surface Scanning and Exposure Rate Measurements                                          !
Camma scans indicated that most areas of the property had radiation levels in the range of 7 to 12 pR/h; this range is typical of natural background radiation levels.            Some areas of elevated radiation were detected near or
      ,,             adj acent to portions of the building which contain sources and waste material.
One of the general areas of elevated gamma levels was along the east side of the building, facing the railroad tracks. The Isotope Shop Area (ISA), the adj acent stairwell, the Dry Waste Storage Room, and the Warehouse (adjacent to the ISA Room) are located on this side of the building. These areas serve as storage facilities for contaminated materials, sources, and waste. Another area exhibiting elevated gamma levels was at the rear of the building, immediately west of the loading dock area. This is near the section of the warehouse facility, now being used to store radioactive vaste.           Exposure rates approached 1 mR/h at several of these outside locations but decreased to 1
l                     between 25 and 50 pR/h at a distance of 10 to 15 meters from the building.          No
}                     measurements, suggesting possible outdoor contamination, were noted.
On the roof of the building, exposure rates ranged from <0.1 to 38 mR/h at 1 meter above the roof surface.                The highest measurement, of 70 mR/h was measured above the Hot Cell area. Exposure rate measurements on the Roof are presented in Table 10.
Exposure rates were also measured at twelve soil sampling locations.
Results of these measurements, presented in Table 11, range from 7 to 130 R/h at contact and from 7 to 310 pR/h at 1 meter above the surface. Locations of significantly higher exposure rates at 1 meter above the surface were due to the distribution of radiation sources, stored inside the facility.
         ~
Radionuclide Concentrations in Soil Results of soil sample analyses are presented in Table 12. Concentrations of Co-60 ranged from <0.1 to 2.5 pCi/g; Cs-137 concentrations ranged from 0.1 to 2.2 pCi/g. Although co-60 levels in some samples are slightly elevated, r,
9

I lI l
they are well below the concentrations typically considered by the NRC as            1 acceptable for release to unrestricted use by the public. Levels of Cs 137 are comparable to background concentrations. No other gamma emitting radionuclides were present at levels outside the range of natural background.
Radionuclide Concentrations in Water and Sediment
   ,           Tables 13 and 14 present the radionuclide concentrations measured in samples of water and sediment from three locations in the storm sewer. No significant levelt were noted in water;         the sediment samples contained above-background concentrations of Co 60, with the highest level of 16 pCi/g occurring in sample 1 Jrom the loading dock area.
Sanitary Sewer A scan of the interior of the sanitary sewer manhole at the front of the AMS facility indicated elevated gamma radiation levels. In the bottom portion of the manhole, the general levels were 4 to 5 mR/h; the highest level obtained
.          was 20 mR/h, near the bottom of the drain line. Measurable levels of Co 60
{
t were detected in both the water (150 pCi/1) and sediment (640 pCi/g) samples collected from the sewer (see Tables 13 and 14). Concentrations of Cs-137 were below procedure detection limits.
RADIATION SAFETY EVALUATION
   .a A- meeting was held on Thursday, November 17,          1988, to discuss AMS's response to the recommendstions        summarized in the executive summary of the 1985 ORAU report 1       The meeting attendees were:     R. Jucius, AMS Radiation Safety Officer,      S. McDermott, AMS Assistant Radiation Safety Officer,
          -D. Gibbons, NRC III, and C. Murphy, ORAU. Each recommendation in the Executive Summary is listed below, along with a brief synopsis of the AMS response, and a comment, if appropriate.
r-                                               10

             -   .,         .-    -. - ~ - . - - - - . . - . -                       .      . . . - -    . - .    . . - .. .
d i 1.
Short Term Recommendations 4
Policies and Procedures 8
0  Implement the use of a i                                                                       Radiation Work Permit (RUP) system which will        '
require the Radiation Safety Officer (RS0) to authorize the work request and be present to monitor the work activity.
1 An RWP system was established by AMS (date unknown).
Comment:          The RWP procedure is generic in nature; it does not adequately t-address the                 following:
t
: a. Specify individuals authorized to survey the area to establish the conditions for use of the RUP, i
i e                              b. Provide for personnel monitoring based on time methods, rather than periodic. reading of the self reading dosimeter,
: c. Specify the frequency for health physics monitoring of the area covered by the RWP, and 4                              d. Provide an appropriately completed example.of an RWP.
i In addition, -the procedure does not require health physics surveillance during operations conducted under the RWP. Any job requiring an RWP for completion should be monitored by health physics personnel any time an entry is made into the RWP area.
The RWP procedure should be reviewed for appropriateness and completeness, and be signed and dated by the RSO.
    ~~'
O Implement           a         respiratory . protection      program consistent with NRC 3                        guidelines, r_                                                                     11 1

i ii AMS has not implemented and has no plans to implement an approved respiratory protection program. Respirators are still being utilized by AMS as an additional level of protection, but they take no credit for their use (i.e. protection factor - 0). Their current procedures require hi volume air sampling during operations, which may generate airborne contamination. Air concentration data to date indicate that the highest concentration present has not exceeded the occupational level from 10 CFR 20 Appendix B.
Comment: None Staffing and Training 0 Improve the professional health physics capabilities by augmenting the staff or providing in-depth training,      ,
AMS has added two individuals with health physics backgrounds to the 9
London Road staff.
Comment:   None O
Provide formal radiation protection training for all employees.
All AMS employees are required to participate in a '.ormal radiation protection training program.       An 8 hour refresher training program is required on an annual basis. The training program is documented.(i.e.
u date of training, proficiency exam).
Comment: None Facilities 0  Perform a complete decontamination of the Hot Cell and duct system.       This may best be performed by a professional decontamination firm.
r-                                                12 n

_ - . _ . . - . _ _ _                   _. . _ - _       . _ _ . _   _ . . ~     . . _ _ . . _ _ . . - _ _ _ . . . _    _._
J LI The Hot Cell decontamination project is ongoing and approximately 75%
,                                     complete.        Portions of the exhaust duct have been removed and replaced
                                     -with temporary =ductwork and HEPA filtration. -The remaining ductwork is.
I'                                   -embedded in concrete, and will not be removed at the present time.
i 4
                                     ' Comment: None 0
: j. g                                 Increase the single HEPA filter on the Hot Cell to a two stage series i                                     HEPA filter _ system, i
G Modifications to the HEPA filtration system must receive approval from the NRC prior to implementation.             A request for modification will be
!                                      submitted at a later date.                                                                        '
j                                      Comment: -None O
Provide improved illumination in the Hot Cell.
Burned out bulbs have been replaced.
Comment: Visibility in the Hot Cell has been significantly improved.
O Upgrade ventilation system pre-filters and holders.
No change in the system at_the present time.
Exposure rates in the cell
.                                      preclude manned. entries for maintenance work.
: 4      o n
Comment:     A redesign of the' pre-filter holder and' installation of the pre-filters- in the Hot Cell would significantly-reduce the-radioactive material _ loading on the HEPA _ filters,            and substantially reduce the exposure rates 'in the general _ vicinity of the second floor HEPA Filter
                                     ' Room as well as reduce the frequency for_ filter changeout. This
;                                      recommendation should be reviewed in conjunction with the filter redesign noted above, i
g                                                                               13

I l-0  Plug' the-basement-floor drain to minimize the discharge of radionuclides to the' sanitary sewer system.
All basement floor drains have been plugged.
Comment:      Although the floor drains have been plugged, elevated exposure ratus measured on the surface. of the plug may indicate significant contamination in the drain line buried beneath the' building.
Equipment 0   Supplement the high range instrument measurement' capabilities with an additional instrument.
     *^
The- current. instrument inventory list now includes a Teletector, 2 Eberline PIC 6's, and 2 Eberline ASP-l's with multiple probes.
Comment: None r                                        0    Install a new frisker system in the change room.
LAMS removed- the old unit, -and replaced it with a Ludlum Model 177 ratemeter with thin window pancake-GM probe; AMS has also added a frisk station in the chemistry laboratory, just off the main office. A frisk station is available in the emergency kit kept in the pump house on r=                                           Mandalay Road, and a backup unit is available in_the-Instrument Room, na
                                                                                                                                                -q
                                                                                                                                                -l Comment: None
* Redesign and install a new exhaust stack sampling system.-
_i A-new exhaust stack sampling-system was installed.
                                                 ' Comment:     -The design specifications were reviewed, based on the supplied information;     the ORAU calculated volumetric flow rate was determined to be -1.9 ft /3 min compared to the 4 ft / 3min-specified in the design.                  This p                                                                                                   14

Ii l
1 vill bias the sampling results ti..c*ds larger particle sizes, and may                                        !
result in higher line loss due to lower transport velocity.
J                 Tire Protection 0 Develop and implement a fire pre plan with the Cleveland Fire Department.
l A specific fire pre plan has not been prepared by AKJ.                     A copy of the AMS Emergency Action Procedures and supporting document > tion was provided for review.
Comment:       The document states that fire department personnel have been advised not to enter the building until AMS personnel have arrived at the site and determined the radiological conditions. Additional information in t'    ter detail is provided in the supporting documentation; however, this      ormation should be provided to the Fire Department by wri; letter,   and updated annually to reflect any changes in the procedures.
AMS should provide walk.through tour 6 of the facility for Fire Departmant personnel and should coordinate any necessary training required for emergency response on an annual basis.
O Provide automatic fire suppression systems throughout the facility (Hot cell excluded).
,                        No action.
            .6.
Comment:       The fire detection and suppression systems for the facility should be reviewod and upgraded as por the recommendations in the 1985 ORAU report.
Foorgency Planning O Review and upgrade ISP 1, Emergency Action Procedures.
O Initiate preliminary emergency action plans for all agencies listed in Section 1.4 of ISP.1.
15
     )r.
* l
{1 i n                                                                                                i The procedura has been revised. No informati(n was provided to indicate that emergency action plans hav6 been established.
Commentt    An abbreviated review of the agencies listed, produced the following results:                                                           ;
                      . Agency              Individual     Status                                     !
Contacted                                                 ,
Cleveland Police    Patrolman      No knowledge of Plan Department          Howard Cleveland Fire      N/,             Phons numbst lisced
                      , Department                         her been changed. New number ..
(216) 654 6350 Hillcrest           Kitty          The hospital has an Hospital            Gabran          emergency contingency plan for handling                          ,
potentially radioactive                    ,
accident victims. Ms.,Gabram has no knowledge of a specific arrangement related to AMS,
     - r. .
Written emergency action plans should be developed and implemented for u
* each agency listed. in ISP.1.          ISP.1 should be dated, signed, and reviewed annually to ensure that 'all information,         phone numbers, and contacts are current.
Waste Management                     ,
0  Package and dispose of the current inventory of dry waste.
I Several' shipmen.ts of waste have bean made to date; the next shipment is    !
planned after completion of the decontamination process,                     ,
16
_ -                                    ___                                                    _     i

I II I
Comment: Considerable improvement is acknowledged for this area.
O Decontaminate the dry waste storage area.
I The surface contamination levels and radiation levels in the dry waste storage area (basement) have been considerably reduced.
u.
Comment:   The levels were reduced and the surfaces were repainted. This will probably increase the level of effort for the finsi decommissioning of the facility.
O Decontaminate the liquid waste area, the batch tank, the holdin5 tank, and associated piping.       This may best be performed by a professional decontamination firm.
4 AMS proposed, and the NRC approved, the isolation of the waste holdup tank room, to allow for decay of the radioactive material to levels that would reduce exposure during decontamination. The area vill be sealed and monitored on a monthly basis.
Comment: None Long Tern Recommendations
    .         Facilities
    .a O
Redesign the illumination system in the Hot Call to facilitate remote bulb change.
This recommendation still under consideration.
Comment: Nona
* Upgrade-the remote manipulators to provide access to all areas of the Hot Coll.
17
               =    ,

4 ii AMS does n+ < consider this a feasible recommendation, basa4 u   - at.
;                comment:    The present manipulator system does not allow the operator the ability to access all areas of the cell.           Once decontamination is complete,   periodic cell cleaning would reduce the contamination levels t
and exposure rates within the cell; however, limited access may allow the l
l contaminatio. levels to become excessive in the future.
Equipment 0 Calibrat6 all portable survey instruments semiannually; repair or dispose on non repairable instrumentation.
In house calibrations are performed on low range instrumants at the
   ~
frequency specified in the license. High range instruments are sent to an outside facility for calibration.        Non repairable in=truments are 4
still on the shelf.
Comment: All non functioning instrumentation should be disposed of or removed from the shelf.
O Calibrate all rotameters semiannually.
Procedure not implemented.
Comment:     Rotameters used in the determination of offsite release of
    .4 radioactive materials should be calibrated on a semiannual basis.
Material Accountability
* Develop   a new program or modify the existing material accountability
    ~
program to include radioactive vaste as an inventory item.
Procedure not implemented, r-                                                18

, Ii l
Comment:    Vithout an accurate inventory of radioactive waste AMS cannot verify that their Co.60 license limit has not been exceeded. This procedure should be implemented.
Emergency Planning i
O Establish     written   procedures     for handling a potential radiation
  ,,                 emergency.
A written procedure " General Rules for Health Physicists and Radiological Safety Officers" has been prepared.
Comment:   This document should be reviewed and updated to reflect current industry practices (e.g. emergency action exposure limits should be specified, etc.).
Vaste Management O Redesign the holding tank to add a level gauge.
A new liquid waste heldup tank has been installed in the clean area of the basement. This tank does not have a gauge, however the tank has been designed to permit yiewing of the liquid inval in the tank.
Comment:   None t
a O
Develop contingency plans for liquid releases to the sanitary sewer system.
AMS has developed. an op1 rating procedure " Release of Liquid Vaste into, Sanitary Sewerage System", dated August 11, 1987 (Appendix D).
Comment: None 7-                                                   19 ik  dM                                           g       "-

4 l1 SUMMtJtY At the request o t~     the Nuclear Regulatory Commission, Region III, the Radiological Site Assessment Program cf ORAU conducted a survey of the Advanced Medical Systems London Road Facility, located in Cleveland, Ohio. Radiological information included direct radiation levels inside and outside of the l        building,    contamination levels on building surfaces, and concentrations of radionuclides in soil,      sediment,   and water. An assessrent of the previous survey's recommendations was also performed.
An evaluation of the current radiological conditions of the site indicated that decontamination     procedures and packs 6i ng and shipment of waste have been successful in reducing levels of contamination and direct radiation. Most contamination has been confined to restricted areas; however, several locations
   *~
of significant surface contamination were identified in non restricted areas on all   three building iloors.      Areas of contamination in restricted portions of the facility have been defined and current radiation survey information is
,         posted at their entrance.          Further reduction in exposure rates will be achieved, when additional waste is removed from the facility.
The only area in which exposure rate levels have not been reduced is in tho Hot Cell. This area is nat access!ble for entry.                            Currently on!y one of the
           .:wo manipulator arms are functioning.
The radiological conditions outside of the facility are generally within or near background ranges.-       Higher exposure rates are present at locations a
adjacent to areas of the building where sources and radioactive waste are t sin 5 stored. Soil and sediment from store drains contained above background Co-60 levels but not at sufficient concentrations to pose an environmental concern.
Levels of Co.60 in the sanitary drain have been reduced, but the diret-t radiation level is still significant, relative to NRC limits for unrestricted
     ~
areas. Access to the sanitary sewer manhole at the front of the AMS facility should be controlled, g-                                                20
                                                                 - _ - _ - - - _ _ - - - - -                         1

Ii 1
l Progress    has   been    made on    implementing many of the short term recommendations and some of the long term recommendations from the 1985 ORAU l
report. Some problems with AMS actions on these recommendations were identified.
It is ORAU's opinion that AMS has made significant improvements in the radiological safety program at the facility. Further actions will be needed to
   ,     achieve and maintain acceptable levels of contamination and direct radiation, both inside and outside the facility.         Efforts in improving the overall radiation safety program should be continued.
  ,_                                            21 s.
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                                                                                 'On_. the First Floor 23 3

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_                                                 27
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      '                                                                e uETERS FIGURE 8:    Loyout of Front Office, First Floor, Indicating Measurement Locotions 29 o.s
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                                                                                   +\
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                          ' FIGURE 9: Layout of Chemistry Laboratory, First Floor, Indicating Measurement Locations 30 I[

II AuSc3 WALL T                      -
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                                                                               'Nw I
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METERS FIGURE 10: Layout of Main Stairwell, First Floor, Indicating Measurement Locations 31
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METERS FIGURE 11: Layout of instrument Calibration Room. First Floor, Indicating Measurernent Locations i n                                               32
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HALLWAY                                                                                                                              AIRLOCK
                                                                 -                                                                                                                                  0               2 UETERS FIGURE 12: Layout of Airlock and Hailway Off instrument Calibration Room, First Floor.
Indicating Measurement Locations

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METERS FIGURE 13: Layout of Laundry Room, First Floor, Indicating Measurement Locations 34 I'
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                                                      *        $HOWER DRAIN $                                   .
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METERS FIGURE 14: Layout of Change Room and Hallway, First Floor, Indicating _ Measurement Locations 35 e--
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FIGURE 15: Layout of Stairwell at Main Entrance, Second Floor, Indicating Measurement Locations
  -r                                           36 t-

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Indicating Measurement Locations

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      -                                                    38
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FIGURE 18: Layout of Room 3, Unoccupied Office Space, Second Floor, Indicoting Measurement Locations 39 r~
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METERS FIGURE 19: Layout of Room 4, Unoccupied Office Space, Second Floor, Indicating Measurement Locations 40

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!               .                                                                                                                                     METERS FIGURE 20: Layout of Room 5, Unoccupied Office Space, Second Floor, Indicating Measurement Locations                                                                                              l
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WALL                                                                        METER 5 F:GURE 21: Layout of Equipment Room. Second Floor.
Indicating Measurement Locations

l AMS22 l
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  -                                                WALL
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FIGURE 22: Layout of Entrance to HEPA Filter Room, Second Floor, Indicating Measurement Locations 43
      -"6..

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METERS               .j FIGURE 23: Layout of Women's Restroom, Second Floor, indicating Measurement Locations 44 o,
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 !'                                       FIGURE 24: Layout of Men's Restroom, Second Floor, Indicating Measurement Locations 45
       .g.
_ _ _ . _ _ . _~                                         - ,                   ,.

              . . _ .  - _ - _ . -         _ _ _ _ . . . _ . _ . . . _ . . _ . . . .. __ _ . . . _ . , _ .                   . _._..__-_-..m..     . ,_.                 ._
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->    (I AMS18 WALL                               WALL i
;                                                                                                      I               I 1                I
                                                                                             ,2l                             WALL 1./4 HOLDING                                                                          ,
TANK 3
i WALL                                                    FLOOR                        WALL 4
1 4                                                                                                           A4 WALL MEASUREMENT LOCATIONS e    FLOOR / LOWER WALL A    OUTER ORAIN SU!! FACE d
2
                                                                                                                                +
l                                                                                                                                         4 u
O                  2 METERS a
FIGURE 25: Layout of Air Sampling Room, Basement Floor, Indicating 'Mecsurement Locations i --
      ,_                                                                                                           46
     )-

                                                                                       ~_
b 'lN h AM!17                                        ,
I l
1
                                              \\ \\ \
N.CTEEL h \\\\\\\\         SHE(V(5 o.,
WALL x\\ STEEL SHELVES N 1 4 SINK 3            SEWER               A-3 g               DRAIN WALL          2L       FLOOR          WALL il I i
                                           '.5 O I-l O I '
                                                                      , E f41ASUREMENT WALL                   LOCAT10NS
                                                                         +
N
!                                                                                    N O         2 m
METERS Lt FIGURE 26: Layout of Isodose Curve Storage Room, Basement Floor, Indicating Measurement Locations
  .".                                              47 N

11 Wsis i
Ad-
                                  " g7 I        TABLE HALLWAY           6             O
    ,,                                      **NEk t
sYtEY?NK
                                 /                  /
i l                  I       *r ,,  & a1 sw!m"aExs
* Wm 'l-                   l
    ..                      1                  1
                                                         ~~i        !
WALL
             .                                                                    MEASUREMENT LOCATIONS     !
WALL e FLOOR / LOWER WALL -
A OUTER DUCT SURFACE
                                                                                                 +
                                                                                               /
MN O          2 t=;;=a===!
METERS a
FIGURE 27: Layout of Unoccupied Room and Hallway, Basement Floor,
           ,                  Indicating Measurement Locations 48 L
i

e
    - 11
                'AM519 tv W/.LL 1
5 l                     2 l
____e   _
l                                   WALL             FLOOR                WALL
                                                                      # MEASUREMENT LOCATIONS i
A l
                                                                                 '\.
WALL                          \[-
0          2 N.
l METERS u-1 I
FIGURE 28: Layout of Main Stairwell, Basement Floor, s                                             Indicating Measurement Locations 49
     .O
    ' 4 - .m b

a
                       ,                  p,                 -
3
    +-]
:-                                             -       1 CMS 32                                                                                                                                                                        '-
6-I tY '~
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W4LL l l l 119
                                                                                              ''             '2
                      ~
Ii !l
                                  . WALL /    WALL                                                                                            e4 5
                                     ,                                               e, N           -
e5
: v.             D 18                      ,15
                                                                                                                                             #8 317                                                                          e7 10 WAu.               FLOOR                   WE                                                                                                     G IMUSUREMEM LOC 20MS
_                                                  e9 16 e           l                                                              11 WALL I
WALL q,
                                                                                                                                                                        ,g' FLOOR                                     WM
                                                                                                                                                                                 \
o            4 m
vo m; FIGURE. '29: Layout of isotope Shop Area. First Floor,                                                                                     -
Indicating Measurement Locations

f  ,1           - .
rVS37 i
1
   - , . -                                        WALL
                                              ,12 i
I                                             j l
eT3
                                                   ~*-
     ,.                                       ji           ji DOWN           UP 314 i     i WALL                FLOOR          WALL 4' MEASUREMENT LCCAT'74S 4
                                                                         +\#
WALL 0        2 METERS h
FIGURE 30: Layout of Stairwell Off Isotope Shop Area, First Floor, Indicating- Measurement Locations
         ..                                                  61

.              .. -     =
       .                                                                                      1 AMS36 l
l i
WALL l                     2h
                                                        ,2 s             q
  ..                                                I g 24 2,                 ;
23
                          , ,                       i
                    *^                                                                "^
CLEN4 ZONE          CONIAMINATEO ZCNE l
1 I
WALL s
el McAsvREMENT LOCATIONS
                                                                             +\
1                                                                      0         2 6
METERS
   >m FIGURE 31: Airlock to Isotope Shop Area, First Floor,
                                . indicating Measurement Locations 52 C

AML*5 4
1 4
RADIATION AREA
                                          .                                      ROPE BOUNDARY WALL                     /
_._ _ p __ /
a6 1       ,15 l,4     -
4
    ,.                            I ''                  .is           '' 4;l l                  .is      29           l
:                                             2,          20 l
;                                                         22        .i2
                                                               *28 23
.                                 j                                        I 24
,                                 I , .6               23                  l j.
1 j
                                        . e26             27        g3
               ,        WALL                         FLOOR                                WALL 5
9 MEASUREMENT LOCATIONS A
3:
M a                                                                              0 METERS FIGURE 32: Layout of Waste Storage Area in Main Warehouse, 1                             First Floor, Indicating Measurement Locations 53 r-4-

e
} ll AMS3's 4
WALL
                                                                                   *lI                             ,
_ _ .4 _ _ _.l .3 h      h ROPE BARRIER I
4                                        .
l CHAIN uNK FENCE X           X     X     X     X
_ WALL                     FLOOR            WALL x    y    , FENCE E
S MEASUREMENT LOCATIONS
                                                                                                  +\
N N
e w.s                                                               0         4 METERS FIGURE 33: Layout of DU Storage Area, First Floor, Indicating Measurement Locations 54 E

rr        ,     ,                                         r                             -                   -
                                                                                                                                                                                  ;- , f AMS46 1
g5 WALL                                                                                                                       witte toi to nt iI II II 93                                             MALL 9     4 1
V
                                                                                                 ,1 11 12                                                                                                                            -
O                                   3                                                                                                             2 WALL                   .-
                                                      , 10                                 ,~ -                     '
9                                               '                                             WALL e                                             -
                                                                                                ,- ' FLOOR S MEASUREuENT LOCATIONS
                     ,8                           g7         96                  - WALL A
WAL*.                                FLOOR                WALL                                                                                      \
N WALL o          2 m
METERS WALL FIGURE 34: Layout of Waste Storage Area Across from Front Office First Floor.
Indicating Measurement Locations l                                                                                                                     _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -              -_

II
                   - AMS31
(                                 f WALL l gb i                    i 8            DRuus            0 IO G                97 9
i
                                         -4 4  7 TELETHERAPY UNIT
                                                                         /l
* 16
                                         ,6           STORACE AREA %g]8 3                    ,( lV          , g.
I
                                              ,20            ,2                 f3
                                                                     ,14
                                                                                              ~
l     I
                                       #                                                               ##   MEASUREMENT LOCATIONS 5
l     I                             1/'
WALL                 . FLOOR                   %                                  4 l                                                                                          N WALL WALL O-         4 m
METERS eA FIGURE 35: Layout of Warehouse, First Floor, Indicating Measurement Locations 56                                                       l 1
k.I

O AMS2O 9
                                                                                         )
I h
                         .                                                               I WALL s
                                       /        IM HCPA Housiy
        .                                          A N
O2       #T'"~
2.
                                         " bt$
exhaust  e4 STACK                g6 D
ltAaLEe (ccNtwoal
                                                          *)
          .         WALL               FLOOR                 WALL MEASUREMENT LOCATIONS 8 FLOOR / LOWER WALL f UPPER WALL /CDLING
      ,                                 WALL
                                                                        +
bXt O           2 h
METERS u
FIGURE 36: Layout of _ HEPA Filter Room, Second Floor, Indiccting Measurement Locations 57 L.

4
  ! l l-                       AMS16-I W 17 N                  _
                                                                                                 ,          WALL 21
                                                                                                   '       N l                    'l    _
N                                 is LIQUID WASTE
                                                                                              \          HOLDUP TANK        2h*  e  20 3
9  19 N
N        =  4 NE W illlllAlllllla!
                                                                                                      ~
l 7       6    5           # 10 3g e
I
* 8        0 p
                                                                                                                            "     ,
* g uEAsUREMENT LocADONS
                                                                                                       ,t4           13     12 WALL                   FLOOR                WALL 15                       +\.
w 0         4 g                                                                                                                                     METERS FIGURE 37: Layout of Dry Waste Storage Room, Basement Floor, Indicating Measurement Locations 58 r
L,

ll. (t                                                                                    ,
AM544 t-l t
io            9
                             ,                            e.
                             .               e6           5,
                                     ,n 4        3    2          1 e          e    e
* oE MEASUREMENT LOCATIONS-
                                                                   +\
b
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0           2 METERS FIGURE 38: Hot Cell Exposure Rate Measurement Locations at Table Top Level 59 r-~
s.
                          ....g.                                             '

4 11 AMS47
  ?
                        , 10          g9               6, 7                           S e             e6                 o 4            2               1 e            e                   e e MEASUREMENT LOCATIONS
                                                                  +
O         2-m METERS t
FIGURE 39: Hot Cell Exposure Rate Measurement Locations at 1m above the Table Top p.;                                       60 6

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       +e-
    - lJ-          -
TABLE 1..
I RESULTS OF SURFACE CONTAMimTION MEASUREMENTS
* NON 3tESTRICTED AREAS' i-ADVANCED EDICAL SYSTEMS                                                                                ;
LONDON ROAD FACILITY
'                                                                             CLEVELAND, CHIO
                                                                                                                                                                          't 4
Beta-Gemme Contamination (dpm/100 em2-            3 Floor / Room                - Figure i            Location                                Total                              Removable r
so                                                                                                                                                                   ;
       ^
First Floor
                                                                                                           <1170                                -E Call Control Area                     7                    1 2 -.                                <1170                                  <6 3                                   <1170                                ---
4                                       1500                               <6
                                                                                                            <1170                               ---
5
                                                                                                            <1170                                    7 Front Office                          8                     1 2                                    <1170 3                                       1200 4                                    <1170                               --
5                                   <1170                                    6                    ,
Chemistry Lab                          9                    1                                    <1170                                  18 2                                      1200
                                                                      '3                                     <1170                               ---
4                                    <1170                               --
5                                    <1170                                 <6
                                                                                                               <710                                   6 Main Stalrwel1-                    10                       t.
2                                      <710                                 <6 Instrument
                                                                                                                <710                                <6 Calibration %om                     11                     1
                                                                      .2                                        <710                                <6                    '
3                                      <710                                <6-
    . ;r 4-                                     <710                                <6
                                                                      -5                                        <710-                               <6 6                                      <710                                 <6 7                                      <710 8                                      <710.                             -
                                                                       -9                                       <710-12                     -1 Old Hot Cell Window           2800000                                    <6
      " -Airlock /Hellway
: 2.                                    <710                                 <6 3                                     2700                                 <6 4                                     <710                                 (6
:5                                       <710                                 20                 - i
                                                                        '6                                      <710                               -
7                                      <710                              ---
64
    .p                                                                                                                                                                    ;
                                                                                                                                                                    .,y

1I TABLE 1 (Continued)
RESULTS OF SURFACE CONTAMINATION MEASUREMENTS NON-RESTRICTED AREAS ADVANCED MEDICAL SYS7 EMS LONDON ROAD FACILITY        .
CLEVELAND, OHIO Beta-Cams Contaminailon ( pm/100 cm 23 Floor / Room                 Figure #           Locat ic,n                       Total             Removaulo Airlock / Hallway                                       8                                (710              ---
(Continued)                                            9                                1100              --
10                                <710              ---
11                                <710              ---
Laundry / Change Room           13 and 14                1                               <710                   7 2                                <710                 10 3                                <710                   7 4                                1900                   8 5 Under Shelves             300000                   13 6                                <710                <6 7 Shower Stall                100000                  49 8                                1000                 10 9                                1100                <6 i                                                               10                                 1700                <6 l
11                                <710               ---
12                                  760                <6 13 Table Top                      7800               ---
14                                 1700              ---
15                                <710               --
SECOND FLOOR Main Stalrwell                      15                   1                                <710                <6 2                                <710                 15
    ,, Unoccupied Office                     16                   1                              <l170                  <6 Space Room #1                                           2                              (1170                  (6 3                                2400                 <6 4                                2700                 <6 5                              <1170                  <6 6                              <1170                    9 7                              <t170                  <6 0                              <1170                  <6 9                                1000                 <6 10                              <1170                  <6 Unoccuplod offles                   17                    1                             <t170                  <6 Space %cm #2                                            2                              <1170                  18 3                                1700                35 4                              <!170                   10 65
  /n.
ss P                          ,-

Il TABLE I (Continued)
RESULTS OF SURFACE CONTAMINATION MEASUREMENTS 410N-RESTRICTED AREAS ADVANCLO MEttlC/ L SYSTEMS LONDON ROAD FArlLITY CLEVELAND, OHIO Seta-Gamma Contamination (dpm/100 cm )
Fluor / Room                                                       Figure #         Locatlon                            Total             Removable Unoccupled Office                                                                          5                                <1110                 12 Space Room #2                                                                             6                                (1170                 <6 7                                <l170                 <6 8                                  2700                <6 9                                <l170                 <6 Unoccupied Of f tec                                                       18               1                                <1170                 <6 Space Room #3                                                                             2                                <1170                 <6 3                                   1300               <6
!          Unoccupied Office                                                         19                1                                <1170                 <6
            $ pace Room #4                                                                            2                                 <1170                 <6 3                                 <1170                   7 4                                4117U                  <6 Unoccupled Office                                                         70                1                                  <110                <6 Space Room (S                                                                             2                                   <710                <6 Equipment Room                                                            21                1                                <1170                   9 2                                  1200                  6 3                                  2000                <6 4                                <1170                  19 5                                <1170                 32 6 FIoar                          43000                  17 I                                                                                                      7                                <1170                 47 6 Wall                          3/0000                  <6
{,                                                                                                9 Flwr                           77000                110 10 Door Stoop                       6000                 <6 En9ry Hall to the                                                          22                 1                                <710                 23 HEPA Filter Room                                                                            2 Table                           9500                   6 3 Bricks                         22000                 13 4 Floor                            5100                  8 5 Floor                          16000                 <6
      -                                                                                                 6 Ocor                         130000                  <6 Wenens Restroom                                                           23                 1                                 <710                <6 2                                  <710                 10 3                                  <710                <6           d 66
    . . r, 5+

li TABLE I (0ontinued)
RESULTS OF SURFACE CONTAMiteTION MEASUREMENTS HON-RESTRICTED AREAS' ADVANCED HEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OH10 Beta-Gamma contamination (dpm/100 cm2)
Floor / Room                      Figure #           Locattor.                        Total              Removable Mens Restroisn                                   24                    1 Sink Drain                  13000                 <6 2                               (710                 <6 3 Floor                        10000                 <6 4                               3900                 <6 RASEMENT, Air Sempt ing Roan                               25                    1 under valve                 27000                 54 2                              *.710                  7 3                              <710                100 4 Drain t.Ine                300000                 <6 S                              <7 '10               35 isodose Curve Rocan                             26                   1 Above Doorknob              32000                  10 2                               <710                 10 3                               <710                   8
,                                                                                                4 Under Sink                 700000                510
}                                                                                                5                               <710                   9 l
l                          Unoccupied Office                                27                    1                              1100               130 l                               Room Leading to                                                  2                               <710                 <6 Ory Weste Storage                                                3                               <?10                   9
{                                                                                                4                               <710                   6 5 Doctwork                    16000                 49 H:l lw.sy                                        27                    6 Drain                      190000                 44
       ,_4                                                                                        7                              <710                   9 Baseaant Stalrvell.                             28                    1                              <710                 <6 2                              4710                  <6 E Dash                       Indicates measurement not perfornied, b
57 s

ll TABLE 2 RESULTS OF SURFACE CONTAMIMTION MEASUREMENTS RESTRICTED AREAS ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OH10 Beta-Gamma Contamination (dpm/100 cm )
Floor / Room     Figure i          Locetion                           Total                   Removable u.
First Floor Isotope Shop Arua   29 and 30              1                                 22000                  450 cnd Stalrwell                            2 $1nk                         450000                  38000 3 Floor                         180000                       72 4                                       -- a              140 5                                  37000                  270 6                                  70000                     17 7                                  <1170                  300 8                                      1300                  15 9                                      9000             1400 10                                   <1170          ,
                                                                                                                <6 11                                    36000               1200 12 Compact >d Waste              950000                          9 13                                    96000               1100 14                                        ~~              6400 15 Floor                         430000                     710 16                                        --                870     /
17                                        --                760 18                                       --               1200 19 Floor                         120000                       41 Airlock (Rostricted     32               20                                     <1170                220 Side)                                 21 Floor                         210000                          6 22                                     <1170                 110-23                                     <5000                   50 24                                     <1170                    50 a
Depleted Uranium         33                  1
          -Sto-age                                  2                                       ---               ---
3                                    <1700                     6
                                                                                            ...               .--      l 4
                                                                                            ---               ---      1 5
6
   --                                               7 8
9                                        - - . .
10                                                                   l t1                                         ---               ---
l 12                                        ---
l l
1 l
68
[I

                              , . _ . .         . _ - _ _ _ _ . _ . _ . _ _ . - _ . . _ - - ~ . . __ _ _ , _ . . . . _ . . . . . _ _ _ . _ _                                           _ _ . . _ _
e
,   11 4                                                                                                                                                                                                     5 TABLE 2 (Continued)
RESULTS OF SURFACE CONTAMimTION MEASUREMENTS
    +                                                                                             RESTRICTED AREAS ADVANCED MEDICAL SYSTEMS a                                                     LONDON ROAD FACILITY CLEVELAND, OHIO                                                                                  '
Beta-Gamme Contamination (dpm/100 cm23
               . Floor / Room             Figure #                                . Location                                                            Total          Removable r<
;  o-        Depleted Urontum                                                            13                                                                   --           ---
l               Storage-                                                                 14 Floor Crack                                                  300000                     6 15                                                                 5100                <6
.                                                                                        16 Floor Crack                                                  400000    ,
                                                                                                                                                                                <6 5            Wasto Storage Area             34                                              1                                                              <1170                 <6 l'            ,(across from front.                                                         2                                                               <t170                    7 offtee)-                                                                     3                                                              <l170                  13-i                                                                                           4                                                              18000                 <6                -i
     ''-                                                                                                                                                   <1700                 <6
 ,                                                                                          5 I'                                                                                                                                                            ---           --
6
!                                                                                           7 8                                                                 ---            ---
9 10                                                                   ---           ---
            .W rehouse                       35                                              1                                                              <710                  <6 2                                                               <710                   <6 3                                                                <710                   7 4                                                              14000                   <6 5                                                                <710                    7 6                                                                <710                  <6                -
7                                                                <710                  11
                                                                                          ;8                                                                 <710             --
9                                                                <710             ----
10                                                                 <710-                 <6' 11 Weste Container                                              840000                   <6 k                                                                                     12 Source Hood                                                 230000                   55 13                                                              - 4600              ---
14                                                                 1000             --
15 Source Holder                                               480000-              ----
16 Floor                                                       770000,              --
17                                                                <710              ---
16:                                                               <710          ----
a-                 ,                                                                 19'                                                               <710-              ---
20                                                                 <710               --
SECOND FLOOR Cil1._HEPA F1 Iter -             36                                              1         ~
                                                                                                                                                                --           1500 Room,                       ,
2 Under Filter-                                              550000                380 69 5 '.
                                                                                                                                              --._z.,,-s             .   - - . . .         ,

l _,I '
TABLE 2 (Continued)                                               !
RESULTS OF SURFACE CONTAMiteTION HEASLREMENTS r-,                                                       . RESTRICTED AREAS -
ADVANCED ME0lCAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OHl0 Beta-Gamme Contamination (dpm/100 em2 )
Floor / Room       Figure #          Location                          Total              Removable v.
           ' Call hem' Filter                              3 Floor Penetration           480000             13000 Room                                       4 Floor                         99000             3100                    l 5                                  ---            4100             .[
6                                  ---              ---
{
7                                  ---              ---
8                                                   ---                -
9                                  ...              ...
10                                  ---              ---
           =BASEMEKf                                                                                                          .
Dry Weste Storage        37 .                 1 Floor       ,
1100000.                110              I 2 Floor                        190000                  50 3                              <1170                  85 4-                             <1170                170 5 Floor                    10000000                 390              )
6 Floor                     3500000                 570              i 7 Floor           ,         1200000               1200 8 Floor                     5500000               3000                 ,
9                               18000             1400                  !
10                                42000               960           -r 11' Table Top               21000000              14000               .,
12 Floor                      -510000                 .420-                ;
13 Floor -                     500000                 340 14 Floor                       910000              -940               j 15          -
                                                                                            < 1170 _             .6
                                                                                                                  <                  i
  .i                                                     -16                                81000,               280 17                               71000                150 18 Door                        930000-             3600 19                             . <1170                140 20      _
                                                                                            <1170                  82-
                                                         -21 Floor-                       290000                   35
           . #Desh' Indicates u esurement not performed.
  .q
                                                                         ;70

                                                                                                                                   -                             _ ~
II TABLE 3                                                              ;
CAMM EXPOSURE PATE AND BETA ~CAMMA DOSE RATE MTASUREMENTS NON-RESTRICTED AREAS - FIRST FLOOR i
ADVANCED MEDICAL SYSTEMS                                                        !
LONDON RCAD FACILITY CLEVELAND, OHIO Canma              Beta Ganma Exposure Rate                Dose Rate
.                               Room                                          Figurn #                  Location                (mR/h)           (arad/h)
Cell Control Room                                             7                        1                    0.1             0.1 2                     0.1            0.1 3                  <0.1            <0.1 4                  <0.1            <0.1 5                  <0.1            <0.1 Front Office                                                 8                        1                     0.1            0.1 2                    0.1            0.1 3                     0.1            0.1
* 4                 <0.1            <0.1 5                     0.1            0.1 Chemistry Lab                                                 9                        1                 <0.1             <0.1
                     -                                                                                          2                    0.1            0.1 3                 <0.1             <0.1 4                    0.1            0.1 5                 <0.1             <0.1 Main Stairvell                                             10                          1                <0.1             <0.1 2                 <0.1            <0.1 Instrument Calibration 11                                                             1                 <0.1            <0.1 Room                                                                                 2                 <0.1            <0.1 3                 <0.1            (0.1 4                 <0.1            <0.1 5                 <0.1            <0.1 6                 <0.1            (0.1 7                 <0.1             <0.1             '
8                 <0.1             <0.1 9                   <0.1           <0.1 Airlock / Hallway                                          12                          1                  20             87 2                   0.5            0.5 3                   1.0             1.1 4                   1.0            1.0             l
-                                                                                                                 5                    1.6.           1.6             ;
6                    1.8            1.8             !
7                   0.5             0.5             l l
                                                                                                              -71 e
k*
l

__..___m.     . _________-.__.__.~__.__.__m.____                                                       .
                                                                                                               ..___.___..x
* l ll l
1
 ;                                                                  TABLE 3 (Continued)        ,
j
                                           - CA.tdA EXPOSURE RATE AND BETA-CAMMA DOSE RATE ttEASUREMENTS                                        .
NON-ROSTRICTED AREAS - FIRST FLOOR                                                        '
i ADVANCED HEDICAL SYSTEMS LONDON ROAD FACILIT*!
I                                                                       CLEVELAND, OHIO Gamma                Beta Gamme Exposure Rate           Dose Rate l.
Room                     Figure #                   Location      (mR/h)                (arad/h) 1,.
Airlock /Mallway                                              8           1.0                         1.0 (Continued)                                                  9           0.5                         0.5 10            2.5                         2.5 11            0.1                         0.1 Laundry / Change Room           13 and 14                      1           2.1                         2.1 l                                                                                                                                 0.6 2           0.6
]                                                                                         3           0.8                         0.8 4                                                                                         4           0.6                         1.0 5           0.4                         7.3 6           0.3                         0.3 7         <0.1                          2.4 I
8         <0.1                        <0.1 i
* 9         <0.1                        (0.1
!                                                                                       10          <0.1                        <0.1              ,
11           <0.1                       <0.1
:                                                                                       12          <0.1                        (0.1
,                                                                                        13          <0.1                         0.2 14           <0.1                       <0.1 15          <0.1                       <0.1
)
?
.                                                                                                                                                1
           ,                                                                                                                                      1 I
s l
l l
I I
l
    ~
II r.

Il TABLE 4 G VMA EXPOSURE RATE AND BETA-C#fttA DOSE RATE MEASUREMENTS NON-RESTRICTED AREAS - SECOND FLOOR                     i ADVANCED HEDICAL SYSTEMS L0h00N ROAD TACILITY                              l CLEVELAND, OHIO                                  I Gamma      Beta Gamma l                                                                              Exposure Rate Dose Rate Room                   Figure #    Location        (mR/h)     (mrod/h)
Hain Stairve11                15            1            0.1          0.1 2            0.1          0.1     1 i
Unoccupied Office Space        16           1           <0.1         <0.1      l Room #1                                   2           (0.1         <0.1      1 3             0.1         0.1      l 4             0.1         0.1 5             0.1         0.1 6             0.2         0.2 7             0.1         0.1 8           <0.1         <0.1 0             0.1         0.1      ,
10           <0.1         <0.1 Unoccupied Qtfice Space        17            1            0.1         0.1 Room #2                                    2            0.1         0.1 3            0.1         0.1 4            0.1         0.1 5            0.1         0.1 6            0.1         0.1 7            0.1         0.1 8            0.1         0.1-9           <0.1        <0.1 Unoccupied Ol'fice Space       18            1            0.1          0.1 Room #3                                    2            0.1          0.1 L                                                   3            0.1          0.1 Unoccupied Office Space         19           1            0.1          0.1 Room #4                                    2            0.1          0.1 3             0.1         0.1 4            0.1          0.1 Unoccupied Office Space         20            1            0.1         0.1
                     -       Roca #5                                     2            0.1         0.1 73 5
                                                 ,/

i i
TA!nLE 4 (Continued)
CAte% EXPOSURE RATE AMD BETA-GAMMA DOSE PATE MEASUREMENTS NON-RESTRICTED AREAS - SECOND FLOOR ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY Cl. EVE 1AND, 01110 Gamma      Beta Gamma Exposure Rate Dose Rate Room                    Fisture #     Location    (mR/h)      (mrad /h) !
l Eauipment Room                       21              1       0.1          0.1    j 2       0.1          0.1 3       0.1          0.1 4       0.4          0.4 5       0.7          0.2 6        2.0         2.7 7        1.3         1.3 8      52           58
          ~
9        1.4         2.7 10        2.2         2. 2 Entr;' llall to !! EPA              22               1      8.0          8.0 Filter Room                                   2        2.0         2. 2   l 3       2.5          2.5 4        1.4          1,5 5        1.2          1.6 6        6.0         s.0 k' omens Restroom                   23               1       0.1         0.1 2       0.1         0.1 3       0.1         0.1 Mens Restroom                        24              1       1.0          1.3 2       1.2          1.2 3       0.9          1.3 4       0.2          0.3 a
74 r--
L-v                                                         ~

ll O
TABLE 5 gam % EXPOSURE PATE AND BETA-CAte% DOSE RATE FIASURE!!ENTS NON-RESTRICTED ARFAS - BASCHEitT FLOOR a                                          ADVANCED ttEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OHIO Camma         Beta Gamma
      .                                                            Exposure Rate     Dose Rate Room              Figure #       Location        (mR/h)         (mrad /h)
L Air Sampling                25             1               2. 3            2.9 2               1.1             1.1 3               3.0             3.0 4               2.9             9.8 5               0.6             0.6 Isodose Curve Room          26             1               1.5             2. 3     l 2               1.1             1.1      l 3               0.9             0.9      l
.                                                        4               2.2            18 5               1.4             1.4 Unoccupied Room             27             1               6.6             6.6 Leading to Dry                        2              11              11 Waste Storage                         3               0.2             6.2 4                3.0             3.0     1 5                2,7             3.1
-              Ita11way                   27             6                2. 2           6.7 7                1.1             1.1 Basement Stairvell         28              1             <0.1            <0.1 2             (0.1            <0.1 hM a
    ]
3 el P                                                           75

ll TABLE 6 OAMMA EXPOS!!RE PATR AND BETA-CAMM DOSC FATE HEASifREMENTS RESTRICTED AREAS - FIRST Fl.00R ADVANCED MEDICA!. SYSTEMS LOfiDON ROAD FACILITY CLEVE1AND, OHIO Camma       Beta Gamma Exposure Rate  Dose Rate      ,
Room                Figure #       Location      (mR/h)       (mrad /h)     {
Iso' tope Shop Area      29 and 30            1           6.0           6.4 and Stairvell                            2            7.0         14 3          24            26         l 4            7.0           7.0      1 5           6.0           6.6       l 6          11            12         l 7            3.7           3.7 8            2. 4          2.4 9            5.0           5.1 10             4.4           4.4 11             4.3           4.9 12          200           220 13           35            36 14             6.0           6.0 15          440           450 16            12            12 17          21             21 18           34            34 19           16            17 Airlock (Restricted      31                20             6.0          6.0 side)                                   21             3.4           3.7 22             5.5           5.5 23             -- a          ---
24             ---           ---
Uaste Storage Area       32                   1           0.3           --
Warehouse (Main)                           2           0.7           ---
3           0.4           ---
4          12             ---
5          13              ---
6            1.6           ---
7           O.4            --
8           0.3            ---
9            2.5           ---
10             1.3           ---
11             1.5           ---
12             6.5            ---
13             2.8            --
14             0.1            ---
15            0.3            ---
76 e-6

O TABLE 6 (Continued)
CAMMA EXPOSURE RATE AND BETA-CAMMA DOSE NATE MEASUREMENTS RESTRICTED AREAS - FIRST FLOOR ADVA:lCED MEDICAL SYSTEMS LONDON ROAD FACILITY
!                                                                           CLEVE1AND, OHIn Gamma      Beta Gamma Exposure Rate Dose Rate Room               Figure #         Location      (mR/h)     (mrad /h)
!                               Waste Storage Area                                    15            0.3          ---
Warehouse (Main)                              16            1.7          ---
(Continued)                            17            3.2          ---
18            0.7          ---
1 19           12            ---
I                                                                                     20          69             ---
l 21          56             ---
22          84             ---
23            6.0          ---
i 24           13            ---
25           30             ---
26            7.0          ---             !
27           9.0           ---
28          20             ---
29          22             ---
30            6.0          --
31          52             ---
Depleted Uranium                  33                 1           0.1           ---
Storage                                     2           0.1           ---
3           0.1           0.1 4           0.1           ---
5           0.2           ---
6         <0.1            ---
7           0.1           ---
8           0.3            --
a                                                                    9         <0.1             ---
10           0.1            ---
11           0.2            ---
12          <0.1            ---
13          <0.1            ---
14           -              ---
15           ---            ---
16           --              - - -
c.
Vaste Storage Area              34                  1           1.2            1,2 (across from front                           2       100           100 office)                                   3'      500          500 r,                                                                77 4'

1 TABLE 6 (Continued)
GAMMA EXPOSURE RATE AND BETA-CAMMA DOSE PATE MEASUREMENTS RESTRICTED ARTAS - FIRST FLOOR ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVE1AND. OHIO Gamma     Beta Canna Exposure Rate Dose Kate  j Room                 Figure #       Location       (mR/h)    (mrad /h) l Waste Storage Area                          4         350         35 0 l                                                  (Main) (Continued)                         $         160         160 l                                                                                             6       3000                --
7       5000             --
l l                                                                                             8       7000             ---
I                                                                                             9       2000             --
!                                                                                            10        3000            ---
l 11        2000            ---
12        2000            ---
                        ~
1 Warehouse                   35               1           0.2         0.2     l 2           2.0          2.0 3           1.4          1.4 4           1.8          2.1 5           1.1          1.1 6           1.6          1.6 7           1.8          1.8 8           1.0           1.0 l                                                                                            9           1.0           1.0 10            1.0          1.0 11          24          43 12          13           18 13            1.0          1.1 14           0.2           0.2 15           6.0         17 16          16           34
                          ,a                                                                  17            2.0           2.0 18          57           57 19            2.0           2.0 20            1.0           1.0 aMeasurement not performed.
78 C

I1 l
TABLE 7 GAMMA EXPOSL'RE RATE AND BETA-GAMMA DOSE RATE MEASUREMENTS RESTRICTED AREAS - SECOND FLOOR i                                        ADVANCED MEDICAL SYSTEMS l                                           LONDON ROAD FACILITY I                                              CLEVELAND, OHIO l
l Gamma            Beta-Camma
   ,                                                    Exposure Rate '      Dose Rate Rooma           Location                (mR/h)            (mrad /h)
Cell HEPA Filter        1                      20                 20     ,
2                      95               100 3                   1100               1100 4                      40                 42 5                      40                 40 6                      25               -- b       ,
7                     130               ---
8                      55               ---        l 9                     450               ---
10                      45               ---
aRefer to Figure 36 .
hDash indientes measurement not performed.
   *h
    ,_                                                   79 t-

TABLE 8
                                                                                                      )
CAMMA EXPOSURE RATE AND BETA-CAMMA DOSE RATE M?ASUREMENTS RF9TRICTED ARFAS - BASEMENT FLOOR ADVANCED !!FDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OHIO                          ,
l Camma          Beta-Gema i
  ,,                                                                 Exposure Rate       Dose Rate Rooma             Location              (mR/h)           (mrad /h)
Dry Waste Storage          1                 18                 36 2                  25                 28 3                  14                13
(                                                      4                    9.0               9.0
;                                                      5                   15                32 6                  21                 79
,                                                      7                   27                46 8                   27              120 9                   13                13 10                    6.2               6.9 11                   23               370 12                    4.4              13 13                   14                22 14                    7.5              23 15                   14                14 16                   27                28 17                   21                22 18                    5.5              21 19                   11                11 20                   16                16 21                   18                23 aRefer to Figure 37.
: r.                                                                80 6

e 4
1ABLE 9 GAMMA EXPOSURE PATE MEASUREMENTS IN THE 110T CELL ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OHIO Exposure Ratch (R/ min)
Location 8                      Tabletop Level      1 m above Tabletop 1                                  0.8                   0.1 2                                  1.9                   0.5
  ..               3                                  0.5                   0.3 4                                  0.5                    -c 5                                  2.9                   0.7 6                                  3.8                   0.7 7                                  0.9                   0.4 8                                  0.8                   0.8 9                                  0.9                   0,5 10                                  06                    0.5 11                                 20 5                    -
aRefer to Figures 38 and 39.
bExposure Rates measured with Victoreen Model 550-6.
cDash indicates neasurements not collected.
dExceeds measurement limitation of instrumentation.
   .a 81 4

4' TABLE 10 CAMMA - EXPOSURE RATE MEASUREMENTS ON THE ROOF ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OH10 Exposure Rate (mR/hr)
Locationa Contact          I meter    l l
1                                                     <0.1      '
2                                                       0.3
                       ,,               3                                                       2.9 4                                                       0.4 5                                                      <0.1 6                                                     <0.1 7                                                       3.9 8                                                       4.5 9                                                       5.5 10                                                      11 11                                       70             38 12                                                       0.1 i                                      13                                                       0.4   ,
14                                                      <0.1 15 (approx. 5 m from stack)                               2.0 16                                                      <0.1 17                                                       0.3 18                                                      <0.1 19                                                      <0.1 20                                                      <0.1 21                                                      <0.1 22                                                      <0.1 23                                                      <0.1 24                                                      <0.1 25                                                      <0.1 26                                                      <0.1 27                                                        0.4 28                                                        1.2 29                                                      <0.1 30                                                        1.2 31                                                        0.9 32                                                        0.5 33                                                        0.4 34                                                        2.9 35                                                        0.4 36                                                        0.2 37                                                      <0.1
                            -          38                                                      <0.1 39                                                      <0.1 40                                                      <0.1 aRefer to Figure 40c 82

0
                                  'iABLE 11 OUTDOOR GW1A EXPOSURE RATES ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVE!AND, 06110 Exposure Rate (pR/h)
Locationa                    Contact       Im 1                            72        310 2                            18          18 ,
3                            16          18 4                            26          37 5                           134         310 6                            21          26 7                            14          14 8                            11          11 9                             9           9 10                            10          10 11                             7           8 12                             7           7 aRefer to Figure 41.
l
.. d 83 t --

i!
TABLE 12 RADIONUCLIDE CONCENTRATIONS IN SURFACE SOIL ADVANCED HEDICAL SYSTEMS LONDON ROAD FACILITY CLF? ELAND, ORIO l
                                                                                , Radionue11de Concentrations (pC1/g)          ,
Sample No.                 Locationa                              Co-60            Cs-137 1              Entrance Door on East                          2.2 1 0.lb      2.2 1 0.1
               ...                          Side of Building 2
Approximately 7m from                          0.1 1 0.1       0.3 1 0.1                  ;
the East Side of the Building on Old RR Tracks 3              Approximately 13 South                         0.31.0.1.       0.2 1 0.1 (from North Corner of Building) 10 m East 4             21 m South (from North-                        2.5 A 0.1       0.4 1 0.1                  ;
east Corner of Building 5 m East 5             North of Drain on East                            (0.1          0.1 1 0.1 Side of Building 6             6 m East of Building 41 m                         (0.1          0.3 1 0.1 South (from NE Corner                      -
of Building) 7             Approximately 52 m South                        1.3 1 0.1       0.4 1 0.1 (from NE Corner of Building) 5 m East 8              2.5 m North from SE Corner                     2.3 1 0.1       0.4 1 0.1
                                            - vf Building, Against I
                 ,a                           the Wall 9             At NE Corner of Buidling                          <0.1         0.5 1 0.1 10             Uest Side of Sidewalk                           0.6 1 0.1       0.5 1 0.1 at the Main Entrance Door to the Facility
                  --        11              In Shrub. Bed at Uest                          0.2 1 0.1        0.8 1 0.1 Side of Concrete - Driveway 4
84 eA

e ll TABLE 12 (Continued)
RADIONilCLIDE CONCENTRATIONS IN SURFACE SOIL ADVANCED PIEDICAL SYSTEMS LONDON ROAD FACII.1TY CLEVELAND, OH!O 1
Radinnuclide Concentrations (nCi/c)
Sample No.           Locationa                     Co-60             Cs-137 12           NW Corner of Ruiiding                 <0.1          0.3 1 0.1   1
   ,,                     at the Fence Corner                                           l l
Nearest to the Sidewalk 1
aRefer to Figure 41.
I         hUncertainties represent the 95% confidence levels. hased only on counting statistiest additional laboratory uncertainties of i 6 to 10% have not been l          propagated into these data.
t e
W
     -                                                 8.5 t

4 l1 TAELE 13 RADIONUCLIOE CONCENTRATIONS IN WATER ADVAr;ED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELAND, OHIO
                                                                                                  )
Sample                                              Radionuclide Concent rations (001/1)
Number         Locationa                 Gross Beta              Co-60            Cs-137 i    Storm Drain at                  10.1 i 1.3h          },1 g n,9          (n,g Loading Dock 2    Storm Drain at                   3.7 i 1.0           3.4 1 0.9        0.9 i 0.9 Loading Dock Inset 3    Storm Drain                      2.4 i 1.0           2.5 1   0.4        <0.1 approximately 18m North from SE corner
  -                of Muilding 4   Locked Sanitary Sewer          120   i 10          150    i 10          <2.7 Drain in Front of the
          .        AMS Facility, Near l
NE Corner aRefer to Figure 42.
hUncertainties represent the 95% confidence levels, based only on counting statistics; additional laboratory uncertainties of 16 to 10% have not been these data.
N v.
p-                                                     86 n-

s (l
TABLE 14 RADIONLCLIDE C0tCENTRATIONS IN SEniMENT ADVANCED MEDICAL SYSTEMS LONDON ROAD FACILITY CLEVELA!;D OHIO 7adionuelf de Concentrationn (pCf /c)
                                                             ~~                               '
l             Sample No.            Location 8                      Co-60             Cs-137 i            Storm Drain at                     16.0 1 0.4h        0.6 1 0.1 Loading Dock 2            Storm Orain at                      2.51 0.1          0.4 1 0.1 Loading Dock Inset 3            Storm Drain                         1.4 1 0.1         0.2 1 0.1 Approximately 18m North f rom SE Csrner
       -                        of Building 4            Locked Sanitary Sewer             640    i 10           <1.6 Drain in Front of the
            .                   AMS Facility, Near NE Corner aRefer to Figure 42.
ht incertainties represent the 95% confidence levels, based only on counting statistics; additional laboratory uncertainties of i 6 to 10%
have not been propagated into these data.
        .s
      --                                                    87

6 if REFERENCES
: 1. " Evaluation of the Operational Radiation Safety and Fire l'rotection Programs of the Advanced Medical Systems, Inc. , London Road Facility, Clevoland, Ohio," Oak Ridge Associated Universities, December, 1985.
: 2. " Milestone Report, Docket w30 16055, License # 34 19089 01," Advanced Medical Systems, October 12, 1988.
f 4
e f
64 e
a a 88

I il
(
l l
l l
APPENDIX A 11RC SCOPE OF VORK t
e4 a.

    . 11/10/68      at:14         mi1E F ,1t41 14                  s .,. we.    %.
IbV10'89i4Ile                         NRC REGION 3B                 PO4 k                  NtfCLEAR es0VLATCRV c0MMitel0N i
R 5010N lli i                                                   ,....
      %                                   eksN . % yNelLLINots $3131 liOV10tW                                   I MEMORANDL'M FOR: Leland C. Rouse, Chief, Full Cycle Safety Branch, NKIS FROM Bruce Safety5.Branch, Mallett, Region !!!Ph.D., Chief, Nuclear Materials
           $UBJECT:          REQUEST FOR TECHNICAL A33!$TANCE Enclosed pleese find a task desc1'iption for the use of Oak Ridge Associated Universities' (0RAU) staff to perfom confimatory surveys at the Advanced Medical Systems (AMS) facility in Cleveland, Ohio. This description is for one of the Items we specified earlier to ycu this year for placement on the ORAU contract. We have tentatively scheduled with ORAU to perfom the survey the week of November 14, 1988 If you have any questi'onc, planco contact me or Darrel Wieder.an of my staff.
MA%
Bruce 5. Mellett, Ph.D., Chief Nuclear Meterials 5afety Branch

==Enclosure:==
As stated ec w/ enclosure:
R. 5. Provencher HMS$
C.E.More11us,k!!!
D. 6. Wiedeman, Rl!!
R. E. Burgini R!!!                                        .
  .a e
A-1

      , ........          . :. . . .        e.+   . . . ..                 . . . . . .
g;                      313 790 5&&E
                    .                                                                                           i t
inLMALAL AWA JI ANOC FOR SAPNUAL64 MC&A INSPECTIONS AT FUEL FACILITIES _                 --
EXHit!T 1. 1642 REQUEST FOR TECHNICAL A5515TANCE (RFTA)            ,
2NSPECTOR's NAME Robert E. 'surgin DATE OF REQUEST )0/31/88 REGION 'III               IAANCH'I'i8            AS$!$TANCE b lETION DATE 11/18/88 MATURE AND EXTENT OF ASSISTANCE:
Recusat is for professional assistaneet by Oak Ridge Associated Universities
     ,             to perform a radiological site assensatant and confirmatory surveys of Advanced Medical Systems' teletherapy source fa.brication facility on London Road in Cleveland. Chio.
             ' JUSTIFICATION!
TI 2800/14                                                           .
4 days with Glen Murphy supervising 3 tsche = 16 man / days ESTIMATES OF TIME: 4 days                 AND' COST: 5 15.000
                 ............................................. .........c...................
IF ASSISTANCE RESULT 5 ARE PROPRIETARY STATE WHYr u
AUTHORIZATION:             sw                                           //   /[
Reg'onal Branch Chief                             Date APPROVIO:                      <
                                                                         ~
IE Froject officer                          Date
/
* COMENT51 b
A-2

      ,     u,2 o,a          teo4           -n e w u.                        - - *              --
8IdVis'SS141is                                 NRC REGION 3B              PB3
            .                                                                                                           \
l TA$K DESCR!PTION
: 1.      Facility: Advanced Medict) $yttamA 1020 London Road j
Cleveland, Ohio License Naber 34 19089-01                                                            l Docket Number 030 15055
}  ,           2. Contacts:
i                                  Richard5.B.Nellett Bruce Provencher NMS$ (FT5 492 0690)                                         i I
Darrel S. Wiedema,n, R!!(! FFisRIII FT3 388 5512).
                                                                                    ~
                                                                                                                     -H 348-6516)
Robert E. Burgin, R!!! (F95 384-5622)
: 3.      Site Identification            e      4 4
Advanced Medical systems Inc.                  at 1020 London Road is located inanindustrial/cocidenbalare(AMS),      a of          Cleveland, Ohio,anc,occupiesthe 19tmer Picket Cnhalt Teletherapy faellity.
AMS occupies three floors on the southeastern end of a large warehouse /
manufacturing butidin3 The main floor includes an office area, an isotope shop area a a t cell
            .        miscellaneous unoc,cupied areas,.           a shie'ided The  basementwork       room, includes   drya and storage liquidarea and waste space. storage     facilities, airsamplin!1equipmentandotherunoccupied The second  floor includes add       tional office space (unoccupiec),
exhaust ventilation equipment room and a mechanical equipment room.
                    -AMS occupies approximately 255(21,,000 ftt)ofthetotalbuildingspace (approxim4tely 45,000 fts),
AMs is licensed by the NRC to possess up to 300 kCi of Co-60, 40 kCi of Cs-137 and 9,000 pounds of depleted uranium. License number 34 19089-01 authorizes AMS to zerform research development, and processing of to install dismantle, sources for distrisution to authorlted recipients;leth service and maintain Picker Corporation and AMS te Picker radiography units to remove, install or exchance sources n
    "                Picker Corporation, AMS i;nc. , and Keleket Barnes teletfierapy equipment; 49 daytlop and demonstrate equipment containing sealed sources; and te leak test sealed sources installed in Picker Corporation and AMS, Inc.
devices.
: 4. General Work Reevirement
* The Radielegical Site Assessment Program of Oak Ridge Associated
     ~               Universitian (0RAU) will conduct a radiological site assessment and confirmatory surveys of Advanced Medical Systems London Road facility in Cleveland, Ohio. The confirmatory surveys are required to assure that AMS has complied with conditions of an October 30, 1987 Confirmatory Order Modifying License (Order) which required that the London Road facility be decontaminated and modified as specified in the order.
A-3 C

N K U n c.s w n s o     tv yV 10 '(~8 tot 09 Yhe surveys should include:
: 4. Ares exposure readings and an'insessaient of the levels of fixed and i reecvable contamination in are,ts used by MS within the building,
: b. An assessment, of the contamination in the sewer or drain lines exiting the building for unrestricted areas including the manhole where contamination was identified by MS in 1984.
: c. ' An assessment of the exposure readings ir. side the hot cell and surrounding the isolated WUT roos.
    .          d. Followup to creas identified as hazards in a 1980 survey performed
    "                                                                                     i by ORAU.
: 5. Responsjbility/ Schedule / Costs
: s. Work described in this* task order shall be performed under the i
l supervision of Mr. Glen Murphy, ORAU.
bi    See atta:had Technical Assistanco Request form for schedvir and estimated cosa.
L r
LJ 2
y                                             A-4 t

11 i
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4 1
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l                                                                       APPEND 1X B RADIATION CilARACTERIZATION SURVEY PIAN 4
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Il RA.DIATION CHARACTER 1ZATION SURVEY PIAN FOR                                        l ADVANCED HEDICAL SYSTEMS C1.EVEIAND, 01110 I
J         1. SITE INFORMATION Advanced Medical Systems                      (AMS),   is located at 1020 London Road, in an industrial / residential area of Cleveland, Ohio.                        AMS nanufactures and fabricates ooaled sources of Cobalt +60 and Cesium 137 for teletherapy and radiography machines. AMS is authorized to possess up to 300 kC1 Co 60 in any form for re. search and development and manufacture of sealed sources.
Aits is authorized to possess Co 60 and Cs 137 as sealed sources during removal, replacertent or exchange of taletherapy or radiography sources.
AMS occupies an area within a large warehcuse type building, and an affiliated structure which houses the radioactive materials handling area.
The facility consists of - a main floor which houses an office area, an isotope shop area,             a llot Cell,             an instrument calibration facility, a shielded work room, and other miscellaneous storage areas for radioactive waste       and source housing storage.                      The basement houses an active radioactive liquid hold up tank, and.an inactive radioactive liquid holdup system.        The second floor contains additional unoccupied office space, a mechanical equipment room, and a shielded llEPA filter / ventilation room.
The llot cell support facilities includes continuous radiation stact monitoring,            cell    temperature monitoring, ventilation controls, llEPA filtration system, stack air sampling system, and other features.
II. PUREOSE The purpose of the survey Is:
: 1) to characterize the levels of fixed and removable contamination within the building; B-1 4

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: 2) to assess the contamination in the sewer or drain lines leaving tho building to unrestricted areas;
: 3) to assess the exposure rate readings inside the Hot cell, and the area surrounding the inactive radioactive liquid holdup systew; and,
: 4) to review and assess the implementation of recommendations from the 1985 radiation safety evaluation, performed by ORAU.1 III. RESPONSIBILITY                                                                   I Work     described in this survey plan will be performed under the             I supervision of Mr. J. D. Berger, Program Manager, and Mr. G. L. Murphy, l                    Assistant Program Manager, for the Manpower Education, Research, and Training Division, of Oak Ridge Associated Universities (ORAU).
IV. SURVEY PROCEDURES Document Review Current survey results supplied by AMS will be reviewed and compared with survey data generated by ORAU. Other pertinent documentation developed in support of the decontamination plan will be reviewed.
Cridding No grids vill be installed inside or outside the building.      All survey information    will be referenced to pertinent building features or landmarks.
A. Outdoor Survey
: 1. Surface Scanning Walkover surface scans of the area outside the building but within the fenced area, and the area outside the building bounded by London "d- 2
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VI Road, will bn surface neanned by Nal(T1) detectors coupled to ratemeters    with     audible indicators. Elevated areas will be identified for additional measurement and sampling. In areas where radiation    levels     from the facility exceed the range of the scintillation detectors,      compensated GM detectors will be used for scanning.
: 2. Exposure Rate Measurements
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Camma exposute rates will be measured at the surface contact and one meter above the surface at a ninimum of eight locations around the l                  facility.      The exposure rate measurements will be made with either NaI(T1) detectors or compensated CM detectors cross calibrated onsite with a high pressure ionization chamber (PIC), or a portable ion        !
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: 3. Dose Rate Measurements 4
                   .; minimum of     ei &ht dose rate measurements will be made with a thin window CM detector coupled to a scaler. Measurements will be made with and without an aluminum absorber, and calculated to approximate the dose at one centimeter through 7 ag/cm2 ,
4  Soil Sampling A minimum of eight surface soil samples (0 15 cm) will be collected at random locations around the AMS facility. Soil samples will also be collected at locations of elevated radiation levels.
: 5. Water Sampling Water samples will be collected from storm drains, sewer drains, and other areas identified as the survey progresses.
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: 6. Sediment Sampling
                 -Sediment samples will be collected at each water sampling location, if available.
: 7. Sewer Sampling p,
Contamination has been identified at the exit of the main sewer line i
from the facility.      This area will be surveyed for expos-te rates, surface contamination, sediment campling (if available), and water sampling (if available). Also the area will be reviewed in terms of restricted access, and proper posting and labeling.
: 8. Miscellaneous Sampling a,
other sampling techniques may be added to the survey plan based on results as the survey progresses.
B. Facility Survey
_ . 1. Surface Scanning
                 ' Surface scans will be performed on 100% of the accessible floor areas within the AMf: identified restricted areas. Surface scans will be performed using a Ludium large area detector (600 cm2 ) coupled to a
 ,                   4dlue Model 2220 ratemeter/scalor. Random surface scans will be forformed in the non restricted areas.
Lower     walls   (up   to   2 meters), uppers walls, ceilings, and miscellaneous work surfaces in both the restricted and non restricted areas will :be randomly scanned. Particular attention will be given to _ piping, ledges, ductwork, cracks, counter tops, and other areas where material would be likely to accumulate.
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ll l 2._  Surface Contamination Measurements The        facility             has     been         divided       into       two     areas
                   -(restricted /non restricted) by the licenree based on the probability of -renovable contamination or the porisibility of external exposure.                            1 1
The restricted areas are identified as follows:                                                  !
baseme'0: -        . Inactive dry waste storage room, inactive liquid waste 4..                                handling systems, active liquid waste handlin5 system; I                   first floor;          airlock,. isotope shop area (ISA), decon room, Hot Cell,      ISA stairwell, storage warehouse,_ interim vaste storage room, deplet.ed uranium storage area; and, j                   second floor: cell /ISA exhaust fi?tter room.                                                   o A. minimum of 200 single point beta gamma contemination measurementk                             I will. be performed in the facility, using a thin window CM pancake detector' coupled to a scaler.                     At eacn locatica,           a smear for removable contamination will also be collected.
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: 3. Exposure Pate Measurements i
Gamma exposure- race measurements will be. performed at a minimum of 100      locations throughout .the facility.                        The exposure rate measurements will be performed using either NaI(T1) or compensated GM detectors cross calibrated onsite with a PIC.- For high exponare rate areas,     an ion chamber (Victoreen 450 or Keithley 36100) or an Automess Teletector will be used.
[}             Equipment is not available for exposure rate measurements in the Hot
                   -Cell; however exposure rate measurements can be performed by AMS and' observed        by ORAU.            ORAU will verify the calibration of the-measurement instrument.
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: 4. ~ Roof. Survey 1
4 Gamma exposure rates will be measured at a minimum of 30 locations on the r'oof, using a Keithley 36100 or a victoreen 450 ton chamber.                     The
                                                  . measurements will be made' at 1 meter from the surface 'and at contact at the maximum reading location.
j-                             V .= -  ANALYSIS AND INTERPR. ETAT 7,0N OF RESULTS n.
;                                      Samples and data will be: returned to ORAU, Oak Ridge, TN for analysis and l '-
                                      . interpretation of results.
VI.    : SCHEDULE l                                                            Survey                        -November 14 -.18, 1988 y
                                                          -Data Analysis                     December 15, 1988 Draft Report                    January 30, 1989 i
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APPENDIX C i
l                       HAJOR SAMPI.ING AND ANALYTICAL EQUIPMENT l
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i APPENDIX C Major Sampling and Analytical Equipment The display or description of a specific product is not to be construed as  i an endorsement of that product or its manufacturer by the authors or their employer.
A. Direct Radiation Measurements Eberline RASCAL Portable Scaler /Ratemeter Model PRS-1 (Eberline, Santa Fe, NM)
Eberline PRM 6 Portable Ratemeter (Eberline, Santa Fe, NM)
Eberline Beta Camma " Pancake" Detector Model HP-260 (Eberline, Santa Fe, NM)
Teletector Model 6112B
                 ',Eberline, Santa Fe, NM)
Ludlum Alpha-Beta Floor Monitor.
Model 239-1 (Ludlum, Sweetwater. TX)
Ludlum Ratemeter-Scaler Model 2220 (Ludlum, Sweetwater, TX)
Keichley Ionization Chamber 3      Model 36100 (Keithley, Cleveland, OH)
Reuter-Stokes Pressurized Ionization Chamber Model RSS-Ill (Reuter-Stokes, Cleveland, OH)
Eberline compensated C-M Detector Model HP 270 (Eberline, Santa Fe, NM)
Victoreen Ionization Chamber Model 450 (Victormen, Cleveland, OH)
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Victoreen NaI Scintillation Detector Model 489 55' (Victoreen, Cleveland,-OH)
B.. Laboratory Analyses EG&G ORTEC High Purity Germanium Detector Model GKX-23195 S, 23% efficiency (EG&G ORIEC, Oak Ridge, TN)
Used in conjunction with:
   ...             Lead Shield, G-16 (Gamma Products Inc., Palos Hills, IL)
High Purity Germanium Coaxial Well Detector Model GVL 110210-PWS-S, 23% efficiency (EC&G ORTEC, Oak Ridge, TN)
Used in conjunction with:
Lead Shield Model G-16 (Applied Physical Technology, Atlanta, CA)
Nuclear Data Mul'tichannel Analyzer ND-66/ND 680 System (Nuclear Data, Inc., Schaumburg, IL) i Low Background Alpha Beta Counter Model LB-5110 (Tennelec, Oak Ridge, TN)                                     ;
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l APPENDIX D MEASUREMENT AND ANALYTICAL PROCEDURES u
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I APPENDIX D
                                                                -Measurement and Analytical Procedures Surface Scans surface scans in the facility were performed by passing the probes slowly over the surface.                        The distance between the probes and the surface was maintained at a minimum - nominally about 1 cm. Identification of elevated levels was based on increases in the audible signal from the recording or
;                          indicating instrument.                       Bets scans of large surface areas on the. floor of the
!                          facility were accomplished by use of a Sas proportional floor monitor, with a
                          -600 cm 2                 sensitive crea.            The instrument was slowly moved in a systematic pattern to cover 100% of the accessible area. Combinations of detectors and instrument for the scans were:
I                                Beta Gamaa - Pancake GM probe with PRM 6 ratameter.
Beta Gamma -Pe.ncake GM probe with PRS-1 scaler /ratemeter.
                       -         Gamma                      - Na2 scintillation detector (3.2 cm x 3.8 cm crystal) with prs-i ratemeter.
Beta                      - Gas Proportional Floor Monitor with Ludlum Model 2220 scaler /ratameter Exposure Rate Measurements Measurements of low level gamma exposure rates were performed using Eberline Model PRM-6 portable ratemeters with Victoreen Mo, del 489-55 gamma Lt scintillation probes, containing 3.2 cm x 3.8 cm NaI(TI) scintillation probes.
Count rates were converted to exposure rates ( R/h) by onsite cross-calibration with a Reuter-Stokes Model RSS-111 pressurized ionization chamber-(PIC).
Gamma exposure -rate measurements for moderate radiation intensity fields were performed using the 'Victoreen Model' 450 or the Keithley Model 36100
_.          loni=ation chambers.                       A compensated GM- detector was also t. sed to measure exposure rates =in low to moderate intensity fields. The teletector was used in high radiation fields.
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4 II Beta-Camma Dose Rate Heasuroments Measurements of direct beta gamma radiation levels were performed using Eberline Model PRS-1 portable scaler /ratemeters with Model HP 260 thin window
          " pancake" CH detectors. Dose rates were calculated by applying the conversion factor of 1400 cpm / mrad /h to the net count rate.                              j l
   ,,     Surface Contamination Measurements Measurements of total beta gamma contamination levels were performed using Eberline Model PRS 1 portable scaler /ratemeters with Model HP 260 thin-window
          " pancake" CM probes. Count rates (cpm) were converted to disintegration rates 2
(dpm/100 cm ) by dividing the net rate by the 4 w efficiency and correcting for the active area of the detector. Effective window area for the GM detectors is l               2 15 cm ; the average background count rate was approximately 40 cpm.
l Removable Contamination Measurements Smear measurements were performed on numbered filter paper disks, 47 mm in diameter. Smears were sealed in labeled envelopes with the locations and other pertinent information recorded.        The smears were returned to Oak Ridge and evaluated using a low-background alpha-beta proportional system.
Soil and Sediment Sample Analysis
   .a           Soil and sediment samples were dried, mixed, and a portion placed in a 0.5 1 Marinelli beaker.        The quantity placed in each beaker was chosen to reproduce the calibrated counting geometry and ranged from 600 to 800 g soil.
Net. soil weights were determined and the samples counted using solid state germanium detectors coupled to a Nuclear Data Model ND-680 pulse height analyzer    system. Background and Compton stripping, peak search, peak identification, and concentration calculations were performed using the r                                                D-2 6

9 lil computer capabilities inher*.nt in the analyzer system. Energy peaks reviewed for determination of Co 60 soil concentrations were 1173 kV and 1332 kV; Cs 137 levels were determined from the 662 kV peak.        Spectra were also reviewed for the presence of other radionuclides at concentrations above those normally encountered in environmental media.
Water Sample Analysis u.
Cross Beta Water samples were rough-filtered through Whatman No. 2 filter paper.
!                                   Remaining suspended solids were removed by subsequent filtration through 0.45 pm membrane filters. The filtrate was acidified by addition of 10 ml of concentrated nitric acid.        A known volume of each sample was evaporated to dryness   and    counted    for   gross beta using a Tennelec Model LB-5110 low-background proportional counter.
camma Spectrometry Water samples were placed into 3.5 liter Marinelli beakers. Gamma spectrometry was performed usin6 the same general counting procedures as described for soil samples.
Uncertainties and Detection Limits
     ,                                     The uncertainties associated with the analytical data presented in the tables of this report,       represent the 954 confidence levels for that data.
These uncertainties were calculated based on both the gross sample count levels and the associated background count levels. When the net sample count was less than the 954 statistical deviation of the background count,             the sample concent, ration was reported as less than the detection capabilities of the
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measurement procedure.       Because of variations in background levels, sample volumes- or weights, measurement efficiencies, and Compton contributions from other radionuclides in samples,       the detection limits differ from sample to D-3

I1 sample and instrument to instrument. Additional uncertainties of i 6 to 104, associated with sampling and laboratory procedures, have not been propagated into the data presented in this report.
l The uncertainty associated with survey instrument measurements, based on the reproducibility of the instrument response to a check source is less than 1 104       However, an uncertainty of i 10 to 20% is considered typical for most portable instrument applications, based on count rate displays.
Calibration and Quality Assurance Laboratory and field survey procedures are documented in manuals developed specifically for the Oak Ridge Associated Universities' Radiological Site Assessment Program.
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With the exception of the measurements conducted with portablo gamma j                                                                  scintillation survey meters, instruments were calibrated with NBS-traceabis standards.      The calibration procedures for the portable gamma instruments are performed by comparison with an NBS calibrated pressurized ionization chamber.
Quality control procedures on all instruments included daily background and check-source measurements to confirm equipment operation within acceptable statistical fluctuations. The ORAU laboratory participates in the EPA and EHL Quality Assurance Programs.
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