ML20148K230

Responds to E Marienbach in Response to NRC .Requests Listed Addl Info in Order to Continue Review of Application for License within 30 Days of Ltr Ltr Receipt

ML20148K230
Person / Time
Issue date:	08/26/1987
From:	Fisher W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Monti R ANADRILL, INC.
Shared Package
ML20148K137	List: ML20148K148 ML20148K230
References
461418, NUDOCS 8803310048
Download: ML20148K230 (4)

Text

._ __. .-_ _ __ __ _______ _- __ _ -. _ _ _

b i

t NHLS:CLC 5 mp-Control No. 461418 NC 2  ;

e Anadrill, Inc. .

ATTN: Mr. R. Monti, President 200 Macco Boulevard ,

' Sugar Land. Texas 77478 Gentlemen:

This is in response to your letter dated August 10, 1987, signed by Mr. Edouard Marienbach, Radiation Safety Officer, in which you responded to our letter dated July 13, 1987. In our July 13 letter we stated that there were various items in our letter dated May 13, 1987, to which you failed to respond.

We are concerned that after sending you two letters requesting further information in regard to your license application dated March 2,1987, we still have not received any answer in regard to certain matters as identified below.

We are concerned that your carelessness in regard to your failure to provide a proper response to our questions may be indicative of similar inattentiveness in regard to the implementation and execution of your radiation safety program.

We request that you explain your difficulty in providing a proper response to our two previous letters. Failure to address the matters identified below will give cause for us to consider whether your request for a license should be ,

denied.

1. In Item 3 of our letter dated May 13, 1987, we requested that you provide ,

a description of your program for conducting annual inspections of the job  ;

performance of each logging supervisor required by 10 CFR 39, Section ,

39.13(d). You did not respond to this item in your submittal dated June  ;

24, 1987. In Item S of our letter dated July 13, 1987, we again requested this information and defined detailed items that should be included in  :

your response. One of these items included a request for a description of  !

the elements to be reviewed during these audits. Your response dated August 10, 1987, failed to provide this description.

You should respond to this item by describing the detailed elements that  ;

will be reviewed during your unannounced audits of well site activities.

Examples of elements that should be audited include performance of surveys and use of proper survey techniques, proper handling and use of sealed sources, possession and proper use of personal dosimetry equipment, operational adequacy and calibration of survey equipment, proper source ,

and container labeling, proper storage and security of licensed material, ,

and proper use of area postings.

1 C: NHLS q+t.  !

CLCain:cz  :

S/11/87 8803310048 870930 F REG 4 LIC30 42-26877-01 D;p

Anadrill, Inc. .

2. Item 8 of our letter dated May 13, 1987, requested that you amend your operating procedures to include all of the elements described in 10 CFR 39.63 and to ensure that the procedures are prepared in adequate detail in order to provide spe:ific instructions to workers. Your submittal dated June 24, 1987, included information in regard to 10 of the 14 elements in the regulation. Item 7 of our letter dated July 13, 1987, requested a response to the four remaining items. Your submittal dated August 10, 1987, provided an incomplete response to three of the items and no response to the fourth item (pertaining to actions to be taken if a sealed source is ruptured). Further information required for each of the four items is specified below:

a. 10 CFR 39.63(h) requires operating procedures in regard to picking up, receiving, and opening packages containing licensed material, in accordance with S 20.205. Your August 10, 1987, submittal states that a person receiving a source container must "Perform survey of the source. If excessive readings are noted, notify the facility manager and R50 immediately."

You should describe in the procedure how the survey should be conducted, the instrumentation to be used, and what readings are "excessive." Note also that S 20.205 specifies time limits for holding a container prior to accomplishment of the survey, maximum allowable exposure rates at the surface and at three feet from the surface of the container, and circumstances requiring NRC notification. These requirements should be included in the procedure,

b. 10 CFR 39.63(k) requires operating procedures in regard to inspection and maintenance of sealed sources, source holders, logging tools, source handling tools, storage containers, and transport containers as required by S 39.43. 10 CFR 39.43 requires specified inspection and maintenance activities before each use and semiannually.

Your August 10 submittal did not describe the inspection and l maintenance to be performed prior to each use and the associated records to be maintained. You should amend your procedure to include these requirements as well as the warnings in regard to sealed source maintenance described in S 39.43(c)-(e).

c. 10 CFR 39.63(1) requires operating procedures in regard to identifying, and reporting to NRC, defects and noncompliance as required by 10 CFR Part 21. Your procedure states, "In compliance with 10 CFR Part 21, defects and/or noncompliance with the regulations must be reported to the facility manager who will in turn report it to the R50."  ;

Your procedure should be amended to describe to the worker the kinds of defects and the types of equipment subject to reporting.

i

Anadrill, Inc. .

d. 10 CFR 39.63(o) requires operating procedures in regard to actions to be. taker,if a sealed source is ruptured including actions to prevent-the spread of contamination and minimize inhalation and ingestion of licensed materials and actions to obtain suitable radiation survey instruments as required by 8 39.33(b).

None of your responses to date have included amended procedures which address this requirement.

3. Item 9 of our letter dated May 13, 1987, stated that if you propose to calibrate your survey instruments yourself, you must provide detailed procedures including calibration sot.rces to be used (identity of radionuclide and activity, make and model number, output, and accuracy),

qualifications and training of persons performing calibrations, and record forms to be used. Your submittal dated June 24, 1987, stated, "Calibration procedures may be done by the facility using an approved calibration instrument (Tech / Ops Model 773 Instrument Calibation [ sic]

Device). Correct procedures are outlined in the Tech / Ops Operations Manual."

Our letter dated July 13, 1987, requested once again that you respond to the items identified in our previous letter including submittal of detailed procedures and identification of the names and qualifications of individuals performing this function. The letter also stated, "You should also be aware that possession and use of byproduct material for use other than that requested for well logging does require specific authorization on your NRC license. If you intend to acquire such material you should so specify.

i- The record form used in conjunction with instrument calibration should be j sufficient to record the details of the calibration for each instrument as l identified in 5 39.33(c)."

Your submittal dated August 10, 1987, provides a procedure consisting of 11 lines of text which does not provide sufficient detail to instruct a worker to perform instrument calibration. Included herein is a draft Regulatory Guide for use in your response. Section 10.4 of this Guida l

j should be used in preparing your procedure. You should also identif who

will perform this work and should describe in detail the training that will be provided. The record form should describe in detail the results of the calibration including the following

• the make, model number, and serial number of the instrument being l calibrated

• for each of the 2 points per scale checked -

l the calculated exposure rate, the indicated exposure rate, l

the ceduced correction factor, and the scale selected on the instrument f

l l

k

Anadrill, Inc. .

• description of the calibration source, including exposure rate at a specified distance on a specified date

• the instrument reading in the "battery check" mode

• the angle between the radiation flux and the detector

• whether any detector shield is installed or removed Also, a calibration label should be attached to each instrument indicating the date of calibration and the date due again.

You should further describe the Tech / Ops calibrator you intend to use and indicate that you are requesting to have this byproduct material added to your license.

If we do not receive a reply from you within 30 calendar days from the date of this letter, we shall assume that you do not wish to pursue your application.

Please reply in duplicate and refer to Control No. 461418.

Sincerely, Original signed by William L. Fisher, Chief Nuclear Materials and Emergency Preparedness Branch

Enclosure:

Draft Well Logging Licensing Guide bec: CCain bec w/o enclosures:

RLE>angart