ML20198N259
| ML20198N259 | |
| Person / Time | |
|---|---|
| Site: | 15000015 |
| Issue date: | 01/13/1998 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rosel G ROSEL CO. (FORMERLY ROSEL WELL PERFORATORS, INC.) |
| References | |
| EA-98-017, EA-98-17, NUDOCS 9801210009 | |
| Download: ML20198N259 (5) | |
Text
- f UNIT E D ST ATES
. /'
[ CW,It NUCLEAR REGULATORY COMMISSION
~
REGION IV -
- ' . / 611 RYAN PLA2A DRIVE. SUITE 400
/ AR LINGTON, T EXAS 76011-8064 ,
January-13, 1998 EA 98-017 George F. Rosel, President The Rosel Company 302 South Clay Liberal, Kansas 67901
SUBJECT:
APPARENT VIOLATION OF RECIPROCITY REQUIREMENTS
Dear Mr. Rosel:
s On January 8,1996, the NRC completed a review of documents submitted to the NRC by The
' Rosel Company (TRC). These documents detailed work performed in NRC jurisdiction during
- calendar years 1996 and 1997. The findings of the review were discussed with you during a telephone call on January 8,1998.
On December 3,1997, Mr. Roger Taylor, the Open Hole Manager for TRC, informed NRC Region IV that during a review of company records, he had discovered that TRC had failed to file an NRC Form 241 " Report of Proposed Activities in Non-agreement Statas" prior to performing licensed activities in the State of Oklahoma, a non-Agreement State, during 1997.
On December 12,1997, TRC submitted the NRC Form 241 and appropriate fem required to perform licensed activities in NRC jurisdiction for both the remainder of 1997 and 1998. At the NRCs request. TRC was asked to review any licensed activities which may have been performed in NRC jurisdiction during 1996. On January 6,1998, Mr. Taylor provided additional information which indicated that TRC had also failed to file an NRC Form 241 for licensed activities performed in the State of Oklahoma in 1996. During the January 8,1998, telephone conversation, you agreed to pay the fee for your 1996 activities. This fee ($1100.00) should be submitted to this office, Attn: Ms. Christi Hemander.
l As discussed with you during the January 8,1998, telephone call, an apparent violation was identified and is being considered for escalated enforcement action in accordance with the L " General Statement of Policy sad Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The apparent violation involved a failure to file an NRC Form 241 as required by 10 CFR 150.20 before conducting licensed activities in a non-Agreement State in 1996 and 1997. The NRC considers the apparent violation to be significant, in part, because TRC failed to provide notification, by filing an NRC Form 241, of proposed activities to be performed in Oklahoma despite the fact that TRC had filed such forms for work performed in c - non-Agreement States in 1993,1994 and 1995. This failure denied the NRC the opportunity to inspect to assure the safety of TRC's activities. ,
i:'
The sig.1ificance of the apparent violation, and the need for lasting and effective corrective action were discussed with you during the telephone call of January 8,1998. As a result, it may not be necessary to conduct a' predecisional enforcernent conference to enable the NRC to make an enforcernent decision. However, a Notice of Violation is not presently being issued for this I Q apparent violation. Before the NRC makes its enforcement decision, we are providing you an g
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, j The Rosel Company- '2-opportunity to'e_ither (1) recpond, within 30 days of the date of this letter, to the apparent violation identified in this letter or (2) request, within 7 days of the date of this letter, a J j
predecisional enforcement conference.
Your response should be clearly marked as a " Response to An Apparent Vioistion" and should -
include: -(1) the reason for the apparent violation, or, if cor. tested, the basis for disputing the E apparent 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. Your response should be submitted under oath or affirmation and may reference or include previous docketed correspondence, if the correspondence adequately ,
addresses the required response. The enciosed NRC Informatio 1 Notice 96-28, " SUGGESTED -
GUIDANCE REl.ATING TO DE'XLOPMENT AND IMPLEMENTATION OF CORRECTIVE -
' ACTION," may be of use in preparing this response. if an adaquate response is not received
= within the time speedied or an extension of time has not boon granted by the NRC, the NRC will
- proceed with its enforcement decision or schedule a predecisional enforcement conference. ,
J if you choose not to provide a written response and would prefer participating in a predek:isionai enforcement conference, please contact D. Blair Spitzberg, Ph.D., at (817) 860-8191 as soon as possible.
In addition, please be advised that the number and characterization of apparent violations ;
desenbod in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its 4
enclosures, and your response (if you choose to provide one) will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, propnetary, or safeguards information so that it can be placed in the PDR without y redaction.
Should you have any questions conceming this inspection, please contact Mr. Jeffrey Cruz at
- (817) 860-8164 or Dr. Spitzbe g at the number identified above.
4 Sincerely, y .
g .. /
n '
Ross A.~ Scarano, Director
/
Division of Nuclear Materials Safety
- docket No.: 150-00015 License No.: Kansas 27-C057-01
Enclosures:
i 1l NRC Enforcement Policy, NUREG-1600 m- . 2. NRC Information Notice 96-28
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