ML20215H693
| ML20215H693 | |
| Person / Time | |
|---|---|
| Issue date: | 05/29/1987 |
| From: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20215H667 | List: |
| References | |
| NUDOCS 8706240187 | |
| Download: ML20215H693 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION
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coes ettvn ictmOis sour MAY 2 91987 MEMORANDUM FOR: John A. Grobe, Director, Enforcement and Investigation Coordination Staff FROM:
Jack A. Hind. Director, Division of Radiation Safety and Safeguards
SUBJECT:
ALLEGATION MANAGEMENT SYSTEM: ALLEGATION NO. RIII-85-A-0028 RE: SEGREST ENERGY GAS AND OIL (FORMERLY SEGO WELL SERVICE)
(LICENSENO. 34-20407-01)
During a routine inspection of the subject licensee on November 30, 1984, nine violations of NRC requirements and/or license conditions were identified, including the unauthorized possession and use of a sealed americium / beryllium
( Am:Be) source in well-logging operations.
The violation was brought to the licensee's attention during the November 30, 1984 inspection.
Further, the licensee was specifically informed by way of an April 5, 1984 letter from NRC Materials Licensing representatives that the source had not been evaluated nor approved for well-logging applications, and that the source was not included on Sego Well Services' NRC license.
On December 17, 1984, NRC Region III was notified that the source had been used on three occasions since the November 30, 1984 inspection. This matter was referred to the Office of Investigations (01) on February 26, 1985 to determine if Sego Well Services willfully violated their license conditions. On March 20, 1987, the case was " administrative 1y closed" by 01 for lack of resources.
On May 5, 1987, the Division of Radiation Safety and Safeguards was assigned to
" review the matter for potential enforcement action." A rev.iew of Segrest Energy Gas & Oil's (formerly SEG0's) NRC license revealed the following:
1.
On April 15, 1985, SEGO was issued (and paid) a $500 civil penalty based
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on the " breakdown in the management oversight and control of [their]
licensed activities."
This breakdown was evidenced by nine violations being identified during the November 30, 1984 inspection (only eight violations were considered in the civil penalty package; the unauthorized use/ possession of the Am:Be source violation was referred to 01).
2.
On August 1, 1985, NRC Licensing representatives amended SEG0's license to allow the use of the subject Am:Be source in gas and oil well-logging operations (thus eliminating the violation). This amendment was for l
limited use of this source.
NMSS/HQ agreed with the amendment.
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8706240187 0706M REG 3 LIC30 34-20407-01 PDR i
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bMY 2 91987 John A. Grobe 2
Although the allegation was substantiated and resulted in the identification of a violation of NRC requirements (license condition), it appears that the violation continued (from November 1984 through February 1985) as a result of poor licensee communications between their home and field offices, and not as a deliberate action or with careless disregard of NRC requirements.
In addition, since the licensee was authorized to possess and use well-logging sources (since April 1984) and eventually received NRC licensure for the previously unauthorized source (in September 1985), the violation did not pose a significant health and safety concern.
Based on the above, the Division recommends that Region III administratively close our case file in this matter.
6xthdhl d, Director ack A. Hin Division of Radiation Safety and Safeguards cc:
C. J. Paperiello C. H. Weil I
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SEGO PERFORA TING LOGGING yggygqgg P.O. Box 117 614 439 4746 Cambridge, Ohio 43725 l
l May 9, 1985 Mr. James G. Keppler Regional Administrator United States Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Re: License No. 34-20407-01 EA 85-33
Dear Mr. Keppler:
Enclosed is our check number 2555 in the amount of five hundred dollars ($500.00) for imposed violations by the NRC as per your letter dated April 19, 1985. Also, I have listed below answers to same and hope that everything is to your satisfaction.
~
l Al.
We will admit to the alleged violation but still do not feel that the individual actually received the exposure shown.
Misuse of film badge by individual and questionable film badge report.
A2.
A3.
Individual has been reprimanded and instructed on the proper use of film badge. Individual has received 0 reading each month since violation.
A4.
All individuals instructed on proper handling of sources and misuse of film badges.
AS.
All have completed as of date of writing this letter.
B1.
We do admit to both violations.
B2.
A definite oversite on our part.
B3.
We have reread 10 CFR Part 20 and feel that we now fully understand this regulation.
B4 Same as B3.
B5.
Effective date of this letter.
C1.
We admit to this violation.
C2.
This was an oversite on our part>.
The individuals were qualified, but weren't listed as users.
C3.
An amendment to our license has been applied for on January 14, 1985 which would add four more individuals as users (see attached letter). To date, we have not received this amendment. Until such time that we do receive admendment, jobs are being supervised by listed users.
C4 When we receive our amendment all operators will be listed as users.
C5.
Effective date of this letter.
D1.
We. admit to this violation.
D2. ;The' described source was: located..in. Michigan.? We thought the source had been_ leak. tested,but..it apparently was not.
It was.primarily lack [of communicatio'na tbetween(the two; shops.
D3.
Said: source has-been~put into storage until all problems have beenjcorrected.
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. D4.
All copies of leak tests in Michigan are sent to Cambridge offices and recorded.
D5.
Effective date of this letter.-
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We admit to this violationg.,,,_,,,,,m y F ya
- This survey meter,was. alsoplocated}iniMichigan andy againi;;pqrnwy,,,
o E2.
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this violation 1 was theyresultfofJinsufficie.nt1c'ommunicati' s between;ouritwoishops y o
E3. ' Individuals'in Michigan were instructed to have the meter calibrated every
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six months and send results to the Cambridge shop'.
E4.
Same as.F3.
j E5.
Effective date of this letter, May 9th, 1985.
F1.
We admit to this violation.
F2.
This was an oversite on our part. We were surveying at the front sign instead of the passenger compartment.
F3.
The survey sheets have been changed to include surveying passenger compartment.
F4.
Same as F3.
F5.
Effective May 9th, 1985.
G1.
We admit to this violation.
G2.
We misunderstood 10 CFK 20.101. We thought that because this individual had not received any exposure for the year prior to the third calendar quarter that the 1.72 REM was not a violation.
G3.
All exposure reports closely monitored each month. Also, we have changed to a different radiation survey service.
G4.
Same as G3.
G5.
Effective May 9th, 1985.
Hl.
We admit to this violation.
H2.
This was an oversite on our part'.
H3.
We now minitor all incoming packages containing radioactive material and the results are documented on the receiving papers.
11 4.
Same as H3.
H5.
Effective May 9th, 1985.
I believe all the above responses will suffice but, should they not, please don't hesitate to contact me.
We certainly want to have all problems resolved so that we won't have any further ones, and hope that all necessary adjustments, etc. have been made to your satisfaction.
Very truly yours, SEGO WELL SERVICES, INC.
/3LAA' h M David G. Art Acting Radiation Safety Officer DGA:pk CERTIFIED MAIL, RETURN RECEIPT REQUESTED Director, office of Inspection and Enforcement, USNRC, Washington, DC 20555 cc:
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J UNITED STATES NUCLEAR
'pIh[h REGULATORY COMMISSION, Region III
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ATTN: Mr. Bruce Mallett
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Wa cre requesting the following changes to our License #34-20407-01.
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(1) Add to Item 6, the following:
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y F. Americium 241:BE F. Sealed Neutron Sources F. Not to exceed
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(Parkwell Laboratories, 2.7 Curies per so[r'be I
7 difik Model PL-Ambe) 42 o
G. Cesium 137 C. Sealed Sources
'G. Not to exceed d$
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125 Millicuries [M'f' (Gamma Industries Model VD-HP) i.'
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users:
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, (2) Add to Item 12, the following-
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l Jonathan W. Hudson
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William T. Barthalow ce i
Dennis R. McConahy 1;;
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, Charles T. Berger
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" ?i Please find enclosed resumes and training certificates for the above persons. If you have any questions, please call (614) 439-4746.
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'l. r*,.N-3, Sincerely,
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David G. Art, Acting R.S.O.
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