ML20236S528
| ML20236S528 | |
| Person / Time | |
|---|---|
| Issue date: | 07/22/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236S523 | List: |
| References | |
| 15000042-98-09, 15000042-98-9, NUDOCS 9807240409 | |
| Download: ML20236S528 (7) | |
See also: IR 015000042/1998009
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ENCLOSURE 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
150-00042
License:
Texas L00065
Report:
150-00042/98-09
Licensee:
Cardinal Surveys Company
Facility:
Cardinal Surveys Company
Location:
Odessa, Texas
Dates:
June 11-12,1996
Inspector:
Richard A. Leonardi, Jr., Radiation Specialist
- Approved:
D. Blair Spitzberg, Chief
Nuclear Materials Safety Branch 2
Attachr'ent:
Supplemental Inspection Information
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9807240409 990722
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EXECUTIVE SUMMARY
Cardinal Surveys Company
Odessa, Texas
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NRC Inspection Report 150-00042/98-09
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This reactive inspection was conducted in response to the licensee's notification that Cardinal
Surveys Company (Cardinal) had failed to file an initial NRC Form 241 prior to performing
licensed activities in exclusive Federal jurisdiction on April 17,1998.
Use of Radiotracer in Oklahoma
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Based on interviews with licensee personnel and a review of records pertaining to
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Cardinal's use of licensed material at a well site near Butler. Oklahoma, on April 17,
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1998, it was determined that the licensee failed to file an initial NRC Form 241 for
proposed activities in exclusive Federal jurisdiction in accordance with 10 CFR 150.20.
.This Texas licensee used 145 millicuries of iridium-192 coated on artificial proppant to
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tag a fracture-stimulation job.
Corrective Actions and Follow-uo on Previous Insoection Findinas
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Cardinal notified NRC Regional IV staff by phone on' April 27,1998, after discovering that -
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they had failed to file a NRC Form 241 prior to conducting licensed activities in exclusive
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Federaljurisdiction on April 17,1998. Cardinalimmediately faxed Region IV copies of a
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completed Form 241 with a copy of the check covering the fee, followed later with the
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original Form 241 and required fee.
An inspection completed in May 9,1996, identified a similar violation conceming
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. Cardinal's failure to file a revision to their original NRC Form 241, authorizing Cardinal
the additional use of licensed material at a location in Wyoming not authorized on the
original Form 241 dated September 12,1995.
The il nsee's corrective actions discussed in a letter dated June 14,1996, in response
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to NRC's Notice dated May 22,1996, appeared iresik,ctive in preventing the recurrence
. of a similar violation in 1998.
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Repor12etails
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Purpose of Inspection and Program Overview (87100,87103)
1.1
Insoection Scoce
The inspector reviewed Cardinal's use of licensed material in Oklahoma, an area of NRC
jurisdiction, for activities conducted on a well site near Butler, Oklahoma, on April 17,
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1998. These activities were conducted without Cardinal having applied for reciprocity in
acccrdar.ce with 10 CFR 150.20.
1.2
Observations and Findings
On April 27,1998, a Cardinal staff member telephoned NRC Region IV and notified
regional staff that Cardinal had used licensed material in Oklahoma at a single jobsite on
April 17,1998, but had failed to file a Form 241 as required. A NRC inspection was
performed on June 11-12,1998, to review the circumstances involving Cardinal's failure
to file a Form 241 prior to conducting activities in NRC jurisdiction.
Cardinal holds a Radioactive Material license (Texas L00065) issued by the state of
Texas which authorizes Cardinal to perform tracer operations in oil / gas ws;ls at
temporary job site locations throughout Texas. Cardinal's corporate offices are located
in Odessa, Texas, with a field office in Hobbs, New Mexico. Cardinal utilizes 12 tracer
operators, four logging trucks, and three high pressure injection systems (Tagmaster
units) to provide tracer services to customers in Texas and New Mexico, and
occasionally in Oklahoma. Cardinal uses 20 ejector tools to provide fluid profile studies
using primarily liquid iodine-131. Cardinal does not use sealed sources for conventional
well logging.
1.3
Conclusions
Based on the inspector's interview of Cardinal personnel and the review of Cardinal's
Texas license, supporting documents, and other records maintained by Cardinal, the
inspector concluded that Cardinal's activities that were conducted in NRC jurisd;ction on
April 17.1998, appeared to be in accordance with Cardinal's Texas license, and their
Operating and Emergency Procedures.
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Use of Licensed Materialin Oklahoma (87100)
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2.1
Insoection Scoce
The inspector's review included a detailed review of Cardinal's failure to file NRC Form
241 for licensed activities in Oklahoma on April 17,1998.
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2.2
Observations and Findings
Based on interviews with Cardinal's radiation safety officer (RSO) and administrative
secretary, the inspector determined that Cardinal performed a fracture-stimulation tag job
(frac tag) on April 17,1998, on a well site (Shelton lease, Well No.10-7) near Butler,
Oklahoma, involving the use of 145 millicuries of iridium-192 coated on proppant to tag a
fr= jeh
During interviews with Cardinal's RSO and secretary, the inspector determined that
Cardinal's president received an e-mail request for a tracer job from a customer in
Oklahoma. Cardinal's routine procedere called for the person receiving a request for
work to provide the name of the customer requesting work to one of the salesman, who
in turn would contact the customer and set the job up. Cardinal s salesmen, secretary,
and RSO were aware that any tracer work scheduled for Oklahoma had to be
coordinated through the RSO or the secretary to ensure that the required notifications
had been given to NRC Region IV prior to performing the frac tag However. after
Cardinal's president received the request for a tracer tag from the Oktat.oma customer,
he apparently setup the tracer job without sales personnel, RSO, or secretary being
aware of the scheduled tracer job in Oklahoma. The RSO is frequently out of the office
on field jobs snd was not in the office when the tracerjob was scheduled by Cardinal s
president, nor were the RSO or secretary aware that Cardinal had pe: formed the frac tag
on April 17,1998, until on April 27,1998, the secretary was processing billing invoices
forjobs performed and noticed that Cardinal had performed a frac tag on April 17,1998.
Cardinal's secretary disclosed that when she realized that Cardinal had performed a frac
tag in Oklahoma, she immediately notified NRC Region IV staff of the oversight, and
faxed completed copies of NRC Form 241 with a copy of the required check. Cardinal's
secretary indicated that when she questioned Cardinal's president regarding the frac tag
and Cardinal's failure to file the NRC Form 241, the president disclosed that he had
forgotten the need to request reciprocity in accordance with 10 CFR 150.20.
10 CFR 150.20 requires, in part, that licensee file a NRC Form 241, " Report of Proposed
Activities in Non-Agreement States" at least 3 days before enga7 l in licensed activities
in Non-Agreement States. Cardinal's failure to file a NRC Form 2 as discussed above,
was identified as a violation of 10 CFR 150.20 (b)(1) (150-00042/98-09).
2.3
Conclusions
One violation of NRC requirements was identified for this Texas licensee's failure to file a
NRC Form 241 before conducting licensed activities in NRC jurisdiction.
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Corrective Actions and Follow up on Previous inspection Findings (87100,92702)
3.1
insoection Scooe
This portion of the inspection included a review of correcNve actions the licensee had
taken or planned on taking relative to the NRC inspection of June 11-12,1998, and a
review of the licensee's corrective actions in response to a previous Notice of Violation
letter dated May 22,1996, involving a NRC inspection completed on May 9,1996.
3.2
Observations and Findinos
The inspector determined that an administrative secretary for Cardinal identified
Cardinal's failure to file a NRC Form 241 for licensed activities that had been conducted
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in Oklahoma (a NRC state) on April 17,1998, during the processing of billing invoices
on Apnl 27,1998. The secretary immediately telephoned NRC Region IV staff on the
same day regarding Cardinal's failure to file the required NRC Form 241. and faxed
Region IV copies of a completed NRC Form 241 with a copy of the required fce check.
Cardinal's self-identification of the their failure to file a NRC Form 241, Cardinal's prompt
reporting of this failure to the NRC, and their submission of a completed NRC Form 241
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by fax constituted immediate corrective actions.
During discussions uith Cardinal's RSO during the inspection, and subsequent
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discussion with Cardinal's president during the exit briefing on June 26,1998, the
inspector was informed that Cardinal representatives had discussed iong-term corrective
measures, but had not drafted a written description of proposed corrective actions at the
time of the exit briefing.
During the review of a previous NRC Inspection Report and Notice of Violation
(150-00042/95-01) dated May 22,1996, involving the inspection of Cardinal on
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November 6,1995, the inspector noted that Cardinal was issued the Notice for the failure
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to have filed a revision to their original NRC Form 241 dated Septembar 12,1995, to
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request authorization to use licensed material at an additional use location in the state of
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. Wyoming. Cardinal's response letter signed by Cardinal's president and dated June 14,
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1996, discussed Cardinal's corrective actions including the establishment of a new
company policy requiring that tracer jobs will not be scheduled unless three days notice
can be given to the NRC Region IV office. Additionally, Cardinal designated other staff
members that were authorized tc sig,1 and process a !!RC Form 241 for propoced tracer
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work in NRC jurisdiction'1.
It appears that Cardinais conective actions discussed above were ineffective in
preventing the recurrence of the same violation as cited in the previous NRC Notice
dated May 22,1996.
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3.3
' Conclusions
Cardinal initiated immediate corrective actions after discovering that they had failed to file
a NRC Form 241 for heensed activities that Cardinal had conducted in Oklahoma on
April 17,1998, which inclu_ded the immediate notification to the NRC Region IV of their
oversight and the faxing of a completed NRC Form 241 with a copy of the required check
to NRC Region IV staff.
The inspection revealed that Cardinal's corrective actions in response to a similar
violation identified in a NRC Notice of Violation dated May 22,1996, appeared ineffective
in preventing the recurrence of the same violation cited in this Notice.
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Exit Meeting Summary
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The inspection findings, as noted in the report, were discussed with the licensee during
a telephonic exit briefing conducted on June 26,1998. The licensee acknowledged the
findings as presented. The inspector asked the licensee whether any materials
examined during the inspection should be considered proprietary, No proprietary
information was identified.
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ATTACHMENT
SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
James S. McLaughlin, President of Cardinal
George W. Newman, RSO
Annette Davis, Administrative Secretary, Cardinal
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INSPECTION PROCEDURES USED
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IP 87100: Licensed Materials Program
IP 87103: Inspection of incidents at Nuclear Materials Facilities
IP 92702: Follow up on Corrective Actions for Violations and Deviations
ITEMS OPENED AND DISCUSSED
Ooened
'150-00042/9809-01 VIO
Failure to file a NRC Form 241 prior to conducting licensed
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activities in NRC jurisdiction was identified as a violation of
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LIG T OF ACRONYMS
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NRC
Nuclear Regulatory Commission
radiation safety officer
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