ML20058E550
| ML20058E550 | |
| Person / Time | |
|---|---|
| Site: | 07000310 |
| Issue date: | 07/09/1982 |
| From: | Racster C SCHLUMBERGER TECHNOLOGY CORP. (SUBS. OF SCHLUMBERGER |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20058E554 | List: |
| References | |
| 20942, NUDOCS 8207300072 | |
| Download: ML20058E550 (3) | |
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Nuclear Regulatory Commission S
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,M I',:, E P h s b Radioisotopes Licensing Branch Division of Fuel Cycle and Material Safety "7' f ? "
b y Washington, D.C.
20555 I
Gentlemen:
Reference your letter of April 23, 1982 (and follow up letter dated May 27, 1982) regarding renewal of license SNM-287.
I will answer your questions using the same item references used in your April 23 letter.
1.
This is addressed in a separate letter (copy attached).
2.63.Please change " activity not to exceed 6 ci/each" to read
" activity per device not to exceed 6 ci" and" activity not to exceed 20 ci/each"to read " activity per device not to exceed 20 ci".
We request a total possession limit of 200 gram of Pu238.
N We will submit Model 11-207947 and 11-142525 for scaled o
D source review.
(We erronously referred to 11-142108 in application.
The correct reference is 11-142525.)
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4.
No single source will exceed 20 curies.
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5.
Our training program for Schlumberger Field Engineers G
pb attached.
Attached also is a copy of the written exam administered (closed book).
80 is a passing score.
I Schlumberger Field Engineers that have passed the test 43 are authorized as users by the Radiation Safety Officer (C.
E. Racster).
The score on the test is maintained on S
computer, available at the office of the Radiation Saf.g Officer, llou s t on, TX.
N, With i R ca%CO k.
6.
We have about 100 facilities in the USA where sour.
a stored and from which field crews operate.
s-fic1ds,
Wiesg (ige [
3 14G ing and decreasing activity in the various facilities are opened, closed and moved rather of t 4 4'
- p. O.
Box % 75,te'*
permanent facility is 5000 Gulf Freeway,
( M '/y/
- he llouston,TX 77252-2175.
An up-to-date listing of fi facilities is available from the Radiation Safety Of Ilouston,TX.
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USNRC License Renewal-SNM-287 July 9, 1982 Page 2 i
l 7.
As you have noted, the survey procedures for tracer work are documented in our operating procedures.
I We do not require surveys at the well site when using scaled sources.
All our logging sources meet or exceed the ANSI standards for well logging sources.
Only one incident, to our knowledge, involving well site contamination with a well logging source has occurred.
(Except for fishing accidents.)
This incident did not involve Schlumberger and did involve a source that would not meet the present ANSI specifications.
We do require monitoring at the well site during fishing operations.
We consider routine well site monitoring to be unnecessary.
All sources are kept in the transportation packages (shicids) except when in the logging tool or being transferred to and from the logging tool.
The two minute (maximum) period at the start and finish of a logging run are the only times at the well site that the sources are unshicided.
(Once they are in the hole, the carth acts as an enormous shicid.)
During this two minute period, the operation is under the direct personal control of the Schlumberger Field Engineer.
See page XII-1 of the Radiation Sources and Controls manual.
Unauthorized personnel are escorted out of the area by our personnel.
8a.
The attached ! proposed) policy regarding temporary storage on trucks will be implemented 120 days after approval by NRC (SNM License and Radioactive Materials License) and all l
Agreement Statas in which we are licensed.
As you realize, it will be a time consuming process to get approval from all the licensing agencies.
It would be most helpful if you will expedite approval by the Agreement States through your Agreement State Program and the Conference of Radiation Control Program Directors.
The proposed policy will be in-cluded in the transportation section of the Radiation Sources and Controls manual when NRC and Agreement State approvals are received.
The 7 foot distance was selected to cover all areas external to the truck which exceed 2.0 mr/hr for all truck types and expected source load.
Since the general public in attendance at a particular well site, restaurant or motel is purely ran-dom and the time intervals would be measured in minutes or hours, I can see no way that any individual member of the general public would receive more than a few mr in a year.
/
USNRC 1,icense Renewal-SNM-287 July 9, 1982 Page 3 8b.
We use the " Caution-Radiation Area" signs at our storage area in the field facility.
When the sources are in the pits and the lid in place, the level will not exceed 2mr/hr.
Ilowever, when the lid is off and sources are being put in or out of the pit, the level may exceed 5 mr/hr.
Thus, we feel that the " Caution-Radiation Area" signs best cover the situation.
We have, in fact, been cited by state inspectors for having the radioactive material sign rather than the
" Caution-Radiation Area" sign.
We will continue to use
" Caution-Radiation Area".
9a.
A sample of the wipe test kit is attached.
An example of our wiping procedure is also attached.
Each field facility have wiping procedures for each type of source stored there.
b.
Assay is performed by Nuclear Sources 4 Services, Inc.,
P. O.
Box 24042, llouston,TX 77034.
10.
20.205 exempts packages not exceeding "A" quantity if in Special Form from " Procedures for Picking Up, Receiving, and Opening Packages".
All special nuclear material used under this license will be Special Form and will not exceed "A" quantity.
11.
Our Radiation Sources G Controls manual will be amended to include the prohibition against handling logging sources with the bare hand.
You should receive your amended pages by September 1, 1982.
12.
We are committed to maintaining personnel exposure as low as reasonably achievabic.
We do maintain NRC-4 records on all badged employees.
We require investigation and reporting to the Radiation Safety Officer of all badge readings exceeding 600 mr/ calendar quarter.
This is 205, of the 3000 mr quarterly limit.
(For persons with acceptable bank account shown by NRC-4 and NRC-5.)
The investigations lead to changes in operating procedures, badge wearing and storage procedures.
It works well for us.
Your comment on our page VIII-2 will cause an amendment to our Radiation Sources 4 Controls manual.
You should received your amended pages by September 1, 1982.
It is hoped that the additional information in this letter and its attachments will help you to renew our SNM license expeditiously.
Sincerely, n.
Racster Radiation Safety Officer f
CER/md Attachments L