IR 015000035/1989001
| ML19332G010 | |
| Person / Time | |
|---|---|
| Site: | 015000035, 03005901, 03005900, 03005902 |
| Issue date: | 12/06/1989 |
| From: | Cain C, Rajendran S, Vasquez G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19332F992 | List: |
| References | |
| 15000035-89-01, 15000035-89-1, 30-05900-89-01, 30-05901-89-01, 30-05902-89-01, 30-5900-89-1, 30-5901-89-1, 30-5902-89-1, NUDOCS 8912200031 | |
| Preceding documents: |
|
| Download: ML19332G010 (10) | |
Text
{{#Wiki_filter:ng- - - c ' * ' ', ;.. ' r . p,'.
APPENDIX D I U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
. , t Combined NRC Inspection Reports: 30-05900/89-01 Licenses: 35-00502-02' 30-05901/89-01 35-00502-03 30-05902/89-01 35-00502-04G 150-00035/89-01' General License 10- CFR 31.5 Dockets: 30-05900 g'
30-05901 30-05902 150-00035 i Licensee: Halliburton Company P.O. Drawer 1431 Duncan, Oklahoma 73536 Inspections At: Duncan, Enid, and Oklahoma City, Oklahoma Inspectors: dM h _ lE!6!97 G. M. Vasquez, Radiation Specialist, Nuclear Date' ' Materials Inspection Section ' ! b tk b I 6[W S. Rajendran, Radiation' Specialist, Nuclear Dat6 l ' Materials. Inspection Section Approved: M*;$ N 17f6ffFi - Charles L. Cain, Chief, Nuclear Materials Datd ! ' Inspection Section Inspection Summary Inspection Conducted September 12 and October 10-12, 1989 (Report 30-05900/89-01, 30-05901/89-01, 30-05902/89-01, and .' 150-00035/89-01) Areas Inspected: A routine, unannounced inspection was conducted on September 12, 1989, in Duncan, Oklahoma, followed by field of fice inspections at Duncan, Enid, and Oklahoma City, Oklahoma, on October 10-12, 1989, of fixed ' gauge.and tracer material manufacturing, distribution, and use.
Specific areas
inspected. included organization and scope of the radiation safety program, internal audits, and notifications and reports.
L 8912200031 891211 . REG 4 LIC50 35-00502-02 PDC , c ,
h e.py [iu ci;
- ! -
..
a - , - - . m.' '. m .' . 'a 'Mi - 1 ~- 9
- '
. ,
4( {(j j ' 9 i . * t N %l. :.V ' ' > c - . ~ + ' '
- !
' - '* yi, ', - -2-'
, .
< ;. M a - > n- '( -.I p.
4 r "- Results:l In general; the licensee's radiation safety program;.appea'redito be - ! ~ c<
, . b _ adequate.. Identified.; weaknesses related to the-licensee's audit program land
' b ,, ' materials accountabi.lity. -
{. - .
) L " ! our apparent violations were _ identified: $.,m ' , ,. d F . > . ,.. .,, . 'h yen.: 1.- Failure:to_ post required documents (Section 3), j _ u.. ..
-12. : Failure;to perform an-adequate-audit of licensed materials (SectionL4)~._ ,,l ya ,
13..' Fa1. lure.to perform audits of licensed tracer materials every.3 months ' ' *m !(Section4)._ - ' ' c.
.. m ..g
. . e - 4.; FailuretonotifhNRCofallossof'licensedmateria1L(Section5).. J ' ' ' .3 , 'l + . .a !
- t + s s e ~ ,h i ' p3 pq.7 .[
..,, _ ?'. $ i i
3 ll d + .{
' '
, ,
- t
m +) ' .l.
c, . -T.
J. t_.; . _ \\ ' c, . r --- yL
L I p ,s.
, y' o ' i .
, , ,
- ...
. a.
" V
l .m - i. h 3..* ' . A ' ' Q 1 - f. -w .; . i . h] < , ! a- - , i 4Q , N5.). '; e ( y,c _, - t ' '
- [.'. , . rl '
.'.\\,I
,4
g -- , - . , , s4 . \\d7 a.. ]i. g > - ..
. , - I, -3- . t V
, p DETAILS
t c ] b 1.
Persons Contacted !
- Al Baker, President, Halliburton Services (Houston, Texas)-
Ray Durbin, Corporate Attorney, (Duncan, Oklahoma), . .. a
'
- Ronald L'. Bechtel, Manager, Department of Government Regulations (Duncan, Oklahoma) ~
'
- Richard Leonardi, Radiation Safety Of f.icer (Duncan, Oklahoma)-
p' Ralph Houser,. Assistant Radiation ' Safety Officer (Dunca'n, Oklahoma) . Roger Ledford (Duncan, Oklahoma) , Ron Coon (Duncan, Oklahoma) Gary Phelps (Duncan, Oklahoma) Dr. Ron Buchanan (Duncan, Oklahoma) Craig Smith, Field Supervisor, Vann Systems (Oklahoma City, Oklahoma) ' ' IJim Lawson, District Manager (Enid, Oklahoma) 2A1 Rahimi, District' Manager (Oklahoma City, Oklahoma) 3John Oswald (Duncan,. Oklahoma)'
1p.
Ralph Voss (Duncan, Oklahoma) l
- Telephonic exit briefing conducted October'16,-1989
'
- Preliminary' exit briefing conducted October 12, 1989
q I Present-during inspection at Enid field camp 2Present during inspection at Oklahoma City field camp 3Present during-inspection at Duncan field camp ~ , . Licensee Actions on Previous' Inspection Findings 2.
' n (Closed) (30-05901/88-02 and 30-05902/88-01): Failure to perform sealed- '
' source-leak tests within-the required 3 year period.
The. licensee had . > " revised.their' gauge computer program by adding additional instructions-to 2 require each field site to check for source' leak tests that may be due.
The inspectors found no sources that were overdue for~ leak testing.
.(Closed) (30-05901/88-02 and 30-05902/88-01): Failure to leak test a Ni-63 plated source every 6 months. The' licensee issued formal letters to' appropriate departments located in Duncan, requiring confirmation that leak tests had been performed. The inspectors found no sources that were overdue for-leak testing.
a -- (Closed) (30-05901/88-02 and 30-05902/88-01): Failure to conduct physical-l . . inventories every 6 months of all sealed sources and/or devices.
The ' licensee had issued a computer generated notice to all appropriate departments in Duncan and has monitored the responses.
Based on a random , sampling'of sources, inventories appeared complete.
l !
(T g _RWl ~ -
J y , < , .~ , ,, ' r J!
' ' r g h,';. 4 ,
- 4 a
. =. w v.
, .. , p >4 - -4-- , b '(Closed)L(30-05901/88-O'2 and 30-05902/88-01):. Failure to. label-sealed ] b'
sources " CAUTION RADIOACTIVE: MATERIALS"'or " DANGER - RADI0 ACTIVE ' % ' [' MATERIALS.".The' inspectors reviewed labeling on selected devices,'and all.
i , 'were found to be' adequately labeled, ' , i' (Closed)(30-05901/88-02and:30-05902/88-01): Failure to provide constant' surveillance and immediate control of licensed material. in an unrestricted .* . : c-area. The inspectors observed no material in an unrestricted area that ' was not under constant. surveillance and immediate control.
,s
M c3.
'Oroanization and Scope of the Radiation' Safety Program I
' The Halliburton division 'and subsidiaries licensed by the NRC to possess and use radioactive materials include: HalliburtonServices(HS), i K'* . Halliburton Reservoir Services (HRS), Vann Systems, Jet Research Center, - p Otis Engineer 1_ng, Halliburton Logging Services (HLS), and Halliburton ' Geophysical Services,.Inc. (HGS). 'Each division and subsidiary has had ~' t itsfown administrative structure and hes operated independently of each L J, other.
All divisions and: subsidiaries ~were owned by Halliburton Company, " which has been v_iewed as a' holding company.
The licensed activities of the Jet Research Center, HLS, and HGS were not > inspected, f Despite; their autonomy, the Radiation Safety Officer (RS0) for HS has also ]' .been.the RS0 for; HRS, Vann Systems, and Otis Engineering. The. licensed - ' activities for these: four ' companies has been authorized by four NRC . licenses: ~A.
-License No. 35-00502-02 authorizes HS, Otis Engineering, and Vann Systems to perform tracer studies in oil and gas wells,.as well as to use depleted uranium sinker bars.
However, of the three companies, . -Vann Systems was the only one in possession of licensed materials.for 'l -
- tracer activities. The Vann Systems field office in Oklahoma City.
~ ' possessed only 14 microcuries of Co-60 beads at the tirse of' the inspection.
, HS, which previously had tracer materials at their field camps, has ! e 1 transferred these materials to other licensed companies and has performed final radiation surveys at field camps to ensure this, t Otis Engineering, which previously possessed uranium sinker bars has > transferred all licensed materials to HRS. A-license-amendment , request to that effect had been submitted to NRC on August 21, 1989.
i !
- B.
License No. 35-00502-03 authorizes HS to research, develop, and
manufacture density gauges and logging instruments; manufacture-l
1 tracer sands; test. decontamination procedures in the laboratory; use calibration standards; and use laboratory devices containing licensed material. Of these activities, the licensee has ceased
l d
fq%uiv:p
' 0y ww % Q% ~/ ? , g A j , v . y j'
- - 5-l c
wmc ! ! O decontaminating reactor components, manufacturing logging; i1 instruments, and manufacturing tracer sands..However, the licensee ? stated that-they would-like to maintain authorization to manufacture f . , , -. tracer. sands and-logging. instruments as an option for the future.
The_ licensee's'most significant use of radioactive materials 'I > $g, authorized under this license appeared to be the manufacturing of the, density gauges. Between November 1, 1988, and November 1, 1989, they
, yy manufactured approximately 24 gauges per month..These gauges were 'I ~" ' ~then distributed under License No. 35-00502-04G.to persons generally ' licensed-pursuant to 10 CFR 31.5, mostly to HS field camps.
Each gauge contained a Cs-137 sealed source witn activity of 10 mci, 20 mC1, 55 mci, or 100 mC1.
& w ' ? C.
License No. 35-00502-O4G authorizes HS to distribute density gauges.
.
. to person:, who possess a general license pursuant to 10 CFR 31.5.
' ' Most of-these gauges were distributed _to Halliburton divisions or subsidiaries.-
D.
HS utilizes the' general license provided by 10 CFR 31.5 which
authorizes use of density' gauges that are distributed under License l . . di-No. 35-00502-04G'. Most of these' gauges have been located at'various Halliburton field' camps in the> United States and abroad. 'Many have been attached to equipment on trucks and. transported to and from - temporary job-sites.- Several of Halliburton's divisions and y subsidiaries have been located in Agreement States and' abroad.
lThe' inspectors reviewed material transfer-reports th'at were sent to the NRC as required under=10 CFR 32.52. Also, labeling-and markings of gauges .at the Enid, Cklahoma City, and Duncan fieldicamps complied _with license conditions.
. The'RSO responsible for NRC License Nos.- 35-00502-02, 35-00502-03, 35-00502-04G, and for the general license pursuant"to 10 CFR 31.5,'was ', , < part of the Government Regulations Department at HS. 'The Manager of the - Government Regulations: Department has supervised a contract with a-consultant to perform routine field site audits required by the licensee's ~ audit program; however, the consultant has not reported to the RSO. The ' consultant has reported'to the Manager'of the, Government Regulations '
~ Department.
, The licensee has provided 40 hours of. initial-training to all personnel associated with gauge manufacturing.
Training records were sampled and , appeared to meet the requirements of 10 CFR Part 19.
Interviews.with . ' selected personnel also verified this.
The Vann Systems. authorized user also appeared to be well~ trained.
,
yng;7 r - '- - 3l g4g +
, 7, 4g:. m - ( c.
. p, V, . R-6-L '. ( , The inspectors reviewed records of receipt.for Cs-137 sealed sources ' ' ' x = shipped by the supplier.. The licensee stated that incoming transport- .; ' containers were surveyed to verify that material'had not shifted in e transport.
Records of' material transfer within Halliburton subsidiaries
P were sampled and found to-be' adequate.
[
Film badge records were reviewed and were found to be complete. Typical . R, whole body exposures have been low, The maximum annual personnel exposure y for 1988 was 250 mrem.
J ' The licensee's procedures for radioactive waste disposal were reviewed.
Since the.last inspection they have not disposed of, any material.
, , !:4 The inspectors. reviewed the licensee's transportation activities to '
- determine compliance with 10 CFR1Part >71 and-the applicable regulations of the Department of Transportation., Proper shipping papers describing the
' - sealed sources in; gauges were found to be in. several' trucks carrying _ the ' - materials. At the'Vann Systems; facility, Co-60 beads had been secured in , La locked storage box in'back of a truck: They also reportedly carried the necessary documents to'the,iob sites in the truck, Records of shipments a 'of-gauges between Halliburton subsidiaries and temporary field sites also m appeared to comply with applicable regulations.
x The inspectors also reviewed. required postings.1-The Vann Systems field a office located in Oklahoma' City, where approximately 14 microcuries: of Co-60 beads were stored, did_not have the required postings.
This was-identified as.a violation of 10'CFR'19.11 for License No. 35-00502-02.
' ' -The inspector ubserved, through a; random sampling, that radiation survey ' instruments at the manufacturing and research' facilities had been'. calibrated.at'6-month. intervals.
Some users have sent their instruments directly to the vendors and maintained their own calibration -records.
The radiation-safety program's. organization was.very complex and has~been in a state of change since;the previous inspection. Halliburton-has o , several subsidiaries-that are autonomous, yet whose licensed activities ' g overlap. Overall, the program's organization appeared acceptable.
One violation-was identified.
4.- Licensee Internal Audits c On September 23, 1987, the NRC issued an Order. Modifying License, along with a Notice of Violation and a Proposed Imposition of_ Civil Penalty.
The Order originated when~NRC determined that the licensee's completed and-proposed corrective actions for identified violations did not extend far enough to ensure thorough management involvement.
The Order described the requirements for a corporate audit program.
The current approved audit program was submitted in a letter dated December 21, 1988.
w.
- - - .
g; y - . , W' ' ' , ,
- @u p
_ ' g b: ,% . '
" {' ,,, 7,, y
> p _ - m Since 1987, the Manager of Government Regulations has supervised a ' contract with~an individual to perform routine audits of Halliburton's field offices.
The' contractor has submitted all audit findings to'the . .,. I N . Manager of Government' Regulations.
The RSO bas also performed.some of
- l these audits and submitted all findings to the Manager of Government
' 'J Regulations,
s-The licensee stated that as of November 1988, all HS field camps in the.
l m, country havebeen audited. The-1.icensee performed radiation surveys of - 7E all field camps regardless of whether records indicated the camp possessed - - .anyilicensed material. :This was to ensure that none of the camps had tracers, to document closcout surveys for those camps that in the past-possessed tracers, and to look for unaccounted for sources, in addition to fulfilling their audit program requirements.
.The inspectors visited several Halliburton f acilities in order to
determine the effectiveness of the corporate audit program.
It appeared , '1 .that the research departments and the gauge manufacturing operations in' s Duncan were audited as required.
The inspectors also visited.three HS .i i field camps and one Vann Systems facility. The three HS fie,J camps appeared-to have been audited, but two had discrepancies that should;have been discovered by the audits.
At the Oklahoma City facility, the inspector determined sealed source i
Serial No.' S277,.a 9.5 mci Cs-137 source, was received in the facility in February 1984 but was not on=the' facility's inventory.
Additionally, - sealed source Serial No. S750 was: onj the facility's inventory, but'the source was.not-at the facility and the district engineer had no records of ever possessing the source.
These it' ems were discovered during the inspection despite audits conducted by the contractor on December 30, 1987',;and December 15, 1988.
' 1' During the inspection of the Duncan facility, sealed source Serial-No.~X350 was found during the inspector.'s facility tour in an authorized- . storage, location in plain-view with other gauges. The' licensee stated . that the source had previously been on the list of unaccounted for sources < for approximately 1 year. The district engineer was aware of the device and stated that it had been at the camp for several-years. -However, it-was.not on their inventory. Despite an audit conducted by the contractor _ . on September-22, 1988, the licensee presumed this source was missing.
'l
The fact that the audit program had not identified the discrepancies ] indicated inadequate audits of the field camps.
This was identified as a y violation of License Condition 19 of License No. 35-00502-03 which references the Radioactive Safety and Material Audit Program, originally l submitted to the NRC in a letter dated October 22, 1987, revised i February 3, 1988, and revised again on December 21, 1988.
The Vann Systems facility in Oklahoma City was also inspected. The , inspector determined that no audits had been performed in calendar year 1989.
Failure to perform comprehensive audits of licensed tracer l
" ' q ' A , .2-~l.
..
y _- _ w - - - -
N c.b w u s . m:j, + g .;
- Gr: ' . . , ya .-8- - i ' > , - ,, < , . . %' materials every 3 months'was. identified as a violation of License
Condition 13 of.NRC License-No.'35-00502-02.
This license condition-i 0,is references a letter dated December 21, 1988,. which describes the audit V program.
{ In-. general, it appeared that facilities had been audited within the p v required time periods; however, some of the audits were not effectively , 4, " performed, y . , i.
Two violations were identified.
p - -
- 5.
Notifications'and Reports.
! _g .'When an inspector _ asked if the licensee had a loss or theft of licensed PC, . ma'terial,. the ilicensee's. management stated that they had no lost sources,
but they did haveEsome sources that were unaccounted for.
4 - .At the inspector's request,-the licensee developed a list of all the ' sources whose whereabouts were unknown to the licensee. On October 11, '1989, the-licensee presented the list to the inspectors.
A' copy of this_ -
list is. attached as: Appendix E.
' g.
, , Halliburton Company's divisions and subsidiaries operate field camps in & ' nonagreement; states,-agreement states, and abroad.
Though the field camps 'have low 1 turnover of these devices, they do transfer them among their 'r ' _ numerous; locations both domestically and abroad. Therefore, it appears ,, , that each of!the divisions and subsidiaries, while in NRC jurisdiction, 'have been' individually-authorized under 10 CFR 31.5 to_ possess,, store, and= tuse these gauges.
However, the Government Regulations Department at HS t has.been designated by Halliburton Company to act on behalf of.the various divisions'and s'ubsidiaries in regulatory matters. Also, the manager of ' ~ Government Regulations has~been the chairperson of the corporate radiation Lsafety committee.
'
' .In~the.latter part of 1986,.the Government Regulation Department _in HS, ' i ' began working.on a' computer program to track the locations of generally and specifically licensed sources, as well as their. leak tests..They_' sent - _; ' ' ' letters to_all the field camps in an attempt to determine the locations of f all' gauges. Additionally, the Government' Regulations Department has kept " . logs.of. material-transfers among the~ camps. The computer-based tracking ' , . -program was based _on the responses from the field camps, the logs, and n .other rec.ords.
By the middle of 1987, the first reports were generated from the computer, - and the licensee started auditing their field sites.
By November 1988, all domesticLHalliburton field locations had been audited and the list of . unaccounted for gauges was substantially shorter than originally estimated.
.c .- G
- r-
" r , , - v =
. W -~ ' , w&llN . '* h W;. ; ~
- .g.
. , pp,< i . . ,
. . V-@ - ,, ' 'Since November 1988','the only.new action taken by the' licensee to look for ,' these lost sources has been to contact overseas, operations and have them ~ s.
!.y ', report their. inventory. Though-the licensee had demonstrated progress in.
[ attempting.to' locate-these' gauges-through November 1988,lvery little k progress-has been made since then, e.. . - V.
.The.following Cs-137 source serial nos. were last known to be in Oklahoma, a state where NRC maintains jurisdictioni S-622 (10 mC1), X-030 (10 mC1), CS2-751 (10 mC1), Y-211 (10 mC1),~ Y-61 (10 mci), A-424'(50 mC1), and X-375 W (10 mC1). Since November 1988,'the~ licensee'has'neither' located theJ
- W sources nor reported them to NRC as missing.
Failure to notify NRC of a ,' 5 theft or loss of' material was identified as a violation.of c: , Q 10 CFR 20.402(a)- for the General-License authorized under 10 CFR '31.5.
L' ~0ne~ violation was identified.
6.
Exit Interview ' A preliminary exit briefing was conducted on.0ctober 12, 1989, with the . . individuals identified in Section;1.
li-AJtelephonicfexit briefing was-conducted on October l'6, 1989, with the ' ' individuals identified in Section -1; the Chief, Nuclear. Materials - . ' Inspection Section; and the inspector, The specific findings were not - a Ldiscussed; however, NRC's. concerns about a clear delineation'of , responsibility associated with the management.of,the radiation safety.
program were discussed.
" , -
l-- l [ -~ w P t i
s .; i t i ,- d 1-r ( e-
y 7r W k
3, w;- m gA.
gK ' ~ - , ++ ' --; , ygg - qp.;pp ;g - '-
4 33< y"a y, - h.;O , w o. ' - @([[fi; Q ' W , , ,
j{ !q ;( % ,~ 's APPENDIX:E- ' , r ,,, . . g UNACCOUNTED FOR RADI0 ACTIVE DENS 0 METERS 4q , ln , L9
i, Source- 'Densome'ter Source Act.
L st' Leak Last Known 'Date Densometer ' k.,@ L.Se ri al' # -' Serial'#. -(mci) . Test Date Location- .Ackno'wledged Missing _ . y G . . . , 03/24/86~ . Unknown 8/86 p LZ-103
- W35-0018'
55.8 ' r' O ' S-662 730508.
10.0 - 01/11/79- . Unknown ? > ' LX-030 31V111(or): 10.0' 03/25/80 Unknown- ? ' - ' 7 st 31V136-k UlU X-007 73716. 10.0 11/19/79 Palistine,.TX.
? f
CS2-724 _ 41-0043' 55.0 05/04/83 Vernal, UT.
? W
J CS2-751-73-1101 10.0 01/13/84 , Unknown . ?- f' F, 'r - X-211, 31V442 110.0 12/23/86 Duncan, OK.
09/28/89 - . $* i 'Y-61:
- 61N6199SC
20.0 01/21/85 Davis, OK.
? --'
'A-424i
- Unknown
'50.0 02/21/73' Duncan, OK.
?- a, _-918^. Unknown 110.0-01/05/82 Duncan,.OK, ?-- y
- X-375
' MD-002 10.0' 02/10/72 ~Turkish Pet.
? K4 15-188-MS-341 10:0-04/15/75 Mission Marine -?
, P> . South Africa or
United Dubai, Arab' ' ,m , Emirates . . j .. p? " -:855 MS-13 10.0 07/15/71.
Key West South:Am.
7.
l .A-454E MS-246-10.0 03/26/73 Sold to:Sedco N. Sea ? A-597-PFD-244? 10.0 12/10/73 'Scarborough IN Drill ? ! ' , ' . . _ Ship,cItalian Oil Co.
',' ' '829:. '73-1515 10.0 08/22/84 ~ tEgypt ? p' w lA-499: MS-106 10.4 08/22/73-Global Marine Unit ? , b'
- 712, Orange, TX.
U' ,,S-664-73635- - 10. 0 - 01/11/79 'Dubai', United Arab -? ' - . , Emirates ,A S-553-73538; 10.0 08/30/78-Qatar..
- ?
l 821' MS-6.
10.0 10/28/69 Atwood Oceanonic,. ~ ?
. , f (Big John), Sabine-Pass, TX; ' [[_, I E.
gf .
- 4-,
' 1,f)Y L, '$
- .
i _.. ..% v - .;. y w ..2
- . [.
& < 4-. =.E { h,
- _ s }}