ML20134J074
| ML20134J074 | |
| Person / Time | |
|---|---|
| Site: | 15000017 |
| Issue date: | 05/13/2020 |
| From: | Mary Muessle Division of Nuclear Materials Safety IV |
| To: | Jacobs T Oceaneering International |
| References | |
| EA-20-024, NMED Item 200094, NRC Event 54557 IR 2020001 | |
| Download: ML20134J074 (13) | |
See also: IR 015000017/2020001
Text
May 13, 2020
NMED Item 200094
Mr. Tommy Jacobs
Corporate Radiation Safety Officer
Oceaneering International, Inc.
10600 West Sam Houston Parkway North
Houston, Texas 77064
SUBJECT:
NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION,
NRC INSPECTION REPORT 150-00017/2020-001
Dear Mr. Jacobs:
This letter refers to the event reported to the U.S. Nuclear Regulatory Commission (NRC) on
March 2, 2020 (Nuclear Material Events Database (NMED), Item 200094, NRC Event
Notification 54557), involving the loss of a sealed source containing NRC-licensed byproduct
material at a temporary job site in the Gulf of Mexico. You followed up the initial telephone
notification with a written report, dated March 23, 2020, which presented the facts and
circumstances surrounding the event. The enclosed report presents the results of the NRCs
review of the event, the associated timeline, as well as the NRCs understanding of the actions
taken by Oceaneering International, Inc. A final exit briefing was conducted (telephonically) with
you on May 4, 2020, to discuss the results of our review.
Based on the results of this review, the NRC has determined two violations of NRC
requirements occurred. The violations were evaluated in accordance with the NRC
Enforcement Policy, which can be found at the NRCs Web site at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The violations are cited and described in the
enclosed Notice of Violation (Notice) because they were either self-revealing as a result of the
event or identified by the NRC inspector during the in-office review. The violations involved the
failures to: (A) maintain constant control and surveillance of licensed material while not in
storage, as required by Title 10 of the Code of Federal Regulations (10 CFR) 20.1802; and
(B) read and record the exposures from direct reading dosimeters at the beginning and end of
each shift.
In accordance with the NRC Enforcement Policy, Violation (A) would normally be categorized at
Severity Level III and considered for escalated enforcement action. However, after considering
the facts and circumstances of the loss of licensed byproduct material, and in consultation with
the Director of the NRCs Office of Enforcement, I have been authorized to exercise
enforcement discretion in accordance with Section 3.0 of the Enforcement Policy, Use of
Enforcement Discretion, and assess Violation (A) at Severity Level IV.
T. Jacobs
2
The NRC is exercising discretion because of the circumstances that resulted in the byproduct
material falling into the Gulf of Mexico represent an isolated, rather than programmatic
weakness. Further, the NRC determined that the byproduct material, because of its physical
characteristics and inaccessible location, is of limited safety and environmental significance and
does not pose a material health, safety, or security risk to members of the public.
The NRC considers Violation (B) above to be a low safety significance violation and thus has
categorized it in accordance with the NRC Enforcement Policy at Severity Level IV. This
violation is being cited as Severity Level IV because it was identified by the NRC inspector
during the review.
The NRC has concluded that information regarding: (1) the reason for the violations; (2) the
corrective actions that have been taken and the results achieved; and (3) the date when full
compliance will be achieved is already adequately addressed on the docket in your 30-day
report dated March 23, 2020, and in the enclosed inspection report. Therefore, you are not
required to respond to this letter unless the description therein does not accurately reflect your
corrective actions or your position. In that case, or if you choose to provide additional
information, you should follow the instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure," a
copy of this letter, its enclosures, and your response, if you choose to provide one, will be made
available electronically for public inspection in the NRC Public Document Room or from the
NRC's Agencywide Documents Access and Management System, accessible from the NRC
Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this matter, please contact Ms. Patricia Silva of my staff at
817-200-1455.
Sincerely,
Mary Muessle, Director
Division of Nuclear Materials Safety
Docket: 150-00017
License: General License under 10 CFR 150.20
Enclosures:
1. Notice of Violation (Notice)
2. NRC Inspection Report 150-00017/2020-001
cc:
Jeff Dauzat, Administrator
Louisiana Dept. of Environmental Quality
Charlotte Sullivan, Manager
Texas Department of State Health Services
Mary C.
Muessle
Digitally signed by
Mary C. Muessle
Date: 2020.05.13
11:55:08 -05'00'
SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive
Keyword:
By: JEV
Yes No
Publicly Available
Sensitive
OFFICE
HP:MIB
C:MIB
ACES
D:DNMS
NAME
JEvonEhr
PASilva
JGroom
MMuessle
SIGNATURE
JEV
PAS
JRG
DATE
05/06/2020
05/07/2020
05/8/2020
Enclosure 1
Oceaneering International, Inc.
Docket No. 150-00017
Houston, Texas
License No. 10 CFR 150.20
During an NRC review of NRC Event Notification 54557, two violations of NRC requirements
were identified. In accordance with the NRC Enforcement Policy, the violations are listed below:
A) 10 CFR 20.1802 requires that the licensee shall control and maintain constant
surveillance of licensed material that is in a controlled or unrestricted area and that is not
in storage.
Contrary to the above, on March 2, 2020, the licensee failed to control and maintain
constant surveillance of licensed material that was in a controlled or unrestricted area
that was not in storage. Specifically, the licensee failed to control a radiography
exposure device that was being moved between radiographic exposures on an offshore
Gulf of Mexico production platform, which resulted in the radiography exposure device
falling into the Gulf of Mexico.
This is a Severity Level IV violation (NRC Enforcement Policy Section 3.0).
B) 10 CFR 34.47(d) requires, in part, that direct reading dosimeters such as pocket
dosimeters or electronic personal dosimeters, must be read and the exposures recorded
at the beginning and end of each shift.
Contrary to the above, on March 2, 2020, for direct reading dosimeters, the licensee
failed to read and record the exposure at the beginning and end of each shift.
Specifically, the licensee conducted radiographic operations at an offshore Gulf of
Mexico production platform and failed to record the end-of-shift direct reading dosimeter
for the two active radiographers.
This is a Severity Level IV violation (NRC Enforcement Policy Section 6.3.d).
The NRC has concluded that information regarding: (1) the reason for the violations; (2) the
corrective actions that have been taken and the results achieved; and (3) the date when full
compliance will be achieved is already adequately addressed on the docket in your letter dated
March 23, 2020, and the enclosed inspection report.
However, if the description therein does not accurately reflect your position or your corrective
actions, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201
within 30 days of the date of the letter transmitting this Notice of Violation (Notice). In that case,
or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation;
EA-20-024, and send it to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001 with a copy to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, and the Regional
Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 East Lamar Blvd.,
Arlington, Texas 76011-4511.
If you choose to respond, your response will be made available electronically for public
inspection in the NRC Public Document Room or in the NRCs ADAMS, accessible from the
website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response
2
should not include any personal privacy or proprietary information so that it can be made
available to the public without redaction.
In accordance with 10 CFR 19.11, you may be required to post this Notice within 2 working days
of receipt.
Dated this 13th of May 2020
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
150-00017
License:
General License under 10 CFR 150.20
Report:
2020-001
EA No:
Licensee:
Oceaneering International, Inc.
Locations Inspected:
N/A - In-office review
Inspection Dates:
N/A - In-office review through April 30, 2020
Exit Meeting Date:
May 4, 2020
Inspectors:
Jason vonEhr, Health Physicist
Materials Inspection Branch
Division of Nuclear Materials Safety, Region IV
Approved By:
Patricia A. Silva, Chief
Materials Inspection Branch
Division of Nuclear Materials Safety, Region IV
Attachment:
Supplemental Inspection Information
2
EXECUTIVE SUMMARY
Oceaneering International, Inc.
NRC Inspection Report 150-00017/2020-001
The U.S. Nuclear Regulatory Commission (NRC) conducted an in-office review concerning a
lost source event reported by Oceaneering International, Inc., to the NRC on March 2, 2020
(Nuclear Material Events Database Item 200094, NRC Event Notification 54557) in
accordance with Title 10 of the Code of Federal Regulations (10 CFR) 20.2201(a)(1)(i). The
report concerned the loss of a sealed source containing NRC-licensed byproduct material in
excess of 1,000 times the associated quantity listed in Appendix C of 10 CFR Part 20.
Program Overview
Oceaneering International, Inc. was a reciprocity licensee operating under a general license
granted under 10 CFR 150.20 using State of Louisiana License LA-7396-L01. The general
license authorizes the licensee to possess and use NRC-licensed byproduct material in
accordance with NRC regulations, the provisions of the State of Louisiana radioactive
materials license, as well as Oceaneering International, Inc.s Operating and Emergency
Procedures submitted to the NRC concerning the licensees lay-barge and offshore platform
radiography activities.
NRC In-Office Review Findings
The licensee had a three-person crew conducting radiographic operations offshore in the
Gulf of Mexico in block West Delta 73A, approximately 75 miles south of New Orleans,
Louisiana, on the afternoon of March 2, 2020. One of the licensees crew was moving the
radiographic exposure devices associated equipment between radiographic exposures on
the offshore production platform when the exposure device fell into the Gulf of Mexico.
The licensee crew members informed the licensees client, a third-party energy company,
and informed the licensees management team. The licensees management representative
then informed the NRC via the NRC Headquarters Operations Officers.
The NRC determined that two violations of NRC requirements occurred. The violations
involved the failures to: (A) maintain constant control and surveillance of licensed material
while not in storage, as required by 10 CFR 20.1802; and (B) read and record the exposures
from direct reading dosimeters at the beginning and end of each shift. Violation (A) was
determined to be a Severity Level IV violation by use of Enforcement Discretion, while
Violation (B) was determined to be a Severity Level IV violation in accordance with the
NRCs Enforcement Policy examples in Section 6.3.
3
REPORT DETAILS
1.
Program Overview
1.1.
Program Scope
Oceaneering International, Inc., was a reciprocity licensee operating under a general
license granted under Title 10 of the Code of Federal Regulations (10 CFR) 150.20. The
licensee was authorized for reciprocity with State of Louisiana radioactive materials
license LA-7396-L01, Amendment 166, expiration date December 31, 2020. The
general license authorized the licensee to possess and use NRC-licensed byproduct
material in accordance with NRC regulations, the provisions of the State of Louisiana
radioactive materials license, as well as Oceaneering International, Inc.s Operating and
Emergency Procedures (Section X, Revision 1) submitted to the NRC on May 24, 2018,
concerning the licensees lay-barge and offshore platform radiography activities.
The licensee was initially granted general approval for the conduct of reciprocity
activities in areas of NRC jurisdiction for calendar year 2020 on December 13, 2019.
For the specific licensed activities conducted on March 2, 2020, at the West Delta 73A
offshore production platform in the Gulf of Mexico, the licensee applied for and received
approval from the NRC on February 26, 2020.
1.2.
In-Office Review Scope
On March 3, 2020, through April 30, 2020, the NRC conducted an in-office review of the
event that occurred on March 2, 2020 (Nuclear Material Events Database Item 200094,
NRC Event Notification 54557). The scope of the review was to examine the activities
conducted under the NRC general license as they related to public health, safety, and
security and to confirm compliance with the NRCs rules and regulations and with the
conditions of the State of Louisiana license as they concerned radiographic operations
leading up to and including the activities on March 2, 2020.
Within the areas identified above, the review included a selected examination of
procedures and representative records, and interviews with personnel.
2.
Timeline of NRC Event Notification 54557
On the evening of March 2, 2020, an assistant radiographer for the licensee was
attempting to move radiographic exposure equipment down a set of stairs on the outer
edge of an offshore production platform in block West Delta 73A off the coast of
Louisiana. The assistant radiographer set the radiography camera down (Source
Production and Equipment Company Model 150, S/N 1507, containing a model G-60
iridium-192 source, S/N AI2604, with an activity of approximately 18 curies) at the top of
the stairway. The assistant radiographer went to move the drive cables (approximately
37 feet long), still connected to the radiography camera, down the stairway. The
radiography cameras iridium-192 source was locked in the shielded position during this
movement.
Prior to reaching the middle of the stairway on the way down, the assistant noticed the
camera beginning to shift on the stairway and begin falling. The assistant
4
unsuccessfully attempted to intercept the radiography camera as it fell down the
stairway. The radiography camera bounced off the stairway, snapped the drive cable,
and fell into the Gulf of Mexico approximately 60 feet below the stairway.
Figure 1 - Location of the Offshore Production Platform in West Delta 73A, relative to nearest land formations.
At the point of the West Delta 73A production, the Gulf of Mexico was approximately 160
feet deep. The production platform was approximately 18 miles from the Pilottown and
Pass A Loutre State Wildlife Management Area, and 73 miles from New Orleans. (see
Figure 1).
3.
Licensee Compliance with NRC Reporting Requirements
The licensee reported the approximate time of the loss of the radiography device into the
Gulf of Mexico at approximately 1850, Eastern Standard Time. The licensee called the
NRC Headquarters Operations Officers at 2231 Eastern Standard Time to report the
lost material.
The licensee was required to make a telephonic notification in accordance with the
NRCs regulation in 10 CFR 20.2201(a)(1)(i). This reporting regulation requires the
notification by telephone to the NRC immediately after its occurrence becomes known to
the licensee the loss of licensed material in an aggregate quantity equal to or greater
than 1,000 times the quantity specified in Appendix C of 10 CFR Part 20. The loss of
the material on March 2, 2020, was approximately 18 curies of iridium-192, which was in
excess of 1,000 times the corresponding value in Appendix C (1 microcurie).
While 10 CFR Part 20 does not specify or define what immediate means in terms of
reporting criteria, the licensee was also subject to certain immediately reportable
circumstances under 10 CFR 30.50, which specifies that immediate reporting shall be
made as soon as possible but no later than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the discovery of the applicable
5
event or circumstance. The licensees telephone notification was made within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of
the events occurrence, which was immediately known to the licensee, and therefore,
reasonably met the NRCs timeliness criteria for this requirement.
In addition, following a telephone notification made in accordance with
10 CFR 20.2201(a)(1)(i), the licensee was subsequently required to submit a written
report within 30 days of the making the telephone notification in accordance with
10 CFR 20.2201(b). This written report was received by the NRC on March 23, 2020
(NRC's Agencywide Documents Access and Management System (ADAMS)
Accession ML20094F751). The NRCs review of the report determined that it was both
timely and adequately addressed the required content described in
10 CFR 20.2201(b)(i)-(vi).
4.
NRC Findings
The NRCs in-office review through April 30, 2020, resulted in two violations of NRC
requirements. These violations involved the licensees failures to: (A) maintain constant
control and surveillance of licensed material while not in storage, as required by
10 CFR 20.1802; and (B) read and record the exposures from direct reading dosimeters
at the beginning and end of each shift.
The inspector reviewed the licensees records as they related to: the most recent
iridum-192 source leak test; depleted uranium leak test; training records for all licensee
crew members conducting radiography on the offshore rig; survey records leading up to
the loss of material; and the licensees written operating and emergency procedures as
they pertained to the conduct of offshore radiography. The inspector also reviewed
written statements from all three licensee employees (Note: two of these employees
were not in the immediate vicinity and did not witness the subject event). The inspector
conducted a telephonic interview with the third licensee employee, a radiographer
assistant, who was attempting to move the radiography equipment and witnessed the
radiography exposure device fall into the Gulf of Mexico. Aside from Violation (B) noted
above, no deficiencies in records, training, execution of written procedures, or other
NRC requirements were identified as a result of the NRCs review.
In accordance with the NRC Enforcement Policy, Violation (A) would normally be
categorized at Severity Level III and considered for escalated enforcement action. In
particular, the quantity of radioactive material that the licensee lost, approximately
18 curies of iridium192, was in excess of 1,000 times the corresponding value in 10 CFR
Part 20 Appendix C (1 microcurie), and therefore meets the Severity Level III
enforcement example in the NRC Enforcement Policy, Section 6.7.c.10(a).
However, after considering the facts and circumstances of the loss of the byproduct
material, the NRC exercised enforcement discretion in accordance with Section 3.0 of
the Enforcement Policy, Use of Enforcement Discretion, and assessed Violation (A) at
Severity Level IV. The NRC determined that exercising discretion was appropriate
because the circumstances that resulted in the byproduct material falling into the Gulf of
Mexico and the inaccessibility of the byproduct material by any reasonable actions of
members of the public. The NRC determined that the byproduct material does pose any
material health, safety, or security risk to members of the public.
6
The licensees failure to control and maintain constant surveillance of licensed material
that is in a controlled or unrestricted area and that is not in storage was identified as a
violation of 10 CFR 20.1802. (150-00017/2020-001-01)
With regards to Violation (B), the NRC in its review of the records associated with the
radiographic activities on the day of the event, March 2, 2020, determined that the
licensee personnel failed to record the end-of-shift direct reading dosimeters, as required
by 10 CFR 34.47(d). Although radiographic activities were conducted prior to the loss of
the radiography camera, the event appeared to have overshadowed the licensees
attention with regard to this particular requirement. The licensee was not able to provide
any alternative method or record to account for the exposures received on the day of the
event. However, the licensees personal dosimeters, worn in accordance with
10 CFR 34.47(a) and exchanged monthly, would account for the exposures received on
March 2, 2020, in addition to the rest of the monitoring period.
The licensees failure to read and record the exposures from direct reading dosimeters
at the beginning and end of each shift was identified as a violation of 10 CFR 34.47(d).
(150-00017/2020-001-02)
5.
Corrective Actions
The licensee began exploring actions in a timely manner that were lessons learned from
going through the event. Examples of actions the licensee was exploring, including
those that may assist in preventing recurrence, included:
1. Updates to operating and emergency procedures to address proper manual
handling requirements.
2. Updates to operating and emergency procedures to address actions when a
source is dropped or lost to sea.
3. Research and development recovery plan for lost sources to sea.
4. Radiation safety officers to draft and share a letter explaining manual
handling process for moving cameras.
5. Technical evaluation of source life and tracking of the source and camera
internally, indefinitely.
6. Research and explore tethering devices to prevent dropped objects with
regards to the camera, crankout, and guide tube.
For Actions 1, 2, and 4, the licensee included specific feedback in the 30-day report,
dated March 23, 2020.
6.
Exit Meeting Summary
On May 4, 2020, the NRC conducted a final telephonic exit briefing with Oceaneering
International, Inc. The licensee was represented by Mr. Tommy Jacobs, Corporate
Radiation Safety Officer.
7
The licensee acknowledged the inspection findings and did not dispute any of the details
presented during the call.
Attachment
Supplemental Inspection Information
PARTIAL LIST OF PERSONS CONTACTED
Tommy Jacobs, Corporate Radiation Safety Officer
Aaron Lawrence, Morgan City, Louisiana, Site Radiation Safety Officer
Andre Domingue, Assistant Radiographer
INSPECTION PROCEDURES USED
87103 - Inspection of Materials Licensees Involved in an Incident or Bankruptcy Filing
87121 - Industrial Radiography Programs
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
150-00017/2020-001-01
Failure to control and maintain constant surveillance of
licensed material that is in a controlled or unrestricted area
and that is not in storage. (10 CFR 20.1802)
150-00017/2020-001-02 VIO
Failure to read and record the exposures from direct
reading dosimeters at the beginning and end of each shift.
Closed
None
Discussed
None
LIST OF ACRONYMS USED
Agencywide Documents Access and Management System
CFR
Code of Federal Regulations
Nuclear Material Events Database
NRC
U.S. Nuclear Regulatory Commission