Information Notice No. 84-28: Recent Serious Violations of NRC Requirements by Well-logging Licensees
SSINS No.: 6835
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.
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-
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
(3) Failure to control operations including failure of licensee employees
to follow approved radiation safety procedures.
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
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
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
E. D. Flack, IE
1. Selected Cases Involving Serious
Violations of NRC Requirements
2. List of Recently Issued IE Information Notices
April 17, 1984
Page 1 of 3
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.
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.
1. Management and employees did not understand the conditions of the
2. Employees were inadequately trained; e.g., they did not know how to
use radiation monitoring instruments properly or how to control
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.
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.
April 17, 1984
Page 3 of 3
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.
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
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
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.
1. The licensee did not read the license or regulations to determine its
2. The licensee did not implement its procedures.
1. The licensee exposed its workers to undetermined radiation levels.
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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