ML20011F438
| ML20011F438 | |
| Person / Time | |
|---|---|
| Site: | 03005901, 03005900, 03005902 |
| Issue date: | 02/23/1990 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Baker A HALLIBURTON CO. |
| Shared Package | |
| ML20011F439 | List: |
| References | |
| NUDOCS 9003060034 | |
| Download: ML20011F438 (1) | |
See also: IR 015000035/1989001
Text
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.In Reply Refer To:
-
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Licenses:
35-00502-02
'
E35-00502-03
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35-00502-04G'
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General: License.10 CFR 31.5
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Dockets:---30-05900/89-01-
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L30-05901/89-01
E30-05902/89-01
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150-00035/89-011
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.'Halliburton Company
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Halliburton-Services
"
' ATTN: iA' A. Baker
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-Presidents
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H-
P.O.' Drawer ~1431
a
- Duncan, Oklahoma 73536;
-
Gentlemen:
.This refers to your letter dated February 6,1990, in response to our letter
,
and attached Notices of-Violation (NOVs) dated December 11, 1989. We have
,
reviewed your, reply and find-it responsive to our concerns.
c.
-With regard to.the~ violation listed in Appendix C of the NOV, daaling.with the
1
reporting;of lost: sources, we-understand-that your records reviews and physical
searches will continue in an' effort to locate the remaining sources.
-
'We w111' review your corrective actions during future inspections to determine-
..whether-full. compliance has been achieved and will be maintained.
-
.
05h!b#$1beci By:-
A.-B. BEACH-
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A.. Bill Beach, Director
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,
Division of Radiation Safety
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and Safeguards
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Oklahoma. Radiation Control Program Director
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bc.c;w/ copy of licensee letter:
RDMartin
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KDMB:- Original-(IE-07) '
LAYandell
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.MRodriguez, OC/LFDCB (MS 4503)
CLCain
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WLFisher
GMVasquez
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- NMIS.~
MIS' System
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RIV Files (2)
RSTS Operator
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GMVasquez//W-
RIV:NMIS
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FEB- 91990 -
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HALUBURTON SERVICES.
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~ GOVERNMENT REGULATIONS DEPARTMENT
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Serior Environmental Engineers
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R.L. BECHTEL .
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-Manager-
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J.W. PRESGRoVE
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Industrial Hygienists
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' FAX Number (405) 2513917
J.R. SANDERS, JR.
J. F. BECKNER, JR.
,,
Wteer's Direct Dal Number
-(405)251-3749
February 6,
1990
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Bill. Beach, Director
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-Division of Radiation Safety & Safeguards
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U.S. Nuclear Regulatory Commission
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= Region IV
611 Ryan Plaza Drive ~
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Suite 1000
Arlington, Texas
67011
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RE:
Corrective Action Response Letter to Notice of Violations
E
' Letter Dated-- 12-11-89
.
30-05900/89-01, 30-05901/89-01, 30-05902/89-01,
Dockets:
150-00035/89-01
Dear Mr. Beach:
'
This. response will follow the same format at your " Notice of.
,
' Violations" letter dated 12-11-89.
Response To " Notice of Violations"
License:
35-005-2-02
,
Docket:
30-05900/11T-01
u
Response To Violation #1:
,
The-Vann System location in Oklahoma City was overlooked
during Halliburton Services field location audits as stated
in.your compliance letter.
Mr. Dan Kelly in now auditing all
-Vann' System locations.
Mr. Kelly conducted'an audit of the
Vann System location in Oklahoma City, Oklahoma on 12-11-89.
'
h ..-
'A copy of Mr. Kelly's audit report is enclosed for the
Commission'r review.
,
Response To Violation #2:
This violation was valid in that the Vann System location in
Oklahoma did not have the required records or an appropriate
survey-meter as required.
This location was sent the needed
records on 10-12-89 and 10-16-89.
This office also furnished
this location recommendations for a hand held survey
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instrument. : ' Mr'. - Dan Kelly 's audit. of . this facility- should
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point out any deficiencies in'the future which can be cor-
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rected.
.The above corrective measures apply to.NRC License 35-005-2-02,
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Docket- 30-05900/89-01.
1
Response'to " Notice of Violations"
'
,.
'
' License:
35-00502-03 '
Docket:
30-05901/89-01
- Response To Violation:
The discrepancies described were apparently due to_the
Halliburton Services Densometer responsible person not being
knowledgeable and current on his district's Radioactive
Densometer' inventory.
The comments given to Messrs,-Vasquez,
and Rajendsan by Mr.-Rahimi were not based on information-
!
that should have been available to Mr. Rahimi.
The following
i
comments are made:
i
1.
Sealed source S-277 did show up on copies of Oklahoma
City District inventories dated; l-5-88, 4-7-88, and
<
.6-17-88,-see copies attached.
2.
Mr. Kelly's audits dated 12-24-87 and 12-15-88 did-
-indicate source S-277 to be in the Oklahoma City Dis-
trict.
This Source /Densometer was leak tested in the
,
Oklahoma City District.on 6-7-81 and'2-10-84.
3.
-Mr. Rahimi was apparently not aware that source S750 was
being stored and used.in the Oklahoma Division instru-
ment shop.at the. time of the NRC inspection.
Mr.
!
Kelly's audit of 12-15-88 indicated that this source was
,
in the Oklahoma City inventory.and that all-records were
S
available.
Mr. Kelly's audit of 12-11-89 also indicated
that all needed records were available for source SN
,
S750.
Please see copies of inventories and' Dan Kelly's
audits.
4.-
Source SN X350 was1 received at the Duncan field camp
5-17-82.
The source was leak tested at the Duncan field
camp on. 12-10-86. ~ Copies of the Duncan field camp
fg,
inventories' dated 1-5-88 and 6-17-88 indicated source SN
- l
X350 was in the Duncan field camp inventory.
A receipt
~
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.
record (Important Notice) dated 5-17-82 was in our
scurce/Densometer file confirming the source was re-
'
elved at the Duncan field camp.
Mr. Dan Kelly's audits
dated 1-2-88 and 9-22-88 also indicated that source
X-350 was in the Duncan field camp.
Shortly after the
NRC inspection, source X-350 in Densometer SN 3IV645 was
,
transferred to Ft. Smith, Arkansas.
However, the
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-Material Transfer '(MT) was dated 10-2-89.
Apparently,
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the MT was processed 10-2-90, and this source X-350 was
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.taken off Duncan's inventory, but the source was not
4
transferred to Pt. Smith until November 1989.
Also,
'
someone in Government Regulations Department must have
deleted source SN X-350 from Duncan's inventory.
How or
why source'X-350 was added to the " Unaccounted Dens-
ometer" list I do not have a clue.
The discussion in items 1-4 above was offered as additional
,
information and will hopefully help clarify this situation.
The
items of violation were valid in that the responsible Halliburton
personnel in Oklahoma City field camp was apparently not aware of
his Densometer inventory status at'the time of the NRC inspection.
J
Secondly, the completed audit reports submittad by Mr. Kelly were
- apparently not reviewed by anyone including the Radiation Safety
- Officer.
Consequently, the deficiencies noted by Mr. Dan Kelly
were not corrected on a consistent basis.
The' Oklahoma City Division field' locations were not consistently
reviewing the computer generated quarterly inventory and actually
checking their physical inventories against the computer
inventory.
The following corrective measures have been implemented since~the
.
NRC inspection:
1.
Dan Kelly's field location audits are addressed and sent
directly to the Radiation Safety Officer (RSO) for his
review.
2.
The RSO will review each audit in its entirety and
2
initiate corrective measures to remedy the indicated
deficiencies.
i
3.
The RSO will submit to the Manager of Government Regu-
lations a form letter outlining the specific corrective
.
measures taken.
A copy of this form is' enclosed.
4.
Mr. Dan Kelly will also strive to resolve any Densometer
inventory discrepancies found during his audits as soon
as possible after they are discovered.
Response To " Notice of Violation:
'
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License:
Response To Violation:
The unaccounted sources listed in your " Notice of Violation,
Appendix C" were not reported to the NRC as lost sources
since Halliburton Services Management felt the sources were
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not lost, but simply misplaced.-
The sources are presently
.
unaccounted for, but were still in the possession of Halli-
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burton Services at some unknown location.
Since the NRC inspection of September 12, 1989, and October
10-32, 1989, the following unaccounted sources have been
located
Source Z-103:
This source in Densometer SN W35-0018 was-
sold.to the University of Wyoming in June 1986.
Appar-
ently no report'to the NRC was made under 10 CFR 32.52
as required.
"
Source S-662:
This source is shown to be currently-in
Dubai, United Arab Emirates.
This will be confirmed by
correspondence.
Source X-030:
This source is in Densometer SN 3IV111
and mounted on skid unit #6384.
The location of the
skid unit is being searched at the present time,
j
Source X-007:
This source was originally in Densometer
f
SN 3IV136.
Then source SN X-74 replaced source X-007 in
'
the same Densometer 3IV136.
Source SN X-007 is now in
our stock source inventory.
Source CS2-724:
This source /Densometer is in Vernal,
l
Utah and has been since 1983.
Mr. Kelly's audit dated
i
6-15-88 and a current computer inventory printout
i
confirms this.
Why this source was reported as un-
j
accounted for is a mystery.
Copies of the audit and
!
computer inventory are enclosed.
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Source CS2-751:
The location of this source is not
presently known.
1
Source X-211:
This source X-211 was discovered in
Duncan on a instrument kit No. 7846 in our instrument
!
kit inventory.
~
Source Y-61:
This source was returned from the Davis,
I
oklahoma facility and the source is now at the Rayfrac
Building here in Duncan.
Source A-424:
This source location is still unknown.
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Source X-350:
This source is currently in Ft. Smith,
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Arkansas after being transferred recently from the
Duncan field camp.
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Source X-375:
Our records indicate this source was sent
to Gulf Nuclear to be used as a reference source.
We
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will follow-up on this notation to confirm the transfer.
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The location of sources A-424, CS2-751,.and X-375 have not
currently been confirmed.
A letter dated 2-5-90 was sent to'nine
.(9) Halliburton Services International Divisions requesting their
assistance in locating the still unaccounted for Densometers.
A
. copy'.of-this letter is enclosed.
-
,
Halliburton Services will continue to search for the two un-
accounted for sources-until all resources have been exhausted.
The above corrective' measures should address all the violations
listed in your " Notice of Violations" letter dated 12-11-89.
Please contact this office for additional information or further
clarification.
Sincerely,
Richard A. Leonardi
V
Radiation Safety Officer
RAL:mcp
enc: (15)
cc: -Al Baker
Vann-System Locations
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-COMNET MESSAGE
80052151
FOR GVRZO11
GOV'T RLGULATIONS
PAGE 01
(AUTHOR"O COPY)
DF 03
l
3[RADI0 ACTIVE. MATERIAL WARNING WASHER PRESENT AND LEDGIDLE (PART-5458.31596)
1
ASSAY 2 PLATE PRESENT AND LEDGIBLE-(PART- 1450.31133)
TWO DOT _RADI0 ACTIVE YELLOW ~II LADELS PRESENT AND LEDGIDLE-(PART #70.70790)
1.--
c.?~ DOT-7A TYPE A LABEL PRESENT.AND LEDGIBLE (PART 4450.31624)
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EACH.DENSOMETER MUST DE MARKED:
RADI0 ACTIVE MATERIAL, SPECIAL FORM,
N.O.S.-
.
UN2974-HALLIDURTON SERVICES-DUNCAN, OKLAHOMA (SHOULD DE ON LADEL)
1
..'ALL RADI0 ACTIVE MATERIALS NOT VEHICLE MOUNTED MUST BE STORED IN A LOCKED AREA
LOCATED AWAY FROM NORMALLY OCCUPIED WORK AREAS.
ALL STORAGE FACILITIES MUST
'BE; POSTED WITH:
CAUTION RADI0 ACTIVE MATERIALS AND CAUTION RADIATION AREA
'
SIGNS. PART 470.79222 AND 70.79223 AND MUST BE MARKED:
RESTRICTED AREA
'
AUTHORIZED ENTRANCE ONLY (LOCAL PURCHASE).
THE RADIATION LEVELS AT THE
FENCE / OUTER WALLS OF THE STORAGE AREA MUST BE <0.6 MR/HR.
h YOU HAVE ANY QUESTIONS OR NEED ASSISTANCE CONTACT RICHARD LEONARDI
AT KILGORE
EXAS.OR CONTACT THE GOVERNMENT REGULATIONS DEPARTMENT IN DUNCAN.
GURCE
DENSOMETER
ACTIVITY- MANUFACTURER
LAST
NEXT
DATE OF
JMBER
NUMBER
(MCI)
AND/OR
WIPE
WIPE
LEAK TEST
MODEL
DATE
DATE
COUNT
.
.._----
a(L A' O'MA CITY , OKLAHOMA
H
151-
3IV503
10.05
NSSI/GTGHP
12-14-86
12-14-89
1-9-87
- 98
3IV415
10.8
NSSI/GTGHP
1-31-84
PAST DUE
57~dGS
8005
100
AMERSHAM /
12-14-86
12-14-09
1-9-87
32-438
3IV682
10
GNI/CS2
12-14-86
12-14-89
1-9-87
32-445
3IV690
10
GNI/CS2
12-14-86
12-14-89
1-9-87
32-785
30V783
55
GNI/CS2
12-14-86
12-14-89
1-9-87
32-764
020SDB
55
GNI/CS2
12-14-86
12-14-89
1-9-87
277
73404
9.5
NSSI/GTGHP
12-16-86
12-16-09
3-2-87
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FOR'OVRZO11- GOV 'T REGULA'10 S
PAGE 01
D U? HOR"$ COPY)
.
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OF 03
Ll Mf:DIDACTIVE MATERI AL WARNING WASHER . PRESENT AND LED 01BLE (PART 4458.31596)
'
Z "A MAYLPLATE PRESENT AND LEDGIDLE ( PART 11458.31133)
'iTW0? DOT ~RA010 ACTIVE' YELLOW II:LADELS PRESENT-AND LEDGIPlE-(PART'170.'707?O)
'DOEJ7A: TYPE-A LABEL.PRESENT AND LEDGIDLE (PART #458.31624)
7
~
L LEACH--DENSOMETER MUST BE MARKED:
RADIDACTIVE M4TERIAL, SPECIAL FORM,
N.O.S.-
IUN2974-HALLIDURTON-SERVICES-0UNCAN, OKLAHOMA (SHOULD DE ON LADEL)
l
'
- ALLERADI0 ACTIVE MATERIALS NOT-VEHICLE MOUNTED MUST BE STORED IN A LOCKED AREA
l
LOCATED-AUAY FROM NORMALLY. OCCUPIED WORK AREAS.
ALL STORAGE FACILITIES NUST
,
Q BC POSTED-WITH:.
CAUTION RADI0 ACTIVE MATERIALS AND CAUTION RADIATION AREA
- SIGNS . PART 970.79222 AND 70.79/2'3 AND MUST BE MARKED
RESTRICTED-AREA
!
,
AUTHORIZED ENTRANCE ONLY (LOCAL PURCHASE).
THE RADIATION' LEVELS AT THE
l
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g: ' FENCE /0 UTER WALLS OF. THE STORAGE AREA MUST BC < 0.6 MR/HR.
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LYOU HAVE'ANY QUESTIONS OR NEED ASSIS1ANCE CONTACT RICHARD'LEONARDI AT KILGORE
$
6 MAS OR CONTACT THE GOVERNMENT REGULATIONS DEPARTMENT IN '0UNCAN.
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O JRCE
DENSOMETER
ACTIVITY
MANUFACTURER
LAST
NEXT
DATE OF
JMDER
NUMDER
(MCI)
AND/OR
WIFE
WIPE
LEAK TEST
"
MODEL
DATE
DATE
COUNT
L
r.______
__________
________
____________
________
________
_________
LAHOMA CITY, OKLAHOMA
L151
3IV503
10.05
NSSI/GTGHP
12-14-86
12-14-89
J-9-87
'
'L98'
31V415
10.8
NSSI/GTGHP
1-27-88
1-27-91
2-1-88
l.
'.:75GS-
8005
100
AMERSHAM /
3-17-88
3-17-91
3-17-88.
'
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U2-438
3IV682
10
GNI/CS2
12-14-86
12-14-89
1-9-87
(J2-443
31V490
10
ONI/CS2
12-14-86'
12-14-89
.1-9-87
[
'32-7G5
30V783
55
'GNI/CS2
12-14-86
12-14-09
1-9-87
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k
, s 2 :7'6 4
020SDB
55
ONI/CS2
12-14-86
12-14-89
1-9-87
777..
73404
9.5
NSSI/GTGHP
12-16-86
12-16-89
3-2-87
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10VICE
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ACQUIRED 05-03-51
9 ~ 'E!!$P.E T R L 31V41S-
ISOTOPE
CEGIUM-1:'7
LASTWIPE 01-27-88
h c' APT NDP.
JNIT-ACT
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NEXTUIPE 01 27-91
,.JNTT NBR~ 0131
COMP-ACT
9.160
COUNT
02-01-80
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CO2~445
.MODEL/MANUF GNI/CS2
ACQUIRED 04-16-82
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.ENGMETR
3IV6c0
TSOTOPE
LASTWIFE 12-14-86
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. pART NDR'
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10.000
NEXTWIPE. 12-14-89
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NIT;.HBR
75050-
COMP-ACT_
8.670
COUNT
01-09-87
?OURCF
- CS2-09
MODEL/MANUF GNI/C89
ACQUIRED 04 16-G2
DENShErP ~31V402
ISOTOFE
LASTWIFE 12-14-86
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INIT-ACT
10.000
NEX1 WIPE 12-14-89-
7
UNI T NBR
COMP-ACT
3, ,70
COUNT
01-09-87
}DURCE
CS2-N'1
.iGEL/MANUF ONI/CD?
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ACQUIRED 03-09-D4
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[SOTOPE
LASTWIPE 12-14-06
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INIT- ACT
55.000
NEXTWIPE 12-14-89
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COM P-- AC T
49.826
COUNT
01-09-G7
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ilCOMNETtMESSAGE-
80052027~
~
.FORLGVRZO11: GOV 'T REGULATIONS
PAGE 00:
{fAUTHOR"SLCOPY)L
OF'03
tt
'
'
iT0 s l FEC2751' :-JOHN ~ 0SWALD.
MESSAGE WAS'SENT ON :05JAN80 13:45
b:
FROM: GVRZO11- GOV'T REGULATIONS
",
TITLEi: DENS 0 METERS.
"
.
,LSUBJECT I-, QUARTERLY ' INVENTORY , 6,MONTHEINSPECTION, AND LEAK TEST CERTIFICATE
-
,
4
.J V 'FOR VERIFICATION AND FILING
1 ACTION' REQUIRED:
NEEDED BY:
ePMESSAGE' ENTERED BY USER: GVRZO11'
AT LTERM
GOVREG07
- i
< MESSAGE? PRINTED:BY USER fGVRZO11
GOV 'T REGULATIONS
AT LTERMs
- t
1 CURRENT USER ID
GVRZO11-
GOV'T REGULATIONS
T
-l
'
' ATTACHMENTS:-'
- l
A
lCCI
,
h'DIVZ001
C '.
H. MCDUFF
GVRZ101
RICHARD LEONARD 1
p
,
" LISTED BELOW ARE<THE-SOURCES / DENS 0 METERS OUR RECORDS INDICATE ARE IN YOUR DEPT./
' DIVISION'.
ALSO LISTED IS'THE MANUFACTURER, ACTIVITY LEVEL, ISOTOPE (IF OTHER
FTHAN. CESIUM-137), AND WIPE TEST DATA.
lTHIS1 LIST SERVES -QUARTERLY INVENTORY AND 6 MONTH INSPECTION FOR STORAGE LOCA-
JTIONSi.
WE WILL-SEND-YOU AN UPDATED LIST AT LEAST EACH QUARTER.
YOU SHOULD
sPHYSICALLY VERIFY AND INSPECT DENS 0 METERS / SOURCES EACH TIME YOU RECEIVE' THIS
tLIST.
IF.THE LIST IS' CORRECT PRINT'AND' FILE IT,WITH YOUR RADI0 ACTIVE MATERIAL
LFILES..
IF THE. LIST'IS NOT CORRECT CONTACT THE GOVERNMENT REGULATIONS DEPART :
' MENT?IN'DUNCAN.
-;EACHELOCATION WILL DE RESPONSIBLE FOR ORDERING AND PERFORMING WIPE TESTS FOR
EACH OFETHEIR SEALED SOURCES / DENS 0 METERS AT'THREE YEAR INTERVALS'(UNLESS OTHER -
JWISE'NOTED ON THE' LIST).
THE PART NUMBER FOR WIPEETEST KITS IS 458.00080.
f0RDER WIPE $ TEST KITS AT LEAST 90-DAYS IN' ADVANCE'0FLTHE DUE DATE-: INDICATED ON.
iTHE LIST BELOW-
JTHIS: LIST 1WILL SERVE'AS YOUR CERTIFICATE OF LEAK TEST:
THIS IS TO CERTIFY THE
. LEAK TESTS 0N THE DELOW NAMED SOURCES WERE (0.005 MICR0 CURIES (<11.000 DPM)
(TRANSFERABLE' ACTIVITY,-BY DAVE SIMON, CRD AND/OR INSTRUMENT ASSEMBLY, DUNCAN..
.
-
$
M
.we,
' h ,-
a
,,
COMNET MESSAGE
80032027
FOR GVRZO11
GOV 'T REGULATIONS
PAGE 01
0F 03
(AUTHOR"S, COPY)
i
~ RADI0 ACTIVE MATERIAL WARNING WASHER PRESENT AND LEDGIDLE (PART 4400.31596)
.
' '. ASSAY PLATE PRESENT AND LEDGIDLE (PART 845S.31133)
TWO DDT RADIDACTIVE YELLOW II LABELS PRESENT A'!O LEDGIBLE (PART 470.70790)
.
2
00T 7A TYPE A LABEL PRESENT AND LEDGIBLE (PAR 1 4458.31624)
EACH DENS 0 METER MUST BE MARKED
RADIDACTIVE MATERIAL, SPECIAL FORM,
N.O.S.-
.
UN2974-HALLIDURTON SERVICES-DUNCAN, OKLAHOMA (SHOULD BE ON LABEL)
CLL RADIDACTIVE MATERIALS NOT VEHICLE MOUNTED MUST BE STORED IN A LOCKED AREA
3.
LOCATED AWAY FROM NORMALLY OCCUPIED WORK AREAS.
ALL STORAGE FACILITIES MUST
BE POSTED WITH:
CAUTION RADI0 ACTIVE MATERIALS AND CAUTION RADIATION AREA
. SIGNS
PART 970.79222 AND 70.79223 AND MUST BE MARKED:
RESTRICTED AREA
AUTHORIZED ENTRANCE ONLY (LOCAL PURCHASE).
THE RADIATION LEVELS AT THE
FENCE /0 UTER WALLS OF THE STORAGE AREA MUST BC <0.6 MR/HR.
F YOU HAVE ANY QUESTIONS OR NEED ASSISTANCE CONTACT RICHARD LEONARDI AT KILGORE
'"EXAS OR CONTACT THE GOVERNMENT REGULATIONS DEPARTMENT IN DUNCAN.
l
30URCE
DENS 0 METER
ACTIVITY
MANUFACTURER
LAST
NEXT
DATE OF
JUMDER
NUMUER
(MCI)
AND/OR
WIPE
WIPE
LEAK TEST
d
MODEL
DATE
DATE
COUNT
........
..... ....
........
............
........
........
.........
JUNCAN, OKLAHOMA
l
1029
3IV110
10.5
NSSI/GTGHP
2-19-87
2-19-90
3-2-87
1
134
PF0002
11
GNI/CS1000
12-10-86'
12-10-89
2-2-87
!
5676
73717
9.7
NSSI/GTGHP
10-15-87
10-15-90
10-16-87
!
3714
60375C
21
NSSI/GTGHP
12-10-86
12-10-89
2-2-87
X81
73945
10
NSSI/GTGHP
12-10-86
12-10-89
2-2-87
<242
3IV562
10.5
NSSI/GTGHP
12-10-86
12-10-89
2-2-87
!
(45
6099SC
19.3
NSSI/GTGHP
12-10-86
12-10-89
2-2-87
X303
31V596
10
NSSI/GTGHP
12-10-86
12-10-89
2-2-87
X350
31V645
10
NSSI/GTGHP
12-10-86
12-10-89
2-2-07
3703
SIN 001
21
NSSI/GTGHP
12-10-86
12-10-89 *2-2-87
2119
W320047
56.6
GAMMATRON/GTGHP
10-14-87
10-14-90
10-14-87
l
X183
3IV478
11.3
NSSI/GTGHP
1-15-87
1-15-90
3-2-87
)
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NN
TOMr. John oswald
Engineering
Duncan Oklahoma
_
DLPAk14tLN1
1(K AIlON
Richard A. Leonardi. Jr.
FROM
Sansocibdir
Government Regulations
Duncan, OK 73536-o100
DLPARI ALLMI
1(K AllON
A wipe test is needed on Source No. X350
in Densometer No. 3Iv645
l
,
This test must be made NOW to meet N.R.C. or Agreement Stste Regulations. DO NOT Cil ANGE
,
NUMBERS.
'
Using the cotton wipe material, wipe around Source Holder Flange and return to platic bag. Provide
the following information:
,
Mo'lty
Date
/2 /0 f 6
Source wiped by
ntv
Source Location Ms*
'J' M
ONII
-
,
Richard A. Leonardi Jr.
Return along with wipe to:
INEGXKWIK
Halliburton Services
Drawer 1431
Duncan, OK 73536 -0100
DGK:im
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smut u '
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Upbn receipt of this. Unit, plcoca comploto fonn cnd' roturn os indicated.
i
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KEEP A COPY OF THIS AS A RECEIPT RECORD!!!I
.
.
'
IMPORTANT NOTICE
I'
WHEN A RADIOACTIVE DENSOMETER IS SOLD, LEASED, INSTALLED ON OUR
EQUIPMENT TRANSFERRED OR RETURNED BY LEASEE, THE PERSON HANDLING THE
TRANSACTION SHALL FILL OUT THIS FORM IN DUPLICATE. ONE COPY lS TO BE SENTTO THE
i
DIVISION ENGINEER AND THE OTHER COPY TO:
DAN G. KELLY
HALLIBURTON SERVICES
'
-
DRAWER 1431
~
DUNCAN.OK 735%
THIS DENSOMETER WAS (SOLD)(LEASED)(l$ MOUNTED ON HALLIBURTON EQUIPMENT)(15
!
TO BE USED WITH HALLIBURTON EQUIPMENT)(TRANSFERRED)(RETURNED BY 1EA$EE)
j
UNDERLINE ONE.
'
SOURCE SERIAL NO.
- ' 4 T
DENSOMETER SERI AL NO.
5
'
,-
MOUNTED ON iI#!
I
'
'
'*6
.
UNIT NO.
'-
=.,_
TYPE IQUIPMLNT
'
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'
'
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LOCATION
TOWN
$1 ATE
ZIP
I
DENSOMETER RECEIVED BY AND SERIAL NUMBERS WERE CONFIRMED BY:
i
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,,
.
NAME
DATE
.
IF OTHER THAN ABOVE DESCRIBE:
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Ron Bechtel
l
Government Regulations
l
l
Richard Leonardi, Jr.
Government Regulations
i
l
Corrective Measures Taken to Rectify Deficiencies
Documented in Dan Kelly's Radiation Safety Audits
l
l
The following corrective measures were taken to rectify
.
'
radiation safety program deficiencies found during a recent
radiation safety audit as described below.
OFSG COMPANY AUDITED:
,
AUDITED LOCATIONS:
DATE OF AUDIT
DATE OF AUDITOR
REPORT:
,
1
AUDIT LOCATION
CONTACT:
-
'M
CORRECTIVE MEASURES COMPLETED
NO CORRECTIVE HEASURES REQUIRED
'
Telephoned contact person regarding deficiencies
Sent the required Source /Densometer Records listed
on Attachment
.
<
Ordered and will send completed assay plates for
the Sources /Densometers listed on Attachment
k
Sent
Leak Test Kits as requested.
,
Sent copy of Densometer computer program user
instructi,ons
Sent copy of recent computer Densometer inventory
printout
'
.
.
.
9
1
o
.
'
.
=,
.
. ..
Sent copy of
Radioactive Material License
Sent copy of
Radiation Safety Procedures
Sent copy of " Notice to Employees"
'
Sent copy of " Posting Card"
Sent copies of " Notice of Violation" and/or
Corrective Action Letters
Sent storage area survey procedures and standard
survey report forms
Sent survey meter information and purchase
-
'
information
Sent required radiation labels and/or signs as
listed on Attachment
SPECIAL INSTRUCTIONS:
See Atthchment
Richard Leonardi
Radiation Safety Officer
RLamep
CC:
enclosures: 1
.
CORRECTIVE.RL
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ATTACHMENT
Source
Densometer
Secled Source
Radiation
Previous
Receipt
Number
Serial 0
Certificate
Profile
Leak Test
Record
!
,
1
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!
SPECIAL INSTRUCTIONS
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DENSOMETER INFORMATION
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Inspected By
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Date
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- _ _ - _
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,
.
.
- Licted below are the sources /densometers our records indicates are in your dept / !
.
division.
Also listed is the manufacturer, activity level, isotope (if other
than Cesium-137), and wipe test data.
-
This list serves: Quarterly Inventory and 6 Month Inspection for storage loca-
tions.
You will need to pull an updated list at least once each quarter.
You
'
should physically verify and inspect densometers/ sources each time you receive
this list.
Also, the "Next Wipe Date" column should be checked to determine
,
if any of the densometers will need to be wiped to keep their "Last Wipe Date"
within the 3 year requirement of NRC.
If the list is correct, file it with
your radioactive material files.
If the list is not correct, contact the
Government Regulations Department.
Each location will be responsible for ordering and performing wipe tests for
Gach of their sealed sources /densometers at three year intervals (unless other-
wise noted on the list).
The part number for wipe test kits is 458.00080.
Order wipe test kits at least 90 days in advance of the due date indicated on
th3 list below.
'
This list will serve as your certificate of leak test:
This is to certify the
look tests on the below named sources were <0.005 microcuries (<11,000 DPM)
transferable activity, by Dave Simon, CRD and/or Instrument Assembly, Duncan.
l
During the densometer inspection referenced above the following items must be
varified:
.
'
l. Radioactive material warning washer present and legible (part # 458.3 1596)
2. Assay plate present and ledgible (part # 458.31133)
3.Two DOT Radioactive Yellow II Labels present and ledgible (part # 70.70790)
4. DOT 7A Type A Label present and ledgible (part # 458.31624)
5.Ench densometer must be marked:
Radioactive Material, Special Form,
N.O.S.-
l
UN2974-Halliburton Services-Duncan, Oklahoma (should be on label)
!
6.All radioactive materials not vehicle mounted must be stored in a locked area
l
located away from normally occupied work area.
All storage facilities must
bs posted withs CAUTION RADIOACTIVE MATERIALS and CAUTION RADIATION AREA signs
,
part # 70.79222 and 70.79223 and must be marked: RESTRICTED AREA AUTHORIZED
i
ENTRANCE ONLY (Local Purchase).
The radiation levels at the fence / outer wall
of the storage area must be <0.6 MR/HR.
If you have any questions or need assistance contact Richard Leonardi at Kilgore
th3 Government Regulations Department in Duncan.
SOURCE
DENSOMETER
ACTIVITY
MANUF/MODEL
LAST
NEXT
LEAKTEST
NUMBER
NUMBER
(MCI)
NUMBER
WIPEDATE
WIPEDATE
DATE
ACCT / LOC
55685
VERNAL
X145
731063
8.873
NSSI/GTGHP
11-17-89
11-17-92
01-08-87
X497
W28-0119
10.120
GAMMATRON/GTGHP
01-11-90
01-11-93
01-25-90
Y44
V660014
15.888
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
CS2-479
31V702
8.352
GNI/CS2
01-20-90
01-20-93
X089
31V203
8.758
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
CS2-724
410043
47.045
GNI/CS2
02-24-87
02-24-90
02-25-87
,
X086
73942
8.035
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
X054
73922
8.404
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
843
PFD4
6.316
GNI/CS1000
01-11-90
01-11-93
01-25-90
S580
73491
7.761
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
CS2-724
W410043
47.045
GULF NUCLEAR
01-11-90
01-11-93
01-25-90
1576GS
8002
100.125
AMERSHAM /
01-22-88
01-22-91
02-08-88
S441
73474
7.474
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
S708
098SC
15.931
NSSI/GTGHP
06-02-88
06-02-91
07-07-88
Y21
6076SC
17.596
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
CS2-675
731037
8.482
GNI/CS2
01-20-90
01-20-93
XO75
3IV129
8.276
NSSI/GTGHP
01-23-90
01-23-93
879
V350019
6.500
GNI/CS1000
01-11-90
01-11-93
01-25-90
.
.- . - - -
-
-
-
_ .
-
.
.
I
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.
.
>
'
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Y42,
61N096SC
16.052
NSSI/GTGHP
01-11-90
01-11-93
X124
731053
8.141
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
g . 2006
C3105
42.410
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
,
'
2005
3DV849
42.725
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
S145
731030
7.235
NSSI/GTGHP
01-11-90
01-11-93
01-25-90
0008
731044
8.924- 3M/4P6D
01-23-90
01-23-93
CS2-756
3IV793
8.692
GNI/CS2
01-20-90
01-20-93
Y99
V66-0042
20.996
GAMMATRON/GTGHP
01-11-90
01-11-93
01-25-90
'2100
W320014
53.309
GAMMATRON/GTGHP
01-11-90
01-11-93
01-25-90
.
'
X661
V36-0181
9.959
GAMMATRON/GTGHP
01-11-90
01-11-93
01-25-90
2116
W410042
55.260
AMMATRON/GTGHP
01-11-90
01-11-93
01-25-90
1
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In Reply Refer To:
.
Licenses: 35-00502-02
35-00502-03
l
35-00502-04G
General License 10 CFR 31.5
Dockets: 30-05900/89-01
l
30-05902/89-01
i
30-05902/89-01
150-00035/89-01
Halliburton Company
'l
Halliburton Services
]
ATTN:
A. A. Baker, President
'
.P.O. Drawer 1431
Duncan, Oklahoma 73536
Gentlemen:-
]
,
This refers to the routine, unannounced radiation safety inspection conducted
by Messrs. G. M.-Vasquez and S. Rajendran of this office on September 12 and
October 10-12, 1989, of the activities authorized by NRC Byproduct Material
Licenses 35-00502-02, 35-00502-03, 35-00502-04G, and the General License
pursuant to 10 CFR 31.5, and to the discussion of our findings held by the
inspectors with members of your staff at the conc)usion of the inspection. The
enclosed combined NRC Inspection Reports 30-05900V89-01,30-05901/89-01,
'
30-05902/89-01, and 150-00035/89-01 document this inspection.
The inspection was an examination of the setivities conducted under the license
as they relate to. radiation safety and to compliance with the Commission's
rules and regulations and the conditions of the license.
The inspection
consisted of selective examinations of procedures and representative records,
interviews of personnel, independent measurements, and observations by the
inspectors.
During this inspection, certain of your activities were found not to be
conducted in full compliance with NRC requirements for License
Nos. 35-00502-02, 35-00502-03 and the General License authorized by
i
Consequently, you are required to respond to this matter in
writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules
,
of Practice," Part 2, Title 10, Code of F deral Regulations.
Your response
9
should be based on the specifics contained in the Notices of Violation enclosed
with this letter. No violations were identified for License No. 35-00502-04G.
-
l
The inspectors also reviewed the actions you had taken with respect to the
g-
violations observed during our previous inspection of License Nos. 35-00502-03
and 35-00502-04G conducted on August 4-5, 1988. They verified that the
corrective actions for these violations had been implemented as stated in your
reply dated November 16, 1988.
RIV:NMIW+E
NMIS M
C:NMISWL
- 1 SS
I
GMVasquez
SRajendran
CLCain
BBaach
13 / 6 /8 9
lb/6 /89
(t./6 /89
Q/g/89
1
40
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Halliburton Company-
-2-
i
-
)
<
' ele are concernsd about the implementation of your program in the area of
j
management control that permitted these violations to occur. Consequently, in
your reply to this letter, you should describe those specific actions planned
or taken to improve the effectiveness of the management control of your
licensed operations, with particular emphasis on measures currently being taken
!
to prevent further violations.
In 1987, an order modifying your. license
required you to implement an internal audit program. We are concerned about
the quality of your audits in that deficiencies were noted by NRC in three out
of four of the field stations inspected. These results indicate inadequate
audits were performed.
The response directed by this letter and the accompanying Notice is not subject-
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this letter, we will be pleased to
!
discuss them with you.
UlflMINYgned By:
A.B. BEACH
A. Bill Brach, Director
Division af Radiation Safety
'
and Safeguards
'
Enclosures:
1.
Appendix A - Notice of Violation for License No. 35-00502-02
2.
Appendix B - Notice of Violation for License No. 35-00502-03
3.
Appendix C - Notice of Violation for the General License Pursuant to
4.
Appendix D - Combined NRC Inspection Reports
30-05900/89-01
30-05901/89-01
30-05902/89-01
150-00035/89-01
5.
Appendix E - Litt of Unaccounted for Densometers
cc:
Oklahoma Radiation Control Drogram Director
,
bec:
DMB - Original (IE-07)
RDMartin
)
ABBeach
LAYandell
LShea, RM/ALF (AR-2015)
"CLCain
- RJEverett
- GMVasquez
- SRajendran
ff S~ '
' MIS System
RIV Files (2)
- RSTS Operator
- REHall, URF0
- W/766
.
.
-..
- -
-
,
..
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- . .
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APPENDIX A
-
,
p
NOTIC,E,0F VIOLATION
Halliburton Company
Dockets:
30-05900/89-01
i
Duncan, Oklahoma '
Licenses: 35-00502-02
-
During an NRC inspection conducted on September 12 and October 10-12, 1989,
.
.
violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989) (Enforcement policy), the violations are listed
below:
1.
License Condition 13 requires, in part, that the licensee conduct its
'
program in accordance with the statements, representations, and procedures
contained in the licensee's letter dated December 21, 1988. The
Radioactive Safety and Material Audit Program description attached to the
letter states, in part, that comprehensive audits of the hahdling, use,
storage, and disposition of licensed tracer materials shall be conducted
at intervals not to exceed 3 months.
,
Contrary to the above, no such audits were performed at the Vann Systems
office in Oklahoma City during the period dynuary I through October 12,
,
1989, in regard to possession of Co-60 beads licensed for tracer
activities.
This is a Severity Level IV violation.
(Supplement VI)
2.
10 CFR 19.11 requires, in part, that the licensee post specified
documents.
Contrary to the above, as of October 12, 1989, none of the specified
documents were posted at the Vann Systems office in Oklahoma City,
Oklahoma, where approximately 14 microcuries of Co-60 beads were located
at the time of the inspection.
l
This is a Severity Level V violation.
(Supplement VI)
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Pursuant to the provisions of 10 CFR 2.201, Halliburton Company is hereby
requirm to submit to this office, within 30 days of the date of the letter
transmitting this Notice, a written statement or explanation in reply,
~
including for each violation: (1) the reason for the violation if admitted,
k
(2) the corrective steps which have been taken and the results achieved,
5
(3) the corrective steps which will be taken to avoid further violations, and
(4) the date when full compliance will be achieved. Where good cause is shown,
consideration will be given to extending the response time.
Dated at Arlington, Texas,
this
lith
day of December
1989
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APPENDIX B
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Halliburton Company
Docket:
30-05902/89-01
Duncan, Oklahoma
License:
35-00502-03
During an NRC. inspection conducted on September 12 and October 10-12, 1989, a
'
violation of NRC requirements was identified.
In accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1989) (Enforcement Policy), the violation is listed below:
License Condition 19 requires, in part, that the licensee conduct its
program in accordance with the statements, representations, and procedures
contained in the letter dated December 21, 1988. The Radioactive Safety
and Material Audit Program description attached to the letter states, in
part, that comprehensive audits of the handling, use, storage, and
disposition of generally licensed sealed sources shall be conducted at
intervals not to exceed 12 months.
.
Contrary to the above, inadequate audits were performed at the Oklahoma
,
City and Duncan, Oklahoma, sites in that discrepancies in source
i
inventories were not identified.
Specifica1$y, at the Oklahoma City site,
'
sealed source Serial No $277, a 9.5 mci Cs '137 source, was not on the
facility's inventory though it had been received at the facility in
February 1984. Additionally, sealed source Serial No. 5750 was on the
facility's inventory, but was not at the facility and no records existed
that the sealed source was ever received at the facility. Both of these
discrepancies were identified by the inspectors despite licensee audits
conducted December 30, 1987, and December 15, 1988.
At the Duncan site, sealed source Serial No.-X350 was discovered during
,
the inspection and was found to have been at the field site for several
years. However, the source was not on the site's inventory and was, in
fact, on the licensee's list of unaccounted for sources. Despite licensee
audits conducted on January 2 and September 22, 1988, these discrepancies
were identified by NRC during the inspection.
This is a Severity Level IV violation.
(Supplement VI)
-
Pursuant to the provisions of 10 CFR 2.201, Halliburton Company is hereby
required to submit to this office, within 30 days of the date of the letter
transmitting this Notice, a written statement or explanation in reply, ,
including for each violation:
(1) the reason for the violation if admitted,
'
(2) the corrective steps which have been taken and the results achieved,
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-(3) the corrective steps which will be taken to avoid further violations, and
(4) the- date when full compliance will be achieved. Where good cause is shown,
consideration will be given to extending the response time.
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Dated at Arlington, Texas,
this
11th
day of December
1989
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APPENDIX C
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Halliburton Company
Docket:
150-00035/89-01
Duncan, Oklahoma
General License:
}
During an NRC inspection conducted on September 12 and October 10-12, 1989, a
violation of NRC requirements was identified.
In accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1989) (Enforcement Policy), the violation is listed below:
_'
10 CFR 31.5(c) states, in part, that any person who acquires, receives,
possesses, uses or transfers byproduct material in a device pursuant to
10 CFR 31.5(a) shall comply with the provisions of 10 CFR 20.402 for
reporting theft or loss of material.
10 CFR 20.402(a) requires, in part,
'
.
that the licensee notify the NRC immediately after it determines that a
loss or theft of licensed material has occurred.
.
Contrary to the above, as of November 1988, the licensee has been unable
to determine the location of the following Cs-137 sealed sources
'
identified by serial number and activity:
S-662 (10 mC1); X-030 (10 mC1);
,
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CS2-751 (10 mC1); X-211 (10 mC1); Y-61 (20 r$1); A-424 (50 mC1); and
X-375 (10 mC1). Since that date, the literske has neither located the
i
sources nor reported them to the NRC as missing.
The sources were last
known to be in Okithoma,- a state where the NRC maintains jurisdiction.
This is a Severity Level IV violation.
(Supplement IV)
Pursuant to_ the provisions of 10 CFR 2.201, Halliburton Company is hereby
required to submit to this office, within 30 days of the date of the letter
,
-
transmitting this Notice, a written statement or explanation in reply,
including for each violation:
(1) the reason for the violation if admitted.
(2) the corrective steps which have been taken and the results achieved,
(3) the corrective steps which will be taken to avoid further violations, and
,
(4) the date when full compliance will be achieved. Where good cause is shown,
consideration will be given to extending the response time.
'
Dated at Arlington, Texas,
this
lith
day of December
1989
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APPENDIX D
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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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
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150-00035/89-01 General License 10 CFR 31.5
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Dockets: 30-05900
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30-05901
1
30-05902
150-00035
]
Licensee: Halliburton Company
P.O. Drawer 1431
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Duncan, Oklahoma 73536
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Inspections At: Duncan, Enid, and Oklahoma City, Oklahoma
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Inspectors:
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G. M. Vasquez, Mdiation Specialist, Nuclear
Date'
hterials Inspection Section
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5. Rajendran, Radiation Specialist, Nuclear
Dat6
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Materials Inspection Section
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Approved:
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A
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Charles L. Cain, Chief, Nuclear Materials
Dati
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Inspection Section
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Inspection Summary
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Inspection Conducted September 12 and October 10-12, 1989
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(Report 30-05900/89-01, 30-05901/89-01, 30-05902/89-01, and
350-00035/89-01)
Areas Inspected: A routine, unannounced inspection was conducted on
September 12, 1989, in Duncan, Oklahoma, followed by field office 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 scopesof the radiation safety program,
internal audits, and notifications and reports.
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In general, the licensee's radiation safety program appeared to be
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adequate.
Identified weaknesses related to the licensee's audit program and
materials accountability.
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Four apparent violations were identified:
f
2.
Failure to post required documents (Section 3).
2.
Failure to perform an adequate audit of licensed materials (Section 4).
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3.-
Failure to perform audits of licensed tracer materials every 3 months
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(Section 4).
4.
Failure to notify NRC of a loss of licensed material (Section 5).
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DETAILS
1.
Persons Contacted
'Al Baker, President, Halliburton Services (Houston, Texas)
- Ray Durbin, Corporate Attorney, (Duncan, Oklahoma)
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" Ronald L. Bechtel, Manager, Department of Government Regulations (Duncan,
'
"kichard Leonardi, Radiation Safety Officer (Duncan, Oklahoma)
'
Ralph Houser, Assistant Radiation Safety Officer (Duncan, Oklahoma)
'
Roger Ledford (Duncan, Oklahoma)
Ron Coon (Duncan, Oklahoma)
Gary Phelps (Duncan, Oklahoma)
Dr. Ron Buchanan (Duncan, Oklahoma)
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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)
3Ralph Voss (Duncan, Oklahoma)
.
- Telephonic exit briefing conducted October 16, 1989
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" Preliminary exit briefing conducted October 12, 1989
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Present during inspection at Enid field camp
2Present during inspection at Oklahoma City field camp
3Present during inspection at Duncan field camp
2.
Licensee Actions on previous Inspection Findings
(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
require each field site to check for source leak tests that may be due.
I
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
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overdue for leak testing.
(Closed) (30-05901/88-02 and 30-05902/88-01):
Failure to conduct physical
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,
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(Closed) (30-05901/88-02 and 30-05902/88-01):
Failure to label sealed
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sources " CAUTION RADIOACTIVE MATERIALS" or " DANGER - RADI0 ACTIVE
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MATERIALS." The inspectors reviewed labeling on selected. devices, and all
,
were.found to be adequately labeled.
,
(Closed) (30-05901/88-02 and 30-05902/88-01):
Failure to provide constant
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surveillance and immediate control of licensed material in an unrestricted
,
area. The inspectors observed no material in an unrestricted area that
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was not under constant surveillance and immediate control.
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13 .
Oroanization and scope of the Radiation Safety Program
The Halliburton division and subsidiaries licensed by the NRC to possess
and use' radioactive materials include:
Halliburton Services (HS),
Halliburton Reservoir Services (HRS), Vann Systems Jet Research Center,
Otis Engineering, Halliburton Logging Services (HLS), and Halliburton
Geophysical Services, Inc. (HGS).
Each division and subsidiary has had
its own administrative structure and has operated independently of each
other. All divisions and subsidiaries were owned by Halliburton Company,
which has been viewed as a holding company.
+
ThelicensedactivitiesoftheJetResearchhenter,HLS,andHGSwerenot
inspected.
Despite their autonomy, the Radiation Safety Officer (RS0) for HS has also
been the RSO 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
,
tracer activities. The Vann Systems field office in Oklahoma City
possessed only 14 microcuries of Co-60 beads at the time of the
inspection.
HS, which previously had tracer materials at their field camps, has
transferred these materials to other licensed companies and has
performed final radiation surveys at field camps to ensure this.
Otis Engineering, which previously possessed uranium sinker bars has
transferred all licensed materials to HRS. A license amendment
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request to that effect had been submitted to NRC on August 21, 1989.
B.
License No. 35-00502-03 authorizes HS to research, develop, and
manufacture density gauges and logging instruments; manufacture
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
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decontaminating reactor components, manufacturing logging
instruments, and manufacturing tracer sands. However, the licensee
stated that they would like to maintain authorization to manufacture
ts acer sands and logging instruments as an option for the future.
The licensee's most significant use of radioactive materials
authorized under this license appeared to be the manufacturing of the ,
density gauges. Between November 1, 1988, and November 1, 1989, they
manufactured approximately 24 gauges per month.
These gauges were
then distributed under License No. 35-00502-04G to persons generally
.
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licensed pursuant to 10 CFR 31.5, mostly to HS field camps.
Each
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gauge contained a Cs-137 sealed source with activity of 10 mC1,
20 mC1, 55 mC1, or 100 mci.
'
C.
License No. 35-00502-04G authorizes HS to distribute density gauges
to persons 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
No. 35-00502-04G. Most of these gaugey have been located at various
Halliburton field camps in the United SFtates and abroad. Many have
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been attached to equipment on trucks and transported to and from
temporary job sites. Several of Ha111 burton's divisions and
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subsidiaries have been located in Agreement States and abroad.
The inspectors reviewed material transfer reports that were sent to the
NRC as required under 10 CFR 32.52. Also, labeling and markings of gauges
at the Enid, Oklahoma City, and Duncan field camps 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 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of initial training to all personnel
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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.
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The inspecters reviewed records of receipt for Cs-137 sealed sources
shipped by the supplier.
The licensee stated that incoming transport
containers were surveyed to verify that material had not shifted in
transport.
Records of material transfer within Halliburton subsidiaries
were sampled and found to be adequate.
Film badge records were reviewed and were found to be complete.
Typical
,
whole body exposures have been 1ew. The maximum annual personnel exposure
,
for 1988 was 250 mrem.
The licensee's procedures.for radioactive waste disposal were reviewed.
Since the last inspection they have not disposed of any material.
The inspectors, reviewed the licensee's transportation activities to
determine compliance with 10 CFR Part 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
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a locked storage box in back of a truck. They also reportedly carried the
necessary documents to the job sites in the truck,
Records of shipments
of gauges between Halliburton subsidiaries and temporary field sites also
appeared to comply with applicable regulati
s.
,
The irspectors also reviewed required postings. The Vann Systems field
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 observed, 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
several subsidiaries that are autonomous, yet whose licensed activities
overlap. Overall, the program's organization appeared acceptable.
One violation was identified.
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4.
Licensee Internal Audits
On September 23, 1987, the NRC issued an Order Modifying License, along
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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.
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Since 1957, the k nager of Government Regulations has supervised a
contract with an individual to perform routine audits of Ha111 burton's
field offices. The contractor has submitted all audit findings to the
Manager of Government Regulations. The RSO has also performed some of
these audits and suomitted all findings to the Manager of Government
Regulations.
The licensee stated that as of November 1988, all HS field camps in the
country have been audited. The licensee performed radiation surveys of
all field camps regardless of whether records indicated the camp possessed
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any licensed material. Th r was to ensure that none of the camps had
tracers, to document closeout 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 facilities in order to
determine the effectiveness of the corporate audit program.
It appeared
that the research departments and the gauge manufacturing operations in
,
Duncan were audited as required. The inspectors also visited three HS
field camps and one Vann Systems facility. The three HS field camps
appeared to have been audited, but two had discrepancies that should have
been discovered by the audits.
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At the Oklahoma City facility, the inspector determined sealed source
Serial No. 5277, a 9.5 mC1 Cs-137 source, was received in th: facility in
February 1984 but was not on the facility's inventory. Additionally,
sealed source Serial No. S750 was on 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 items were discovered during the
inspection despite audits conducted by the contractor on December 30,
.
1987, and December 15, 1988.
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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 c1mp for several years. However, it
was not on their inventory. Despite an audit conducted by the contractor
on September 22, 1988, thelicenseepresumedthissourcewasmissing.
The fact that the audit program had not identified the discrepancies
1
indicated inadeq w te audits of the field camps. This was identified as a
.
violation of License Condition 19 of License No. 35-00502-03 which
references the Radioactive Safety and Material Audit Program, originally
- ubmitted to the NRC in a letter dated October 22, 1987, revised
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
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etterials every 3 months was identified as a violation of License
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Condition 13 of.NRC License No. 35-00502-02.
This license condition
I
references a letter dated December 21, 1988, which describes the audit
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program.
t
In general, it appeared that facilities had been audited within the
-required time periods; however, some of the audits were not effectively
,
performed.
,
Two violations were identified.
5.
Notifications and Reports
When an inspector asked if the licensee had a loss or theft of licensed
material, the licensee's management stated that they had no lost sources,
but they did have some sources that were unaccounted for.
,
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.
HalliburtonCompany'sdivisionsandsubsidiahiesoperatefieldcampsin
,
nonagreement states, agreement states, and abroad. Though the field camps
have low turnover of these devices, they do transfer them among their
numerous locations both domestically and abroad. Therefore, it appears
i
that each of the divisions and subsidiaries, while in NRC jurisdiction,
have been individually authorized under 10 CFR 31.5 to possess, store, and
use these gauges. However, the Governmert Regulations Department at HS
)
has been designated by Halliburton Company to act on behalf of the various
divisions and subsidiaries in regulatory matters. Also, the manager of
Government Regulations has been the chairperson of the corporate radiation
safety committee.
In the latter part of 1986, the Government Regulation Department in HS,
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 cf
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
other records.
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 domestic Halliburton field locations had been audited and the list of
unaccounted for gauges was substantially shorter than originally
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estimated.
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Sinca Nnvember 1988, the only new action taken by the licensee to look for
these lost sources has been to contact overseas operations and have them
report their inventory. Though the licensee had demonstrated progress in
attempting to locate these gauges through November 1988, very little
progress has been made since then.
The following Cs-137 source serial nos. were last known to be in Oklahoma,
i
a state where NRC maintains jurisdiction:
5-622 (10 mC1), X-030 (10 mci),
CS2-751 (10 mC1), Y-211 (10 mci), Y-61 (10 mC1), A-424 (50 mC1), and X-375
(10 mci). Since November 1988, the licensee has neither located the
'
sources nor reported them to NRC as missing.
Failure to notify NRC of a
theft or loss of material was identified as a violation of
10 CFR 20.402(a) for the General License authorized under 10 CFR 31.5.
l
One violation was identified,
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6.
Exit Interview
A preliminary exit briefing was conducted on October 12, 1989, with the
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individuals identified in Section 1.
]
A telephonic exit briefing was conducted on getober 16, 1989, with the
individuals identified in Sectinn 1; the Chi'hf, Nuclear Materials
Inspection Section; and the inspector. The specific findings were not
discussed; however, NRC's concerns about a clear delineation of
responsibility associated with the management of the radiation safety
program were discussed.
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APPENDIX E
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UNACCOUNTED FOR RADI0 ACTIVE DENS 0 METERS
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Source
Densometer
Source Act.
Last Leak
last Known
Date Densometer
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Serial #
Serial #
(MC1)
Test Date
Location
Acknowledged Missing
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Z-103
W35-0018
55.8
03/24/86
Unknown
8/86
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S-662
730508
10.0
01/11/79
Unknown
?
.
X-030
31V111(or)
10.0
03/25/80
Unknown
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31V136
X-007
73716
10.0
11/19/79
Pa11stine, TX.
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C52-724
W41-0043
55.0
05/04/83
Vernal, UT.
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CS2-751
73-1101
10.0
01/13/84
Unknown
?
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X-211
31V442
10.0
12/23/86
Duncan, OK.
09/28/89
'
.
Y-61
6]N61995C
20.0
01/21/85
Davis, OK.
?
A-424
Unknown
50.0
02/21/73
Duncan, OK.
?
,
X-375
Unknown
10.0
01/05/82
Duncan, OK,
?
918
MD-002
10.0
02/10/72
Turkish Pet.
?
S-188
MS-341
10.0
04/15/75
Mission Marine
?
South Africa or
United Dubai, Arab
a
Emirates
855
MS-13
10.0
07/15/71
Key West South Am.
?
A-454
MS-246
10.0
03/26/73
Sold to Sedeo N. Sea ?
'
A-597
PFD-244
10.0
12/10/73
Scarborough IN Drill ?
Ship, Italian Oil Co.
829
73-1515
10.0
08/22/84
Egypt
?
A-499
MS-106
10.4
08/22/73
Global Marine Unit
?
- 712, Orange, TX.
S-664
73635
10.0
01/11/79
Dubai, United Arab
?
Emirates
S-553
73538
10.0
08/30/78
Qatar
?
821
MS-6
10.0
10/28/69
Atwood Oceanonic,
?
(BigJohn), Sabine
Pass, TX.
l-
,
e
-
.
. . -
.