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Insp Rept 15000042/98-09 on 980611-12.Violations Noted. Major Areas Inspected:Response to Licensee Notification That Cardinal Surveys Co Had Failed to File Initial NRC Form 241 Prior to Performing Licensed Activities
	ML20236S528
Person / Time
Issue date:	07/22/1998
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20236S523	List: ML20236S521; ML20236S524; ML20236S528;
References
	15000042-98-09, 15000042-98-9, NUDOCS 9807240409
	Download: ML20236S528 (7)
	v • d • e

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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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EXECUTIVE SUMMARY

Cardinal Surveys Company

Odessa, Texas 1

NRC Inspection Report 150-00042/98-09 1

L 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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Cardinal's use of licensed material at a well site near Butler. Oklahoma, on April 17,

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 - q

they had failed to file a NRC Form 241 prior to conducting licensed activities in exclusive i

, Federaljurisdiction on April 17,1998. Cardinalimmediately faxed Region IV copies of a I

' completed Form 241 with a copy of the check covering the fee, followed later with the j

original Form 241 and required fee.

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. An inspection completed in May 9,1996, identified a similar violation conceming

L . 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

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

1 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, !

1998. These activities were conducted without Cardinal having applied for reciprocity in l

acccrdar.ce with 10 CFR 150.20.

1.2 Observations and Findings

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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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2 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. I

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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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3 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 )

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

by fax constituted immediate corrective actions. }

During discussions uith Cardinal's RSO during the inspection, and subsequent ,

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 i

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 i

request authorization to use licensed material at an additional use location in the state of j

. Wyoming. Cardinal's response letter signed by Cardinal's president and dated June 14, '

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

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members that were authorized tc sig,1 and process a !!RC Form 241 for propoced tracer

l 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

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in preventing the recurrence of the same violation cited in this Notice.

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4 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 l

INSPECTION PROCEDURES USED {

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

activities in NRC jurisdiction was identified as a violation of {

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10 CFR 150.20.

LIG T OF ACRONYMS

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NRC Nuclear Regulatory Commission

RSO radiation safety officer !

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ML20236S528

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