ML20125C626
| ML20125C626 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20125C615 | List: |
| References | |
| 15000042-92-02, 15000042-92-2, NUDOCS 9212140015 | |
| Download: ML20125C626 (3) | |
Text
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APPENDIX NOTICE OF VIOLATION Robco Prodection Logging, Inc.
Docket No. 15000042 Snyder, Texas 79549 License No. Gen Lic 150.20 During an NRC inspection conducted on November 12, 1992, 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, the violations are listed below:
A.
10 ofR 150.20(b)(1) requires that when engaging in activities in non-Agreement States under the general license granted by 10 CFR 150.20(a), you must file four copies of Form-241 (revised) " Report y
of Proposed Activities in non-Agreement States" and four copies of your Agreement State specific license with the Regional Administrator of the appropriate Nuclear Regulatory Commission Regional Office at least 3 days before engaging in such activity.
Contrary to the above, tracer work was performed throughout Oklahoma on July 22-23 and September 3-4, 1992, and on other occasions under the provisions of 10 CFP 150.20(a) without revising Form-241 dated December 26, 1991, to any NRC office.
This is a Severity Level IV violation (Supplement VI).
B.
10 CFR 150.20 provides that persons who hold a specific license from an Agreement State are granted an NRC general license to conduct the name activity in a non-Agreement State provided the general license complies with 10 CFR 39.15, and 39.31 through 39.77.
1.
10 CFR 39.39 requires, in part, that each licensee maintain record:
of each use of licensed material.
Contrary to the above, as of November 12, 1992, no such records were available.
This is a Severity Level V violation (Supplement VI).
2.
10 CFR 39.67(e) requircs that the licensee make a radiation survey at the temporary jobsite before and after each subsurface tracer study to confirm the absence of contamination.
10 CFR 39.67(f) requires that the licensee retain records of surveys for inspection by the Commission for 3 years after they are made.
Contrary to the above, as of November 12, 1992, no such records were available.
This is a Severity Level V violation (Supplement VI).
9212140015 921207 PDR STPRG EMVf
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, Pursuant to the provisions of 10 CFR 2.201, Robco Production Logging, Inc. is hereby required to rubmit a written statement or explanation to the Regional Administrator, Regio) IV, with a copy to the U.S. Nuclear Regulatory Commission, ATTN:
rocunent Control Desk, Washington, D.C. 20555, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this 7th day of December, 1992
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