ML20207T458

Forwards Ltr Sent to Div Managers by Senior Vice President Jg Cook Re Changes Made in Field Operations Concerning Use of Radioactive Tracer Sand,Increasing Training Requirements, & Improving Recordkeeping Sys

ML20207T458
Person / Time
Site:	07000522
Issue date:	03/12/1987
From:	Dunlop J HALLIBURTON CO.
To:	Everett R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8703240039
Download: ML20207T458 (4)

Text

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ALLIBU RTON SERVICES DRAWER 1431, DUNCAN. OKLAHOMA 73536-0154 J. A. " SPIKE" DUNLOP (405) 251-3124 President March 12, 198 75~.?_, y. j _

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LS Mr.

R. J. Everett U.

S. Nuclear Regulatory Commission Region IV ggsf17 611 Ryan Plaza Dr.

Suite 1000 Arlington, TX 76011

Dear Mr. Everett:

Attached is a copy of the letter sent to our Division Managers by Mr. John G.

Cook, Senior Vice President.

The letter outlines the changes which are being made in our field operations relative to use of radioactive tracer sand.

As you can see we are curtailing the extent of our operations, increasing our training requirements, imoroving

. our - recordkeeping system and working towards imorovince our equipment.

If you have any questions regarding our decisions,

please let me know.

Very truly yours, J.

A.

Dunlo_

RB/JAD:im Attachment 8703240039 870312 s

PDR ADOCK 07000522 C

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T-3N O A Halliburton Company

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HALLIBURTO SERVICES DIVISION MANAGERS TO:

Duncan, Oklahoma 73536 J.

G. Cook FROM:

Senior Vice President, Domestic Operations Mar h 10, 1987 DATE:

Tracer Sand Recommendations SUEUECT:

Recent Nuclear Regulatory Commission inspections of our '

facilities which utilize radioactive tracer sand indicate a lack of compliance with their regulations.

Deficiencies in handling, use, proper control, recordkeeping, and disposal have 4 been noted.

Significant improvements must be made if we continue to use radioactive tracer services and products.

Each of you have been contacted regarding your continued offering of these products and services.

Based upon that contact and the fact that regulatory compliance must be achieved the following changes are to be implemented.

1.

Shreveport, Dallas, Corpus Christi, New Orleans, Los Angeles, and Wichita Divisions are to be the only Divisions offering radioactive tracer sand services.

All other Divisions are to eliminate their usage of these materials.

2.

Use will be limited to service center locations as determined in previous discussions.

Dallas:

Kilgore, Palestine, Wichita Falls Los Angeles:

Santa Fe Springs, Bakersfield Shreveport:

Bossier City, Laurel, Felda, Natchez Corpus Christi:

Alice New Orleans:

Lake Charles Wichita:

Liberal other locations within those Divisions will be removed from the tracer license as authorized locations after surveys and final inspections are performed.

3.

Division responsibility for radioactive operations and compliance must be assigned to an individual.

That individual may delegate individual location responsibilities but ultimately overall responsibility for the Division rests with the appointed person.

This responsibility will include compliance with the densometer license in addition to the tracer sand license.

Please provide Government 802328

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JRegulations Department with the name of the respon-:

Esible-individual.

4.

Eliminate the practice of shipping radioactive. wastes to Duncan..Those. service centers 1 currently shipping waste to1Duncan who continue to^ offer radioactive' i,

tracer-services should~ ship their consolidated I

radioactive waste directly.to Gulf Nuclear, Inc.-in Odessa, Nuclear Sources'and Services, Inc.-in Houston or other licensed' disposal facilities.. Currently k radioactive waste generated.by:some Divisions is l

shipped to.Duncan via Company truck._ Itfis sorted,Q consolidated, and. repackaged by Materials Department personnel for shipment tu) Gulf Nuclear.

The. shipment to Duncan requires additional handling procedures, receipt,. transfer, and invoice. documents,'and trained personnel.. It is a time consuming process which 4

utilizes a facility which was not specifically.

designed as a repackaging station.

In addition, several of the NRC alleged violations centered around these waste handling practices.

There are existing procedures for the packaging of empty radioactive containers and associated materials.

The consolidation-of containers can be done at the service centers and the drums containing empty cans and unused sand sent directly to a disposal firm..

Paper wastes, such as empty 1 boxes and shipping-cartons, if after surveying and documentation indicate no contamination, can be disposed of at the local. landfill.

Radioactive labels and nomenclature must be removed from the waste paper materials before shipment to a landfill.

5.

Training of personnel will be on an annual basis and required for an individual to remain qualified as.a RAYFRAC operator.

The content and length of the training sessions will be determined by the Radiation Safety Officer and based upon the job functions of the trainee.

6.

Locations no longer offering tracer services will be removed from the radioactive tracer license and should be fully aware that-radioactive tracer material cannot be utilized by Halliburton personnel at those locations.

Such service centers should contact a center which is licensed to handle radio-active tracer materials or an independent contractor who can furnish radioactive tracer services to customers.

The problem of pumping equipment con-tamination will have to be taken into consideration by you and the independent contractor.

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All camps offering radioactive tracer services.should strive to utilize high pressure = injection equipment.

The use of.high' pressure injection equipment will.

minimize our equipment contamination and represents

" state-of the art" technology currently not utilized byc the : competition'.

Third party tracer companies couldethen be made. aware.that contamination of our a

pumping equipment by their utilization of' low pressure injection units is not acceptable.

8.

Improvements in the recordkeeping system' dealing wi h receipt, use, transfer and-disposal documents must e

made.

You must be able to, fully and. completely

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document your involvement with radioactive tracer materials.

A system of-internal checks and. audits will be; initiated on an irregular and unannounced basis to ensure compliance.

4

' Help in complying with these requirements and developing your compliance and recordkeeping programs can be obtained from Richard Leonardi,cRadiation Safety. Officer located at the-

-Kilgore Service Center, 214/983-1821 or the Government Regulations Department in Duncan.

-.,The above. requirements pertain only to tracer sand usage.

All the regulatory requirements relative to densometers remain c

in effect as they are under a. separate license and not effected by these operational changes.

3:

Our ability to offer radioactive tracer products and

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services to our customers is dependent upon your complying with the termstand provisions of the appropriate NRC or State license.

Non-compliance will subject Halliburton to fines and, in addition, the possibility of license revocation, i

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RB/JC:im 4

cc:--Mr. J. A. Dunlop U

Mr. S.

J. Babin l

Mr. W.

T. Malone Mr. Cecil Richardson bc:

Mr. Bill Gilchrist Mr. Bill Ritter l

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