Text

Forwards Documents Board Requested in 890301 Prehearing Conference Order,Including Insp Repts 87-04,dtd 871124 & 88-21,dtd 880426,info Re Radiological Surveys Taken at Five Locations Used by Larsen & Larsen Labs State of UT License
	ML20245A410
Person / Time
Issue date:	06/09/1989
From:	Hodgdon A; NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Bechhoefer C, Kline J, Shon F; Atomic Safety and Licensing Board Panel
References
	CON-#289-8760, REF-QA-99990004-890609 CAL, NUDOCS 8906220008
	Download: ML20245A410 (47)
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.....' June 9, 1989 '89 JLN 14 PS :03 (cNd; ape y hhti Dr. Jerry R. Kline . Charles Bechhoefer, Chairman Atomic Safety,and Licensing ' Administrative Judge Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Frederick J. Shon.

Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20355 In the. Matter of WRANGLER LABORATORIES .LARSEN LABORATORIES ORION CHEMICAL COMPANY AND JOHN P. LARSEN ,

Docket No. 9999004 1

Dear Administrative Judges:

This letter forwards copies of documents which the Board requested in )

its March 1,1989 Prehearing Conference Order. Enclosed are: the Region IV j Inspection Reports 87-04, dated November 24, 1987 and 88-21, dated April 26, i 1988; information regarding radiological surveys at the 5 locations in Utah ' ;j that were used by Mr. Larsen; a copy of Larsen Laboratories Licens Number, !

UT-2500183 issued by the Utah Bureau of Radiation' Control; and the Confirma-tion of Action Letters dated November 12, December 8, and December 31, 1987 and March 18 and April 1, 1988. j Sincerely, ;

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O N Ann P. Hodgdon ,

Counsel for NRC Staff cc: Service List j R90622000s 890609 REQ 4 GA999 EXIWRANG ro 6

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IOf24 W I General License i Docket: 99990004/87-04 EA: 87-223 Wrangler Labs c/o Larsen Labs Inc.

ATTN: John P.-Larsen,_ President-3853 North Sherwood Road Provo, Utah 84604 Gentlemen:

This refers to the special, announced radiation safety inspection. conducted by Mr. D. B. Spitzberg of this office on November 4-5,.1987, of the activities authorized by the General License provisions of 10 CFR 40.22, and to the discussion of our findings held b the conclusion of the _ inspection.yThethe'enclosed NRC inspector with Mr.-John Larsen at NRC Inspection Report 99990004/87-04 documents this inspection.

The inspection was conducted to review allegations of unsafe practices at your Evanston, Wyoming facility. The inspection was an examination of the activities conducted under the general license as they relate to radiation safety and to compliance with the Commission's rules and regulations. The inspection consisted of selective examinations of procedurea and representative records, interviews of personnel, independent measurements, and observations by the NRC inspector.

During this inspection, certain of your activities appeared to be in violation of NRC requirements. We are releasing this report at this time for your information and you are encouraged to review our findings and take corrective action as you believe appropriate. You will be notified by separate correspondence of our decision regarding enforcement action based on the findings of this inspection. No written response is required at this time.

This letter also confirss the telephone conversation between Mr. John P. Larsen and Mr. R. J. Everett of my staff on November 10, 1987, concerning your commitments to take certain actions including the cessation of uranium ~

processing and our request to conduct an enforcement conference _ to address the findings of the NRC inspection referenced above and your response to these findings. As agreed, the enforcement conference will be held at the Federal Building, 125 S. State Street, Salt Lake City, Utah, Room 3425 on December 2, 1987, at 1:00 p.m.

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4-Wrangler Labs Should you have any. questions concerning this letter, we will be pleased to discuss them e!th you.

Sincerely, c~-

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William L. Fisher,_ Chief .

Nuclear Materials and Emergency' Preparedness Branch

Enclosures:

1. Appendix A - NRC Inspection Report-99990004/87-04

2. Appendix B - Source Material Receipt and Transfer cc w/ enclosures:

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} APPENDIX A U.S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 99990004/87-04 License: General Docket: 99990004 l Licensee: Wrangler Labs Unit 121 Top of. Sage Industrial Park Evanston, WY 82903 Inspection At: Evanston, Wyoming Inspection Conducted: November 4-5, 1987 Inspector: / h@ bx/ 8. M u_ //!A3 h7 Date

/ D. Sp 5pitzberg,s Nuclear MaterialInspection Sectionfeyior RadiatioF5pedalist Accompanied By: J. E. Haes, Jr., Chief, Radiological Health Services, State of Wyoming Approved: W81 2014 / $ d ///z3!g7 R. J4tverett, Chief, fuclsat Materials Date Inspection Sect %n l

Inspection Summary Inspection Conducted November 4-5, 1987 (Report 99990004/87-04)

Areas Inspected: Special, announced inspection of activities conducted under general license provisions of 10 CFR 40.22, and review of an allegation of

, unauthorized and unsafe use of licensed material (case 4-87-A-082). Included in the inspection was a review of radiation protection practices, selective examinations of procedures and representative records, interviews of personnel, independent measurements, and observations by the NRC inspector. _

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Results: Within the areas inspected, two apparent violations were identified. ;

for possession at one' time of more than the general license limit of 15 pounds I of source material (Section 6.a) and for possession of quantities of licensed j material which requires a specific license without having been issued a j specific license (Section 6.a). These violations appeared to have occurred on !

several occasions since March 1987. The allegation of an unauthorized user was :

substantiated in that the user was found not to be authorized to possess and use. source material in excess of general-license quantities. The alleged use {

of source material in an unsafe manner was substantiated and the investigation I into this allegation did result in identifying the apparent violations j referenced above and two open items referenced in Sections 6.d and 7.

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t DETAILS

1. _

Persons Contacted

John P. Larsen, President, Wrangler Labs A11eger

Present during the exit briefing.

2. Reason for Special Inspection On October 28, 1987, Region IV was notified by the Wyoming Health l Department of an allegation it had received concerning activities which were being conducted at a mini-warehouse located near Evanston, Wyoming.

The allegation ouestioned the authorized use of licensed material at that location.which reportedly involved the chemical processing of uranium-238 into a chemical catalyst product. The allegation also: questioned if the -

user was operating in a safe manner according to NRC requirements. The user had stated that he represented two organizations:; Wrangler labs, Provo, Utah; and Orion Chemical, Provo, Utah. The NRC inspector was dispatched to inspect activities at the site. He was accompanied by a representative of the Wyoming Health Department.

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3. Background The company president, who was the alleged unauthorized user, had over the years been involved in the processing of depleted uranium (DU) to the product uranyl acetyl acetate (UAA) in the state of Utah. He had previously worked under a general license pursuant to 10 CFR 40.22 under l the name of Orion Chemical Company. The-licensee's facility was inspected by the NRC in August 1982, at which time four violations of NRC-requirements were identified. Included in these were a violation for.

i possession of more than the general license limit of 15 pounds of. source material at one time during August 1982, and a violation concerning l contamination found outside the facility resulting from unauthorized -

disposal. Following the August 1982 inspection, the NRC issued an Order to Show Cause and Order' Temporarily Suspending License to Orion Chemical on September 3, 1982. The Order was rescinded on October 25,- 1982, af ter I

the licensee had implemented suitable corrective action, and'following the l September 1982 reinspection of the facility. On December 15, 1982, the NRC assessed Orion Chemical Company a civil penalty for the violations identified during the August 1982. inspection.

In May 1982, Orion Chemical had applied for a specific license to conduct the same activities it had previously conducted under the general license.

This license (59B-1436) was issued in December 1983 and was reissued under a different name, Larsen Laboratories, on May 13. 1985, by the state of Utah fo110 win 94ts becoming an agreement state. According to information received from the State of Utah, Larsen Laboratories was investigated by l

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i the State Bureau of Radiation Control during the period April through May 1986 with several violations identified. A Notice of Violation, Order, and Order to Show Cause was issued by the state in June 1986.

According to the Order, the violations. collectively showed a " careless disregard by the licensee of Department of Health requirements." On July 30, 1986, the state issued a Proposed Imposition of Civil Penalties to Larsen Laboratories. Following a September 1986 hearing, the state issued a November 5,1986, order suspending.the license and imposing civil penalties. This followed the October 1986 inspection by the state, which

' .l showed many of the violations to be uncorrected. 1 I

Note: Under the general license provisions of 10 CFR 40.22, a licensee is exempt from the requirements of 10 CFR Part 19 " Notices, Instructions, and Reports to Workers; Inspections";. and 10 CFR Part 20 " Standards for Protection Against Radiation."

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4. Process Description I

The NRC inspector discussed with the company president the activities he had been conducting in Wyoming and reviewed a pamphlet containing the process description. This description had apparently been submitted in !

support of previous specific licenses. In simplified form, the licensee '

had been receiving from a supplier DU metal slugs, which would be dissolved into solution using nitric acid, followed by the precipitation of UAA using 2,4 pentanedione. To the precipitate would be added benzene j to promote recrystallization of UAA. The product would then be filtered, ,

dried, ground, and packaged. The licensee had been processing lots of 15 pounds or less of DU, as this was the possession Ifmit of the general ;

license. VAA product contained generally between 45 and 48 percent DU by 'l weight, j

5. Facility Description i

The NRC inspector toured the licensee's facility on November 4, 1987. The l licensee had leased the Quonsehtut type building in January 1987 and had !

received the first shipment of DU from the supplier in March 1987. The approximate 30 X 40 foot area comprising the licensee's facility appeared orderly on the day. of the inspection with no active processing ongoing.

The facility was equipped with stainless steel work benches, catch basins, and storage cases. There was no plumbing to the facility. . The NRC inspector observed two S5 gallon drums of benzene, one each of 2,4 pentanedione and nitric acid, and a smaller container of sulfuric !

acid. There were also several- containers of used process chemicals bearing dissolved uranium. Two contaminated waste barrels were observed, each containing some contaminated dry trash as detemined by radiation survey. Process equipment observed included numerous stainless steel buckets, hot plates, three microwave ovens used to dry the product,' and a blender used to, pulverize the product. Some rolls of linoleum had been placed on theJpor; however, most of the floor area was t:oncrete. ,

Despite descr,iptions in the licensee's pamphlet of ventilation hoods, HEPA filters, and provisions for air sampling, which may have been utilized in

1 I b the licensee's Utah operations, the NRC. inspector;found little in the way of engineering controls to control potential airborne radioactivity.

Processing had been conducted in open air using only natural ventilation, except for the nitration step, which did.have a crude suction fan and wet scrubber to remove acid fumes and oxides of nitrogen.

6. Documentation Reviewed-

a. Receipt / Transfer / Shipping Records -

The NRC_ inspector reviewed records of licensed material receipt and transfer since the Wyoming operations began in January 1987 (see Appendix B). According'to these records, the licensee did not-receive more than the 150 pound general license limit per calendar-

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year of source material. ' Records indicated, however, that during'the periods March 27 through April 7; April 21-30; June 1; June 26-27; August 6-7; and September 23. through November 5,1987, the licensee was in possession of more than the 15 pounds of source material at one time authorized by the general license provisions of 10 CFR 40 and without a specific license. These findings were identified as apparent violations of 10 CFR 40.3 and 40.22(a). .The company president indicated that some of this overage was from residua 1' product recovered from waste material from his Utah operations. Licensee-records of material receipt, transfer, and disposal were found to have been maintained in accordance with 10 CFR 40.61,

b. Waste Disposal The NRC inspector reviewed records showing the May 29, 1987, shipment of 17 drums (127 ft3 ) of dry waste to the University of_ Utah for disposal by burial at a licensed waste burial facility. Most of the waste war from the previous Utah operations and was disposed of under State of Utah Order dated November 5,1986.- As noted earlier, under' the provisions of the general license, the licensee is exempt from the waste disposal requirements of 10 CFR 20.301 .311.

c. Licensee Surveys / Instrumentation The NRC inspector reviewed available smear surveys of alpha contamination performed by the licensee following cleanup from each process batch. The surveys were made using an alpha scintillation detector and revealed no levels above the NRC recommended guidelines of 1000 dpm/100 cm2 . There was a total of 36 individual smear survey results recorded since the Wyoming operatiens began'in January.1987.

The licensee was also in possession of two portable beta gamma survey instruments; however, any results of use of these instruments had not been recorded. Certificates showed that licensee instruiiients had been ca11 treated by the manufacturer in late 1986. The licensee also had a high-volume and a breathing zone air sampler; however, no >

calibration data.or measurement results from tnese instruments were available for review.

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d. Users / Personnel Dosimetry The NRC inspector reviewed the available records pertaining to personnel exposures, which had been maintained largely as a result of 3 previous operations in Utah. According~to these records,.four J individuals had been inv'olved in some manner in licensed activities.

Some of these were college students. Because of the general license provisions of 10 CFR 40.22, there are no requirements for.

identification of,.or training.and. qualifications of users. But since the user exceeded the general _ license quantities of source material without a specific license as'noted in Section 6.a. he was found to be unauthorized to conduct such activities. Three:

individuals had been issued thermoluminescent dosimeters from l

. September 1986 to the time of the inspection, with external exposures all minimal. A whole body count performed on the company president in July 1986 was below. the 9 nCi action level of Regulatory Guide 8.22, Bioassay at Uranium Mills." Urine bioassays on three-individuals were submitted to a contractor laboratory in June 1985,.

June 1986, and February 1987. All results were below.the Regulatory l Guide 8.22 action levels except for one individual, whose February 1987 sample measured 108t5 pg/l uraniumi The individual was resampled in March 1987 with the result <5 pg/1. The higher sample could indicate excessive internal exposure and inadequate airborne i uranium confinement. Also there was no data to show how long after a potential intake the sample was obtained. This finding is ,

considered an open item pending further urine analysis of the 1 individual for uranium and-albuminuria. (0 pen Item 99990004/8704-01) ;

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7. Independent Surveys The NRC inspector performed random radiation surveys for direct alpha,

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beta gamma, and removable alpha contamination both inside and outside the a licensee's facility. Of 14 smear _ surveys, .all were less than 1/3 of the NRC guidelines for removable alpha contamination for unrestr.icted areas.

Direct alpha surveys showed measurable surface contamination above.

background throughout the facility. Three areas surveyed were above 2 the NRC guidelines for average surface contamination.of 5000 dpm/100 cm ,. and one of these was more than twice the guideline for maximum surface 2

- contamination of 15,000 dpm/100 cm . . This find!ng is considered an open l item pending proper licensee removal of this contamination (south catch -

basin support) (0 pen Item 99990004/8704-02). Beta gamma surveys using a pancake probe and count-rate meter also showed low leve1 ~ surface contamination throughout the facility. Evidence of loose contamination was found100 (background by cpm survey)ing

, and. dustthe

/ dirtair filter floor of a portable sweepings heater

- 1800 cpm. No - 1800 cpm evidence of contamination was found outside of the facility.

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8. Exit Briefing The NRC inspector met with the company president at the conclusion' of.the inspection to discuss the findings. The president was-informed.that Region IV management would review the findings before taking enforcement action, and that a decision would be made concerning~ the appropriateness of continuing such operations under the regulatory exemptions provided by the general license.

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- APPENDIX B SOURCE MATERIAL RECEIPT AND TRANSFER Source Material Source Materici Apparent Net Balance i Date Received (1bs) Shipped (1bs) Onhand (1b) j 03/03/87 15 --

15.00.

7.38 03/24/87 -- 7.62 ..l 03/27/87 15 22.38 G ivi-03/29/87 -- 7.06 15.32 @ j 04/07/87 -- 6.55 S.77 04/18/87 -- 7.92 0.85 ;

04/21/87 15 --

15.85 @ d2 04/30/87 --

p 8.80 f . -P 7.05 j 16.69 d) d3

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06/01/87 --

16.69 06/02/87 15 15.00 06/13/87 --

7.80 7.20 ]

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'22.20- @ d4 06/26/87

. 06/27/87 -- 11.00 11.20 07/12/87 -- 12.71 # 12.71-1 07/17/87 15 15.00 08/06/87 15 8.10 21.90 @ +f i 08/07/87 -- 16.77 .

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09/03/87 -- 13.65 13.65 09/09/87 15 --. 15.00 l

{ 09/23/87 '15 30.00 6 09/30/87 -- 10.14 _19.86

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10/19/87 15 12.79 22.07 b '

Total ,150 147.60 1

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' i APR 2 61988 y

lJ General License Docket: 99990004/88-21 -

EA: 87-223 l L

Wrangler Labs !

c/o Larsen Labs, Inc. -

ATTN: John P. Larsen, President'

3853 North Sherwood Road

Provo, Utah 84604 Gentlemen:

'This refers to the special, anncunced radiation. safety inspection conducted by Mr. D. B. Spitzberg of inis office on April 6 and 8, 1988,.of the activities authorized by the General License provisicrs of 10 CFR 40.22, and to the discJssion of our findings held by the NRC inspector with Mr. John Larsen at the :onclusion of'the inspection. The_ enclosed NRC Inspection Report 99990004/88-21 ~ documents tnis inspection.

The inspection was conducted in order to verify compliance with NRC Confirmation of Action Letters with respect to the removal of licensed material and decontamination of the Evanston faci'.'ty, to _ rev'ew-the' action taken in response to previous inspection findings, and to perform an independent closecut survey. The irspect'on consisted of selective examinations of procedures and representative records, in erviews of personnel, independent measurements, and observations 3y the NRC inspector.

No violations of NRC requirements were ideltified during this inspection.

Should you have any questions concerning tnis letter, we will be' pleased to discuss them with ycu. j Sincerely, l

'Origind Slgned By j i

Wilitam L. Fisher, Chief- 1 Neclear Meterials and Emergency. ;

Preparedness Branch '

Enclosure:

Appendix - NRC Inspectdon Report :

99990004/88-21 w/stt.achment cc w/ enclosure:

Utah Radiation Control Program Director Wyoming Radiation Control Program Director !

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' APPEND 1h U.S. NUCLEAR REGULATORY COMMISSION f REGION IV J 1

i License: General' HRC Inspection Report: 99990004/88-21.

Docket: 99990004 Licensee: Wrangler Labs Unit 121 Top of Sage Industrial Park Evanston, Wyomirg 32903 Inspection At: Evanston, Wyoming Inspection Conducted: Aard1 6 and 8, 1989

/-#g-88 Inspector: f/[ (( M u.

IT.,_B. Spi ~tzoergf,3dnpr Ratf ation Specialist Date

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D. A. Powers, Cnief , Nuclear Materials Date '

Inspection Section Inspection Summary InspectionCondLctedApri'6Brid8,1988,,(Repcrt 99990004/88-21)

Arens Inspected: Special, announced instsetion of activities conducted uncer The inspection was conducted to general license provisions of 10 CFR 40.M. verify the removal of licen that it could be retumed to unrestricted use, and to review action taken in Included response to two open items identified during a previous inspection.

in the inspection was a review cf radiation protection practices, selective l

examinations of procei'res and representative records, interviews of personnel, independent measuren its, and observations by the NRC inspector.

Results: Within the areas inspected, no v#olations or deviations were ioentified. All licensed material was c:nfirmed to have been properly rem 3ved from the facility and surveys showed that previously identified areas of The surface contamination hac been decontamina.ed to below NRC guicelines. One og ~ item facility is therefere considered released for unrestricted use.

was identified pencing The sbbmittal ot" bioassay results obtained from individuals during the cleanup activities (Section 4).

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DETAILS

1. Persons Contacted

' John P. Larsen, President, Wrangler Laos Sally Larsen, f acility cleanup worker Kevin Noacx, facility cleanup worker i

Present during the exit. briefing.

2. Reason for Special Inspection On November 4-5, 1937, an inspection (Ntt Inspection Report 99990004/87-was conductsd of the licensee's facility at Sage During the- Industrial No. 4 A-082) made concerning acthities at the f acility.

inspection, two open items were ide itified pending licensee followup to an elevateo cioanoj result from a licensee employee, and for On January areas 19-20, 1988,of fixed surface contamination exceeding NRC guidelines.another survey w Ridge Associated Universities (ORAU), and a procedure was prepared for the safe decontamination of tne f acility and disposal of radioactive waste.

25, 1988, the. general licenses '5 sued to By NRC Orcer dated February Mr. John Larsen and his companies we e suspended and th to properly dispose of all licensed material in their possession Evanston, Wyoming.1988, Mr. Larsen comnitted to perforning the reauired de disposal activities in a:cordance witn the procedures described in the ORAU report.

The NRC inspector visited the facility on April 6 and 8, 1988, to review the licer.see's followup to the open items, to verify that licensed material had bee 0 packaged or removed from the facility, and to verify thrcugh independent measurements that the facility had been decontaminated to safe lesels below NRC guidelines.

3. Licensee Action on Previous Inspecticn findings This. item concerned the need to (Closed) Ooen Item (99950004/8704-01):

perform followup urine analysis for uranium and albuminuria for an The NRC-employee wnose February 1987 urine sanple measured 108 17, pg/1.1987, to inspector contacted this, individual by telephone on November inquire into his activities which may have caused this elevatedThe i measuremen. result.

activities involving source material in Wyoming but that he had performed general labor for the licensee at the Evanston location on a few occasion He Utahstated that locations he were which had been involved performed under in tie issued order decontamination by the state'ofwork at t l

Utah on November 5,1986, and that sone of theHe work involved recalled removal that he. wore of i

surf ace contamination using an elsctric grinder. .

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a dust mask and goggles but that the work environment had been very 'dus.y..

The state of Utan was inforw d of th's information by the,NRC inspector Followupat :

the December 2, 1987, enforcement cc1ference witn the licensee.

urine samples.for this'. individual.were obtained oyBoth the licensee glass andinplasti:

1987.-

accordance with the CAL dated November 12,ing 26't'2 pg/l'and 7 1 3pg/1, -

containers respectively.were used with the results showAlbumin test results were negative (i.e range). This item is considered closef This item was.open pending (Closed) Open Item (99990004/8704-02): licensee'remova' of an area of above the NRC guideline.. The NRC'irspe: tor verified that this' contamination', which was on.the surfue'of a basin support, was removed Other areas of by disposing of;the basin support as radioactive waste, lesser contami Section 4. . This item is corsidered c'esed.

4. Licensee Decontamir.ation and Waste Disposal Activities On April 6,1988, the NRC inspector observed the fina' cleanup work at the facility and noted that ,he ORAU recommendedMuch contamination control, of the facility and hardware protective clothing procedures were h use.

had already been moved to the licensen's Linden, Utah, facility as agreed This agreement was to permit to by the licensee, bRC, and state of Utah.

the licensee to consolidate radioactive waste from Wyoming with that already held ir Utah from previous operations pending authorization for-burial. It would als.o allow the 14censee to store certain laboratory equipment identified in tre OP.; resort as having fixed surface contamination above NRC guidelines entil.a decision is made on the licensure of' future operations. ' The areas which had previously been identified in the ORAU report as hating elevated surf ace contamination in the Evanston f acility had been cecer, tap nated. Licensee surveys using appropriate instrumentation showed these and other areas to be less than NRC recommended guidelines for contamination levels in unrestricted areas.

Contaminated wasta had been placed n solid form in SS-gallon drums for transfer to Utah, Licensee survey, calibration, and inventory logs were-reviewed and found to be in order. The urine samples committed to This as part-of the decontatirntion procedures had not been sent- for analysis.

was identified as an lo en item (99930C04/8ts21-01) pending NRC review of all urine sample resuTts from the Evanston cleanup work.

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On April 8, 1988, all equipment was observed to have been removed from the Evanston facility and transferred to Linden, Utah. Only a sealed barrel On April 12, 1988, the.

of contaminated waste remained to be transferred.

NRC inspector telephoned the licensee who stated that tais last drum of waste had been trans.ferred to Linden, btah, pending final disposal.

No violations or deviat'ons were icentified by the NRC inspector.

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5. Independent MeasJreffentj On April 6, 1988, the NRC inspector pt-formed su-veys of the Evanston f acility using calibrated instruments f 4tted with. an alpha detector and a beta gamma pancake detector.

Particular emphasis was placed on the areas.

These previously identified with elevated fiu d surface contamination.

areas had been treated by wet grinding. The results All of the surveys are areas surveyed,.

summarized in the attachment to t31s. report.

including those previcusly. identified. in the ORAU report as having elevated contamination levels, had been successfully decontaminated to levels less than NRC guidelines for antastricted areas. The facility, having been decontaminated to safe levels, and having had all equipment '

and waste removed, is cons.idered by the NFC to be. available for unrestricted use.

No viciations or deviations, were ider.tif'ed by the NRC~ inspector.

6. Exit Briefing The NRC inspector tret with Mr. John I.arsen at the conclusion of the inspection o disetss the findings. tir. Larsen was informed that, pending removal of the final sea'ed waste drun (which subsequently took place on April 11,1988), ar.d NRC tanagement . approval, the Evanston facility would be considered available #or unrestric;td ase.

Atti.chment: NRC Independent Survey - April 6,1988 I

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5 ATTACHMEh]'

NRC INDEPENDENT SURVE'r - APRIL 6, 1988 BUILDING 1214, SAGE 1600STRIAL PARK EVANSTON, WOMING J INSTRUMENTATION:

EBERLINE PAtl5GA with AC-3 alpha probe LUDLUM 3 witn 44-9 pancake 3M probe l

FLOOR AREAS IDENTIFIED HAVING ELEVATED BETpCAMMA CONTAMINATIO

! TURVEY OF JANUARY 19-20, 1988

NRC Measurement 4/6/88' ORAU Measurement 1/19-20/Ej dpm/100cm' dpm/100cm' beta-gamma

teta-gamma . direct alpha- removable (max) alpta '

Area Avo. Max : imp L

-346 <100-652" 6450-1 N/A 692 <100 410C- : 4032 2 N/A 692 <100' 10080 : 4032 3 N/A 346- <100 9225 : 4032 4 N/A 692- <100 177000 : 4032 5 N/A 692 <100 75000 : 4032 l 6 N/A .346 <100 11750 : 4339 7 N/A 692 <100 16400 : 4032 block B,2 5083

^4032 346 (100 7940 :

block B,8 6530

4839 346 <130 block F,9 6190 9090 105U NRC 5000 15000~ : '3U00 15000.

guideline All other areas randomly t.orveyed on April 6, 1988, were less than the applicable guideline.

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E UTAH BUREAU OF RADIATION CONTROL BRC-03 ;

RADI0 ACTIVE MATERIAL LICENSE . April 1984' 4

~

?ursuant to Chapter 1. Title 26-1-27 of the Utah Code, and the Utah Department of Health '

peculations for the Control of Ion 171ng Radiation, and in reliance of statements and .

5 presentations heretofore made by the licensee designated below, a license is hereby issued i Authorizing such licensee to transfer, receive, possess and use the radioactive material bsignated below; and to use such radioactive material for the purpose (s) and at the place (s)

Jesignated below. Thir licensee is subject to all applicable rules, regulations, and orders sw or hereafter in etfect and to any conditions specified below.

Licensee ) 3. License Number

) UT 2500183

1. Name Larsen Laboratories )

) 4. Expiration Date

?. Address 3853 North Sherwood Drive ) December 31, 1988 Provo, Utah 84604 )

) 5.

) Replaces NRC License No. SUS-1436 Ddioactive material 7. Chemical and/or physical form 8. Maxinun quantity licensee may amont cnd mass natier) possess at any one time jranium (Depleted in A. Any A. 150 Kilograms Jranium 235)

Authorized Use A. To be used in Manufacturing Catalyst for Weapon Systems.

(TIONS Licensed material shall be used only at 2000 South 450 West, Orem, Utah, in the Gold Key

Storage Unit #3.

The licensee shall comply with the provisions of Chapter URC-48 ' Notices, Instructions and Reports to Workers, by Licensees or Registrants, Inspections' and Chapter URC-24, ' Standards '

for Protection Against Radiation *.

Licensed material shall be used by, or under the supervision of John P. Larsen. j The licensee may transport licensed material or deliver licensed material to a carrier for transport in accordance with the provisions of URC-19-500 " Transportation".

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BRC-03 April 1984 1 Page 2 of 2 l 1

UTAH BUREAU Or RADIATION CONTROL i

,, RADI0 ACTIVE MATERIAL LICENSE '

]

SUPPLEMENTARY SHEET j j

License # UT 2500183 1

The licensee shall notify the Bureau in writing when the licensee decides to j permanently discontinue activities involving materials authorized under the license, and report to the Bureau the disposition of licensed material.

Except as specifically provided otherwise by this license, the licensee shall possess and use licensed material described in Items 6, 7, and 8 of this license in accordance with statements, representations, and procedures contained in letter dated April 15,1985, and in - ;

U.S. Nuclear Regulatory Cownission license SUB-1436 as in effect April 1, 1984. The Utah 1 Bureau cf Radiation Control Regulations shall govern the licensee's' statements in .I applications or letters, unless the statements are more restrictive than the regulations.

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-A L ic / l 43 -

tarry r. A er' son, Director Bureau of Radiation Controi 1

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. s-In Reply Refer To: I Docket: 99990004/8704/ Cal 87-24 General License: Wrangler Labs, Evanston, Wyoming EA 87-223 i

Larsen Labs, Incorporated ATTN: John P. Larsen, President 4 3853 North Sherwood Drive !

Provo, Utah 84604

Dear Mr. Larsen:

SUBJECT:

CONFIRMATION OF ACTION LETTER l

This is to confirm the conversation between Mr. John Larsen, Wrangler Labs and l Mr. R. J. Everett, USNRC, Region IV on. November 10, 1987. Based on this conversation, it is my understanding that Wrangler Labs, and/or Larsen Labs, and/or Orion Chemical is taking the following actions: ;

1. Immediately cease all receipt of, and effective November 13, 1987, cease j all processing of licensed material (depleted uranium) until such time that it is further authorized by the NRC. The period between November 10-13, 1987, may be used to complete the processing of the

. licensed material on hand according to your procedures so long as such processing does not exceed 15 pounds of source material. The individuals performing this work will wear lapel air samplers to determine personnel exposure to airborne radioactivity, and will submit urine samples for

, uranium determinations b* fore beginning the procedures, and between 48 and j 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />,following completion of the procedures.

l 2. Effective Nove,3er 13, 1987, secure all licensed material on hand and any ;

l equipment previi usly used to process licensed material at Evanston, !

l Wyoming in its present location at Jay-Gee Industrial Park, Unit 1214, ;

I Evanston, Wyoming. Prevent all access, disposal, or removal of licensed i material from this location until further authorized by the NRC.

l Shipments of final product, up to 15 pounds of source material may --

continue.

l

3. Arrange to have your employee identified by the initials S whose *

, February 18, 1987, urine bioassay measurea 10B vg/1, submit a vrine sample to a qualified laboratory to be tested for uranium and albuminuria.

Report the results of the test to this office upon receipt.

1 CERTIFIED MAIL RETURN RECElPT RE00ESTED Sh E0 d 6, S' RIV:NMIS W J -

DB5pitzberg;ap C:

RJERYett C:NMEPB WLFisher D:D RLB6ngart DAPowers RA AI 87-457 RDMartin is/ @67 ll/g4 /87 11 //^/87 !! /(7/87 n /n /87 / /87 I

_]&

' 7 .I CF 2_ P/'"'

4 002

Larsen Labs, Incorporated 1 I

lssuance of this Confirmation of Action Letter does not preclude the issuance of an order formalizing the above commitment. If your understanding differs from that set forth above, please call Mr. R. J. Everett at (817) 860-8187 immediately.

Sincerely, ti-Robert D. Martin ,

l Regional Administrator

' CC:

Wyoming Radiation Control Program Director Utah Radiation Control Program Director bec:

DMB - IE-07 RDMartin 4 RLBangart REHall WLFisher RJEverett CLCain DAPowers/

T0 Martin, DEDRO Staff JLieberman, OE B5ummers, OE HLThompson, NM55 JCarson NMEPB RIV Files

~

DEC 8 198T ~~'

In Reply Refer To:

Docket: 9999004/8704/ CAL 87-24A General License: Wrangler Labs, Evanston, Wyoming EA 87-223 Larsen Labs, Incorporated ATTN: John P. Larsen, President 3853 North Sherwood Drive Provo, Utah 84604

Dear Mr. Larsen:

SUBJECT:

CONFIRMATION OF ACTION LETTER This is to confirm the conversation between Mr. John P. Larsen Wrangler Labs and Mr. William L. Fisher. USNRC, Region IV,on December 4,1987. Based on that conversation, it is my understanding that Wrangler Labs, Larsen Labs, and/or-Orion Chemical will ti,ke the following actions:

1. By December 8, 1987. obtain, from the following persons, urine samples for uranium analysis by a reputable bioassay laboratory. These urine

4mples are to be voided into containers known to be free of uranium contamination, and the date and time of voiding are to be documented.

O

2. Provide this of fice the address, if available, or a description of the California and Nevada location (s) at which depleted uranium in any form or quantity has at any time been received, processed, or shipped by Mr. John P. Larsen or by any other person on Mr. Larsen's behalf.

3. Dispose of licensed material (depleted uranium) remaining in the Evanston, Wyoming facility. Material in process but not recovered as UAA when operation ceased on November 13, 1987, may be either: (1) processed to

UAA and transferred to a customer or (2) disposed of as radioactive waste.

/

4. Decontaminate all surfaces and equipment within the Evanston, Wyoming facility to or below the following levels:

Average' fixed - 5,000 dpm alpha per 100 cm2 Maximum fixed - 15,000 dpm alpha per 100 cm2 Removab.le - 1,000 dpm alpha per 100 cm2

Average over an area not greater than I square meter.

CERTIFIED MAIL RETURN RECE]pi REOUESTED l RIV:NMIS PNs C:NMISY,C:NMEpBh'h:DR ~

DB5pitzberg;ap RJEveret't WLFisher RLBa t EO Af DApowers RA RD tf 87-457 O/'/87 L/7 /87 iE/'/87 p /d/87 it.// "/877 ,f$

~ " '-- ~ ' '

4 002 L_--_--

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Letter to Larsen Labs, Inc. l

5. Complete the disposal and decontamination work by December 31, 1987, and notify this of fice so that we can. make a confirmatory survey bef ore you vacate the facility.

6. Upon vacating the facility, remove 611 items not belonging to the facility owner.

Issuance of this Confirmation of Action Letter does not preclude the issuance

- of an order formalizing the above commitment. If your understanding differs from that set forth above, please call Mr. W. L. Fishe: at (817) 860-8215 or ,

Mr. D. B. Spitzberg at (817) 860-8191 immediately. !

Sincerely, WG!NC . ;:.. ,; p P. C K r,7 9. ,. g. y Rcbert D. Martin Regional Administrator cc:

Wyoming Radiation Control Program Director Utah Radiation Control Program Director bcc:

DMB - IE-07 RDMartin RLBangart REHall WLFisher j

RJEverett CLCain DAPowersv/

j JMTaylor, DEDRO TOMartin, DEDRD Staff l JLieberman, D/DE LJChandler, Asst. GC/DGC B5ummers, OE l HLThompson, NM55 JCarson NMEPB RIV Files l

l

9,. < c. ~..

6 v y

J. t In Reply Refer To:

Docket: 99990004/87-04/ CAL 88-02 ran ensee: Wrangler Labs, Evanston, Wyoming - M- g 1A 87-2 Wrangler Laboratories, Anc, ATTN: John P. Larsen, President 3853 North Sherwood Drive Provo, Utah 84604

Dear Mr. Larsen:

SUBJECT:

CONFIRMATION OF ACTION LETTER This is to confirm the conversation between Mr. John P. Larsen, Wrangler Labs and Messrs. Dale Powers and Blair Spitzberg, USNRC, Region IV on March 18, 1988. On January 19-20, 1988, a survey was made of your Evanston, Wyoming, facility by Region IV and our contractor, Oak Ridge Associated Universities.

The purpose of the survey was to define any areas within the facility that exceeded NRC guidelines for contamination, and to outline a plan for you to use in decontaminating the facility and disposing of contaminated waste so that the facility could be returned to unrestricted use. The survey findings and decontamination plan are attached to this letter.

In accordance with the Order Suspending License dated February 25, 1988, you are to complete the decontamination and disposal activities by March 26, 1988, and notify Region IV when the work is completed prior to vacating the Evanston facility. Based on our conversation with you, it is my understanding that you will take the following action:

1. Perform the decontamination work and waste disposal activities outlined in the February 25, 1988, Order Suspending License in accordance with the guidelines, procedures, and monitoring described in the attached report.

2. Any equipment specified in Section III of the decontamination plan must either be decontaminated to below NRC guidelines; packaged and disposed of as radioactive waste; or transferred to another licensee who is authorized to receive such material. Contaminated equipment may not be removed from the Evanston facility except for disposal as radioactive waste, or to transfer such equipment to an authorized recipient.

3. Complete records will be maintained showing the disposition of each of the equipment items listed in Section III of the decontamination plan and of all radioactive waste disposed of in accordance with Section IV of the plan.

4. Questions concerning implementation of the referenced plan shall be resolved between you and this office before proceeding with the work.

1 i

RIV:NMIS N !, C:NMIS C:NMEPdb D: A E0 RA / AI 88-DSC DBSpitzberg;ap DAPowe s WLFisher 'rkRLBdhTart HLScott RDMa tin 3/i6/88 5 /ig /88 !!/W/88 6/g/88 / /88 y/g/88 CERTIFIED MAIL

)

RETURN RECEIPT REQUESTED I

', Wrangler. Laboratories, Inc. Issuance of this Confirmation of Action Letter does not preclude the issuance of an order formalizing the above commitment. If your understanding differs from that set-forth, please call Mr. R. L. Bangart at (817) 860-8248.

Sincerely,

. GioGINAL SIGNED ST RO3ERT Di MARTIN Robert D. Martin Regional Administrator Attachments: as stated CC' Wyoming Radiation Control Program Director Utah Radiation Control Program Director bet:

DMB - IE-07 RDMartin RLBangart REHall WLFisher DAPowers CLCain HLScott DB5pitzberg JMTaylor, DEDRO !

T0 Martin, DEDRO Staff .)

JLieberman, D/0E LJChandler, Asst. GC/0GCt/'

B5ummers, OE HLThompson, NMSS 1 JCarson NMEPB RIV Files

ATTACHMENT raon. ca*L cast GJe 'i s.s5.1986 12:26 P.

j i

i ).

DECONTAMINATION PROCEDURES Building 1214-Sage Industrial '2rk Evanston, Wyoming .

I i I

1. Radiation saferv Precations A.

Obtain urinalysis samples from each individus1 involved in the decontamination effort, before the start of the wo'rk and following its completion. Samples should be collected in new plastic or glass screw cap containere.

A minimum volume of 1 liter (about 1.1 quarts) of urine should be obtained for each sample. To prevent accidental contamination of the samples, they should be collected i away from the work site and tho hands should be thoroughly vashed before collection. Analysis of sam !

laboratories; several of these are:ples can be performed by numerous Alpha Nuclear Laboratories t' 9982 Monroe Drive i Dallas, Texas 75220 (214) 351 6092 I I

EAL Corporation 'l ,

2030 Uright Avenue l Richmond, California 94804 l (415) 235-2633 l Eborline 7021 Pan American Hwy., N.E.

Albuquerque, New Mexico 87109 (505) 345 3461 IT Corporation .

1550 Bear Creek Road Oak Ridge, Tennessee 37830 (615) 482 9707 B.

Usar protective clothing to prevent contamination of skin and personal clothing. The minimum recommended for the activities described in this procedure should be splash goggles, disposable (TYVEK) coveralls, rubber boots, and rubber (neoprono or latex) gloves.

or if they become highly contaminated. Cloves should be replaced frequently, C. 4 l Do not eat, drink, chew, or smoke while in the facility, whilo l vaaring radioactivepotentially contaminated clothing, or while handling natorial.

D.

Establish a change area in the facility.

area with heavy papor, plastic. or other easCover the floor of this Delineate onn side of this change area as a "ily disposable seterial.

clean side" and the

. .me, rsin CE% 0AAU EJ 3.19.1986 13:36 P. 9 'l l

I l

i i

ether as the ' contaminated side". Remove potentially contaminated clothing side", before passing from the " contaminated side" to the " clean j l

E. i-Var.h hands thoroughly when leaving the facility.

F. )

Obtain a thin vindow (<2 e5/cm2) C M instrument for monitoring purposes.

This instrument must be calibrated for response in !

cpm /dpm (counts por minute / disintegrations per minute) to uranium 238 and should preferrably be equipped with an audible indicator for immediate response. Possible sources for such equipment include: j

}

Eberline Instrument Corp. 4 Airport Road Sante Fe, New Mexico 87501 (505) 471 3232 ,

i Ludlum Measurements Inc.

501 Oak Street )

Sweetwater, Texas 79556 i (915) 235 5494 '

C.

When leaving the facility monitor hands, face, and personal clothing. Clean any skin or clothing surfaces, having detectable contamination levels, until the levels are reduced to ambient background.

H. i Monitor all potentially contaminated items which are being removed from the offacility I disposed as nonand will be released contaminated waste. for unrestricted use.or Monitoring should include ;

direct measurements removable contamination. for total contamination levels and smears for !

approximately 100 cms Smears are performed by wiping an area of with a dry filter paper, using nedorate pressure. Record all monitoring results. i levels exceeding NRC guidelines levels must Items with contamination be cleaned and resurveyed before roloase. The applicable NRC guidelines are:

Total contarinarien 15000 dpm/100 cm2, maximum over 100 cm')

5000 dpm/100 cm', average ((over 1 m2)-

Enrevable contawinatier.

1000 dpm/100 cz a

11. Buf1 dine surface Decontamination A.

Five floor surface areas (three, imi grid blocks and two smaller spots) were identified by the Janue.ry 1988 survey as exceeding the FRC uranium surface contamination guidelines for release for unrestricted uso. Areas are indicated on Figure 1,.

B.

Because the contamination appears to be in the surface of the concreta and because use of various solvents, concreto etching agents, corrosives, and other chemical cleaners could generate mixed

4, Fa0n : ORNL'ORQU SJD 3.19.1999 13:39' P.'6' b:

. i (radioactive plus horardous chemical decontamination techniques are recomm) ended wherever possible. wast'e, m C.

tising the drawing provided in F15 ure 1, locate and outline each location C.M of residual floor contamination. Monitor the area with the-instrunent to assure that the marked boundaries include all contamination exceeding the guideline' levels (see 1.H.). Also .

identify locations of maximum contamination within the area, to-establish a reference for evaluating the effectiveness of cleanup.

D.

Wipe the surface with a damp cloth to r'emove loose material.

Rocheck been reducedreference locations lovels.

to acceptable to determine whether contamination'has-If so, perform and record-measurements and smears at 2-to 5 locations.(depending'on total area) within the cleaned re51on, E. t

. If. contamination persists, dampen the surface and remove surface deposito using a paint scraper or putty knife. Repeat step II.D.

F.

If contamination 16 still present, scrub the surface using an-abrasive step II.D.cleaner and abrasive pad or heavy gauge steel wool. Repeat C.

If above techniques are -not successful, contamination may be removed by surface abrasion, using standard concrete. finishing or grinding equipment.- The surface should be kept damp to minimise' airborne dust.

Cover adjacent clean surfaces with plastic or heavy paper to '

avoid spread of contamination by splattering during grinding.

Repeat' step II.D. J H.

Repeat steps II.C-C for each of the five identified areas of contamination.

III. Enuinment_Decentawination

\

1 A.

The January 1988 survey identified the following iters of equipment as having uranium contamination above guidelino levels for unrestricted release:

trough (drain) incubator (and contents) fan (grill)

Electrofreeze (drain)

Hotpack oven (inside) j sink unit-(drawers and drain) i microwave oven (inside) polyethylene bottle caps .i bucket'(under trough contains solidified material) elsetric sip"' cord if these items are to be reused for future work with uranium, no decontamination will be required. If they are to be sold or disposed' of as other than radioactive waste, decontamination will be required.

,, . acen - ooug car,b sao s.s9.158e 88 28 Pi M i

i !

I ,'

l B.

Decontamination of some equipment surfaces will be extremely ;

difficult to perform and equally difficult to verify by radiation j measurements.~ It is therefore sug5ested that such contaminated surfaces as drains (trough, Electrofreeze, and. sink) be removed frow- ,

the equipment by sawing (avoid use of torches near contaminated i i

eurfaces) and disposed of intact, as radioactive vaste. Other items which should be disposed of in one piece are the bucket, solidified saterial, the electric cord, and contents of thecontaining' incubator.

C. a Cleaning scraping,ofand remaining scrubbinaurfaces may be accomplished by dan.p viping, -I Svetion II. D-F above.g with abrasivo cleansers, as described in j I

D.

surfaces of equipment, which cannot be decontaminated by abrasive i techniques, say be disassembled (for example, sink drawers and {

1 liners andtreated portions racks-in asthe incubatorvaste.-

radioactive and oven) and the contantinated !

E. l' j Perform and record direct measurements and smears on~all equipment items which have been decontaminated and are being released for i unrestricted use. ',

i IV. Vaste Dianomal ,a 1 A.

Segregate contaminated or potentially contaminated waste for disposal as low specific. activity radioactive waste.

other hazardous materials.or liquids with this waste. Do not include Allow liquids g or wet items to evaporate or air dry before disposal. _4 i

B.

Place radioactive vastes into nov 55 gallon metal drums (17H).

Meintain an accurato listing of items placed into wasta containers. 1 C. ; i Obtain the assistance of a commercial radioactive waste disposal service or pursuo arrangements via the University of Utah, similar-to those used previously, to assure that packaging, labeling, 1 j

transportation, regula tions , and records are in accordance with applicable '

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, RADIOLOGICAL SURVEY RESULTS BUILDING 1214 SAGE INDUSTRIAL PARK <

.EVANSTON, WYOMING. l INTRODUCTION l

Under the provisions of a general license, a small f acility, located in k' Building 1214 at the Sage Industrial Park near Evanston, Wyoming.. was used to .

process small quantities of depleted uranium metal into uranyl acetyl acetate. The processing operations at this, site have ceased and initial decontamination ef f orts have been perf ormed. At the request of Region IV. of the U.S. Nuclear Regulatory Co= mission (NRC), the Radiological Site Assesscent Program of Oak Ridge Associated Universities (ORAU), conducted a radiological survey of the f acility on January.19 and 20,1988. The purpose of; this survey was to determine the current status of the f acility and its contents,' relative l to the NRC guidelines f or release for unrestricted use. This report presents the procedures and results of that survey. j FACILITY DESCRIPTION I

Buildiy: 1214 is 1/4 of a Quonset hut type structure. Dimensions - are I l

approxim9tely 10.6 m by 5.8 m (See Figure 1); the maximum roof height. is approximately 6 m. - Flooring is a poured concrete' slab and there_ are no internal partitions. The west wall and ceiling is a semicircular arch of I corregated metal; east and south walls are drywall and separate this f acility f rom the other three sections of the Quonset hut. The north wall is of wood f

construction and contains a large rollup door, which is the only entrance to )

the f acility. With exception of the west wall and ceiling, which have a !

spotty coating of paint, all internal surf aces are uncoated. The f acility contair numerous small items of equipment and supplies; all of these items are portable or easily movable.

1 Prepared < by the Manpower Education, Research, and Training Division of Oak !

Ridge Ass ociated Univers ities , Oak . Ridge, Tennessee, under Interagency j Agreement DOE No. 40-770-80. NRC Fin No. A-9093, between the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy. J January 29, 1987 l

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PROCEDURES-I. A one meter grid system was established on the floor of the f acility

' f or ref erence of survey measurements. This: grid is . ~ s homt ~ on Figure 1.

2. The floor and lower walls (up' to 2 m) were scanned f or locations of elevated direct radiation levels, using_ end-window- GM detectors, with audible indicating ratemeters'. Locations ' of ' elevated radiation were noted f or f urther investigation.

3. Eleven floor grid blocks (Figure 2) were selected for surf ace contamination measurements . - In each block direct measurements of alpha and beta-gamma levels were systematically perf ormed at L the.

center and f our equidistant ~ peints, midway . between the. center and block corners. Smears f or . removable alpha and beta contamination were perf ormed at that location in- each grid block, where the highest direct level was obtained.

Measurements of total alpha radiation level were perf ormed using Eberline Model PRS-1 portable scaler /ratemeters with Model AC-3 alpha scintillation probes. Measurements ' of total beta gamma radiation le.vels were. perf ormed using Eberline Model PRS-1 portable )

s caler/ratemeters with Model EP-260 thin-window- " pancake" G-M 1 j

probes. Count rates (cpm) were converted to disintegration rates. !

(dpm/100 cm#) by dividing the net rate by the '4

efficiency and correcting f or the active area of the detector.: Eff ective window j areas were 59 em# f or the Zns detectors and 15 cm # for the G-M.

dete ctors . The background rate for .ZnS alpha probes averaged j approximately 2 cpm; the average background- count rate. was

)

approximately 40 cpm f or the G-M detectors. Smear measurements were perf ormed on numbered filter. paper disks,. 47 mm in' diameter. Smears :

were placed in labeled envelopes with the' location. and other 1 pertinent inf ornation recorded. Smears were counted on a: low background proportional counter at the Oak Ridge laboratory.

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. 4.- Thirteen locations. on the walls were selected . f or ' single point' measurements of -total and removable' alpha' and kata-gamma. l contamination levels. These locations are identified on' Figure' 3.

5. Measurements- of total and removable alpha- and beta-gamma-contamination levels were perf ormed on. floor areas, . identified' bv k gamma scans. l

6. Beta scans and measurements of alpha and beta-gamma . contamination a

levels were perf ormed on all equipment and supplies.

FINDINGS j 1

1. Surf ace s cans identified seven small isolated floor ' areas ' ~ of j elevated direct e beta-gamma radiation. These areas are shown on Figure 4. No elevated radiation levels were ' identified . on . wall -

surf aces.

i

2. Results of surf ace contamination measurements on floor. grid - blocks ,

are presented .in Table 1. Three of - the grid block (B,2; B,8; and '

F,9) have average total beta-gamma levels above the NRC guideline of '

5000 dpm/100 cm*; the highest level is- 6190 dpm/100' cm# in. grid block F,9. One of the tlocks -(B,2) also has a location in the north west quadrant with a contamination level of - 16400 dpm/100 cm#, which is. in excess of the NRC . maximum be ta-gamma .- guideline. of-15,000 dpm/100 cm#, . Total alpha' levels . and removable alpha and beta levels were all well within the applicable ' guidelines. Although surf ace contamination guidelines f or uranium are expressed in terms of alpha dpm/100. cm# , it is apparent f rom the floor - measurements i

that the direct beta gamma measurements are significantly higher ,

l than the alpha measurements. This isL not consistent' with the known J alpha / beta emission ratios of depleted uranium.and_ may be ' attributed to alpha self absorption 'in the dust and . the port us surf ace ~ of the :

concrete floor. Theref ore,' it is ORAU's opinion f hat the beta-gamma measurements are more representative of the '- true surface .I contamination levels and ORAU- recommends use of these data' f or comparison with guidelines, rather tht.n the alpha data.

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_ - _ _ . ______ - - O

l 3.. R:s ults of -mecsuraments en tull surf cess cra prcssntad in Tcbla 2.

All centcmination levels were well within the applicable guideline

', values.

4. Measurements at locations .on the . floor, identified by surf ace beta-gamma scans, are summarized in Table 3. The total beta-gamma contamination ' levels at locations ' S and 6 were 17,000 dpm/100 cm'.

Although several other locations had direct beta gamma measurements .

above 15,000 dpm, the contamination at these ' locations was limited to areas of less than 100 cm and the resulting levels -when averaged over the adj a cent 100 cm , were within the guideline values. A removable beta contamination level of' .1620 dpm/100 co' (above the 1000 dpm/100 guideline) was noted at location 6.

5. Results of measurements conducted on equipment and supplies are presented in Table 4. These results indicate that seven items cf equipment have contamination levels exceeding the NRC guidelines f or unrestricted use. These are:

trough, incubator, fan, Electrof reeze, Hotpack oven, sink unit,'and microwave oven.

, in addition, other items with contamination levels above guidelines are caps of polyethylene bottles, a bucket- (located under the f trough), an electric cord, and several pie ces of miscellaneous supplies. A 55 gallon metal drum ' located in the f acility is about 1/4 to 1/3 f ull of trash, including uranium contaminated waste.

SUMMARY

During January 19-20, 1988, Oak Ridge Associated Universities perf ormed a I

radiological survey of a f acility in Bui11 ding 1214 of Sage Industrial Park, Evanston, Wyeming. Results of that survey identified three 1 m x 1 m grid blocks and two additional small areas on the floor, having residual I contamination levels in excess of NRC guidelines. Seven pieces of equipment and several supply items also are contaminated above release limits.

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APR T S !

l LIn Reply Refer To j Docket:. 99990004/87-04/ CAL-$8-02A .. 1 General Licensee: . Wrangler Labs, Evanston, Wyoming 1 j EA 87-223 l Wrangler Laboratories, Inc.. ' '

       ' ATTN: ' John P; Larsen, President'
       .3853 North Sherwood' Drive-Provo, Utahj.84604'

Dear Mr. Larsen:

SUBJECT:

. CONFIRMATION OF ACTION' LETTER This isLto confirm the conversation:between Mr.fJohn P. Larsen, Wrangler Labs
                                        ~

and Messrs.. Richard Bangart, Dale PowersU and.Blair Spitzberg, USNRC, Region ~ IV.on. April 1, 1988. The purpose of the conversation was yourirequest'for a y time extension for you to complete the radioactive waste disposal activities of your Evanston,'Wyomingtfacility. as required by the Confirmation of Action-Letter we. issued to you en March .18,-1988. . With regard to this issue, we . understand that you are working with a. Utah licensee and the State of Utah to-gain _ authorization for transfer and disposal of this. waste.-lYou.have also informed us that final authorization for, and acceptance of this waste'may, take an additional three weeks. Therefore, based'on our conversation with you, it is my understanding that you will' take the following actions: - Prepare all radioactive waste.from your Evanston, Wyoming. facility :in' a dry formby transfer in April packages thatand 8,L1988, are hold inventoried,. sealed,'and: these wastes prepared in the Evanston facfor ility l until authorized by your waste broker and the State'of Utah to transfer # them for disposal. If transfer cannot be completed by. April 22, 1988, you will notify this office in' advance.. All other! facility decontamination efforts ~are to be conducted in accordance.with the' Confirmation of Action Letter dated March.18.-1988, and completed by April 8, 1988. ; Issuance of this Confirmation ~of Action Letter does not preclude:the issuance of.an order formalizing the'above commitment. .If your. understanding differs fromthatsetforth,pleasecallMr.~R.-L.Bangartat(817)860-8248. .! Sincerely, 1 Origla.13gned By, ; Robert D. Martin-Regional Administrator. .; cc:'(seenextpage) 4 I

         ~ CERTIFIED _ MAIL - RETURN. RECEIPT REQUEST ED RIV:NMIS h          C:NMIS[C:NMEP8              D:D         A:E0       RA     AI 88 098
          .D8Spitzberg:cd                   WLFisher       RL88   art HLScott RDMartin
                              'DAPowers                                                                                 l 4/J/88              4/l /88-     4/f /88        4/(1/88     4/ I /88 4/ '/88
                                                                                                                    )   !

J FRot1 NRC RIV'ARL.TX.: .06/08/89--15'i.50: P.;2 ',

                                                                                                                -[/   .j 1

l. s I , Wrangler-Laboratories, Inc. cc: .. . . Wyoming Radiation Control Program Director Utah' Radiation Control Program Director.

      .bcc:
      .DMB - IE          R. D. Martin-                                           <

R.'L. Bangart R. E. Hall: W. L. Fisher-

       'D. A'. Powers C. L. Cain l

H A.B.. Spitzberg dD. Scott J. M.. Taylor .tEDRO T. O. Martin, DEDRO Staff g J. Lieberman, D/0E 4 L. J, Chandler, Asst. GC/0GC .i B. Summers, OE H. L. Thompson,'NMSS J. Carson NMEPB { RIV Files i i 1 l 4 M NRC RIV ARL'.TX.- 06/08/89-15:50 P . .- 3}}

ML20245A410

Contents

Text

Dear Administrative Judges:

Enclosures:

Enclosure:

Dear Mr. Larsen:

SUBJECT:

Dear Mr. Larsen:

SUBJECT:

Dear Mr. Larsen:

SUBJECT:

SUMMARY

'B-E t !

Dear Mr. Larsen:

SUBJECT:

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ML20245A410

Text

Dear Administrative Judges:

Enclosures:

Enclosure:

Dear Mr. Larsen:

SUBJECT:

Dear Mr. Larsen:

SUBJECT:

Dear Mr. Larsen:

SUBJECT:

SUMMARY

'B-E t !

Dear Mr. Larsen:

SUBJECT:

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