Cook, Jackie

From: Sent: To:

Nelson, Olin A <Olin.Nelson@nov.com> Friday, October 02, 2015 9:24 AM Cook, Jackie

Subject:

Attachments:

[External_Sender] RE: REQUEST FOR ADDmONAL INFORMATION VARCO LP (FKA) TUBOSCOPE VETCO INTERNATIONAL, INC. RENEWAL LICENSE NUMBER 42-02084-02 NRC Add Info Letter RAM License 42 02084 02 Doc 030-06399 Cont 586529 sent Oct 2 2015.pdf; NRC Add Inf Att 1 - Name change only sent Oct 2 2015.pdf; NRC Add Inf Att 2 - Appendix B - Sent Oct 2 2015.pdf

Ms. Jacqueline Cook,

I have provided in the three attachments the additional information you have requested.

Should you need anything else let me know!

Have a great weekend coming up!

Sincerely,

Olin

Olin A. Nelson Tuboscope I ~•Y ~'~~ ... Corporate Assistant RSO Quality & Technical Services Office: (713) 799-5208 Cell: (713) 204-5928 Fax: (713) 799-5125 e-mail: Olin.Nelson@nov.com

From: Cook, Jackie [mailto:Jackie.Cook@nrc.gov] Sent: Thursday, October 01, 2015 7:17 PM To: Nelson, Olin A Subject: REQUEST FOR ADDmONAL INFORMATION VARCO LP (FKA) TUBOSCOPE VETCO INTERNATIONAL, INC. RENEWAL UCENSE NUMBER 42-02084-02 Importance: High

Mr. Olin Nelson:

Attached you will find a deficiency email (request for additional information) which requires your response by Tuesday, October 6, 2015. I apologize for the short turnaround time. You may submit your response by email in pelf format or by fax, whichever is more convenient for you. PUBLIC

D fmmecr:· ·,, '"' 1.'!~'ise Please do not hesitate to contact me if you have any questions regardini{'t'ler~t.

Thanking you in advanced for your understanding and consideration irt'~{ ~~.~h ,., eo,.,. .. ,:..,, ~elated . . D A.7 .::;.~~ .,· I ('

Enjoy the rest of your evening. D Other:

F.c •·-«•~ cp:=--~~lhl6_

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Sincerely,

.M6. :Jacqudin.e ":Ja.cltie" 9>. e.a.o& Senior Health Physicist US Nuclear Regulatory Commission Region IV Division of Nuclear Materials Safety Nuclear Materials Safety Branch B 1600 East Lamar Blvd., Arlington, TX 76011 817-200-1132 (office )/817-200-1263 (fax) Email address: Jackie.Cook@nrc.gov

2

Tuboscope I I 2835 Holmes Road (7705 t) P.O. Box 808 Houston, Texas 77001 USA 7 t 31799-5 t 00

October 2, 2015

United States Nuclear Regulatory Commission Region IV 1600 E. Lamar Boulevard Arlington, Texas 76011-4411

Re: Additional Information for Application Renewal, NRC License No. 42-02084-02 Docket: 030-06399 Control: 586529

Attn: Jacqueline D. Cook

Varco L.P. (FKA) Tuboscope Vetco International Inc. (OBA) Tuboscope, NOV Wellbore Technologies wishes to submit the additional information you requested concerning our license renewal application for radioactive material with the United States Nuclear Regulatory Commission, License No. 42-02084-02.

Item# 1: Concerning the name on ow· License, No Transfer of Control or Changes of Ownership has taken place, only a name change was made for the Tuboscope segment group of our company, we still legally are Varco L.P. (FKA) Tuboscope Vetco International Inc. but our business group name was changed by upper management to Tuboscope, NOV Wellbore Technologies. We apologize for any misunderstanding or confusion concerning our name change (Attachment 1 ).

Item # 2: Concerning Portable Gauge licenses, I have completed and submitted Appendix B ofNUREG-1556, Vol 4 as per yow· request (Attachment 2).

Should additional information be required please contact me at (713) 799-5208 or e-mail Olin.Nelson@nov.com

Sin~~rely,

~Ls> tf U----Olin A. Nelson Corporate Assistant RSO Inspection Specialist Quality and Technical Services

cc: Ed Shaffer NRC Radiation File

NON-Put.· IC Q A.3 $ 1sitivE>-~er11rity Related 0 A.7 Sens1; v~ ...... , 0 Other: ---Reviewer:--¥-· -~-.. od; ·w{~c6

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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION IV 1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

}/4~E C;-//JµC-£ cJAlt.7 Change of Control and/or Change of Ownership

(Includes Change of Name)

10 CFR 30.34(b) states that "no license issued or granted pursuant to the regulations ... nor any right under a license shall be transferred, assigned or in any manner disposed of, either voluntarily or involuntarily, directly or indirectly, through transfer of control of any license to any person, unless the Commission shall ... find that the transfer is in accordance with the provisions of the Act and shall give its consent in writing. Although not specifically addressed by 1 O GFR 30.34, licensees undergoing a name change may also be affected by this regulation.

Control over licensed activities can be construed as the authority to decide when and how a license (licensed material and/or activities) will be used. A change of ownership may be an example of a change of control. The central issue is whether the authority over the license has changed. In all cases, determining whether a change of control has taken place or whether a change is in name only is the Commission's responsibility.

Licensees must notify the Commission when they are undergoing a possible change of control and/or a change of name. While this notification is not required within a certain time frame, NRG needs adequate time to review the submittal to ensure that the transfer is in accordance with the regulations.

In order to process your request for a change of control/ownership and/or a name change, the information on the following pages is required. Our fax number is (817) 200-1188. If you have any questions regarding our discussion or this fax, please contact me. When responding to this fax, please include the license, docket, and mail control numbers, located at the top of this page as well as the following pages. Thank you.

Definitions: Transferee: A transferee is an entity that proposes to purchase or otherwise gain control of an NRG-licensed operation.

Transferor: A transferor is an NRC licensee selling or otherwise giving up control of a licensed operation.

O. Nelson -2-

Information Required for Change of Control and/or Change of Ownership (Includes Change of Name)

Source: NUREG-1556, Volume 15

Please provide the following information concerning changes of control (transferor and/or transferee, as appropriate). If any items are not applicable, state so.

1. Provide a complete description of the transaction (i.e., transfer of stocks or assets, or merger). Indicate whether the name has changed and include the new name. Include the name and telephone number of a licensee contact who NRC may contact if more information is needed.

A. Description of the transaction:

B. [ ] No name change vAllc& L. f! { rlCA) /,,. i/e>S<.1fc VfteO ~+Pe.

~8~ /uil;&e.D. -& 11/ov w~ua1>tt'i. /Zf./l..wt,~i"'S / c;IJM£ .... New name of licensed\ ganization·

No change in contact

[ I New contact:-----------...,----------­

[ ] New telephone number:----------------

2. Describe any changes in personnel or duties that relate to the licensed program. Include training and experience for new personnel.

A. ~No changes in personnel having control over licensed activities.

B.

[ ] Changes is personnel having control over licensed activities (e.g. officers of a corporation):

No changes in personnel named in the license.

[ ] Changes in personnel named in the license (e.g. RSO, AUs) - include training, experience and responsibilities:

0. Nelson -3-

3. Describe, in detail, any changes in the organization, location, facilities, equipment or procedures that relate to the licensed program.

[ ] Organization: ] Equipment:

[ ] Location: [ ] Procedures:

[ ] Facility: ~~applicable Describe the status of the surveillance progam (i.e., surveys, wipe tests, quality control) at the present time and the expected status at the time that control is to be transferred.

A. Description of the status of all surveillance program:

B. Surveillance Items & Records: calibrations, leak tests, surveys, inventories, and accountability requirements will be current at the time of transfer

[ ] Yes [ ] No (explain)

5. Confirm that all records concerning the safe and effective decommissioning of the facility will be transferred to the transferee or to NRC, as appropriate. These records include documentation of surveys of ambient radiation levels and fixed and/or removable contamination, including methods and sensitivity.

Records transferred to: [ ] New licensee [ ] NRC for license termination

,/

~<?t applicable

0. Nelson -4-

Confirm that the transferee will abide by all constraints, conditions, requirements and commitments of the transferor or that the transferee will submit a complete description of the proposed licensed program.

__________________ will abide by all constraints, conditions, (transferee company)

requirements and commitments of---------..,--,-----..,------­(transteror company)

Signaturemtle Transferee Official

date

OR

date

Signaturemtle Transferor Official

[ J Description of proposed licensed program from transferee attached {with signature)

OR

J\[Not applicable (name change only)

/QL d t JfA -=--===== C~rtifying Officer - Signature

Ot Iµ ,4 ~ AIEtS"t9N'. (!,91?~414/E ,.4~)., _/(.S[) Certifying Officer - Typed name and title

/CJ-2-15 Date

Appendix B

Suggested Format for Providing Information Requested in Items 5

Through 11 of NRC Form 313

APPENDIXB

Suggested Format for Providing Information Requested in Items 5 Through 11 of NRC Form 313

Table B.1 Items 5 & 6: Materials To Be Possessed and Proposed Uses

Yes No Radioisotope Manufacturer Quantity Use As Listed on Specify Other or Distributor SSD Certificate Uses Not Listed on

Model No. SSD Certificate

Cobalt-60 Sealed source Not to exceed either Yes [ ] [ ] Not applicable manufacturer or the maximum Specific description distributor and activity per source of the gauge use: [ ] Uses are: model number: or maximum

activity per device (Submit safety Device as specified in analysis supporting manufacturer or Sealed Source and safe use) distributor and Device Registration model number: Certificate

Krypton-85 Sealed source Not to exceed either Yes [ ] [ ] Not applicable manufacturer or the maximum Specific description distributor and activity per source of the gauge use: [ J Uses are: model number: or maximum

activity per device (Submit safety Device as specified in analysis supporting manufacturer or Sealed Source and safe use) distributor and Device Registration

: model number: Certificate

Strontium-90 Sealed source Not to exceed either Yes [ ] [ ] Not applicable manufacturer or the maximum Specific description distributor and activity per source of the gauge use: [ ] Uses are: model number: or maximum

activity per device (Submit safety Device as specified in analysis supporting manufacturer or Sealed Source and safe use) distributor and Device Registration model number: Certificate

>< Cesium-137 Sealed source Not to exceed either Ye~ l'<L" ~ot applicable manufacturer or the maximum Specific description distributor and activity per source of the gauge use: [ ] Uses are:

S°L1.1JM171i'.P model number: or maximum PUS! te

tvt1tf A~ activity per device

~;.·~·; (Su"bm~9 .. afety .

Device as specified in an! tf1s supportmg co.u: manufacturer or Sealed Source and sa e use)

~ distributor and Device Registration NQNPI. ~blC model number: Certificate CJ t. ~ ''" •: ..... ~,,-.,.;.,,~elated

0 A 7~ .

B-1

APPENDIXB

Yes No Radioisotope Manufacturer Quantity Use As Listed on Specify Other or Distributor SSD Certificate Uses Not Listed on

Model No. SSD Certificate

Americium- Sealed source Not to exceed either Yes [ ] [ ] Not applicable 241 manufacturer or the maximum Specific descliption

distributor and activity per source of the gauge use: [ ] Use.~ are: model number: or maximum

activity per device (Submit safety Device as specified in analysis supporting manufacturer or Sealed Source and safe use) distributor and Device Registration model number: Certificate

Other Isotope Sealed source Not to exceed either Yes [] [ ] Not applicable (Specify): manufacturer or the maximum Specific description

distributor and activity per source of the gauge use: [ ] Uses are: model number: or maximum

activity per device (Submit safety Device as specified in analysis supporting manufacture.i: or Sealed Source and safe use) distributor and Device Registration model number: Certificate

Financial Assurance Required a11d Evide11ce of Fil1a11cial Assllra11ce Provided

NUREG - 1556, Vol. 4 B-2

APPENDIXB

Table 8.2 Items 7 Through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal

Item No. and Title Suggested Response Yes Alternative Procedures Attached

7. Individual(s) Before obtaining licensed materials, the proposed RSO rf' [] Responsible For will have successfu11y completed the training described Radiation Safety in Criteria in the section entitled "Individual(s) Program And Their Responsible for Radiation Safety Program and Their Training And Training and Experience - Radiation Safety Officer" in Experience NUREG-1556, Vol. 4, dated October 1998.

7.1 Radiation Safety AND Officer

Name: l=.DW-t.t.11 .Sl)lf/11'.. Before being named as the RSO, future RSOs will have successfully completed the training described in Criteria in the section entitled "Individual(s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer'' in NUREG-1556, Vol. 4, dated October 1998. Within 30 days of naming a new RSO, we will submit the new RSO's name to NRC to include in our license.

•'

7. Individual( s) PROPOSED AUTIIORIZED USERS: if [] Responsible For Radiation Safety Before using licensed materials, authorized users will Program And Their have successfully completed the training described in Training And Criteria in the section entitled, "Authorized Users" in Experience NUREG-1556, Vol. 4, dated October 1998.

7.2 Authorized Users

8. Training for The applica'nt is not required to, and should not, submit Need Not Be Submitted with Individuals Who in is training program, for individuals who in the course Application the Course of of employment are likely to receive occupational doses Employment are of radiation in excess of 1 mSv (100 mrem) in a year Likely to Receive (occupationally exposed workers) and ancillary Occupational Doses personnel, to the NRC for review during the licensing ofRadiation in phase. Excess of 1 mSv

. (100 mrem) in a Year (Occupationally Exposed Workers) and Ancillary Personnel

.

B-3 NUREG - 1556, Vol. 4

APPENDJXB

Item No. and Title

9. Facilities and Equipment

10. Radiation Safety Program - Audit Program

10. Radiation Safety Program - Survey Instruments

10. Radiation Safety Program - Material Receipt and Accountability

10. Radiation Safety Program -Occupational Dosimetry

NUREG- 1556, Vol. 4

Suggested Response Yes Alternative Procedures Attached

We will ensure that the location of each fixed gauge [] meets the Criteria in the section entitled "Facilities and Equipment" in NUREG-1556, Vol. 4, dated October 1998.

The applicant is not required to, and should not, submit Need Not Be Submitted with its audit program to the NRC for review during the Application licensing phase.

~

Surveys pursuant to 10 CFR 20.1501 will be performed )1' [ J by a person specifically authorized by the NRC or an Agreement State to perfonn these surveys.

OR

We will use instruments that meet the Criteria in the section entitled "Radiation Safety Program -Instruments," in NUREG-1556, Vol. 4, dated August 1998, and 011e of the following:

Each survey meter will be calibrated by the manufacturer or other person authorized by the NRC or an Agreement State to perform survey meter calibrations.

OR

We will implement the model survey instrument calibration program in Appendix I to NUREG-1556, Vol. 4, dated October 1998.

Physical inventories will be conducted at intervals not H ,..... [] to exceed 6 months or at other intervals approved by the NRC, to account for all sealed sources and devices received and possessed under the license.

We will perform a prospective evaluation I·Y [] demonstrating that unmonitored individuals are not likely to receive, in one year, a radiation dose in excess of 10% of the allowable limits in 10 CFR Part 20 or we will provide dosimetiy that meets the Criteria in the section entitled "Radiation Safety Program -Occupational Dosimetiy," in NUREG-1556, Vol. 4, dated October 1998. DtlDI I~

d '"'eoase ma, .......... J..ae

NO~l-PUr •(~

CJ /.\.~ ,:,er~;r.!·1p.C: :'r" .. :tv t"r·•~!ed 0 A.7 Sensitrvt: !• . .1·

0 Otl'lcr: B-4 Re·~·--r.~

APPENDIXB

Item No. and Title Suggested Response Yes Alternative Procedures Attached

10. Radiation Safety The applicant is not required to submit a response to Need Not Be Submitted with Program - Public the public dose section during the licensing phase. Application Dose However, during NRC inspections, licensees must be

able to provide documentation demonstrating, by measurement or calculation, that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation docs not exceed the annual limit for individual members of the public.

10. Radiation Safety If the gauge meets one or more of the safety conditions £1' [] Program- specified in "Discussion,"in the section entitled Operating & "Radiation Safety Program-Operating Emergency Emergency ProcedW'es," in NUREG 1556, Vol 4, dated August Procedures 1998 state the following:

<5't.1>8ll'ldld wilt/ .hf( Operating and emergency procedures will be

developed, implemented, maintained, and distributed, and will meet the Criteria in the section entitled "Radiation Safety Program - Operating and Emergency Procedures," in NUREG,.1556, Vol. 4, dated August 1998.

For each gauge requested that does not meet one or [ J Procedures more of the safety conditions specified in "Discussion," Attached in the sect\on entitled "Radiation Safety Program-Operating Emergency Procedures," in NUREG 1556, Vol. 4, dated August 1998 provide your operating, emergency and lock-out (if applicable) procedures to NRC for review.

10. Radiation Safety Leak tests will be performed at intervals approved by W' [] Program - Leak the NRC or an Agreement State and specified in the Test Sealed Source and Device Registration Certificate.

Leak tests will be performed by an organization authorized by NRC or an Agreement State to provide leak testing services for other licensees or using a leak test kit supplied by an organization authorized by NRC · or an Agreement State to provide leak test kits to other licensees and according to the kit supplier's instructions.

OR

We will implement the model leak test program [] published in Appendix M to NUREG-1556, Vol. 4, dated October 1998.

B-5 NUREG- 1556, Vol. 4

APPENDIXB

Item No. and Title Suggested Response Yes Alternative Procedures Attached

10. Radiation Safety ROUTThl'E MAINTENANCE r []

Program- We will implement and maintain procedures for routine Maintenance maintenance of our fixed gauges according to each

manufacturer's or distributor's written recommendations and instructions.

S-1<6"' t 1T~ wrTrl 11-f/ NON-ROUTINE MAINTENANCE OPERATIONS .[1 []The

The gauge manufacturer, distributor or other person information aut11orized by NRC or an Agreement State will perform listed in non-routine operations such as installation, initial AppendixN radiation survey, repair, and maintenance of supporting a components related to the radiological safety of the request to gauge, gauge relocation, replacement, and disposal of perform sealed source.~, alignment, or removal of a gauge from non~routing service. operations

in-house is attached

10. Radiation Safety The applicant is not required to submit its response to Need Not Be Submitted with Program - transportation during the licensing process; this issue Application Transportation will be reviewed during inspection. However, the

licensee should develop, implement, and maintain transportation procedures according to NRC and DOT regulations.

10. Radiation Safety This is not applicable to om· program. We will not use vrNot Program - Fixed fixed gauges at temporary job sites. Applicable Gauges Used at Temporary Job OR Sites

We will develop, implement, maintain and distribute [] [] procedures that meet the Criteria in the section entitled "Radiation Safety Program - Fixed Gauges Used at Temporary Job Sites" in NUREG-1556, Vol. 4, dated October 1998.

10. Radiation Safety The applicant is not required to submit a response to Need Not Be Submitted with Program - minimization of contamination if the applicant's Application Minimization of responses meet the criteria for the following sections: Contamination Radioactive Material - Sealed Sources and Devices,

Facilities and Equipment, Radiation Safety Program -Operating and Emergency Procedures, Radiation Safety Program - Leak Testing, and Waste Management -Gauge Transfer and Disposal.

NUREG - 1556, Vol. 4 B-6

Item No. and Title

11. Waste Management - Gauge Disposal & Transfer

APPENDIXB

Suggested Response Yes Alternative Procedures Attached

111e applicant is not required to submit a response to Need Not Be Submitted with waste management during the licensing procc.c;s. Application However, tl1e licensee should develop, implement, and maintain gauge transfer and disposal procedures in its radiation protection program.

B-7

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