IR 015000042/1992002

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 15000042/92-02
ML20127L152
Person / Time
Site: 015000042
Issue date: 01/21/1993
From: Fisher W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Robinson W
ROBCO PRODUCTION LOGGING, INC.
References
NUDOCS 9301270031
Download: ML20127L152 (3)


Text

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REGION IV

611 RY AN PLAZA DRIVE, SUIT E 400 og.....f AR LINGTON, T E XAS 76011-8064 JAN 21 1993 License: General License 150.20 Docket: 15000042 Robco Production Logging, Inc.

ATTN: William H. Robinson, President P.O. Box 1423 1001 East Highway Snyder, Texas 79549 ' SUBJECT: RESPONSE TO NRL INSPECTION REPORT 15000042/92-02 Thank you for your letter of January 6,1993, in response to our letter and attached Notice of Violation both dated December 7, 1992. We have reviewed your reply and find it responsive to the concerns raised in our _ Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine whether full compliance has been achieved and will be maintained.

Sincerely, - p t, r sc - li' i t. d % 1, ./,; M h ( .. William L. Fisher, Chief Nuclear Materials Licensing Section cc: Texas Raotation Control Program Director , ( N' \\i 9301270031 930121 /.i PDR STPRO ESGTX \\\\ PDR I h ' ' - -. _.. - -.. -. _ _ - -. -.. -.... -. _

' . .. . Robco Production logging, Inc.

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. .,, Robco Production Logging, Inc.

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],jphl4 U E./[[ }. ' - -- ,, JANUARY 6, 1993 I 6199

1M UNITED STATES NUCLEAR REGULATORY COMMISSION' -

REGION IV

_ ' 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON. TEXAS 76011-8064 ATTENTION: L.

J.

CALLAN, DIRECTOR DIVISION OF RADIATION SAFETY AND STANDARDS RE: REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 15000042/92-02 DEAR SIRS, A.

Tracer work was performed throughout. Oklahoma without proper notification to any NRC office.

The reason is that some personnel were not fully _ aware of the pro'per procedure f or doing tracer work in a non~ agreement state under the reciprocity provisions of 10 CFR 150.20.. All personnel have now been fully informed as to the correct procedure for Agreement state licensees conducting r activities in a non-agreement state under the reciprocity-provisions.

Four copies of NRC Form 241 along with four copies of Specific License LO3549 will be promptly filed.

with the NRC for work in the calendar year of 1993 along , with the appropriate f ee.

Any time tracer work is to be' > performed in a. non-agreement ' state the NRC' will be informed three days prior to entry into the state.

If it is necessary to enter an NRC state sooner so that the three day notification provision can not be reasonably met, a phone call will - be initiated to the proper officials and a follow up letter of notification will be sent to the NRC office.

B.

Records of the use of licensed material were properly made by Robco personnel. Personnel; however, mistakenly; thought that paperwork dould be discarded af ter each inspection by regulatory-officials.

This necessary paperwork was inadvertently discarded.

Personnel have been inf ormed to maintain records of each use of licensed radioactive. material for inspection by officials-of the-Commission.

Proper records of all uses of Radioactive Material will be maintained and.kept ~on file for-three-years after they are made.

" g a s/ L-h P.O. BOX 1423 / SNYDER. TEXAS 79549 / (915) $73 8531 n.mr - /~ - . _ . . .. - _ _ .

. .. . ROSCO sarciatirino in retoovctiou tocoiwo - (Fij RODUCT10N p CSLOGGING, Inc.

B.

Again Robco Production Logging personnel do make radiation surveys at temporary job sites bef ore and af ter eacn suosurface tracer study to confirm the absence of radioactive contamination.

These records were inadvertently discarded by personnel because they thought that af ter inspection by regulatory officials it was not necessary to further maintain these records.

Personnel have been informed that it is necessary to keep jobsite surveys on fl.e for three years after they are made.

I wish to thank you f or your cooperation on this matter.

I believe as President and Radiation Saf ety Of ficer that hooco does maintain a very effective radiation safety program.

These violations not caused by intent or neglect for radiation safety, but from a lack of information by some of Robco's personnel.

These problems have been properly addressed.

Robco Production Logging intends to compiy with the rules and regulations for the use of radioactive materials in Agreement and Non-Agreement States.

SINCERELY: . f ff ' 1-cr~~ saE. WILLIAM H.

ROBIHSON PRESIDENT AND RADIATION SAFETY OFFICER ROBCO PRODUCTION LOGGING, UC.

P.O.

BOX 1423 1001 EAST HIGHWAY SNYDER, TEXAS 79543 P.O. BOX 1423 / SNYDE R, TEXA5 79549 / (915157.1-8531 }}