ML20129J620
| ML20129J620 | |
| Person / Time | |
|---|---|
| Site: | 15000042 |
| Issue date: | 11/04/1996 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robinson W ROBCO PRODUCTION LOGGING, INC. |
| Shared Package | |
| ML20129J623 | List: |
| References | |
| EA-96-378, NUDOCS 9611070083 | |
| Download: ML20129J620 (5) | |
See also: IR 015000042/1996008
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November 4,1996
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EA 96-378
William H. Robinson, President
Robco Production Logging, Inc.
P.O. Box 1423
1001 East Highway
Snyder, Texas 79550
SUBJECT: NRC INSPECTION REPORT NO. 150-00042/96-08, AND INVESTIGATION
REPORT NO. 4-96-024
Dear Mr. Robinsor:
On October 11,1996, the NRC completed an inspection of activities performed by Robco
Production Logging, Inc. (Robco) at two temporary jobsites near Guymon, Oklahoma. The
inspection included observation of welllogging activities at the temporary jobsites on
June 6,1996, subsequent interviews with you and your staff, and review of pertinent
records at your office in Snyder, Texas. In addition to the inspector's review of Robco's
activities in Oklahoma, the NRC Office of Investigation's Field Office, Region IV, conducted
a concurrent investigation. The investigation concluded on September 24,1996. The
findings of the inspection and investigation were discussed with you during a telephonic
exit briefing on October 11.
As discussed with you during the exit briefing, seven apparent violations were identified
during the inspection. The apparent violations included failures to follow procedures
incorporated by reference in your Agreement State license and failures to follow certain
NRC regulations applicable to activities conducted by Robco in Oklahoma. Specifically, the
apparent violations included, in part, failures to: (1) file an NRC Form 241 as required by
10 CFR 150.20 prior to performing licensed activities in a non-Agreement State; (2) adhere
to Robco procedures which require that any tracer material remaining in the logging tool is
injected into the well bore after logging operations are completed; (3) require that a logging
supervisor use vinyl gloves when handling an ejector tool containing iodine-131;
(4) perform a survey of well sites before and after each subsurf ace tracer study using
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iodine-131 and maintain records of well site and vehicle surveys performed before or after
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tracer material was used or transported; and (5) record each use of tracer material during
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1995 and 1996 and to maintain records that were made by Robco staff in 1995. Two
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additional apparent violations were also identified involving transportation activities
conducted by Robco personnel. The apparent violations identified above are described in
detail in the enclosed inspection report.
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CERTIFIED Mall - RETURN RECEIPT REQUESTED
9611070083 961104
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Robco Production Logging, Inc.
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The NRC considers the apparent violations to be significant, in part, because failures to
adhere to Robco procedures appeared to have contributed to contamination of a logging
supervisor's hands during a tracer study performed on June 6,1996. In addition, some of
the apparent violations were identified during a previous inspection performed by the NRC
in 1992. The NRC is also concerned that Robco failed to provide notification, by filing an
NRC Form 241, of proposed activities to be performed in Oklahoma despite the f act that
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Robco had filed such forms for work performed in a non-Agreement State on previous
occasions.
Based on the results of the investigation, the NRC has concluded that two of the apparent
violations may have been deliberate. Specifically, the investigation concluded that you, as
the president and radiation safety officer, may have deliberately failed to file a Form 241
prior to performing activities in Oklahoma in June 1996 and that you may have deliberately
instructed personnel to not follow Robco procedures requiring that the content of the
ejector tool be emptied into the well bore after logging operations are completed. These
findings have been identified as an apparent violation 10 CFR 30.10(a)(1), " Deliberate
Misconduct," which specifies, in part, that any licensee or any employee of a licensee may
not engage in deliberate misconduct that causes a licensee to be in violation of any rule or
regulation, or any term, condition or limitation of any license issued by the Commission.
The filing of an NRC Form 241, providing notification of work proposed in a non-
Agreement State, and compliance with the provisions of an Agreement State license while
working in a non-Agreement State are required under 10 CFR 150.20.
The apparent violations discussed above are being considered for escalated enforcement
action in accordance with the " General Statement of Policy and Procedure for NRC
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Enforcement Actions" (Enforcement Policy), NUREG-1600. Accordingly, no Notice of
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Violation is presently being issued for these inspection findings. In addition, please be
advised that the number and characterization of apparent violations described in the
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enclosed inspection report may change as a result of further NRC review.
A transcribed, predecisional enforcement conference to discuss these apparent violations
has been scheduled for 8:30 a.m., CT, on November 15,1990. The decision to hold a
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predecisional enforcement conference does not mean that the NRC has determined that a
violation has occurred or that enforcement action will be taken. This conference is being
held to obtain information to enable the NRC to make an enforcement decision, such as a
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common understanding of the f acts, root causes, missed opportunities to identify the
apparent violation sooner, corrective actions, significance of the issues and the need for
lasting and effective corrective action. In addition, this is an opportunity for you to point
out any errors in our inspection report and for you to provide any information concerning
your perspectives on 1) the severity of the violations,2) the application of the factors that
the NRC considers when it determines the amount of a civil penalty that may be assessed
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in accordance with Section VI.B.2 of the Enforcement Policy,3) any other application of
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the Enforcement Policy to this case, including the exercise of discretion in accordance with
Section Vil, and 4) the application of the f actors identified in Section Vill of the
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Enforcement Policv. You should also be prepared to discuss those actions planned or
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Robco Production Logging, Inc.
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taken to improve the effectiveness of management control of your licensed operations,
with particular emphasis on measures currently being taken to prevent further violations.
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You will be advised by separate correspondence of the results of our deliberations on this
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matter. No response regarding these apparent violations is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure (s), and your response will be placed in the NRC Public Document
Room (PDR). To the extent possible, your response should not include any personal
privacy, proprietary, or safeguards information so that it can be placed in the PDR without
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redaction.
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Should you have any questions concerning this inspection, please contact
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Mr. William Radcliffe at (817) 860-8151 or Ms. Linda Howell at (817) 860-8213.
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Sincerely,
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Ross A. Scarano, Director
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Division of Nuclear Materials Safety
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Docket No.. 150-00042
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License No.: LO4925 (Texas)
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Enclosures:
1. NRC Inspection Report 150-00042/96-08
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2. NRC Enforcement Policy, NUREG-1600
3. Proposed _ Enforcement Conference Agenda
cc w/ Enclosures 1 and 3:
Texas Radiation Program Control Director
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Oklahoma Radiation Program Control Director
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