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Program-Specific Guidance About Well Logging, Tracer, and Field Flood Study Licenses - Final Report (NUREG-1556, Vol. 14)On this page: Download complete document The following links on this page are to documents in Adobe Portable Document Format (PDF). See our Plugins, Viewers, and Other Tools page for more information. For successful viewing of PDF documents on our site please be sure to use the latest version of Adobe. Table of Contents
Publication Information[ Next | Top of file ] Manuscript Completed: June 2000 Prepared by Division of Industrial and Medical Nuclear Safety Abstract[ Prev | Next | Top of file ] As part of its redesign of the materials licensing process, NRC is consolidating and updating numerous guidance documents into a single comprehensive repository as described in NUREG-1539, "Methodology and Findings of the NRC's Materials Licensing Process Redesign," dated April 1996, and draft NUREG-1541, "Process and Design for Consolidating and Updating Materials Licensing Guidance," dated April 1996. NUREG-1556, Vol. 14, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Well Logging, Tracer, and Field Flood Study Licenses," dated June 2000, is the fourteenth program-specific guidance document developed for the new process and is intended for use by applicants, licensees, and NRC staff, and will also be available to Agreement States. This document combines and updates the guidance found in Draft Regulatory Guide, "Guide for the Preparation of Applications for the Use of Radioactive Materials in Well Logging Operations," dated July 1987. This report takes a more risk-informed, performance-based approach to licensing of well logging, tracer, and field flood study operations, and it reduces the information (amount and level of detail) needed to support an application for these activities. Figures[ Prev | Next | Top of file ] Figure 2.1 U.S. Map Figure 8.1 Location of Use Figure 8.2 Examples of Sealed Sources Used In Well Logging Operations Figure 8.3 Methods of Certification of Financial Assurance for Decommissioning Figure 8.4 Types of Records That Must Be Maintained for Decommissioning Figure 8.5 RSO Responsibilities - Typical duties and responsibilities of the RSO Figure 8.6 Features of a Typical Source Abandonment Figure 8.7 Permanent Identification Plaque Figure 8.8 Types of Surveys Figure 8.9 Material Receipt and Accountability Figure 8.10 Annual Dose Limits for Occupationally Exposed Adults Figure 8.11 Calculating the Annual Dose to an Individual Member of the Public Figure 8.12 Maintenance, Cleaning, and O-Ring Replacement Figure 8.13 Transportation Figure 8.14 Transport Container Figure 8.15 Personnel Surveys Figure 8.16 Drill-to-stop Well Logging Operations Figure 8.17 Singly Encapsulated ECS Sealed Source Figure P.1 Bird's Eye View of Office Figure P.2 Downhole Storage Array Foreword[ Prev | Next | Top of file ] The United States Nuclear Regulatory Commission (NRC) is using Business Process Redesign (BPR) techniques to redesign its materials licensing process. This effort is described in NUREG-1539, "Methodology and Findings of the NRC's Materials Licensing Process Redesign," dated April 1996. A critical element of the new process is consolidating and updating numerous guidance documents into a NUREG series of reports. Below is a list of volumes currently included in the NUREG-1556 series:
The current document, NUREG-1556, Vol. 14, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Well Logging, Tracer, and Field Flood Study Licenses," dated June 2000, is the fourteenth program-specific guidance document developed for the new process. It is intended for use by applicants, licensees, NRC license reviewers, and other NRC personnel. It combines and updates the guidance for applicants and licensees previously found in a working draft of a "Guide for the Preparation of Applications for the Use of Radioactive Materials in Well Logging Operations," dated July 1987. In addition, this report also contains pertinent information found in NUREG Reports, Regulations, Guides, Policy and Guidance Directories, Information Notices, and other documents as listed in Appendix A. This report takes a risk-informed, performance-based approach to licensing well logging, tracer, and field flood study applications. It reduces the amount of information needed from an applicant seeking to possess and use radioactive materials in these applications. A team composed of NRC staff from Headquarters, the Regional Offices, and Agreement State representatives from Louisiana and Texas drafted this document, drawing on their collective experience in radiation safety in general and as specifically applied to well logging, tracer, and field flood study operations. A representative of NRC's Office of the General Counsel provided a legal perspective. This document presents a step in the transition from the current paper-based process to the new electronic process. It is available on the Internet at the following address: <http://www.nrc.gov/NRC/NUREGS/SR1556/V14/index.html>. This document is not a substitute for NRC regulations, and compliance is not required. The approaches and methods described in this report are provided for information only. Methods and solutions different from those described in this report will be acceptable if they provide a basis for the staff to make the determination needed to issue or continue a license. _________________________ Acknowledgments[ Prev | Next | Top of file ] The writing team thanks the individuals listed below for assisting in the development and review of this report. All participants provided valuable insights, observations, and recommendations. The team thanks Dianne Geshen, Rolonda Jackson, Tamra King, D.W. Benedict Llewellyn, and Agi Seaton, of Computer Sciences Corporation. Additionally, the team would like to acknowledge and thank Dwaine Brown of Halliburton Energy Services, Ken Turner of Schlumberger Technology, and Phil Stoehr of Western Atlas International, for providing photographs, graphics, text review, and technical input. The Participants[ Prev | Next | Top of file ] Brown, Carrie Abbreviations[ Prev | Next | Top of file ]
1 Purpose of Report[ Prev | Next | Top of file ] Byproduct material, as defined in 10 CFR 30.4, depleted uranium, as defined in 10 CFR 40.4, and special nuclear material, as defined in 10 CFR 70.4, are used for a variety of purposes to include: well logging and tracer applications involving both single or multiple well bores; conventional well logging and tracer operations; and, in some cases, research and development. Examples include the following applications:
This report provides guidance to an applicant in preparing a well logging, tracer, and field flood study license application as well as NRC criteria for evaluating the corresponding license application. It identifies the information needed to complete NRC Form 313 (Appendix B), Application for Material License, for the use of sealed byproduct materials in well logging, and unsealed byproduct materials in tracer and field flood study applications. The information collection requirements in 10 CFR Parts 19, 20, 21,30, 32, 39, 40, 51, 70, and NRC Form 313 have been approved under the Office of Management and Budget (OMB) Control Numbers 3150-0044, 3150-014, 3150-35, 3150-0130, 3150-0017, 3150-0001, 3150-0130, 3150-0020, 3150-0021, 3150-0009, and 3150-0120. The format within this document for each item of technical information is as follows:
Notes and References are self-explanatory. NRC Form 313 does not have sufficient space for applicants to provide full responses to Items 5 through 11; as indicated on the form, the answers to those items are to be provided on separate sheets of paper and submitted with the completed NRC Form 313. For the convenience of applicants and for streamlined handling of applications for well logging, tracer, or field flood study licenses, use Appendix C to provide supporting information, attach it to NRC Form 313, and submit it to NRC. Appendix D is a checklist that NRC staff use to review applications and
that applicants can use to check for completeness. Appendix E is a sample
well logging license, containing the conditions most often found on these
licenses, although not all licenses will have all conditions. Appendices
F through V contain additional information on various radiation safety
topics.
In this document, "dose" or "radiation absorbed dose" includes: dose equivalent; effective dose equivalent (EDE); committed dose equivalent (CDE); committed effective dose equivalent (CEDE); or total effective dose equivalent (TEDE). These terms are defined in 10 CFR Part 20. Rem, and its SI [Système International-(international units)] equivalent Sievert [1 rem = 0.01 Sievert (Sv)], is used to describe units of radiation exposure or dose. 2 Agreement States[ Prev | Next | Top of file ] Certain states, called Agreement States (see Figure 2.1), have entered into agreements with the NRC that give them the authority to license and inspect byproduct, source, or special nuclear materials used or possessed within their borders. Any applicant, other than a Federal Agency, who wishes to possess or use licensed material in one of these Agreement States needs to contact the responsible officials in that State for guidance on preparing an application; file these applications with State officials, not with the NRC. In general, NRC's materials licensees who wish to conduct operations under reciprocity at temporary jobsites in an Agreement State should contact that State's radiation control program office for information about State regulations. To ensure compliance with Agreement State reciprocity requirements, a licensee should request authorization well in advance of scheduled use. Under the provisions of 10 CFR 150.20, NRC can recognize and grant a general license to Agreement State licensees. This general license authorization allows Agreement State licensees to conduct licensed operations identified on the Agreement State license in Non-Agreement States; areas of exclusive Federal jurisdiction within Agreement States; and offshore waters provided:
In the special situation of work at Federally-controlled sites in Agreement States, it is necessary to know the jurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. As indicated above, NRC has regulatory authority only over land determined to be "exclusive Federal jurisdiction," while the Agreement State has jurisdiction over non-exclusive Federal jurisdiction land. Licensees are responsible for finding out, in advance, the jurisdictional status of the specific areas where they plan to conduct licensed operations. NRC recommends that licensees ask their local contact for the Federal Agency controlling the site (e.g., contract officer, base environmental health officer, district office staff) to help determine the jurisdictional status of the land and to provide the information in writing, so that licensees can comply with NRC or Agreement State regulatory requirements, as appropriate. Additional guidance on determining jurisdictional status is found in All Agreement States Letter, SP-96-022, dated February 16, 1996, which is available from NRC upon request. Table 2.1 provides a quick way to check on which Agency has regulatory authority. Table 2.1 Who Regulates the Activity?
Figure 2.1 U.S. Map. Location of NRC Offices and Agreement States. Reference: A current list of Agreement States (including names, addresses, and telephone numbers of responsible officials) may be obtained upon request from NRC's Regional Offices. Or visit NRC's Home Page <http://www.nrc.gov>, choose "Nuclear Materials," then "Review of State Radiation Control Program Query Form," and then "Directories." The All Agreement States Letter, SP-96-022, dated February 16, 1996, is available by contacting NRC's Office of State Programs; call NRC's toll free number (800) 368-5642, and then ask for extension 415-3340. Or visit NRC's Home Page <http://www.nrc.gov>, choose "Nuclear Materials," then choose "Review of State Radiation Control Program Query Form" and follow the directions for submitting a query for "SP-96-022." 3 Management Responsibility[ Prev | Next | Top of file ] The NRC recognizes that effective radiation safety program management is vital to achieving safe and compliant operations. NRC believes that consistent compliance with its regulations provides reasonable assurance that licensed activities will be conducted safely. NRC also believes that effective management will result in increased safety and compliance.
To ensure adequate management involvement, a management representative must sign the submitted application acknowledging management's commitments and responsibility for the following:
For information on NRC inspection, investigation, enforcement, and other compliance programs, see the current version of "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, and Manual Chapter (MC) 87113, Appendix G, "Suggested Well Logging, Tracer, and Field Flood Study Audit Checklist." NUREG-1600 is available electronically at <http://www.nrc.gov/OE>. For hard copies of NUREG-1600 and MC 87113, see the Notice of Availability (on the inside front cover of this report). 4 Applicable Regulations[ Prev | Next | Top of file ] It is the applicant's or licensee's responsibility to have up-to-date copies of applicable regulations, read them, understand them, and comply with each applicable regulation. The following Parts of 10 CFR Chapter I contain regulations applicable to well logging, tracer, and field flood study licenses:
To request copies of the above documents, call GPO's order desk in Washington, DC at (202) 512-1800. Order the two-volume bound version of Title 10, Code of Federal Regulations, Parts 0-50 and 51-199 from the GPO, Superintendent of Documents, Post Office Box 371954, Pittsburgh, Pennsylvania 15250-7954. You may also contact the GPO electronically at <http://www.gpo.gov>. Additionally, Title 10, Code of Federal Regulations, Parts 0-50 and 51-199, is available electronically from NRC's reference library at <http://www.nrc.gov>. Individuals may request single hard copies of the above documents from NRC's Regional Offices (see Figure 2.1 for addresses and telephone numbers). Note that NRC publishes amendments to its regulations in the Federal Register. 5 How to File[ Prev | Next | Top of file ] 5.1 Paper Application[ Prev | Next | Top of file ] Applicants for a materials license should do the following:
All license applications will be available for review by the general public in NRC's Public Document Rooms. If it is necessary to submit proprietary information, follow the procedure in 10 CFR 2.790. Failure to follow this procedure could result in disclosure of the proprietary information to the public or substantial delays in processing the application. Employee personal information, i.e., home address, home telephone number, Social Security Number, date of birth, and radiation dose information, should not be submitted unless specifically requested by NRC.
As explained in the "Foreword," NRC's new licensing process will be faster and more efficient, in part, through acceptance and processing of electronic applications at some future date. NRC will continue to accept paper applications; however, these will be scanned and converted to an electronic format. To ensure a smooth transition, applicants are requested to follow these suggestions:
5.2 Electronic Application[ Prev | Next | Top of file ] As the electronic licensing process develops, it is anticipated that NRC may provide mechanisms for filing applications via diskettes, CD-ROM, and the Internet. Additional filing instructions will be provided as these new mechanisms become available. The existing paper process will be used until such time. 6 Where to File[ Prev | Next | Top of file ] Applicants wishing to possess or use licensed material in any State or U. S. Territory or possession subject to NRC jurisdiction must file an application with the NRC Regional Office for the locale in which the material will be possessed and/or used. Figure 2.1 shows NRC's four Regional Offices and their respective areas for licensing purposes and identifies Agreement States. In general, applicants wishing to possess or use licensed material in Agreement States must file an application with the Agreement State, not NRC. However, if work will be conducted at Federally-controlled sites in Agreement States, applicants must first determine the jurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. See the section on "Agreement States" for additional information. 7 License Fees[ Prev | Next | Top of file ] Each application for which a fee is specified must be accompanied by the appropriate fee. Refer to 10 CFR 170.31 to determine the amount of the fee. NRC will not issue the new license prior to fee receipt. An application for a new license or an amendment to an existing license requesting authorization to conduct field flood studies requires that an environmental assessment be performed. Fees for a licensing action that requires an environmental assessment are charged at an hourly rate. Full cost fee recovery is assessed by the professional staff time expended, as described in footnote e.3. to 10 CFR 170.31. Once technical review begins, no fees will be refunded; application fees will be charged regardless of NRC's disposition of an application or the withdrawal of an application. Most NRC licensees are also subject to annual fees; refer to 10 CFR 171.16. Consult 10 CFR 171.11 for additional information on exemptions from annual fees and 10 CFR 171.16(c) on reduced annual fees for licensees that qualify as "small entities." Direct all questions about NRC's fees or completion of Item 12 of NRC Form 313 (Appendix B) to the Office of the Chief Financial Officer (OCFO) at NRC Headquarters in Rockville, Maryland, (301) 415-7554. You may also call NRC's toll free number, (800) 368-5642, and then ask for extension 415-7554. 8 Contents of an Application[ Prev | Next | Top of file ] The following comments apply to the indicated items on NRC Form 313 (Appendix B). 8.1 Item 1: License Action Type[ Prev | Next | Top of file ] THIS IS AN APPLICATION FOR (Check appropriate item):
Check box A for a new license request. Check box B for an amendment to an existing license, and provide license number. Check box C for a renewal of an existing license, and provide license number. 8.2 Item 2: Applicant's Name and Mailing Address[ Prev | Next | Top of file ] Response from Applicant: List the legal name of the applicant's corporation or other legal entity with direct control over use of the radioactive material; a division or department within a legal entity may not be a licensee. An individual may be designated as the applicant only if the individual is acting in a private capacity and the use of the radioactive material is not connected with employment in a corporation or other legal entity. Provide the mailing address where correspondence should be sent. A Post Office box or drawer number is an acceptable mailing address. Notify NRC of changes in mailing address; these changes do not require a fee. Note: NRC must be notified before control of the license is transferred or when bankruptcy proceedings have been initiated. See below for more details. NRC Information Notice (IN) 97-30, "Control of Licensed Material during Reorganizations, Employee-Management Disagreements, and Financial Crises," dated June 3, 1997, discusses the potential for the security and control of licensed material to be compromised during periods of organizational instability. Timely Notification of Transfer of ControlRegulations: 10 CFR 30.34(b). Criteria: Licensees must provide full information and obtain NRC's prior written consent before transferring control of the license, or, as some licensees call it, "transferring the license." Discussion: Transfer of control may be the result of mergers, buyouts, or majority stock transfers. Although it is not NRC's intent to interfere with the business decisions of licensees, it is necessary for licensees to obtain prior NRC written consent before the transaction is finalized. This is to ensure the following:
Response from Applicant: None from an applicant for a new license; Appendix H, excerpted from IN 89-25 (Rev. 1), "Unauthorized Transfer of Ownership or Control of Licensed Activities," dated December 7, 1994, identifies the information to be provided about transferring control. Notification of Bankruptcy ProceedingsRegulation: 10 CFR 30.34(h). Criteria: Immediately (within 24 hours) following filing of voluntary or involuntary petition for bankruptcy for or against a licensee, the licensee must notify the appropriate NRC Regional Administrator, in writing, identifying the bankruptcy court in which the petition was filed and the date of filing. Discussion: NRC must be cognizant when licensees are in bankruptcy proceedings in order to review the licensee's material accountability, to ensure that the licensee prevents access to licensed material by unauthorized personnel, and to allow NRC the opportunity to assess potential public health and safety concerns (e.g., contaminated facility). NRC, in turn, shares its findings with other involved entities (e.g., trustees), so that outstanding health and safety issues can be resolved before bankruptcy actions are completed.
Response from Applicant: None at time of application for a new license. Licensees must notify NRC within 24 hours of filing a bankruptcy petition. References: See the Notice of Availability (on the inside front cover of this report) to obtain copies of Policy and Guidance Directive PG 8-11, "NMSS Procedures for Reviewing Declarations of Bankruptcy" (dated August 8, 1996) and Inspection Procedure (IP) 87103, "Inspection of Material Licensees Involved in an Incident or Bankruptcy Filing." INs are available in the "Reference Library" on NRC's Home Page at <http://www.nrc.gov>. For hard copies, also see the Notice of Availability (on the inside front cover of this report). 8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed[ Prev | Next | Top of file ] Specify the street address, city, and state or other descriptive address (e.g., on Highway 10, 5 miles east of the intersection of Highway 10 and State Route 234, Anytown, State) for each facility at which licensed material will be used, stored, or dispatched, and list the specific activities to be conducted at each location. Field stations are locations where licensed materials are stored or used and equipment is dispatched to temporary job sites. As illustrated in Fig. 8.1., a Post Office Box or Drawer address is not acceptable. Figure 8.1 Location of Use. An acceptable location of use specifies street address, city, state, and ZIP code and does not include a Post Office box or drawer number.
8.4 Item 4: Person to Be Contacted about this Application[ Prev | Next | Top of file ] Identify the name and title of the individual who can answer questions about the application and include his or her telephone number. This is typically the proposed RSO or a principal user of radioactive materials, unless the applicant has named a different person as the contact. The NRC will contact this individual if there are questions about the application. Notify NRC if the contact person or the contact person's telephone number changes so that NRC can contact the applicant or licensee in the future with questions, concerns, or information. This notice is for "information only" and does not require a license amendment or a fee.
8.5 Item 5: Radioactive Material[ Prev | Next | Top of file ] Regulations: 10 CFR 30.18, 10 CFR 30.32(g), 10 CFR 30.32(i), 10 CFR 30.33(a)(2), 10 CFR 32.210, 10 CFR 39.13. Criteria: An application for a license will be approved if the requirements of 10 CFR 30.33 and 10 CFR 39.13 are met. In addition, licensees will be authorized to possess and use only those sealed sources and devices that are specifically approved or registered by NRC or an Agreement State. Discussion: The applicant should list each requested radioisotope by its element name and mass number (e.g., cesium-137), specify whether the material will be acquired and used in unsealed or sealed form, and list the maximum amount requested. Table 8.1 below provides examples of the different types of radioactive materials. Some, not all, are addressed in this report. Note: Additional safety equipment and precautions are required when handling and using unsealed free-form volatile radioactive materials. (Volatile means that a liquid becomes a gas at a relatively low temperature when the sealed container within which the liquid is stored is left open to the environment.) Table 8.1 Types of Radioactive Materials
* Both accelerator and reactor produced Possession limits should be specified in megabecquerels (MBq) [millicuries (mCi)] or gigabecquerels (GBq) [curies (Ci)] for each radioisotope. Applicants should include in the possession limits requested the total estimated inventory, including licensed material in storage and maintained as radioactive waste. The requested possession limits for any radioisotope should be commensurate with the applicant's needs and facilities for safe handling. Applicants, when establishing their possession limits for radioactive materials with half lives greater than 120 days, should review the requirements for submitting a certification for financial assurance for decommissioning. These requirements are discussed in the Section on Financial Assurance and Decommissioning and in Appendix I. Applicants requesting an authorization to use volatile radioactive material must provide appropriate facilities, handling equipment, and radiation safety procedures for using such material.
For non-federal licensees, requests to license naturally-occurring radioactive material (NORM) and accelerator-produced radioactive material should be made to the appropriate State regulatory Agency. NRC does not regulate NORM or accelerator-produced radioactive material. Consult with the proposed supplier, manufacturer, or distributor to ensure that requested sources and devices, where applicable, are compatible with and conform to the sealed source and device designations registered with NRC or an Agreement State. Licensees may not make any changes to the sealed source, device, or source/device combination that would alter the description or specifications from those indicated in the respective registration certificates, without obtaining NRC's prior permission in a license amendment. To ensure that applicants use sources and devices according to the registration certificates, they may want to get a copy of the certificate and review it or discuss it with the manufacturer. Response from Applicant:
8.5.1 Sealed Sources and DevicesRegulation: 10 FR 30.32(g), 10 CFR 39.41. Criteria: Any sealed source used for well logging that contains more than 3.7 MBq (100 microcuries) of byproduct or special nuclear material and is used downhole in well bores of gas wells, oil wells, or in mineral deposits, must satisfy one of the following criteria:
The primary difference between the two standards is that the vibration requirement in 10 CFR 39.41 is not included in the USASI standard. This vibration test was included to ensure consistency between the United States standard and international standards. Discussion: NRC or an Agreement State performs a safety evaluation of sealed sources before authorizing a manufacturer or distributor to distribute sources to specific licensees. The safety evaluation is documented in a Sealed Source and Device (SSD) Registration Certificate. Some examples of sealed sources used in well logging applications are shown in Figure 8.2. Figure 8.2 Examples of Sealed Sources Used In Well Logging Operations. Applicants must provide the manufacturer's name and model number for each requested sealed source. This information is necessary to ensure that each sealed source requested in the application is evaluated and approved by NRC or an Agreement State, included in an SSD Registration Certificate, approved under the provisions granted by NRC in 10 CFR 39.41, or is identified on an NRC or Agreement State license and authorized for well logging. Applicants should consult with the proposed suppliers or vendors to ensure that sealed sources, and if applicable, devices, conform to information contained in SSD Registration Certificates. Licensees should ensure that their uses of sealed sources, and, if applicable, associated equipment are in accordance with Registration Certificates. Applicants may elect to obtain copies of applicable SSD Registration Certificates for future reference. For sealed sources used for well logging applications, NRC licenses only authorize possession of individual sealed sources approved for well logging. To allow flexibility, licenses do not authorize specific sealed source/well logging tool combinations. Applicants should consult with the manufacturer of the sealed sources before using associated equipment, e.g., well logging tools, transport containers, handling tools, etc. Conferring with the vendor or manufacturer before use helps ensure that the associated equipment selected is compatible with sealed sources requested in the application. Response from Applicant:
OR
Note: Information on SSD registration certificates is available electronically at <http://www.nrc.gov>; select the "Library" section. The current version of NUREG-1556, Vol. 3, "Consolidated Guidance About Materials Licenses: Applications for Sealed Source and Device Evaluation and Registration" provides specific information about the SSD registration process. This document is also available electronically at the above internet location, or for a paper copy of NUREG-1556, Vol. 3, see the Notice of Availability (on the inside front cover of this report). For individual copies of SSD registration sheets, an applicant may contact the Registration Assistant by calling NRC's toll free number, (800) 368-5642, and then asking for extension 415-7217. 8.5.2 Unsealed (Tracer) Radioactive MaterialRegulation: 10 CFR 30.32(i), 10 CFR 30.33, 10 CFR 30.72, 10 CFR 39.2, 10 CFR 39.13. Criteria: An application for a license will be approved if the requirements of 10 CFR 30.33 and 10 CFR 39.13 are satisfied. Discussion: Each authorized radioisotope tracer is listed on the NRC license by its element name, chemical and/or physical form, total possession limit, and the maximum amount of each radioisotope (identified by physical or chemical form) used in each type of tracer study requested. The following definitions are provided to clarify single and multiple well tracer operations addressed in this report.
See the sample license in Appendix E. Table 8.2 identifies the types of byproduct material used in tracer and field flood study applications covered by this report. Table 8.2 Types of Radioactive Materials Used in Field Flood Studies and Single Well Tracer Operations
Response from Applicant:
8.5.3 Financial Assurance and Record Keeping for DecommissioningRegulations: 10 CFR 30.34(b), 10 CFR 30.35. Criteria: Financial assurance is not required by most well logging or tracer licensees; however, each licensee is obligated to maintain, in an identified location, decommissioning records related to facilities where licensed material is used, stored, or dispatched. Decommissioning records described above are not required at temporary jobsites. Pursuant to 10 CFR 30.35(g), when terminating the license, licensees must transfer records important to decommissioning to either of the following:
Discussion: NRC regulations, when applicable, require the applicant to provide Certification of Financial Assurance (F/A) or a Decommissioning Funding Plan (DFP). This is to provide reasonable assurance that, after the technical and environmental components of decommissioning are carried out, unrestricted use of the facilities is possible at the termination of licensed activities. NRC's primary objective is to ensure that decommissioning will be carried out with minimum impact on the health and safety of the public, occupationally exposed individuals, and the environment (53 FR 24018). These requirements specify that a licensee either set aside funds for decommissioning activities or provide a guarantee through a third party that funds will be available (see Figure 8.3). Before a license is issued, applicants are required to submit F/A or a DFP when requesting authorization to possess any sealed or unsealed radioactive material with half life (T1/2) greater than 120 days exceeding certain the limits. Criteria for determining whether an applicant must submit a DFP or has an option of submitting either a DFP or F/A are described in 10 CFR 30.35.
Figure 8.3 Methods of Certification of Financial Assurance for Decommissioning. Table 8.3 provides a partial list of sealed and unsealed radioisotopes with T1/2 > 120 days with the corresponding limits in excess of which an F/A or a DFP is required. However, it is NRC's experience that most well logging, tracer, and field flood study licensees use only a few of these radioisotopes. The most frequently used radioisotopes requiring financial assurance in unsealed form are hydrogen-3, carbon-14, and silver-110 metastable, and for sealed sources, americium-241. Radioisotopes with T1/2 > 120 days are listed in Column 1. Column 2 lists the corresponding possession limits of radioisotopes requiring F/A. Column 3 lists the corresponding possession limits of unsealed radioisotopes requiring the submittal of a DFP. These limits apply when only one of these radioisotopes is possessed. Applicants can use the data from Table 8.3 or the method given in Appendix I to determine if F/A is required and the amount that is required when more than one of these radioisotopes is requested. Table 8.3 Commonly Used Licensed Materials Requiring Financial Assurance/Decommissioning Funding Plan
*1 millicurie = 37 MBq Regulatory Guide (RG) 3.66, "Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," dated June 1990, contains approved wording for each mechanism authorized by the regulation to guarantee or secure funds, except for the Statement of Intent for Government licensees. Record Keeping The requirements for maintaining records important to decommissioning, including the type of information required, are stated in 10 CFR 30.35(g). All licensees are required to maintain these records in an identified location until the site is released for unrestricted use (see Figure 8.4). In the event that the licensed activities are transferred to another person or entity, these records shall be transferred to the new licensee before transferring the licensed activities. The new licensee is responsible for maintaining these records until the license is terminated. When the license is terminated, these records shall be transferred to NRC. Figure 8.4 Types of Records That Must Be Maintained
for Decommissioning.
Response from Applicants: No response is needed from most applicants. If F/A or a DFP is required, submit the required documents described in Regulatory Guide 3.66. Note: Licensees must maintain permanent records on locations where licensed materials are used or stored while the license is in force. These permanent records are important for making future determinations about the release of these locations for unrestricted use (e.g., before the license is terminated). Acceptable permanent records include sketches, written descriptions of specific locations where radioactive material is used or stored, and records of any leaking sealed sources, tracer material spills, contaminated waste storage areas, or other unusual occurrences involving the spread of contamination in or around the licensee's facilities or field stations. Permanent decommissioning records described above are not required for temporary job site locations. References: See the Notice of Availability (on the inside front cover of this report) to obtain copies of RG 3.66 and Policy and Guidance Directive FC 90-2 (Rev. 1), "Standard Review Plan for Evaluating Compliance with Decommissioning Requirements," dated April 30, 1991. 8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used[ Prev | Next | Top of file ] Regulations: 10 CFR 30.33(a)(1), 10 CFR 39.13, 10 CFR 39.41, 10 CFR 39.45, 10 CFR 39.47, 10 CFR 39.49, 10 CFR 39.51, 10 CFR 39.63, 10 CFR 51.21. Criteria: Radioisotopes and sealed sources requested in the application must be used for purposes authorized by the Atomic Energy Act of 1954, as amended. The licensee must specify the purpose for which each radioisotope or sealed source listed in Item 5 is to be used, as well as specifying the type of wells in which each type of material will be used (e.g., oil, gas, mineral, geophysical, etc.). In addition, the licensee should describe the type of mineral or geophysical logging to be conducted, e.g., coal, salt domes, etc. Sealed sources used in well logging devices should be used only for the purposes for which they were designed, in accordance with the manufacturer's written recommendations and instructions, as specified in an approved SSD Registration Certificate, and as authorized on an NRC or Agreement State license. The licensee shall specify the manufacturer and model number of each device. Discussion: The applicant's request to use sealed sources and radioisotopes in well logging, tracer, and field flood studies should clearly specify the purpose for which each type of material will be used. Applicants should include a description that is sufficiently detailed to allow NRC to determine the potential for exposure to occupationally exposed individuals and/or members of the public. Note: Traditionally, only Federal or State authorities have been authorized to conduct logging in potable water wells in fresh water aquifers. Approval to conduct these operations requires that applicants justify the need and to provide assurance that sealed sources, in case of accidental loss in a potable water zone, could be recovered. Applicants requesting authorization to perform any of the hazardous operations listed below should clearly indicate their intent and provide specific instructions for conducting such activities in their operating and emergency procedures:
Applicants may use the format given in Table 8.4 to provide the requested information. Table 8.4 Sample Format for Providing Information About Requested Radioisotopes
If the material will be used in field flood studies where licensed material
is intentionally released into the environment, an environmental assessment
(EA) is required in accordance with 10 CFR 51.21. Revision 1,
Supplement to Policy and Guidance Directive FC 84-20, "Impact of Revision
of 10 CFR Part 51 on Materials License Actions," dated March 1994, provides
criteria for determining when an EA is not needed.
Response from Applicant: List the specific use or purpose of each sealed source and/or radioisotope requested in the application. 8.7 Item 7: Individual(s) Responsible for the Radiation Safety Program and Their Training and Experience[ Prev | Next | Top of file ] 8.7.1 Radiation Safety Officer (RSO)Regulations: 10 CFR 30.33(a)(3). Criteria: RSOs must have adequate training and experience. Discussion: The person responsible for the radiation protection program is identified on the license as the RSO. The NRC believes the RSO is the key to overseeing and ensuring safe operation of the licensee's well logging, tracer, or field flood study program. The RSO needs independent authority to stop operations that he or she considers unsafe. He or she must have sufficient time and commitment from management to fulfill certain duties and responsibilities to ensure that radioactive materials are used in a safe manner. The RSO may delegate certain day-to-day tasks of the radiation protection program to other responsible individuals without delegating his or her responsibilities of the radiation safety program. For example, a large well logging firm with multiple field stations and/or temporary job sites may appoint individuals designated as "site RSOs" who assist the RSO and are responsible for the day-to-day activities at the field stations and/or temporary job sites. Typical RSO duties are illustrated in Figure 8.5 and Appendix K. NRC requires the name of the RSO on the license to ensure that licensee management has always identified a responsible, qualified person and that the named individual knows of his or her designation as RSO. Provide NRC with a copy of an organizational chart showing the RSO (and other designated responsible individuals) to demonstrate that he or she has sufficient independence and direct communication with responsible management officials. Also, show in the organizational chart the position of the individual who signs the application in Item 13 of the NRC Form 313. Figure 8.5 RSO Responsibilities - Typical duties and responsibilities of the RSO. To be considered eligible for the RSO position, the applicant must submit for review the specific training and experience of the proposed RSO and detail his or her duties and responsibilities. The proposed RSO should have had a minimum of 1 year of actual experience as a logging supervisor. The RSO is expected to coordinate the safe use of licensed materials and to ensure compliance with the applicable requirements of the Code of Federal Regulations (e.g., Parts 19, 20, 21, 30, 39, etc.). The RSO should possess a thorough knowledge of management policies, company administrative and operating procedures, and safety procedures related to protection against radiation exposures. Response from Applicant: Provide the following:
AND
AND EITHER
OR
OR
Note: It is important to notify NRC and obtain a license amendment prior to making changes in the designation of the RSO responsible for the radiation safety program. 8.8 Item 8: Training for Logging Supervisors and Logging Assistants[ Prev | Next | Top of file ] Regulations: 10 CFR 19.11, 10 CFR 19.12, 10 CFR 19.13, 10 CFR 30.7, 10 CFR 30.9, 10 CFR 30.10, 10 CFR 30.33, 10 CFR 39.13, 10 CFR 39.61. Criteria: Well logging supervisors and well logging assistants must have adequate training and experience as outlined in 10 CFR 19.12, 10 CFR 30.33(a)(3), and 10 CFR 39.61. Although persons engaged in field flood studies operations are not specifically addressed in 10 CFR Part 39, NRC staff has historically accepted classroom training for tracer studies to be an appropriate guide for individuals engaged in field flood studies. Discussion:
Didactic training and testing requirements, performance requirements, annual refresher training, and annual audit requirements for logging supervisors and logging assistants are outlined in 10 CFR 39 61. Refer to Appendix L as an aid in determining the specific training requirements for logging supervisors, logging assistants, and individuals authorized to conduct field flood study/tracer applications. The applicant must submit a description of its training program for logging supervisors, logging assistants, and/or individuals authorized to conduct field flood study applications. Because 10 CFR Part 39 contains different requirements for logging supervisors and logging assistants, applicants must include training programs for each category. When describing the training programs for these positions, include the sequence of events from the time of hiring through the designation of individuals as logging supervisors or logging assistants. Experienced logging supervisors who have worked for another well logging, tracer, or field flood study licensee should receive formal instruction similar to that given to prospective logging assistants. Instructors who provide classroom training to individuals in the principles of radiation and radiation safety should have knowledge and understanding of these principles beyond those obtainable in a course similar to the one given to prospective logging supervisors. Individuals who provide instruction in the hands-on use of well logging and handling equipment should be qualified logging supervisors with at least 1 year of experience in performing well logging operations, or should possess a thorough understanding of the operation of well logging and handling equipment (e.g., a manufacturer's service representative). An internal inspection program (audit) of the job performance of each logging supervisor and logging assistant ensures that the Commission's regulations, license requirements, and the licensee's operating and emergency procedures are followed. The audit must include observation of the performance of each logging supervisor and logging assistant during an actual well logging operation at intervals not to exceed 12 months. If a logging supervisor or logging assistant has not participated in a well logging operation for more than 12 months since the last inspection, the individual must be inspected the first time he or she engages in well logging operations. Response from Applicant:
8.9 Item 9: Facilities and Equipment[ Prev | Next | Top of file ] Regulations: 10 CFR 20.1406, 10 CFR 20.1101(b), 10 CFR 20.1703, 10 CFR 30.33(a)(2), 10 CFR 30.35(g), 1 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||