On February 8, 2000, a Notice of Violation and Proposed Imposition of Civil Penalties was issued for a SL III problem involving (1) the failure to conduct radiation surveys at well sites; and (2) the failure to maintain complete and accurate records of these surveys, as required by License Condition 21 and 10 CFR 30.9; and a SL III violation involving the failure of the Radiation Safety Officer (RSO) to provide adequate oversight concerning the completion of radiation surveys and radiation survey records as required by License Condition 21.