o Stq UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ii:; .iiON 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 US EPA RECORDS CENTER REGION 5 L PRO1 11111111 11111111111 11111 J10 MEMORANDUM REPLY TO THE ATTENTION OF SUBJECT: ACTION MEMORANDUM: Request for approval of an Emergency Removal Action at the Advanced Medical Systems Site, Cleveland, Cuyahoga County, Ohio (Site ID # C56V) FROM: Stephen Wolfe, OSC Emergency Response Branch 1, Section 1 THRU: James E. Augustyn, Acting Section Chief Emergency Response Branch 1 TO: Jason H. El-Zein, Chief Emergency Response Branch 1 I. PURPOSE The purpose of this Action Memorandum is to request and document approval of the selected removal action taken at the Advanced Medical Systems Site (Site) located in Cleveland, Cuyahoga County, Ohio and a ceiling not to exceed $100,000. This response action was necessary to mitigate the imminent threat to the public health, welfare, and the environment posed by the presence of and potential release of cobalt-60 at the Site. On June 15, 2016, the Ohio Department of Health (ODH) requested EPA assistance in responding to vandalism at the Advanced Medical Systems (AMS) Site. ODH requested additional assistance on July 7, 2016, in connection with additional vandalism. ODH is the regulatory agency at the Site and has documented the presence of radiological hazards since the 1990s. EPA documented the presence of radiological hazards during a site assessment performed at the facility in 2015. The Removal Action only addressed the emergency response activities requested by ODH. On June 16, 2016, Branch Chief Jason El-Zein verbally approved an initial ceiling of $50,000 for ERRS to initiate response actions. On June 22, 2016, Branch Chief Jason El-Zein approved via electronic mail a ceiling increase to $100,000 (AR#9).1 This Action Memorandum, if approved, will serve as authorization for expenditures by the EPA, as the lead technical agency, for actions described herein to abate the imminent and substantial endangeiment posed by hazardous substances at the Site. The response actions were conducted 1 This removal action has been completed, but is presented as a proposed removal action for approval in this document. Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer) in accordance with Section 104(a)(1) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1) and Section 300.415 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR 300.415 to abate or eliminate the immediate threat posed to public health and/or the environment by the presence of the hazardous substances, pollutants and/or contaminants. The uncontrolled conditions of the hazardous substances, pollutants and/or contaminants present at the Site require that this action be classified as an emergency removal action. The emergency response work required approximately 20 working days to complete. There are no nationally significant or precedent setting issues associated with the Advanced Medical Systems Site and the Site is not on the National Priorities List (NPL). II. SITE CONDITIONS AND BACKGROUND CERCLIS ID: 0HN000506336 Category: Time-Critical Removal Action The Site includes an approximate 5-acre lot and includes an approximate 80,000 square foot 2.5 story building that includes a basement. AMS began operations at the Site in 1979 when the United States Nuclear Regulatory Commission (USNRC) granted it a license to manufacture USNRC-approved sealed sources for use in medical equipment. In October of 1994 the Executive Director of the Northeast Ohio Regional Sewer District (NEORSD) served an Order upon AMS indicating that the NEORSD would no longer provide wastewater treatment services for the AMS facility due to cobalt-60 contamination. NEORSD installed plugs in the AMS connections to the sewage treatment system rendering the facilities drain system non-functional. Since then, AMS ceased source production and concentrated efforts on those that could facilitate a reconnection of the facility to the NEORSD sewage system (AR#2). In August, 1999, the Ohio Department of Health, Bureau of Radiation Protection became a USNRC Agreement State and assumed regulatory authority over the AMS radioactive materials license. In March, 2003, the Supreme Court of Ohio denied an appeal by AMS of a decision affirming an Ohio Department of Health Order denying AMS' application to renew its Ohio Radioactive Materials License. Since then, the Site has been in stages of decommissioning (AR#2). Due to the NEORSD sewer plugs, the facility's basement flooded in the 1990's. The water was contaminated with cobalt-60 and required evaporation to remedy the problem. A drainage system was installed such that all Site water would circulate through one point where a composite sampler collected water samples for analysis. The water was then discharged to the ground in the rear of the facility (AR#11). A Radiation Safety Officer (RSO) was assigned to the Site by AMS and the RSO regularly collected the composite sample and analyzed the sample on site according to plans submitted with the Ohio Department of Health. On June 14th, 2016, the Site's RSO reported to the Ohio 2 Department of Health, Bureau of Environmental Health and Radiation Protection (ODH) that vandals had cut the power lines running to the facility and began stripping copper wire from the facility rendering the water drainage system inoperable. ODH hired a contractor to provide temporary pumping and water storage until the system could be brought back on line. On June 15, 2016, ODH formally requested EPA assistance in restoring power to the drainage system and further securing the building (AR#4). ODH requested additional assistance on July 7,2016 (AR#8). A. Site Description 1. Removal Site Evaluation EPA met with representatives from ODH, Cleveland Fire, and the RSO on June 14th and inspected the Site after AMS reported recent vandalism. Cleveland Public Power was on site and turned off the power to the lines that were cut by the vandals. The entrance the vandals used to gain access to the building was discovered. The backup generator for the facility was inspected and was inoperable. Approximately 1,000 gallons of water was in the Site's sump (3,000 gallon capacity) and inclement weather was predicted overnight. ODH retained the services of a contractor to board the entrance the vandals used and to provide temporary pumping/storage of the Site's drainage water. ODH and EPA contacted the agent for AMS and was informed that AMS does not have the resources to address the problems caused by the vandalism (AR#s 3,5,6). 2. Physical location The Site is located at 1020 London Road in Cleveland, Cuyahoga County, Ohio, 44110. The geographical coordinates for the Site are 41° 33' 16.86" North latitude and 81° 33' 48.11" West longitude. 3. Site characteristics The Site is comprised of an approximate 5-acre parcel of land with an 80,000 square foot building. Residential properties and a community park are located to the north and west of the site. Railroad tracks and other commercial buildings are located to the south and east. The Site is bordered by London Road to the northeast and Mandalay Avenue to the northwest. All sewer drains leading from the Site were plugged in the 1990's by the NEORSD due to cobalt-60 contamination in the sewers. 4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant The Site's water drainage flows through a sample collector prior to discharging to the rear of the facility. The sample is analyzed by the AMS RSO and reported to ODH. The loss of electricity to the building can cause the Site's water drainage to back up, leave the Site and enter nearby residential area. 3 There are several areas of the facility that have not been decommissioned and that have high levels of radioactivity. In addition, several areas that have been decommissioned by AMS have not been released by ODH for unrestricted use. These areas are dangerous to trespassers and there is the potential for removable contamination to be taken out of the building during trespassing activities. Cobalt-60 is the contaminant of concern at the AMS site and is a hazardous substance (40 CFR § 302.4 [Table 302.4 Appendix B]). Radioactive decay of Cobalt-60 can cause acute radiation syndrome that includes nausea, vomiting, diarrhea, bleeding, coma, and death. Exposure to high levels of cobalt radiation can cause changes in the genetic materials within cells and may result in the development of some forms of cancer (AR#1) 5. NPL status The Site is currently not on the National Priorities List (NPL). 6. Maps, pictures and other graphic representations A Map showing the aerial view of the Site is provided. 7. Environmental Justice Analysis An Environmental Justice (EJ) analysis for the Site is contained in Attachment 1. Screening of the surrounding area used Region 5's EJ Screen Tool. Region 5 has reviewed environmental and demographic data for the area surrounding the Site at 1020 London Road, Cleveland, Cuyahoga County, Ohio, and determined there is a high potential for EJ concerns at this location. B. Other Actions to Date 1. Previous actions EPA is performing removal site evaluation in response to a June 9, 2015, request for assistance from ODH, requesting sampling, clean-up removal/response activities at the Site. EPA has conducted on-site assessment activities and is in the process of finalizing a site assessment report. (AR#11). 2. Current actions ODH requested assistance from EPA to provide resources to restore power to the Site's drainage system, further securing the Site, and to provide means of temporary pumping/storage of drainage water until power is restored (AR#s 4, 8).