ML20138J030

Submits Results of Sediment Analysis from Northeast Ohio Regional Sewer District,Easterly Wastewater Treatment Plant

ML20138J030
Person / Time
Issue date:	06/10/1994
From:	Shear G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Lenhart T NORTHEAST OHIO REGIONAL SEWER DISTRICT
Shared Package
ML20138E446	List: IR 05000420/2005019 ML20138E444 ML20138E449 ML20138E526 ML20138E531 ML20138E722 ML20138G385 ML20138G391 ML20138J030 ML20138J060 ML20138J084 ML20138J088
References
FOIA-96-443 NUDOCS 9702040308
Download: ML20138J030 (11)

Text

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I;ortheast Ohio Regional

' Sewer District A11ti: Thomas tenhart Attorney 3826 Euclid Avenue Cleveland, Ohio 44115

SUBJECT:

RESULTSEASTERLY DISTRICT, OF SE0lHENT ANALYSIS WASTEWATER TREATHENT PLANT FROM THE NORTHEAST

Dear Hr. Lenhart:

This refers to the June 1,1994, conversation between you and Mr. Michael Kurth of my staff regarding the Northeast Ohio Regional Sewer District, Easterly Plan (Easterlys)ediment Easterly sediment analysis analysisresults.

results.Table No.1 of this letter includes the Internal Correspondence which describes the specific sediment sam locations. From April 28 until May 12, 1994, analyzed using the Region III Mobile Laboratory gamma spectrometry Of tmit. E the 37 sediment samples analyzed, 5 samples demonstrated positive readings cobalt-60. These include Sample Nos. 3, 20, 22, 25, and 42. Although 2-Sigma percentage errors included in Table No. I are high.

of cobalt-60 detected in the samples is at or below ~the lower limit ofAlso, the amount detection, becquerel per which gram).is calculated to be 0.5 picocuries per gram (1.85 x 10" activity level detected, lower than the lower limit of detecti'on, ind very low probability for the presence of cebalt-50 in these samples.

Sample No. 22, which was collected from the North Lagoon, south of the breakwater, of cobalt-60. was the only sample which demonstrated a statistically valid level 10" becquerel per gram).The activity of the sample is 1.9 picocuries per gram (7.2 x This result i: 1s:s th:.. the February 20, 1992, Decomissioning the Bloomburg Site, Atta:hmant 3, Maxim .

i which is 8.0 picacuries per gram (0.296 tscquerel per gram) for cobalt-60. ,

Kurth cf my staff at (708) 829-9869.If you have any further questions co 4 Sincerely, hrt:;uvd 4 Gary L. Shear, Chief fuel Cycle and Deco.uissioning Branch

Enclosures:

1. Sediment Analysis Results .

i 2.

Letter dtd 5/9/94 bcc w/ enclosures:

T. C. Johnson, NMSS i W. L. Axelson, RIII 9702040308 970106 PDR FOIA ENGLISH96-343 PDR

i TABLE NO. 1 SEDIMENT ANALYSIS RESULTS SAMPLE LOCATION CO-60 i

NO. 2-Sigma i Error (microcurie per Error 2-Sigma ,

gram) l 1

White City Beach just 0

_ inside breakwall 2 White City Beach just 0 inside breakwall 3 White City Beach just 9.7 x 10 d 6.2 x 10" 64 inside breakwall 14 Off the mouth of the O Rockefeller Relief -

Sewer 17 North fart of yacht 0 club basin near outfall pipes 19 Mouth c' yacht club 0 basin 20 North rirt of yacht r

2. 5 x 10-'  !.2 x 10" '3 cluc bEiin near outfall alpes '

21 North 11;oon south of 0 oreakwz:fr 1 22 North 11;ocn io';th of  : . 9 x *.0-' 2.5 x 1 7 *

.3 l breakwa ir 23 >

North it;oen south of C -

i breakwau r I 24 South st: reline of 0 north la;2on 25 South sh: reline of 4.4 x 10 ' 8.8 x 10

nortn la;3or, 52 l 26 South sh: elins of 0

}

I north la;:or.

1

' 31 Off end c' tain ,

0 l outfall 32 Off end (3 clin 0

• outfall I

33

, {

East of rain cutfall 0

• l j

l 34 East of rain cu: fall 0 '

4 I

5 SAMPLE LOCA110N .u- r NO. C0-60 2-Sigma (microcurie per  % Error Error 2-Sigma gram)_ '

35 Cffshcre samples,

, 0 aimed at Rockefeller relief sewer and plant overflow 36 Offshore samples, 0 aimed at Rockefeller relief sewer and t

plant overflow 37 Offshore samples,

. 0 aimed at Rockefeller relief sewer and plant overflow .

i 38 Offshore samples, . O i aimed at Rockefeller relief sewer and j plant tverflow 39 i Offshore samples, C I

e ai cd at Rockefeller rei 'f sewer and plai.* overflow

I 40 i P19eP ; :.::uth cf i 6

11 I j u

Rockefe'!er relief l sc 2r j 41 Bracketing mouth of 0 -

J Rockefeller relief sewer

! 42 Offshore samples, i 1.4 x 10" 2.0 x 10" 136 i aiced at Rockefeller relief sewer and plar,t overflow I

43 Of fshore samples,

! 0 aimed at Rockefeller relief sewer and i plar.t overflow e

6

SAMPLE LOCATION NO. C0-60 (microcurie per 2-S '. cn a  % Error b E rcr 2-Sigma gram) i "

44 Offshore samples, 0 aimed at Rockefeller relief sewer and plant overflow .

t I

45 t Offshore samples, 0 aimed at Rockefeller relief sewer and I plant overflow 46 Offshore samples, O aimed at Rockefeller

• relief sewer and -

plant overflow 1

47 1 Offshore sacples, 0 aimed at Rockefeller  ;

relief sewer and -

plant everflow '

l  !

48 ';

Offshore samples, O i

aimed at Rockefeller relief sewer and a plant e.erficw I t

i I (

49 Bracketi,g r,cuth of ,

0 l

plant c.srficw  :

l 0 50 Bracketir.g mouth of 0 f plant overfiow l 51 s Offshore samples, 0 i aimed at Rockefeller $

relief sewer and plant ovsrflow t

f y

l 52 Of fshcre sa. ples, i 0 aimed at Rockefeller  ;

l relief sc-er and plant everflow  ;

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! SAP.PLE LOCATION NO. CO-60 T 2-Sigma L (microcurie per  % Error Error 2-Sigma gram) 53 Offshore samples, O I aimed at Rockefeller f relief sewer and plant overflow l 54 Offshore samples, O aimed at Rockefeller relief sewer and plant overflow O

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1 4

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[b, Northeast Ohio Regional Sewer District INTERNAL CORRESPONDENCE TO: DISTRIBUTIOt1 DATE: "#Y 9' 1994 FROM: Spai < es

/

SUBJECT:

Easterly Aquatic Sampl.ing A summary attached of sediment and sampling points at Easterly WWTP is herewith.

DISTRIBUTIOli T. Lenhart, Legal K. Parikh R. Connelly, EMSC

• E. Perez, EMSC W. Mabk, EMSC T. Zablotny, EMSC D. Hudson, EMSC e

.-. .a .._-.u _ . . + . _ . .._ .u _ ,m, _.___. ..~ .

1 1

/ EASTERLY WWTP i

AQUATIC SEDIMENT SAMPLING

Underwater samples of sand and sediment from the no!

area, 1994 forLake rac'ation Erie, and White City Beach area were collectei analysis.

Figure 1, Prcposed Aquatic Sample Points. Sampling locatio ,

t SAMPLES: Aoril 25.1994 Sampling was conducted using the District's Boston Whaler a Ponar type subsurface sampler. In general, the hard packed 1 prevented the sampler from penetrating deep enough to collect ! i sample. The efforts were complicated by zebra mussel shells

prevented Aquatic Sam the sampler halves from closing. As shown on Fi!

i These were: ple Sites, only a few sites were successfully sample

' Site Numbe-Description - \

1,2,3 White City Beach just inside breakwater i i1 14 1

$ 17 Off the mouth of the Rockefeller Relief Sewer f-l NY.h part ci acht ciub basin near outfall 3 ~ ~

[ 19 ' Mouth of yacht club basin  :

! Locations for s :es i 2,3 and 14 were triangulated using theo angular measu emen,ts. The grid base line along the east plant overflow .vas used as for horizontal measurement, and; declination for sites 17 anc 19 to were v ster line was used for distance ca estimated.

SAMPLES: Aor 26.1994 i he Whaler was used, along with a split spoon sampler, for si Aftersites. that, it was decided that the split spoon would not w water Tte boat could not be held steady enough to allow driving the samfer into the bottom. Sampling was conducted in t  ;

north lagoon using a small boat. wadas a id := spade Nor.h l_agoon Sample Sites. See =igure 3, g . . _ _

.= =

fL-Site Number '

Descr.ati?:

l 20 I North part of yacht club tas.n near outfa: p~ pes 21,22,23 North lagoon south of breakwater 24,25,26 South shoreline of north lagoca The location for site 20 was estimated from shore 21 through the shore of the26 were plotted using bearings taken from a theod lagoon.

SAMPLES: Aoril29.1994 .

trowel and stainless steel bucket.ThisHe wor .

the samples. proved very efficient, taking only about two and a

?

{ Site Number Description l 31,32 Off end of main outfall r

33,34 --

East of main ouMal! u I 35-39,42-48, p 51-54 Offshore samples, airned at Rc.ckefeller re ie' sewer and plant overflow 40,41

!.l Bracketing mouth of Rockefe!!sr relief sev.er 49,50 ,

Bracketing mouth of plant overflow j

Sites 31-34,49 and 50 were estimated bc shore caservation

. Si:e 45 was located by Lorari reading.

experience with the other sites. This was adjusted based on based on theodolite reading. All remaining sites were clotted

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) A Northeast Ohio Regional Sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 216 881 6600 FAX:216 881 9709 VIA FACSIMILE AND CERTIFIED MAIL RETURN RECEIPT REQUESTED October 21, 1994 Mr. John B. Martin Regional Administrator United States Nuclear Regulatory Commission Region III 801 Warrensville Road Lisle, IL 60532-4351 Re: Suspension of AMS Wastewater Service

Dear Mr. Martin:

Enclosed is a copy of the Northeast Ohio Regional Sewer District (District) Executive Director's Order that was served upon the Advanced Medical Systems' (AMS) London Road facility on October 21, 1994. This Order requires AMS to cease all discharges to the London Road sewer, including stormwater, not later than 5:00 p.m. on October 24, 1994. As stated in the order, the District will use all means available to enforce this suspension of service, including the possibility of physically disconnecting this facility from the District's systems.

As the Nuclear Regulatory Commission is the agency solely responsible for regulating the radioactive material at 1020 London Road with regard to health and safety, this letter is to formally notify you that alternative disposal or storage will need to be arranged for all water, including sanitary, industrial process, and storm, that may otherwise have been discharged to the public wastewater collection system.

The mission of the Northeast Ohio RegionalSewer Districtis to enhance pubhc health and welfare through the etticient, cost-e!!ective conveyance and treatment of wastewater. This is accomplished by an organization dedicated to professionalism, fairness and consistency that anticipates and responds to the changing environmentalneeds of the community.

h W0l i rY

Mr. John B. Martin W October 21, 1994

, Pcgn Two

(

l I

Please call me at (216) 881-6600 if you have any questions about the foregoing.

Very truly yours, Lr. AJL4 i Thomas E. Lenhart l Assistant General Counsel TEL/td Enclosure cc: Senator John Glenn Congressman Michael Synar j Congressman Louis Stokes ,

NRC Chaiman Ivan Selin  !

Robert Owen, ODH l William Skowronski, OEPA Jim Payne, OAG Michael G. Konicek, Cleveland Erwin J. Odeal William B. Schatz '

Sara J. Fagnilli Richard Connelly p

h

s: -

1  ?; Northeast Ohio Regional Sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 216 881 6600- FAX:216 881 9709 HAND DELIVERED BY MESSENGER AND CERTIFIED MAIL REIURN RECEIPT REQUESTED October 21, 1994 Advanced Medical Systems, Inc.

1020 London Road I Cleveland, Ohio 44110 l

ATIN: David Cesar l

Dear Mr. Cesar:

'the Northeast Ohio Regional Sewer District (" District") has been sampling and analyzing your wastewater discharge into the sanitary sewer  !

at 1020 London Road. The results of these efforts are set forth below. 1 In addition to the radioactive material identified in these effluent samples, a sample of Southerly filter cake (sludge) collected on September 22, 1994 contained 151 pCi/g of Cobalt-60.

SAMPLE RESULTS FOR 1020 LONDON ROAD DATE COLLECTED PARAMETER ACTIVITY 7/5/94 Cobalt-60 29 pCi/L 8/17/94 Cobalt-60 33 pCi/L 9/16/94 Cobalt-60 0 pCi/L 9/20/94 Cobalt-60 0 pCi/L 9/22/94 Cobalt-60 0 pCi/L 9/28/94 Cobalt-60 14 pCi/L 10/1/94 Cobalt-60 87 pCi/L 10/4/94 Cobalt-60 0 pCi/L 10/10/94 Cobalt-60 306 pCi/L As the result of prior discharges of Cobalt-60 from this facility, the District has incurred significant costs and continues to incur such costs related to the existing contamination at the Southerly Wastewater Treatment Plant and for monitoring for possible additional discha'rges such as catalogued above, despite the fact that such discharges are now prohibited by 10 CFR 20,2003.

4 The mission ot the Northeast Ohio Regional Sewer District is to enhance public health and welfare through the etficient. cost-effective conveyance and treatment of wastewater. This is accomplished by an organization dedicated to professionalism. l fairness and consistency that anticipates and responds to the changing environmentalneeds of the commun:ty.

_ _ _ _ _ _ _ . . - .~._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _=- _ _ _

1 . .

Mr. David Cesar

Octcher 21, 1994

{] Page 2 i'

, Pursuant to the authority of the District's Executive Director

under the District's Code of Regulations (" Code") Section 1.0904, the i

i discharge from the Advanced Medical Systems facility at 1020 London Road has been determined to be unacceptable. In particular,'the discharge i contains material that is deleterious to the wastewater treatment system as set forth in Code Section 1.0905(c) and causes the District to incur

} excessive expense in the handling or treatment thereof as set forth in j Code Section 1.0905(e).

In accordance with Code Section 1.0906, the District will no longer provide wastewater treatment services for the 1020 London Road facility l billing account number 01369851009.

i

In addition to being une

ceptable under Code Section 1.0906, the

! discharge from 1020 London rom appears to present a substantial danger j

i to the environment or may bterfere with the operation of the PODf. As stated in Code Section 2.0604, the Executive Director may order an j emergency suspension of service under such conditions.

t You are therefore directed, pursuant to Code Sections 1.0906 and i

2.0604, to cease all discharges of any type to any and all buildirig

, drains and/or building sewers as such terms are defined in Code Sections 1.0204 and 1.0205. This prohibition on discharge includes sanitary flow

, and industrial process water, as well as the discharge of any stormwater. Stormwater discharges are unacceptable due to the i possibility of Cobalt-60 contamination from the roof, stora drains and j connecting sewer being carried to the public sewer by such stormwater.

! You are required to comply with this Order in its entirety by no  :

j later than 5:00 p.m., Monday, October 24, 1994. Failure to comply with  !

this Order by said time will result in such legal or physical actions 4

' deemed necessary or justified under the circumstances, including but not limited to physical disconnection of the 1020 London Road facility from the District's system. j l

l 1

A copy of Code Sections cited are enclosed.

Sincerely,

Erwi J. Odeal l Executive Director i Enclosures cc

Sara J. Fagnilli j Henry Billingsley, II a 4

1 l

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=

NORTHEAST OHIO l q REGIONAL l I

i t  ; SEWER DISTRR ;i j Q.'l,.;.:.e> .

^

., . .v .-- 3 l $m%nw Cod :e of Regulationst e .. . . .

a + .* . .

l l

Title I i f -

Sewer Use Code i!

j k >

l l The Code of Regulat'ons contains three Titles:

4

• Sewer Use Code,

• Pretreatment Regulations, and

!

• Separate Sanitary Sewer Code.

i l This Title has oeen separately printed for distribution to those entities most

! affected by the regulations contained herein. The User is advised that the other Titles may be applicable as well.

g ADMINISTRATIVE OFFICES 1

3 3826 Euclid Avenue

• Cleveland, Ohio 44115-2504 8&16600 Water Quality and Industrial Surveillance 641-6000 ,

4 Pnmed on myce paper.

Pnntec: January,1992

}

1 i

9 CHAPTER 2 -

DE:FINITICNS

,C-Section 1.0201 Definitions - unless the content specifically ,

indicates otherwise, the meaning of the following terms wherever they are used in this Code shall be as defined in the following sections.

Section 1.0202 " Approving Authority" - shall mean the Executive Director of the Northeast Ohio Regiornal Sewer District or his designated representative.

Section 1.0203 " BOD" (denoting Biochemical Oxygen Demand) - shall mean the quantity of oxygen utilized in biochemical oxidation of organic matter under standard laboratory procedure in five (5) days at 200C, expressed in milligrams per liter. '

section 1.0204 " Building Drain" - shall mean that part of the lowest horizontal piping of a drainage system which receives i the discharge from soil, waste, and other drainage 1 pipes including sump pumps, roof drains, and other 1 similar connections, inside the walls of the building and conveys it to the building sewer beginning five (5) feet (1.5 meters) outside the interface of the building. 1 Section 1.0205 " Building Sewer" - shall mean the extension frcan the building drain to the pblic sewer or other place of

, disposal.

Section 1.0206 "C," - shall mean centigrade degrees.

Section 1.0207 " COD" (denoting Chemical Oxygen Demand) - shall mean the amount of oxygen consumed from a chemical oxidant under standard laboratory procedures expressed in milligrams per liter.

Section 1.0208 " Combined Sewer" - shall mean a sewer designed to receive both sanitary sewage and storm water runoff.

Section 1.0209 " Control Manhole" - shall mean a structure that is accessible for the p rpose of maintaining a building sewer. A control manhole may be used as an inspection chamber.

Section 1.0210 " Cooling Water" - shall mean the water discharge from any system of condensation, air conditioning, cooling, refrigeration, or other sources. It shall contain no polluting substances which would produce BOD or SS (suspended solids) each in excess of ten parts per million by weignt, or toxic substances as limited in this Code or other polluting substances which may be limited in this Code.

I-2 Revised 3/91

I v

Section 1.09031 Inspection and Sampling - Se District may inspect -

the facility of any User in order to determine compliance with the requirements of these regulations. The dischargers shall allow the ,

District or its representatives, without prior  :

notice, upon presentation of credentials of i identification, to enter upon the premises of the User at all hours for the purpose of inspection, sampling, or records examination. Delays in permitting access to District personnel in excess of ten minutes shall be considered a failure to emply with this Code for parposes of Section 1.0923. The District sEilT have the right to set up on the User's property such devices as are necessary to conduct sampling, inspection, empliance monitoring, and/or metering operations. Sud devices may include electronic telemetry of alarms and sensors.

SecElon1.0904 Acceptability or Unacceptability of Discharge - i' Determination by District - W e Executive. Director ,

shall determine the acceptability or unacceptability of any discharge to the System. Such a determination '

shall be made on the basis of sound engineering and operational evaluations taking into consideration the nature and concentration of the discharge, its point of entry into the Systen, its compatibility with 3 other discharges in the System, its empatibility 3 '

with the treatment facility receiving it, all ./

applicable federal regulations, and all other factors '

pertinent to the effect of the discharge on any part of the System or treatment process.

Section 1.0905 Unacceptable Discharges - Unacceptable discharges shall include those which have been determined by the Executive Director to:

(a) Contain materials or substances whidi would constitute a hazard to life and limb of personnel engaged in inspection, maintenance, and operation of the System.

(b) Contain materials or substances which are toxic as defined in Section 1.0267 of this Code.

(c) Contain materials or substances which are in any way deleterious to any part of the System.

(d) Contain concentrations of any toxic or deleterious materials or sutstances in excess of any limits set thereon in accordance witn this Code. ,

(e) Cause the District to incur excessive expense in the handling or treatment thereof.

I-31 Revised 3/91

i

.~

4 4 ,

(f) Be incompatible with tne treatment process or i

inhibit the performance of the treatment process at a District treatment facility.

l

. (g) Be of such volume or contain sud BOD, j

4 suspended solids, or other material load whid would cause the treatment facility to exceed its design capabilities.

1

! (h) Cause a treatment facility of the District to i

fail to meet effluent requirements set by State l and Federal regulatory agencies or cause su d j

effluent to have a degrading effect on the i

receiving body of water.

l (i) contain viable pathogenic organisms in sud

quantities as to be a hazard to public health.

i (j) Cause a treatment facility of the District to fail to meet effluent requirements as

{

4 established under the District's NPDES Permit.

t" section 1.0906 Unacceptable Discharges - Refusal of Service - The Executive Director may refuse the service of the District's facilities to any person whose dis e arge 1

l is determined by the Executive Director to be i unacceptable in accordance with the provisions of j this dapter.

! Section 1.0907 Unacceptable Disd arges - Pretreatment Required -

Administrative Order - Any User whose discharge has

} been determined by the Executive Director to be unacceptable in accordance with the provisions of this chapter may be issued administ:rative orders to install and operate a pretreatment system designed to l render said disd arge acceptable. The Executive Director may issue orders to any industrial user to require compliance with any requirement under these Code of Regulations, including applicable categorical pretreatment standards, other discharge limits, and reporting requirements.

Section 1.0908 Acceptable Methods of Pretreat2nent - Review by I District - Rejection of Pretreatment Method - The acceptability of a pretreatment method for any given discharge and the terms for the installation and use thereof shall be reviewed by the Executive Director.

Such a review shall be made on the basis of sound engineering and operational evaluations taking into consideration all factors pertinent to the effect of the discharge both before and after pretreat2nent on  ;

any part of the System. If the pretreatment system -

is found to be unacceptable then the Executive Director may refuse service under Section 1.0906, or may require additional information or design modifications to make the pretreatment method acceptable.

I-32 Revised 3/91

O.

ra NORTHEAST OHIO

~

g REGIONAL t  ; SEWER DISTRIGi

c. -

4; 'r .. ., . Code of Regulations %

7:.- , - . . .,

. + . . u., ,

1

Title II i Pretreatment Regulations '

< > l The Code of Regulations contains three Titles:

• Sewer Use Code,

• Pretreatment Regulations, and

• Separate Sanitary Sewer Code.

This Title has been separately printed for distribution to those entities most affected by the regulations contained herein. The User is advised that the other Titles may be applicable as well.

g ADMINISTRATIVE OFFICES 3

^

3826 Euclid Avenue

• Cleveland, Ohio 44115-2504

• 8816600 Water Quality and Industnal Surveillance . 6416000 ,

- Pnmed on recyce pam Pnnted: January,1992

1 l

- personal service or certified mail, return receipt i requested, specifying the time and place of a hearing to be held by the Board of Trustees or its designated Hearing Examiner regarding the violation, the reasons by the enforcement action is to be taken, the proposed enforcement action, and directing the discharger to show onuse before the Board of Trustees or its designated Hearing Ex miner why the proposed enforcement action should not be taken. Se notice of the hearing shall be served no less than seven calendar days before the hearing. Service may be made on any agent, officer or authorized representative of a discharger or to the disdarger's grincipal place of business or to the facility at whid the remliance occurred. S e proceedings at the hearing shall be in accordance with section 1.0302 and 1.0303 of Title I of this Code of Regulations, and the determination by the Board oTITilstees anall be made in the manner prescribed in that section.  ;

Section 2.0604 l Emergency Suspension of Servim - S e Executive Director may for good cause shown suspend the i wastewater treatment service of a dis &arger when it  ;

appears to the District that an actual or thrcatened i dis &arge presents or may present an imminent or substantial danger to the health or welfare of persons, substantial danger to the environment, may interfere with the operation of the PO2W, or may violate any discharge limits imposed by Title I or Title If of the .

Code of Regulations. Any discharger notified of the suspeTiion of the District's wastewater treatment -

service shall cease all discharges. In the event of failure of the dis &arger to comply with the suspension '

order within the specified time, the District shall '

take all actions necessary, including but not limited to judicial proceedings, to compel the discharger's compliance with such order. Se discharger shall be responsible for all costs associated with said action. i me District shall reinstate the wastewater treatment service upon receipt of proof of the elimination of the nonccanplying discharge or conditions creating the threat of inninent or substantial danger as set forth above.

rection 2.0605 Judicial Proceedings - Following the final appeal to the District permitted under procedures for Administrative determinations of Section 5.1 of the Code, the General Counsel of the District may, 4 T6TIowing the authorization of such action by the District, commence an action for appropriate legal an6/or equitable relief in the appropriate local court.

Section 2.0606 Enforcement Actions - Annual Publication - At least annually, the Executive Director shall publish a list of all industrial users which at any time "during the previous twelve months were in significant non-compliance with applicable pretreatment requirements.

II-26  ?-

ed 3/91

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SURVEY AND SAMPLING PLAN Northeast Ohio Regional Sewer District 3826 Euclid Ave.

Cleveland, Ohio 44115 License No. NA Docket No. NA insoection Dates: October 31 thru November 4,1994 insoector: Mike Kurth Accomoanied bv: Frank Talbot Ohio Department of Health (614) 644-2727 Puroose of the insoection: Periodically sample Southerly and Easterly grit and sludge in an attempt to identify radioactive contaminants. Also, to perform surveys in various treatment areas to identify excessive exposure rates.

Reason for Conducting the Samoling:In a letter dated October 21, 1994, from the NEORSD to AMS, the NEORSD indicated that on September 22,1994, a filter cake (sludge) sample was removed from the Southerly Vacuum Filter and was identified as containing 151 picocuries per gram of cobalt-60.

1. Determine travel times of debris being treated:

Approximate ' Travel Times for Debris:

From AMS to Easterly: 1-2 hrs

, From Easterly to Southerly (Travel Time Thru Easterly Sludge Pumps): 2-12 hrs Treatment at Easterly, Transported to Southerly, Treated at Easterly, Deposited into the Ash Lagoons:

1

i 1

s-24-48 hrs

• The travel times are only an approximation. On October 31,1994, a meeting will be held with NEORSD personnel to determine more exact times regarding treatment processes. Also, diagrams will be generated to follow the flow patterns at Easterly and Southerly.

II. Determine sampling locations and fnquencies:

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1) Easterly Grit Discharge Point

d 9 d% Initial Sample f E +A'q +~Swh g 7O*- Once every 12 hrs -

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2) Easterly Sludge Pump g- '

"') cgf' j

Initial Sample .

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Once every 12 hrs . M;,..LM.

3) Southerly intake Point for Easterly Sludge  ;

Initial Sample i Once every 12 hrs i

nL g 4) Southerly Grit Discharge Point P g -_

Initial Sample d*p ' N A,

• , ,, , h Once every 12 hrs . cg g . ., .

b. e eWp.. -1

5) Southerly Vacuum Filter Area (Filter Cake) d y, initial Sample Once every 12 hrs .

k;s. V>c ' ) ,

b, Southerly Ash in incinerator '

6) .

. g, Initial Sample f;I. -

,V .e * ( Once eyetyA24rs ei'

. , . . . . 'I..v-7w ./

J &, ;'i . y .L .

V' k 9 c ,. y* s 2

3,'.lf(N m

s<

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g . 3 '- ' '

7) . Southerly Ash in Ash Pond b'("' r v% )

initial Sample 'J 4ecaew ;-12J4w-a o h,erl f 4

(_n*}3A s are e~ rg t es grly - e ccys,h e

pg l .J \ pi al/ '

l N s / I Once eve y 2 rs

1. pny other intakes into Easterly (if accessible),

,p se\parate from the London Road Sewer interceptor

s .7 gg 3 Initial Sample ge- l'

f"' $.Once* every 24 hrs

• j lli. urvey #3 4*^" (h* l i j A. Areas to be surveyed:

I Accessible areas- Near or around sludge lagoons, headworks areas, sludge or grit conveyors, etc...

4 B. Documentation:

All survey results and locations of excessive readings i

! will be documented with enough detail to be able to I

relocate any point. Background measurements will i be taken at each location where a sample is j collected. Measurements will be taken in each

, sample collection location as the sample is collected.

IV. Instrumentation A. Field Instruments Ludlum Model 19 MicroR Meter Ludlum Model 12 Count Ratemeter with attached Pancake Probe 3

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i Each instrument will be cross-checked using a traceable Co-60 source.

B. Analytical Region til laboratory gamma spectrometry unit will be used to determine the identification and activity of gamma radionuclide contaminants, if any.

i C. Photographs Photos of areas sampled and surveyed will be taken.

4 L

Reviewed by:  %%

G. M. McCanr/, Chidf Datelo/21r[9I

/

, Fuel Facilities and Decommissioning Section Approved by I a>/ze/f/

G. L. Sh(ar, Chief Date/

Fuel Cycle and Decommissioning Branch

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< , Northeast Ohio Regional Sewer District 3826 Euclid Avenue Cleveland, Ohio 44115-2504 216 881 6600 FAX:216 881 9709 November 2, 1994 Director, Division of Freedom of Information and Publications Services office of Administration U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: FOIA Request for Documents

Dear Director:

On February 17, 1993, representatives from the Northeast Ohio Regional Sewer District (District) reviewed all files available at the Region III office regarding Advanced Medical Systems, Inc., NRC License Number 34-19089-01 (Ah6). This review was .condteted as. part of the District's investigation into the contamination of its Southerly wastewater treatment plant with Cobalt-60.

Pursuant to the Freedom of Information Act and 10 C.F.R. Sec. 9.15, the District requests that the NRC provide the District with copies of any and all records, documents or other infonnation that has been entered in NRC files relating to AMS subsequent to February 17, 1993.

In addition, the District also requests that copies of any and all records, documents or other information that has been entered in NRC files regarding the District, without regard to date, be provided to the Distric t.

The District is aware that this request will generate a very large volume of material. Therefore, as an alternative to an NRC search and production, the District is willing to again visit the Region III office and the Washington Headgaarters office to review the requested files.

The District is a political subdivision and is making this request in conjunction with the investigation of contanination of its facilities with radioactive material and in conjunction with the prevention of future contanination. The Distric t, therefore, has no cmtmercial interest in the requested documents and requests a waiver of all fees pursuant to 10 C.F.R. Sec. 9.41.

b The mission of the Northeast Ohio RegionalSewer Districtis to enhance public health and welfare through the elficient, cost-effective conveyance and treatment of wastewater. This is accomplished by an organt:ation dedicated to professionalism.

, fairness and consistency that anticipates and responds to the changing environmental needs of the community.

'W~CFM AExk F#

~ . ,

~

• ' Director, Division of Freedom cf )

It formation end Publications Servicts November 2,1994 J Pagt Two l

Please call me at (216) 881-6600 to discuss this request or to make arrangements for an onsite file review.

1 Sincerely, l Y {

'lhosas E. Lenhart Y

i Assistant General Counsel i TEL/td cc: Sam Nu11uswami, NRC, Headquarters l

.(ry Shear, NRC Region III William B. Schatz Sara J. Fagnilli Lawrence K. English Richard Connelly 1

)

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