SHIELDALLOY METALLURGICAL CORPORATION

Mr. John D. Kinneman, Chief Division of Nuclear Material Safety Branch 2 U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

TELEPHONE (609) 692-4200 TWX (510) 687-8918 FAX (609) 692-4017

Re: Radiation Doses Associated with the Use of CANAL-L&@and Procedure for Preparing Trial Shipment to NUCOR-Hickman - License No. SMB-743

Dear Mr. Kinneman:

The purpose of this letter is to describe the methodology used during the production of the batch of CANALLite@that was staged and shipped to the NUCOR-Hickman facility in Blytheville, Arkansas. The letter is a follow-up to a May 4, 1998 conference &between representatives of Shieldalloy Metallurgical Corporation (SMC) and the U. S. Nuclear Regulatory Commission (USNRC) and responds to Ms. Pam Henderson’s May 5, 1998 request for additional informaiion. Included herein is a description of that batch of CANAL-LiteOand how it was prepared, a description of the method used to certify its radionuclide contents, an assessment of the radiological impacts from the use of that batch of CANALLitea, and SMC’s commitments in regard to future CANAL-Lite @ shipments.

Description of CAN&L&@ Production As you know, SMC manufactures specialty steel and super alloy additives, primary aluminum master alloys, metal carbides, powdered metals, and related products. Raw materials currently used at the Newfield facility include beneficiated ores which contain oxides of columbium (niobium), vanadium, aluminum metal, titanium metal, strodum metal, zirconium metal, and fluoride (titanium and boron) salts. During the manufacturing process, the facility generates a variety of by-products that have commercial application.

One by-product that has had a successfid commercial market over the last several years is a ferrovanadium slag, known by the trade name of V q . Because of its a l h u m oxide and calcium oxide content, this material serves as an additive to the steel making process for reducing impurities in the final product. Another by-product Comains similar constituents but has even greater applicability for steel manufacturing. This product, known commercially as CANALQ, is produced from ferrocolumbium slag rather than femovanadium slag.

One of the differences between V W and CANALQ is that the latter contains a greater percentage of ahrmirmm oxide and less silicon oxide, which makes it even more effective as a slag fluidizer. However, CANALQ also contains a higher concentration of uranium and thorium than V-, although these elements have no effect on the performance of the product. Because higher c o n d o n s of these elements are present, some form of licensing action is required before CANALQ can be trimsferred to a steel manufacturer.

9805270188 980513 PDR ADOCK 04007102 C PDR

CANAL-LiteQ is a new product, produced by blending V-40Q and CANALQ. This product has a combination of the V 4 P and CANALQ characteristics, but with sufficiently low uranium and thorium concentrations that licensing action is not required for its sale.

In my April 20,1998 letter to Mr. Michael Weber (USNRC Headquarters), I informed him that a shipment of three (3) truck-loads of CANAL-LiteQ were to be delivered to the NUCOR-Hickman facility. The purpose ofthat trial shipment was three-fold: (1) to permit NUCOR-Hickman to evaluate the benefits of using CAN&UeQin their operations; (2) to permit SMC to evaluate blending and product certification methods for potential future use; and (3) to assist SMC in the preparation of a Radiation Safety Procedure (RSP) for CANALLite*production and sale. The following is a brief overview of the way in which the trial shipment was prepared:

0 A nominal blending ratio of CANALQ to vanadium slag was determined by calculation; a temporary restricted area was instituted in the building that housed the blender; and the applicable amounts of feed material were staged.’

e The feed materials were passed through the blender until a total of about 40,OOO pounds of CAN&ZAe*were collected in 22 bins. The contents of the bins were then passed through the blender a second time. After the second pass, radiological “screening” results demonstrated that the source material content of each bin was relatively homogeneous.*

0 A sample of CANAL-Lite*was retrieved from each of the 22 bins and hand-blended to form a composite. Four aliquots of the composite were then subject to the same “screening* methodology to ensure continued homogeneity.

0 Samples of the four aliquots were then forwarded to a commercial analytical laboratory for analysis of uranium and thorium isotopes. The mean .measured source material concentration in this approximately 40,OOO pound lot of CANAGLiteQat this point in the process was 456 116 parts per million (ppm) urauium plus thorium (U + Th).

- From the analytical and screening results, SMC was confident that this lot contained less than 500 ppm source material. However, in order to meet the customer’s demand for timely delivery of approximately 120,ooO pounds of CANALLireq without having to wait for the return of analytical results, the 40,OOO pounds of screened and c h a r a c t e d CANALLite*were re-blended with an additional 80,000 pounds of vanadium slag. As before, the feed materials for the re-blending were run through the blender twice, and composite samples ofthe re-blended mataial were collected and are being forwarded to a commercial analytical laboratory for confirmatory analysis of uranium and thorium isotopes.

Although we have not yet received the analytical results from the re-blended CANAL-Lite? we expect them to exhibit source material (v i- Th) percentages on the order of 110 to 200 ppm. Based on this

Healthphysicscowrage of the CA.NAUite productionoperation was perfourmi by anindividual whomet the q d l h t i o n s of Radiation Surveyor as described in RSP-006, “Training and Qualification of Radiation Protection Personnel”, with ovnsight provided by the SMC Radiation Safety Officer (RSO).

Two passes through the blender were necesuy in order to obtain mean radiolo@d screening results with a standard deviation of less than 25%.

expectation, a total of 120,000 pounds of CANAL-LiteQwas staged for shipment to NUCOR-Hickman for evaluation.

The staged batch of CANAL-Lite*was shipped in bulk using covered dump trailer vehicles. However, the shipment arrived at the site in advance of the expected delivery date. As a result, NUCOR-Hickman rejected the shipment, and it was subsequently returned to SMC’s Newfield facility, where it remains as of the date of this letter.

Attachment 1 contains the procedural steps that were followed for the blending, screening and sampling of the NUCOR-Hickman shipment. Attachment 2 contains a copy of the confirmatory sampling documentation for that shipment. Included are the screening results from the 22 bins (i.e., the first 40,OOO pounds of CANAL-Lite?, the screening results from the four aliquots of the 22-bin composite, and a summary of the initial analytical results showing a mean source material content of 456 ppm. Included as well in Attachment 2 is the M f i c a t e of Analysis from the analytical laboratory, along with a copy of the performance specifications for these analyses.

The final confirmatory sampling results will be fomarded to you as soon as we receive them. When NUCOR-Hicw or other pomtkd clients express an interest in purchasing large quantities of CANAL Lite? we will finalize the RSP for its production such that the product certification methods therein are not only consistenx with the customer’s specifications, but are sufficiently comprehensive to ensure future shipments of CANAL&2eocontain less than 500 ppm source material. This information will be provided to you before any additional CANALLiteois shipped.

Radiological Impact from CAN&L&* Usage In Report No. P4005/G-103, “Radiological Impacts from the Use of CANAL@ - A Slag Fluidizer in Steel Production” (April 27, 1995), prepared as a supplement to SMC’s 1995 application to export source material pursuant to Title 10, Code of Federal Regulations, Part 110, the radiation dose potential for members of the general public from the use of CANAL@ was assessed. In this report, a number of exposure scenarios were evaluated. The results demonstrated that the maximallyexposed (hypothetical) individual has the potential to incur up to 53 millirem per year from loading and unloading supersacks of CANALQ during steel-- operations. All other exposure scenarios resulted in lower potential doses.

However, CANALo contains approximately 4,580 parts per million (pprn) source material (U+Th), while the NUCOR-Hickman shipment of CANAL-LiteQcontains approximately 200 ppm U + Th. Since the estimated radiation doses in Report No. 94005/G-103 were linearly related to the concentration of radioactive materials present, the maximum likely radiation doses tbat appear in Report No. 9400WG-103 are significantly higher than those associated with similar uses of CANAL-Lite?

The following table, extracted from the ‘Summary and Conclusions” section of Report No. 94005/G-103, has been modified to shows not only the maximum individual dose (miliirem per year) from the use of CANALQ as it appeared in that report, but the maximum individual dose (millirem per year) predicted from the use of cAN~&Lite?~

’ Toprepare the ‘CANALLite O w column in this table, a re-assess11wt of doses was not performed. Instead, the dcss th;lt appeared in Repon No. 98000/G-103, reflected in the ‘CANAL* column of the table, were scaled to reflect CAN&Ue (c)’s lower source material content.

Maximum Individual Dose ( d ~ e a r )

CAN&&@ E~urescenarioS CANAL@

(4580 ppm source NUCOR Shipment Future Shipments

sourcemsterial) sourcematerial) mate3id) ( L e s s h r n p p m (Less-500ppm

53 Direct Exposure of a Steel Workr

Inhalation Exposure of a Steel Worker per Dropped 0.02

suPe=p Exposure of a Member of the General Public from Homes 8

Built on End Slag

Exposure of a Child that Ingests Emd Slag

Exposure of a Member of the

Paved Roads Over End Slag

1

General Public Standing on 1

Exposure of a Road Crew Member ConsauCting End

Slag Road 7

Exposure of a Member of the General Public Walking on Roads Constnrcted of End 10

slag

2.31

0.00

0.35

0.04

0.04

0.31

0.44

5.79

0.00

0.87

0.11

0.11

0.76

1.09

ALARA Analysis ThedoseestimaneS Shownmtheafbrema 'onedtabk axe amservative in that the parameters used as input to the calculations were selected sucb that higher rather tban lower doses would result. Nonetheless, the maximum individual CANALUeedoses estimated for all scenarios, for an exposure duration of one (1) year, are only a small W o n a f a m b i background radiation doses over that same time period. In all cases, they are certainly too low to be measured/confirmed with any statistical confidence. Therefore,

' Although CANAGLire will be shippea in bulk rather than in supersacks, this scenario is preserved to ensure potential radiation doses inanredby s t d workers isaddressed. Bemuse loader capacity is similar to the capacity of a supemack, it is not likely that the c0mpat;ltly ~edoseassessnentresultswilldifksignificantly.

further reductions in dose as required in 10 CFR 20.1 101(b) are neither practical nor justifiable in light of the state of monitoring technology.

However, as exhibited in SMC's Radiation Safety Procedure No. RSP-005, "ALARA Program", SMC has a firm commitment to maintaining all radiation exposures from licensed operations as low as is reasonably achievable. Therefore, an important feature of feature CANAL-Lite "production operations will be defensible and auditable procedures for ensuring that radionuclide concentrations in the lots staged for sale do not exceed 500 ppm. In addition, future shipments will be handled by a single use carrier. Finally, when so permitted by one or more of our clients, SMC intends to mount a validation program wherein the radionuclide concentrations in all feed materials, end slag and bag house dust from a steel production run using CANAL@ or CANLL.ite"wil1 be sampled and confirmed to be consistent with the estimates that appear in Report No. 9400YG-103.

Commitments on Future Shipments As I relayed to you in my May 7, 1998 letter, SMC will not attempt to re-ship the NUCOR-Hickman lot of CANALLite@until the USNRC has made a determination that it can be safely released. Furthermore, SMC also c o m m i i c o n c u r s that the proposed product preparation, packaging and certification programs for those lots are acceptable. For business development purposes, however, we hope that the USNRC's review of the information in this letter and in subsequent communiCations will be t i m e l ~ . ~

In her May 5, 1998 telephone call, Ms. Henderson also requested an estimated schedule for CAN&Ue@prep&on and shipment. Because the mark& for that product has not yet been developed, and because the eventual preparatio~~/shipment schedule will be customerdriven, we are unable to provide you with that information at this time. We will, however, keep the USNRC apprised of the schedule on a periodic basis as purchase orders are received.

In regard to the forecast of the total quantity of CANAL-Lite" to be shipped, CANALLite" and its colmterparts, V4W and CANAL@, are valuable raw materials for steel makers who wish to minimize or elimhate the detrimental effects of process slag compositions. The advantages of these products include, but are not limited to reffactory protection, energy savings at ladle furnaces, consistent chemistry, faster steel refining times, good sulphur and inclusion removal, and improved castability and yields. Consequently, SMC intends to include both CANALo and CANAL-Li?e"in our slag fluidizer product line because we anticipate significant industry demand. SMC has approximately a 50% market share of the slag fluidizer market which currently is 50,000 tons per year. This market demand has grown and continues to show a positive growth. We intend to prepare, package, sell and ship these products until our supply of feed materials, primarily ferrocolumbium slag, is exhausted.

' Our request for timeliness is driven by a commirmemmade to the USNRC and caparredinpmvisiom 14 aud 15 of W Number SMB-743 to demonsme that the sale of ferrocolumbium slag is viable. The license, in essence, rrquirarthatthisd "on be deuned successful by October 20,1999. The mar-, production, and sale of CANALUe e is a critical componwt of dis demonstraton. The USNRC's assismnCe in helping SMC to meet this COmmirmeM is greatly appreciated.

.

If you have any questions or if I can provide you with additional information, please call me at (609) 692- 4200, extension 226. SMC is optimistic that steel industry demand for CANAL-&@ will be great, permitting us to enter into a routine production/packaging/sale operation as soon as possible. Such an operation will not only result in a profitable product h e , but will also ensure we meet the letter as well as the intent of provisions 14 and 15 of License Number SMB-743 in a technically-sound, legally- defensible manner.

David R. Smith Radiation Safety Officer

cc: Nigel C. Morrison Mary B. Higgins James P. Valenti Hugo L. Nieves R o b A. DeGrange Lidia M. Stasiuk Mike Williams Eric L. Schorndorf, Esq.- M W u r g Carol D. Berger - EM Michael Weber - USNRC Licensing Branch Heather Astwood - USNRC Licensing Section 2 Penny Lanziiera - USNRC Region 1

A'ITACHMENT 1 CAN&rnQ confirmatory sampling- 'on

f

ATTACHMENT 1 CANAL.-&@Produdion Procedure for the

NUCOR-Hidunan Trial Shipment

1. preparing for CANAL-Lite Q Production

a. Preparation of Work Areas

i. Prior to the commemment of operations, a temporary restricted area shall be established and posted at the blending and Stoxage locations (CANAL-LiteQ production area) as instructed in RsP-012.

ii. The radiological charactensa 'cs of temporary restricted areas shall be determined and documented pursuant to RSP-008 prior to the start of work

(1) Contamination sweys for both removable and to& surface activity shall be conducted and documented on d b l e areas of the blending equipment.

(2) Ambient gamma Qdiation surveys shall be conducted in d e area where blending will take place and in each tempomy material storage area-

b. A Radiadon Work Permit (RWP) shall be prepared based on the anticipated radiological conditions to be eIlcountered during the blending operation.

2. Stagingofh!wed&p 'P-

a. L O W - V O I U ~ ~ area air sampling equipment shall be staged at locations designated by the RSO.

b. Mamials ~lecessary for confirmatory sampling of CAN&LirP(e.g., radiation detectors, sample screening containers, chain of custody forms, labels, shipping containers, etc.) shall be staged.

C. Materials and esUipmem for internal exposure monitoring using Breathing Zone Samplers shall be prepared for use:

i. Flow rates and battery strength for pumps shall be checked prior to use.

ii. Membrane filters shall be loaded into the fdter holders (cartridges).

d. For eachproductionnm, CANAL@andvanadiUm slag shallbe staged.

i. CANAL@ shall be staged within the mnporaly restricted area.

ii. Themmimlratioof vanadium slag to W A L Q o f 1-1 may be assumed for this aial nm.

f ALARA actions prior to the stitrt of work shall include the following:

i. Radiationsurveys in the vicinity of the staged CANALQ in the tanporary restricted area s h a u b e p c r f o r m e d d ~

ii. Findings of the radiation m e y s shall be communicated to production workers.

iii. Lowexposure rate work areas shall be designated based upon the survey results for use by production workers during production operations.

3. Radiation safety During CANAGLire@Production

a. A Radiation Surveyor shall perfonn radiation and contamination surveys periodically during the production process.

b. Contamination control methods as described in RSP-009 shall remain in effect.

C. Area air samples as described in RSP-008 shall be mllected during the blending operations, with airborne radioactivity concentrations determind as described in RSP-018.

d. Breathing zone samples for monitored employees shall be collected for the duration of work in the blending area.

Nde: W y authorized/trained personnel shall enter temporary storage areas and blending work areas.

4. CANAL-Lite @ Production

a. The staged vanadium slag and CANALQ shall be placed into feed bins.

b. Thevarn;adiumslagand CANAL@ shallbe passed through theblenderaminimum of two (2) times prior to its return to the bins.

Note: At the end of a 40,OOO pound production run, approximately 20 bins

and 2,500 pounds of CANAL-me@. of CANAL-&@Will be produced, with each bii contabing between2,Ooo

. c. The CAN&Liteein the bins shall be subject to confhmatory scmming/saxnpling prior to its tzansfer to NUCOR-H~C~IUIL

5. confirmatory screening/sampling

a. All SCreeniDg and sampling results shall be documented on a "CANAGLite@ Con6xmatory sanrpling- 'on" form.

b. AxqmsemativesiunpleofCANWQ shallbecolleaed6romeach of the bins that resulted fmm the production run.

C. Each sample shall be field screened as follows to ensure c o d o n variations a minimized.

Compliance with EPA Land Cleanup Schiager, K. J. and W. J. Smith, "Simple Field Method for Determrnsng . . Staodards", Symposium on U&um Mill Tailings Management, Colorado State University, Decanber 9,1982.

ii. Each sample shall be counted for sufficient time to ensure adequate counting statistics.

Note: A one-minute count should be made of both background and of the sample. If the sample count is 10 times the background count, no finther aajustment in ~ounting time is required. If not, increase the sample count time by one (1) minute and repeat.

From the individual counts for each of the 20 bins, the mean count h a l l be determined by: d.

where = the na count d t from bin number "i", and n = the total number of bins (samples).

e. From the individual counts for each of the 20 bins, the standard dmknion shall be determined by:

4 n-1 Standard Deviation = 0 =

f. Release criterk

i. If the maximum count does not exceed 2a of the mean, and ifa is less than 25% of the mean, the collection bins may be transferred to a tempomy storage location pending receipt of analytical results.

ii. If the maximum exceeds 20 of the mean or if a is greater than 25% of the mean:

(1) The contents of the bins shall be =-blended and step "d", above, shall be repeated; or

(2) Additional vanadium slag shall be added, the contents of the bins shall be re- blended, and step "d", above, shall be repeated.

g. The individual samples from the bins shall be composi tedand four (4) aliquots shall be collected and field mewed.

i. Each aliquot shall be placed into a measurement containex with a repeatable counting geometry.

Note: AonemurmLe * count should bema& of bosh backgmundand of the

adjurhrrpllrhwuntingfhlyisquinxl. HPOf,inawsetbealiquotcount aliquot. I f t h e a l i q u o t c o r r n t i s 1 o t i m e s t h e ~ d w ~ ~ f i a t h e r

time by om! (1) millute andrepe9t,

iii. Ifthe m c a n d stmiad deviation of the net aliquot coums does not overlap the mean and standad deviation ofthe individual sample results:

(1) The aliquots shall be returned to the bins

(2) The bins shall be re-blended

(3) Steps “d”, “e” and “g”, above, shall be repeated.

h. The aliquots shall be ground (to the consistency of powder or fine sand), blended, packaged, and a sample of each shall be forwarded to a commercial laboratory for determination of thorium and uranium isotopes.

Note: The laboratory sball have a USNRC or Agreement State radioactive materials license to possess and analyze radioactive materials, written procedures for sample preparation (i.e., grinding and homogenization) and for performing isotopic thor iduranium analyses and/or gamma spedroscopy, and a QA/QC program which assures the validity of the snalytid Iosults.

i. The sample size from each aliquot shall be at least one (1) kilogram.

ii. The samples shall be sealed into labeled sample containers.

Nate: The label should contain a unique sample number that is traceable to the produdion run number and the aliquot, the date and time of colledion, the name of the individual who collected the sample, and the required analysis. Sample preservatives an! not requid. The collection container should be padded or prdeded from opening during shipment.

G. The samples shall be forwaded by overnight mail, to the off-site analytical labomow for determination of uranium and thorium isotopes (by radiochemical extraction and alpha specm>scopY) Of i=T= (by spectr0scopY).

N e Based on expeded adivity concentratiolas (i.e., less than 2,000 pCi per gram of total adivity), it is not neoessarg to ship the samples as “radioactive material”.

Nate: ’Ibe pudxtse ordg for laboratory services shall contain the following specifications: (1) Couut times should be sfliaent to achieve a nominal

mstarial; a, ’ ‘- ofaIlthoriumanduraniumisotopes,inlmits of- pa gram” shall be reported; (3) A d d values, a l o e with the errorandtheMinimum -le Activity O A ) , shall be reported for each isotope. Do not teport “<MOA”, “< [valueJ”, “not &t.ected”, or any oahcr censomi value.

de&diOnlimitoflO piaxlub of each thorium/Uraniwn isotope per gram of

iv. A colllpletcd chain-0f-y fimn shall aammpany the samples b the laboratory.

1. When the analytical d t s from the samples have been received and validamk

i. The weight percent of each thorium and uranium isotope in each aliquot shall be determined as f O I i 0 ~ :

A, 1 Weight (ppm) =- - x - x 10’ i o f 2 SA,

where A = the Concentration of isotope "i" @Ci per gram) and SA = the specific activity of isotope Y'.

thew eight percent of^ . . Note: "be specific activities (SA) for deterrrrrmsg BTn, 33xlW7 CVg, 2.1~10' Ci/g, and 6.2xloJ C i g , respedively.'

Note For&

decay series shall be assumed to be in equilibrium with the parrnts.

Wy96U, andmu are l.lx107 Cilg, 1.!)x102 C i g , 83x16 C i g ,

* * gweight percent of thorium and uranium isdopes from pamnwspecbroscopy Ix!sld& eachof theprogary in the thorium and uranium

ii. The weight percent of each thorium and uranium isotope shall be summed and the total recorded on the " C A N A L - f i f e o C o ~ q Sampling Documemation" fonn from the production run in question.

iii. The certificates of analysis shali be attached to the "CANAuife~Confirmatory sampling Documentation" fonn.

6. Post production Activities

a. Prior to rehshg the production area for unrestricted use, a final status survey shall be conducted and documented.

b. CANAL-I.&%nay be shipped to NUCOR-Hiclnnan once documentaton is in place that confirms it contains only unimportam quantities of source mambl (iie., a mean weight percent that is less than 500 parts per million).

Note: Based on expected d v i t y conceofratr 'om (Le.., less than 2,000 pCi per gramof W d v i t y ) , it is not necess~ f~ r for CANAL-&&% be sbippedas 'radioactive material".

C. The radioactive material log shall be updared as described inRSP-014 to reflect the quantity of source material shipped off-site.

' Ti 10, Code of Federal Regulatiors, Part 71, "paclcdging and Transportation of Radiaactive Material", Appendix A, Table A-Iu).

1

A m A d 2 CANAL-I&+ C o n f i r y sampling Documeatation

IELDALLOY METALLURGICAL COR IRATION CANAL-Lite Confirmetory Sampling Documentation

Attachment 2 Page 1

Attachment

2 P

age

2

PROJECT NO: 880240 CLIENT: CLIENT PROJECT: DATE SUBMITTED: DATE REPORTED: PAGE:

AMlVfTY

IEM, Inc 84005.05

24-Mar-98 27-Mar-98

MDL p C h

LAB ID 880240-01 Th-232 53.4 10.0 0.4 CLIENT ID: 2026B-38-01 D A Z MATRIX:

Th-230 Th-225 U-238 U-235 u-234

Th-232 Th-230 Th-228 U-23B u-235 u-234

Th-232 Th.230 Th-226 U-238 U-235 U-234

Th-232 Th-230 Th-228 u-238 U-235 U-234

20.9 36.8 23.3 22 23 .?

38.5 20.6 32A 21.3 1.3 21 A

335 223 321 327 0.0 32.8

55.1 322 485 41.8 18 38.0

6.3 11.0 7.1 0.7 ?.Q

11s-4.- 6.2. 0.7 6.3 0.4 6.4

10.1 6.8 9.7 9.7 0.7 9.7

16.3 e.5 14.6 l2A 0.6 11.5

03 0.9 1 .o 0.3 lb

0.4 0.4 0.4 0.8 0 2 18

0.4 U S Ob 12 0.3 1.8

0.4 0.4 0.3 16 0 3 2 5

1. MDA-MlnhmanD.bllEtEbbAEbjvtty 2. BPL-Bd~~Drrbob'~t~Limlt Attachment 2 Page 3

.* .

. .

. . .

_-.. . . . .

QC DATA

PROJECT N O CLIENT: CLIENT PROJECT DATE SUBMJlTED: DATE REPORTED: PAGE

860240 IEM, Inc

84005.05 24-Mar-e8 27-Mar-fJB

;-. . -

fhm2 Th-230 7b-228 u238 u235 u234 Blank 0 +bDP 0 4-02 0,144.1 0.24-0.1 OP44.1 0.6+/-0.3 *. .. . . --.-.- ..

DUP (RPD) 20.9 22.0 10.1 @a NC ?.I LCS (% h e ) 103 98.0 B2.7 99.7

162 $42 83.6 MS (% Rec) 1 OB

MDRATORY APPROVALS:

March 12, 1998

Mr. itcm Eidknn

31 1 North Atpen Broken Arrow, Oklahonirr 74012

oulreach bborarory

4

Re: AmIysks of Slag Samples - lEM Job No. 94005.05

3 .

2.

3.

4.

5.

6.

7.

Fhch samplc wll! he appnxxirnaudy one ( I ) kilngram in size.

The plrrliclc siim in each wnple an brgc. Tiicrcfarc, to cnrmtc uniformity.

samplt: must bt gmnd and Mcndud

Attachment 2 Page 5

-

8.

9,

IO.

11.

12.

Preliminary ~c.sulLs, damped or marked LIS “draft” or “preliminary“ shall he sent hy facximile to JTiM’s Rockvillc, Mqland office. Por initial reporting purposes, the: vendor may h x T ~ J M ~ I S peneraled dirccdy by the intxrurnenution if so degird.

Once the prcliminaty results art: tlpprnvrd, two copies of the final ~qmt, including all yuality conml and chain of u i w y doaunentatin, may hc h c d . AI1 paper or elecmnic wpia it1 your possession Uial arc marked ”draft” M “p~~llirninary” shall be dmoyed.

”!IC I i h ) r a r t v hall commit to delivery if the preliminary mub within tlimr (3) days afkr saniplc rm4pt. ‘fie final q m m8y bc issucrl within tive (5) business dnys &r apptcnwl rd the draft mpon me find repnrt ahould ht scnt to me tit IEM‘rs RoJNille, Marykand ~ I ~ L X ! .

After authorizatkm is given by IZM, the sample may he teWincd to I&*s client. Stimplm iiol rcturiicd to the client within 30 days a f k h e of the find repart shall be disptad of hy the vendor at no ckage to IEM.

I

Pleafit. la m e kntw as scm 8s passible if you ake exception to my of the aforemculimcd I;pedficiiionns, and if a rcfwcnce number (if my) sbauld be: included m Ute sample shiprntrrt. If you have any y u d o n s or if 1 can provide you with additional i n f d o n , plcccsc call me at (301) 7624S02. ‘hank you in advane for your afir;iwnL! in this important projed.

Sincml y ,

Cat01 D. Bcrger, C,H .P.

a: I). R. Smith - SMC File 94005 .OS

Attachment 2 Page 6

8624186406 Shipper's reference

__ __ _ _ -- --- Company name

SHIELOALLOY METALLURGICAL CORP Shippers name '.- Address

national S~NIWS Shipper's account INT'L DOCUMENT EXPRESS 0 ReclPient 0 Third p a w

. . . Ace No . 0 Cash I Chack I Credit Cwd

!

PhonGaxE mall circle onslrequlredl WorldMali Servic*s 0 1st C I ~ U

Spula l S~rvlces eilrs chrtrl"s man spr/v

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c h h w O A P M O 2nd c l a s s 0 0 l h e t No . . . . . t b09l b92-V200

SATURDAY DELIVERY Expires . Type Shlpment Insuranca Wdo.*.d *mar

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Full descrlpt lon of contents

.i)oCuMdEJr~ 475 ALLENDALE IW.

0 Temporary 0 Repair/Retum

Them commodttie.. technology or ro~%~an m r e

*+?---- 0 Shipper 0 Other. . . . . . . .

Destination dutiedtaxes I f lef i blank recipient pays dutiewiexes

DESTINATION RlGlN

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