ML20205G550
| ML20205G550 | |
| Person / Time | |
|---|---|
| Issue date: | 10/24/1988 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | HOLE-TRUTH, INC. |
| Shared Package | |
| ML20205G545 | List: |
| References | |
| EA-88-212, NUDOCS 8810280289 | |
| Download: ML20205G550 (8) | |
Text
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4
,s UNITED STATES NUCLEAR REGULATORY COMMISSION t
in the Matter of
)
Docket No.
30-20880 t
HOLE TRUTH INC.
)
License No. 35-23304-01 Oklahoma City, Oklahoma
)
EA 88-212 I
ORDER N0DIFYING LICENSE, EFFECTIVE IMMEDlATELY i
I Hole Truth, Inc. (licensee), is the holder of Material License No. 3;-23304-01 issued by the Nuclear Regulatory Comission (NRC or Commission) on May 30, 1984.
I The license is due to expire on May 31, 1989.
The license authorizes the licensee to possess sealed sources of americium-241 and cesium-137; to possess 1
and use any form of iodine-131, iridium-192, gold-198 and silver-110; to possess and use any form except liquids of scandium-46; and to possess and use beads or wires of cobalt-60, in tracer studies in oil and gas wells.
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l On July 14-15, 1988, NRC Region IV conducted an unannounced inspection of the l
l licensee's activities at the licensee's facility in Oklahom: City, Oklahoma.
l The inspection disclosed numerous apparent violations of NRC and Itcense 1
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requirements.
The results of the inspection were discussed with the licensee I
at an Enforcement Conference on August 30, 1968. As a result of information l
provided by the licensee at the Enforcement Conference, two violations were f
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modified, one violation was withdrawn and one additional violation was identi-fied. The resulting violations are discribed in rore detail in the Notice of Violation being issued this date.
These violations involve the:
1.
Failure to possess material such that the radiation levels in an l
unrestricted area were not in excess of 100 mi'itrem in any 7 consecuttve j
days as required by 10 CFR 20.105 (b)(2).
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8810280289 881024 REG 4 LIC30 35-23304-01 PDC
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---y-2 2.
Failure to keep records of receipt of byproduct material from June 16 to October 4, 1987 in accordance with 10 CFR 30.51(a).
3.
Failure to maintain records for each use of licensed material in accordance with 10 CFR 39.39.
4.
Failure of an individual to wear personnel dosimetry while working with licensed material in accordance with 10 CFR 39.65.
5.
Failure to block and brace radioactive material packages during transport in accordance with 49 CFR 177.842(d) and 10 CFR 71.5(a).
6.
Failure to use Specification 7A, Type A packaging for transport of radioactive material not in excess of A-2 timits in accordance with 49 CFR 173.415(a) and 10 CFR 71.5(a).
7.
Failure to exchange personnel dosimetry monthly for processing by the supplier f rom January to June 1988 as required by License Condition 19 and the license application.
8.
Failure to maintain records of monthly surveys of the storage bunker in accordance with License Condition 19 and operating procedures.
9.
Failure to perform adequate surveys of vehicles used for storir.g and l
transporting licensed material and keep records of such surveys in accor-dance with License Condition 19 and operating precedures.
Specifically,
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the licensee's surveys failed to identify the presence of a vial containing i
approximately 10 millicuries of iridium-192 which had been present in the
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i locked rear compartment of a pickup truck since July 9,1988 and emitted i
f measured radiation levels at the rear surface of the truck of 1.5 millirem j
I per hour, i
10.
Failure to perform adequate surveys of job site operations and keep iecords I
of such surveys in accordance with License Condition 19 and operating l
j procedures.
Specifically, the licensee's serveys failed to identify l
I unlabeled pipe couplings contaminated with radioactive material which J
had measured radiation levels of 0.6 mr/hr at 6 inches from the surface
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of the pipe coupling.
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f Failure to maintain records of sm veys of licensed raterials upon receipt i
11.
i in accordance with License Condition 19 and crerating procedures.
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1; railure to maintain up-to-date records of radiation exposures as measured l
4 by TLD personnel dosimeters for 1987 in accordance with License Condition j
19 and operating procedures.
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I 13.
Failure to return unused radioactive material to the storage bunker in L
l accordance with License Condition 19 and operating procedures.
14 Failure to maintain disposal records of radioactive materials from f
i June 16, 1987 to July 15, 1988 in accordance with License Cerdition 19 l
and operatino procedures.
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e
. 15.
Failure to label as a radioactive source itees which contained fi/ed contamination frch radioactive material in excess of 0.2 mR/hr, as required by License Condition 19 and operating procedures.
III The president and owner of Hole Truth Inc. (licensee) and his consultant attended the Enforcement Conference held on August 30, 1988.
During the Enforcement Conference, the licensee stated that (1) surveys had been perforced, but no records were available; (2) corrective actions had been taken on all items discussed; and (3) that he only lacked duplicate copies of personnel monitoring records to be in full ccepliance with HRC requirements.
Furtherrore, the licensee committed to having its consultant inspect its operations on a quarterly basis for at least one year and for the owner's vife who had just finished a radiation safety course given by the consultant to aid in the management of the radiation safety records for the company.
The licensee's censultant indicated that the apparent violations were due largely to the pressures brought about by the impact of the economic downturn in the oil industry which led to the bank-ruptcy of two well logging companies with which the licensee had been associated.
The licensee did not dispute the staterents of its censultant.
IV On September 23, 1988, the NRC reinspected the licensee's program and found that all but c.1e of the apparent violations resultirg from the July 14-15, 1988,
a 0
5-inspection had been corrected. Nonetheless, the fact that these violations occurred remains a significant concern to the NRC because collectively they are indicative of a breakdown of management oversight and control.
in addition, the apparent abrupt decline in the quality of the program, when compared to the licensee's previous performance, is also of significant concern.
- Further, although the licensee maintains that it performed the surveys referenced above, it is clear from the NRC's review that some of the surveys were inadequate, in that the licensee failed to identiiy during a vehicle survey the presence of a vial containing approximately 10 millicuries of iridium-192 which had been present in the locked rear compartment of a pick-up truck since July 9,1988 and emitted measured radiation levels at the rear surface of the truck of 1.5 millirem per hour.
In another case, surveys did not identify unlabeled pipe couplings having radiation levels in excess of 0.2 mP/hr.
The nature and number of the violations identified during the July 14-15, 1988 inspection, including failure to identify radiation levels in an unrestricted area and on unlabeled pipe couplings, raises a question concerning the licensee's commitment ano ability to ccn' ply with the Corniss.icn's requirements in the future. Conse-qv ntly, without the further action ordered here, I lack the reasonable assurance that licensed activities will be prcperly conducted such that the health and safety of the public will be adequately protected.
Therefore, I have determined, pursuant to 10 CFR 2.204, that the public health, safety, and interest require that the license should be modified, as described below, effective immediately, and that no prior notice is required.
O
.s 6-V Accordingly, pursuant to Sections 81, 161b, i, and o, and 182 of the Atomic Energy Act of 1954, as amended, and the Commissions regulations in 10 CFR 2.204 and Parts 30 and 39, IT IS HERE8f ORDERED THAT, EFFECTIVE IMMEDIATELY:
License No. 35-23304-01 is modified to require that:
A.
An independent party, qualified in the area of radiation safety, perform quarterly audits of the Radiation Safety Program.
The audits shall continue for a periott of 2 years. The credentials of the independent party and the proposed audit program shall be submitted to NRC Region IV for review and approval within 30 days of the date of this Ordar.
Audits shall be conducted for the purpose of evaluating the effectiveness of the radiation safety program in assuring adherence to NRC requirements and safe performance of licensed activities.
These audits shall include, at a minimum:
1.
Assessment of the effectiveness of management control and oversight of the program in assuring that radioactive material is used safely and that operations are f.onducted in compliance with NRC requirements.
2.
Observation and evaluation of the performance of the licensee while engaged in licensed activities at a well logging field site at least
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twice during the two year audit period provided that the field site audits are separated by at least 12 months.
3.
Assessment of the quality and accuracy of records required to be maintained concerning licensed activities.
The first such independent audit shall be conducted within 1 month of the NRC's notification to the licensee of NRC's approval of the audit program.
The results of each audit shall be simultaneously provided to the licensee and the Regional Administrator, NRC Region IV, within 2 weeks of completion of the audit. The licensee shall provide to the Regional Administrator, NRC Region !Y, within 30 days of receipt of the results of each audit, a description of the corrective act:ans taken for each reconnendation by the independent party and justification for any recorrrendation not accepted.
The Regional Administrator, NRC Region IV, may in writing, relax or rescind any of these conditions for good cause shown.
VI The licensee or any person adversely affected by thic Order may request a hearing within 30 days of the date of this Order.
Any answer to this Order or request for hearing shall be submit,ted to the Of rector, Office of Enforcement.
U.S. Nuclear Regulatory Connission, Washington. 0.C. 2C555.
Copies also shall be sent to the Assistant General Counsel for Enforcement Office of the General
j
' Counsel, at the same address and to the Regional Administrator, flRC Region IV, 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas 76011.
If a person other than the licensee requests a hearing, that person shall set forth with particularity the manner in which the petitioner's interest is adversely affected by this Order and should address the criteria set forth in 10 CFR 2.714(d). Upon failure of the licensee to answer or request a ;. earing within tht specified time, this Order shall be final without further proceedings.
An I
answo r to this Order or a request for hearing shall not stay the imediate effectiveness of this Order.
i If a hearing is requested, the Comission will issue an Order designating the time and place of any hearing, if a hearing is held, the issue to be considered at such a hearing shall be whether, this Order should be sustained.
FOR THE NUCLEAR KEGULATORY C0tHISS10N i
x
>m -
I ages it. Tay1
, Deputy Executive Director for Regiona Operations Dated at Rockville, Maryland, thisgNay of October 1988.
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