IR 015000015/2023002
| ML23300A079 | |
| Person / Time | |
|---|---|
| Site: | 15000015, 015000015 |
| Issue date: | 10/18/2023 |
| From: | Ryan Craffey Division of Nuclear Materials Safety II |
| To: | Chitwood M Empire Wireline |
| References | |
| IR 2023002 | |
| Download: ML23300A079 (1) | |
Text
NRC FORM 591M (04-2022)
Materials Inspection Report U.S. NUCLEAR REGULATORY COMMISSION Page 1 of 1
Add Continuation Page Licensee/Location Inspected:
Empire Wireline LLC 1000 West First Street McPherson, KS 67460 Location Inspected: Job Site in East China Twp., MI Report Number(s) 2023-002 NRC/Regional Office Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Docket Number(s)
150-00015 License Number(s)
GL per 10 CFR 150.20 / KS-27-B992 Date(s) of Inspection 10/11/23; exit 10/18/23 LICENSEE:
The inspection was an examination of the activities conducted under your license as they relate to radiation safety and to compliance with the Nuclear Regulatory Commission (NRC) rules and regulations and the conditions of your license. The inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. The inspection findings are as follows: Based on the inspection findings, no violations were identifie. Previous violation(s) closed. During this inspection, certain of your activities, as described below and/or attached, were in violation of NRC requirements, and were assessed at Severity Level IV, in accordance with the NRC Enforcement Policy. The following violation(s) is/are being cited in accordance with NRC Enforcement Policy. This form is a NOTICE OF VIOLATION, which may be subject to posting in accordance with 10 CFR 19.1 (Violations and Corrective Actions)
Statement of Corrective Actions I hereby state that, within 30 days, the actions described by me to the Inspector will be taken to correct the violations identifie This statement of corrective actions is made in accordance with the requirements of 10 CFR 2.201 (corrective steps already taken, corrective steps which will be taken, date when full compliance will be achieved). I understand that no further written response to NRC will be required, unless specifically requested. The violation(s), specifically described to you by the inspector as non-cited violations, are not being cited because they were self-identified, non-repetitive, corrective action was or is being taken, and the remaining criteria in the NRC Enforcement Policy were satisfie (Non-cited violation(s) was/were discussed involving the following requirement(s)
TITLE NRC INSPECTOR PRINTED NAME SIGNATURE AND DATE LICENSEE'S REPRESENTATIVE Not required (no findings)
Ryan Craffey BRANCH CHIEF Rhex Edwards Digitally signed by Ryan J. Craffey Date: 2023.10.20 17:04:25 -05'00'
Digitally signed by Rhex A. Edwards Date: 2023.10.26 11:59:06 -05'00'
NRC FORM 592M (10-04-2022)
U.S. NUCLEAR REGULATORY COMMISSION Materials Inspection Record Page 1 of 2 NRC Form 592M (10-04-2022) Licensee Name:
Emipre Wireline, LLC Docket Number(s):
150-00015 License Number(s)
KS-27-B992 Report Number(s):
2023-001 Date(s) of Inspection:
October 11, 2023; exit October 18, 2023 Inspector(s):
Ryan Craffey Program Code(s):
03110 Priority:
3 Inspection Guidance Used:
IP 87123 1 Licensee Contact Name(s):
Matthew Chitwood - HSSE Manager 1 Licensee E-mail Address:
matthew@empirewireline.com 1 Licensee Telephone Number(s):
337-342-9587 1 Inspection Type:
Initial Routine Announced
Non-Routine
Unannounced 1 Locations Inspected:
Hybrid Main Office Field Office Temporary Job Site
Remote 1 Next Inspection Date (MM/DD/YYYY):
TBD Normal Reduced Extended No change
1 Location(s) Inspected List:
Job Site - Range Road, approximately 1/4 mile south of Bree Road, East China Township, MI Well M12; GPS 42.794452, -82.489660 1 Scope and Observations:
Empire Wireline, a well services company, was authorized by the State of Kansas to use sealed and unsealed source of byproduct material for well logging and storage cavern logging and integrity testing at its facility in McPherson, Kansas, and at temporary job sites in state jurisdiction. The company conducted these activities at temporary job sites in NRC jurisdiction per a reciprocity request approved in February 2023 for the remainder of the calendar year. The scope of this inspection was limited to an evaluation of licensed activities (logging a salt extraction well using a Hotwell Antares D-T pulsed neutron generator containing 1.3 Ci of H-3) at a well field owned and operated by Cargill in East China Township, Michiga The inspector accompanied the licensee's field personnel to the job site in East China Township. The licensee had been subcontracted to perform periodic evaluations of these salt extraction wells, and as part of this evaluation, the licensee used one of two pulsed neutron generators (the other was there as a backup) to determine the location of the diesel-brine interface within each well. The inspector confirmed that the generator storage containers were adequately secured, blocked and braced, and labeled (UN 2911) for transport. Shipping papers and other records were present as required. The generators were labeled with appropriate etchings; independent surveys of the devices prior to logging operations using a Thermo Scientific RadEye G gamma survey meter (calibrated July 21, 2023) and a Ludlum 26-1 pancake probe (calibrated July 17, 2023) were indistinguishable from backgroun The inspector observed the conduct of logging operations including rigging the generator up and down. Licensee personnel were knowledgeable of generator operation; demonstrated the functionality of interlocks that (1) prevented the generator from operating less than 170 m (558 ft) below grade and (2) prevented the generator from being raised to less than 20 m (66 ft) below grade within 45 minutes of operation to minimize exposure from short-lived activation products in the generator housing; and wore beta/gamma/neutron dosimetry at all times. Independent surveys of the generator after rigging down were indistinguishable from background on the RadEye and less than 900 cpm on the Ludlum. Confirmatory surveys by the licensee were thorough and consistent with these reading NRC FORM 592M (10-04-2022)
U.S. NUCLEAR REGULATORY COMMISSION Materials Inspection Record (Continued)
Page 2 of 2 NRC Form 592M (10-04-2022)
Following the on-site inspection, the inspector interviewed the licensee's RSO by telephone to discuss periodic maintenance and testing of the generator, as well as a prior study performed by the licensee correlating dosimeter neutron readings to true neutron exposure from the generator (which was unlikely to be more than minimal anyways during normal operation assuming functional interlocks), since the licensee's dosimeters were found to be sensitive only to neutrons up to 6 MeV and the generator produced 14-MeV neutrons when energize No violations of NRC requirements were identified as a result of this inspectio Signature and Date - Branch Chief Digitally signed by Rhex A. Edwards Date: 2023.10.26 11:58:47 -05'00'