United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 84-28: Recent Serious Violations of NRC Requirements by Well-logging Licensees

                                                       SSINS No.:  6835 
                                                       IN 84-28 

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                   OFFICE OF INSPECTION AND ENFORCEMENT  
                           WASHINGTON, D.C. 20555 

                               April 17, 1984 

Information Notice No. 84-28: RECENT SERIOUS VIOLATIONS OF NRC REQUIRE- 
                                 MENTS BY WELL-LOGGING LICENSEES Addressees:

All byproduct materials licensees authorized to possess and use byproduct 
materials in well-logging devices and manufacturers who distribute devices 
that incorporate sealed sources for such use. 

Purpose: 

To bring to the attention of well-logging licensees the large number of re-
cent cases involving serious violations of NRC license conditions, to point 
out the common causes of these violations, and to describe their consequen-
ces. 

Discussion: 

From January 1 to December 1, 1983 there have been 26 cases in which the NRC 
has taken escalated enforcement action against byproduct materials 
licensees. Nineteen of these cases involved a civil penalty, six involved 
Orders to suspend the license or to show cause why the license should not be 
revoked, arid one involved both a suspension Order and a civil penalty. 
These escalated enforcement actions were taken because various serious 
violations of NRC license requirements occurred. These violations included 
employees being overexposed to radiation, members of the public being 
unnecessarily exposed to radiation, and public property being contaminated 
with radioactive material. In addition, the financial consequences to the 
affected licensees have been significant because of the loss of income from 
the payment of civil penalties, the cost of decontaminating property, and 
the suspension or revocation of the license. 

An analysis of the causes of these escalated enforcement cases shows that 
there were three common causes for the serious violations and their con-
sequences. These causes were: 

(1)  Failure to read and understand the conditions of the license. 
(2)  Failure to train employees in the conditions of the license including 
     the radiation safety procedures that are incorporated into the 
     license. 
(3)  Failure to control operations including failure of licensee employees 
     to follow approved radiation safety procedures. 


8403140277 
.

                                                            IN 84-28 
                                                            April 17, 1984 
                                                            Page 2 of 3 

Attached are summaries of two well-logging cases. They illustrate the causes 
and consequences of the serious violations that the NRC has found during 
inspections of this class of byproduct materials licensees. 

One of the principal causes of violations is the fact that some licensees 
are not cognizant of all the conditions of their license. NRC has found 
during inspections that some licensees have never read the license or have 
little understanding of its conditions. Conditions and commitments in the 
license form the basis for the issuance of the license, and are necessary to 
protect the health and safety of the public. NRC therefore expects licensees 
to abide with all the conditions and commitments of their license. 

Licensees are reminded that nonroutine service and maintenance of equipment 
such as removal of source capsules from source holders, repair, and 
replacement of seals on source holder/pressure housing, etc., should not be 
undertaken, unless the licensee has specifically requested this 
authorization and provided his procedures for performing these services in 
his license application. Where specific approval has not been granted under 
the license, the source holder or pressure housing containing the source 
should be returned to the source or device Manufacturer or other persons 
specifically licensed to perform the nonroutine servicing. 

Two other principal causes of violations are the failure to properly train 
the workforce and the failure to control the radiation-safety aspects of the 
licensee's operation. Licensee management is responsible for ensuring that 
employees receive proper training, that the proper radiation monitoring 
instrumentation and personnel dosimetry is available and used, and that 
employees comply fully with all the conditions of the license and associated 
radiation safety procedures. 

The licensee's responsibility for control of its operations also extends to 
consultants and contractors. In certain circumstances the NRC encourages 
licensees to seek qualified assistance when the licensee does not possess 
the necessary experience, training, equipment, or personnel dosimetry to 
perform particular activities; e.g., to handle problems arising from an 
accident or unusual occurrence. However, the responsibility for the safety 
of the operations and compliance with NRC requirements remains with the 
licensee. 

Licensees should review the conditions of their license to ensure that they 
understand their responsibilities under the license. This should include an 
examination of the details of their radiation safety program to verify that 
the program complies with all requirements. As a result, licensees can avoid 
the serious consequences to their employees and the public and the 
significant financial costs that can result from failure to follow NRC 
requirements. 

.

                                                            IN 84-28 
                                                            April 17, 1984 
                                                            Page 3 of 3 

No response to this information notice is required. If you have any 
questions regarding this matter, please contact the Administrator of the 
appropriate Regional Office or this office. 



                              J. Nelson Grace, Director 
                              Division of Quality Assurance, 
                                Safeguards, and Inspection Programs 
                              Office of Inspection and Enforcement 

Technical Contacts:      J. R. Metzger, IE
                         (301) 492-4947 

                         E. D. Flack, IE
                         (301) 492-9823 

Attachments: 
1.   Selected Cases Involving Serious 
     Violations of NRC Requirements 
2.   List of Recently Issued IE Information Notices 
.

                                                            Attachment 1 
                                                            IN 84-28 
                                                            April 17, 1984 
                                                            Page 1 of 3 

                                  CASE A 

A well-logging licensee attempted to remove a stuck 2 curie cesium-137 
source from a source holder using lubricants. When this failed, the, source 
holder was placed in a lathe and the lathe was turned on. Attempts were made 
to push the source out of the holder with a drill bit while the source 
holder was turning on the lathe. The source finally fell out of the holder 
but it had been ruptured, causing widespread contamination. 

The licensee did not recognize the seriousness of the incident and the NRC 
was not notified until almost 24 hours after the incident had occurred. As a 
result, a fairly minor problem became a major incident. 

Violations 

1.   The licensee employees conducted unauthorized operations. 

2.   Radiation surveys were completely inadequate for the amount of radio-
     active material that had escaped from the ruptured source. (the 
     instruments went off-scale and licensee employees assumed the 
     instruments were not working properly.) 

3.   A radiation exposure to an employee exceeded the regulatory limit. 

4.   Licensee employees were not properly instructed about what to do when 
     a source became stuck in a source holder. 

Causes 

1.   Management and employees did not understand the conditions of the 
     license. 

2.   Employees were inadequately trained; e.g., they did not know how to 
     use radiation monitoring instruments properly or how to control 
     radioactive contamination. 

Consequences 

1.   Radioactive contamination was spread to 27 homes, several private 
     autos, six business establishments and the premises of the licensee. 

2.   Whole-body exposure to one employee was 13.48 rems. Three employees 
     had a body uptake of cesium-137 equal to about 10% of the NRC limit. 
     One employee had a cesium-137 uptake of 51% of the allowable limit. 

3.   The estimated cost of decontamination was about $250,000. 

4.   Two employees received calculated extremity exposures of 125 rems and 
     25 rems, respectively. 

.

                                                            Attachment 1 
                                                            IN 84-28 
                                                            April 17, 1984 
                                                            Page 2 of 3 

Enforcement NRC issued an Order, effective immediately, that suspended the 
license and required the licensee to show cause why the license should not 
be revoked. The licensee's operations were closed down for 53 days. The 
Order was recinded permitting continuation of well-logging: however, 
decontamination is continuing at the main facility. 

.

                                                            Attachment 1 
                                                            IN 84-28 
                                                            April 17, 1984 
                                                            Page 3 of 3 

                                  CASE B 

A well-logging licensee knowingly disregarded the conditions of its license 
and the NRCs regulations resulting in 19 violations of NRC requirements. The 
more significant violations are listed below. 

Violations 

1.   The licensee never leak tested the sealed sources since receipt about 
     three years ago. 

2.   The licensee never purchased any radiation survey instruments to do 
     required surveys. 

3.   The licensee failed to provide workers with personnel dosimeters. 

4.   The licensee's radiation safety officer, failed to conduct audits at 
     any time to assure compliance with NRC requirements. 

5.   The licensee (not having survey instruments) could riot conduct 
     required surveys of areas where licensed materials were stored and 
     could not conduct required surveys at customer well-logging sites. 

6.   The licensee did not have a storage area for radioactive materials 
     that was described in the application for a license. 

7.   Radiation levels were found to read as much as 200 millirems per hour 
     in an unrestricted area (the limit is 100 millirems per 7 consecutive 
     days). 

8.   The licensee did not instruct workers in the fundamentals of basic 
     radiation protection as required. 

9.   The licensee transported sealed sources in unauthorized containers. 

10.  The licensee failed to maintain any records of receipt, transfer or 
     disposal of radioactive materials. 

Causes 

1.   The licensee did not read the license or regulations to determine its 
     responsibilities. 

2.   The licensee did not implement its procedures. 

Consequence 

1.   The licensee exposed its workers to undetermined radiation levels. 

Enforcement 

NRC issued an Order Suspending License and Order to Show Cause why the 
License Should not be Revoked; the Order is still pending. 

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