Download:
pdf |
pdfFINAL OMB SUPPORTING STATEMENT FOR
10 CFR PART 39
LICENSES AND RADIATION SAFETY REQUIREMENTS FOR WELL LOGGING
(3150-0130)
--EXTENSION
Description of the Information Collection
U.S. Nuclear Regulatory Commission (NRC) regulations in Title 10 of the Code of Federal
Regulations (10 CFR) Part 39 establish rules that specify radiation safety requirements for the
issuance of licenses for the use of sealed sources containing byproduct material and radiation
safety requirements for persons using these sealed sources in well logging operations.
The requirements in Part 39 specify what information must be submitted in an application for a
license to conduct well logging operations, including, for example, the applicant’s program for
training logging supervisors and logging assistants, written operating and emergency
procedures, and a description of the applicant's organizational structure as it applies to the
radiation safety responsibilities in well logging.
Persons affected by the information collection requirements of Part 39 include applicants for,
and holders of, NRC and Agreement State licenses to conduct well logging operations.
A. JUSTIFICATION
1. Need For the Collection of Information
The information required by Part 39 is collected because it is necessary to ensure that
an applicant for a license to conduct well logging operations is properly qualified to
perform this activity, and to ensure the safety of employees and members of the public.
The regulations provide for comprehensive and consistent radiation safety requirements
in NRC and Agreement State regulations, and safety requirements designed to reduce
the likelihood of accidents involving radioactive sources in well logging operations.
2. Agency Use of the Information
The records that Part 39 requires licensees to maintain are reviewed by the NRC staff
during inspections, license renewals, and license amendment reviews to evaluate
compliance with NRC radiation safety requirements for possession and use of licensed
radioactive material in well logging.
For example, internal inspection records are reviewed by NRC inspectors to verify that
the licensee is maintaining and implementing an effective inspection program and that
safety related issues are being identified and corrected. A written agreement between the
licensee performing well logging and with a well owner or operator is necessary to ensure
that recovery or abandonment procedures will be implemented in the event of a stuck or
irretrievable well logging source. The identification plaque is necessary to provide a
warning to anyone attempting to re-enter the well of the presence of the abandoned
source and to provide information on the source and its location within the well. Labels
required on the source, the source holder, or the logging tool containing radioactive
materials, and the storage or transport container, are needed to warn people that these
devices or containers contain radioactive materials and that persons should notify civil
authorities or the company if a labeled device or container is found.
Calibration records are needed to permit NRC inspectors to verify that the licensee is
keeping calibrated and operable radiation survey instrument(s) at each field station and
temporary job site to make required radiation surveys. Similarly, records of the results of
leak testing of sealed sources are reviewed by NRC inspectors to verify that licensees
have the source tested for leakage at least every 6 months, to ensure the sealed sources
maintain their integrity.
The required reports regarding ruptured or irretrievable sources permit the NRC staff to
make a determination whether an inspector should be dispatched to a site and to assure
that corrective actions have been taken. When the licensee, in consultation with the well
owner or operator, determines that a sealed source lost in a well becomes irretrievable,
the licensee is required to notify NRC regional offices immediately by telephone to
request approval to implement abandonment procedures. The NRC regional office, based
on the information provided by the licensee, approves the abandonment if all reasonable
efforts at recovery have been expended.
3. Reduction of Burden Through Information Technology
The NRC has issued Guidance for Electronic Submissions to the NRC which provides
direction for the electronic transmission and submittal of documents to the NRC.
Electronic transmission and submittal of documents can be accomplished via the
following avenues: the Electronic Information Exchange (EIE) process, which is available
from the NRC's “Electronic Submittals” Web page, by Optical Storage Media (OSM) (e.g.
CD-ROM, DVD), by facsimile or by e-mail. It is estimated that approximately 90% of the
potential responses are filed electronically.
4. Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no duplication of requirements.
5. Effort to Reduce Small Business Burden
Approximately 32 percent of NRC’s well logging licensees are small businesses. Efforts
have been made to keep the requirements for information to a minimum. However, since
the health and safety consequences of improper handling or use of radioactive byproduct
material are the same for large and small entities, it is not possible to reduce the burden
on small businesses by less frequent or less complete reporting, recordkeeping, or
accounting and control procedures.
6. Consequences to Federal Programs or Policy Activities if the Collection is not Conducted
or is Conducted Less Frequently
If the information were not collected, or were collected less frequently, NRC would not
have the information needed to assure that licensees are maintaining records and those
licensees will continue to operate programs in a manner that will assure adequate
protection of the public health and safety. Required reports are collected and evaluated
2
on a continuing basis as events occur. Applications for new licenses and amendments
are submitted only once. Applications for renewal of licenses are submitted every 15
years. Information submitted in previous applications may be referenced without being
resubmitted.
7. Circumstances Which Justify Variation from OMB Guidelines
Contrary to the OMB Guidelines in 5 CFR 1320.5(d), 10 CFR 39.31(a) requires that a
licensee label (1) the source, the source holder or the logging tool containing radioactive
materials; and (2) the storage or transport container. The labels are required for the life of
the device and are needed to warn people that these devices or containers contain
radioactive materials and that persons should notify civil authorities or the company if
they find a labeled device or container.
Section 39.35(d)(2) requires that licensees submit a report to NRC within 5 days of a
failed sealed source leak test. However, reporting would be required only if the test
reveals the presence of 0.005 microcurie or more of removable radioactive material. The
report must be filed within 5 days to permit NRC to ensure that the licensee has taken
action to remove the leaking sealed source from service and to check for radioactive
contamination. It also permits NRC to determine whether inspection or other response
may be required to deal with potential problems impacting the public health and safety.
Section 39.65(c) requires licensees to retain records of personnel dosimeters and
bioassay results until the Commission authorizes disposition. The information documents
the radiation doses received by the licensee's employees. This information may be
needed to reconstruct a worker's dose history in the event the worker loses his/her
records.
Section 39.73 requires licensees to maintain certain documents and records at specified
locations. The retention periods for the various documents vary and may be required for
as long as the license is in effect. This information is needed at the various sites so that
the licensee's operating personnel can have easy access to the documents they need to
safely perform well logging activities.
Section 39.75 requires licensees conducting operations at temporary job sites to maintain
certain documents and records at each temporary job site. The retention periods for the
various documents vary and may be required for as long as the license is in effect. This
information is needed so that the licensee's operating personnel can have easy access to
the documents they need safely perform well logging activities.
Section 39.77(a) requires immediate telephone notification, with a written report within 30
days, because the loss of licensed material and rupture of a sealed source could cause
extensive radioactive contamination. Immediate notification would permit NRC to judge
the severity of the situation and consider whether NRC should take immediate action.
The confirmatory letter within 30 days is needed to permit NRC to judge whether the
licensee has taken corrective actions and whether NRC should consider follow-up
actions.
Section 39.77(c) requires licensees to notify NRC by telephone if a source becomes
irretrievable and obtain NRC approval for abandoning a sealed source in a well. The
3
requirement for prompt notification is needed to permit NRC to judge whether all
reasonable effort at recovery has been expended.
Section 39.77(d) requires that the licensee must make a written report to NRC within 30
days after the source has been classified as irretrievable. The written report within 30
days is needed to assure that the abandonment procedures are carried out promptly and
satisfactorily. Furthermore, the report constitutes a record to alert State regulatory
agencies about a sealed source lodged in the well and permission is requested to reenter
the well.
8. Consultations Outside the NRC
Opportunity for public comment on the information collection requirements for this
clearance package was published In the Federal Register on July 28, 2023 (88 FR
48922). As part of the consultation process, the NRC staff directly contacted, via email,
four potential respondents. The stakeholders were representatives of well logging
licensees from various organizations. No comments were received in responses to these
consultations.
9. Payment or Gift to Respondents
Not applicable.
10. Confidentiality of Information
Confidential and proprietary information is protected in accordance with NRC regulations
at 10 CFR 9.17(a) and 10 CFR 2.390(b). However, no information normally considered
confidential or proprietary is requested.
11. Sensitive Questions
None.
4
12. Estimated Burden and Burden Hour Cost
Annual Burden
NRC Licensees
(hrs/yr)
Agreement State
Licensees(hrs/yr)
Total Burden
Reporting
29 (4.1
hrs/response)
65 (3.4 hrs/response)
94
Recordkeeping
4,659
34,007
38,666
Third-Party Disclosure
275
2,012
2,287
TOTALS
4,963
36,084
41,047
The total burden for Part 39 is 41,047 hours. The total cost is $12,314,100 (41,047 x
$300/hr). The burden estimates are based on staff’s best estimate of the time required to
perform information collection activities.
Annual Responses
Reporting
NRC
7
Agreement States
19
Total
26
Record Keeping
22
161
183
Third-Party Disclosure
440
3,220
3,660
Total Number of Responses
469
3,400
3,869
Total number of responses 3,869
The $300 hourly rate used in the burden estimates is based on the Nuclear Regulatory
Commission’s fee for hourly rates as noted in 10 CFR 170.20 “Average cost per
professional staff-hour.” For more information on the basis of this rate, see the Revision of
Fee Schedules, Fee Recovery for Fiscal Year 2023 (88 FR 39120, June 15, 2023).
13. Estimate of Other Costs
The NRC has determined that the quantity of records to be maintained is roughly
proportional to the recordkeeping burden and, therefore, can be used to calculate
approximate records storage costs. Based on the number of pages maintained for a typical
clearance, the records storage cost has been determined to be equal to 0.0004 times the
recordkeeping burden cost. Because the recordkeeping burden is estimated to be 38,666
hours, the storage cost for this clearance is $4,639.92 (38,666 hours x 0.0004 x
$300/hour).
5
14. Estimated Annualized Cost to the Federal Government
It is estimated that the NRC annual cost of professional staff effort for activities other than
the review of a license application is $19,800 (66 hrs x $300/hr). The review of license
applications is covered under 3150-0120.
The staff has developed estimates of annualized costs to the Federal Government related
to the conduct of this collection of information. These estimates are based on staff
experience and subject matter expertise and include the burden needed to review,
analyze, and process the collected information and any relevant operational expenses.
15. Reason for Change in Burden or Cost
The overall burden has increased by 580 hours from 40,454 hours to 41,034 hours (NRC
Licensees = 4,950 hrs + AS Licensees = 36,084 hrs) because of an increase in the
number of licensees. There was also an increase in the burden based on an increase of
the number of reported well logging sources that were abandoned because they were
unable to be retrieved
The number of licensees has remained the same, but the number of responses has
decreased. The change in the NRC licensee burden is due to a decrease in annual reports
from 8 to 5 resulting in a burden decrease of 4 hours from 4,967 hours to 4,950 hours (16
reporting hrs + 4,659 recordkeeping hrs + 275 third-party disclosure hrs).
The number of Agreement State (AS) licensees has increased by 3 from 158 to 161,
resulting in a burden increase of 692 hours from 35,487 to 36,179 hours (75 reporting hrs
+34,092 recordkeeping hrs + 2,012 third-party disclosure hrs).
The number of well logging licensees licensed by the Agreement States is assumed to
follow the same ratio as the total number of NRC licensees to Agreement States
licensees. The NRC estimates that there is approximately 7.3 times the number of
Agreement State licensees as there are NRC licensees. The estimated number of
Agreement State licensees (16,000) is based on information contained in NRC’s 20212022 Information Digest (NUREG-1350, Volume 33). The change from the previous
estimate of 7.2 to 7.3 (Agreement States burdens is 16,000/2,200, approximately 7.3) is
based on (1) the most recent estimate of 2,200 similar NRC licensees and (2) the
estimated 16,000 Agreement State licenses.
The number of NRC licensees is expected to remain at or near the current number (22)
over the coming three years. The number of Agreement State licensees is likewise
expected to remain at or near the current number (161) over the coming three years.
In addition, there was an increase in professional cost from $290/hr to $300/hr.
16. Publication for Statistical Use
None.
17. Reason for Not Displaying the Expiration Date
6
The requirement is contained in a regulation. Amending the Code of Federal Regulations
to display information that, in an annual publication, could become obsolete would be
unduly burdensome and too difficult to keep current.
18. Exceptions to the Certification Statement
None.
B.
COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not used in this collection of information.
7
TABLE 1
ANNUAL INFORMATION COLLECTION BURDENS ASSOCIATED WITH
REPORTING REQUIREMENTS OF 10 CFR PART 39 FOR NRC LICENSEES
Section
Description
Number of
Respondents
Responses
Per Respondent
Total
Responses/yr
Burden
Hrs/response
Total
Burden
hrs/yr
Application for
specific
License
0
0
0
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
1
1
1
1
1
39.43(c)&(d) - See OMB clearance
No. 3150-0120
Requirements
for a specific
license
Requirements
for abandoning
a well logging
source
Requirements
for a specific
license
Leak testing of
sealed sources
Sealed source
inspection and
maintenance
0
0
0
0
0
39.45(b)- See OMB clearance No.
3150-0120
Subsurface
tracer studies
0
0
0
0
0
39.51 - See OMB clearance No.
3150-0120
Use of a
sealed source
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
39.11 -See OMB clearance No.
3150-0120
39.13(b),(c),(e),(f) - See OMB
clearance No.3150-0120
39.15(c)
39.17 - See OMB clearance
No. 3150-0120
39.35(d)(2)
39.53- See OMB clearance No.
3150-0120
39.63 - See OMB clearance No.
3150-0120
39.69(a) - See OMB clearance No.
Energy
Compensation
Source
Operating and
Emergency
procedures
Radioactive
Contamination
8
Section
3150-0120
39.77(a)
39.77(b) - See OMB clearance
Nos. 3150-0014 & 0017
39.77(c)
39.77(d)
39.91- See OMB clearance No.
3150-0017
Description
Number of
Respondents
Responses
Per Respondent
Total
Responses/yr
Burden
Hrs/response
Total
Burden
hrs/yr
0
0
0
12
0
0
0
0
0
0
2
1
2
0.5
1
2
1
2
7
14
0
0
0
0
0
Control
Ruptured
sealed source
Incident
reporting
requirements
Requirements
for abandoning
a well logging
source
Incident
reporting
requirements
Applications for
Exemptions
Total
5
9
16
TABLE 2
ANNUAL INFORMATION COLLECTION BURDENS ASSOCIATED WITH RECORDKEEPING REQUIREMENTS OF 10 CFR PART
39 FOR NRC LICENSEES
Section
39.13(d)
39.31(a)
39.33(d)
39.35(a)
39.37
39.39 (a) and (b)
39.43(a)&(b)
39.61(d)
39.65(a)-(c)
39.67(f)
39.73
39.75
Description
Requirements
for a specific
license
Radioactive
material
labeling
requirements
Radiation
detection
instruments
Leak testing of
sealed sources
Physical
Inventory
Records
requirements
Sealed source
inspection and
maintenance
Training
requirements
Personnel
monitoring
Radiation
surveys
Documents at
field stations
Documents at
temporary
jobsite
Number of
Recordkeepers
Burden Hrs
Per Recordkeeper
Total
Burden
Hours
Record Retention Period
3 years
22
1.25
28
life of device
22
0.5
11
22
1.6
22
0.8
18
22
0.8
18
22
22.5
495
22
7.7
169
22
7.5
165
22
8.6
189
22
120
2,640
22
3
66
22
37.5
825
35
3 years
3 years
3 years
3 years
3 years
3 years
Until Commission authorizes
disposition
3 years
varies
varies
10
Section
39.77(c)(2) - Included in
39.15(a)&(b)
Description
Requirements
for abandoning
a well logging
source
Burden Hrs
Per Recordkeeper
Number of
Recordkeepers
0
Total
Burden
Hours
0
Record Retention Period
0
Total
4,659
TABLE 3
ANNUAL THIRD PARTY DISCLOSURE REQUIREMENTS OF 10 CFR PART 39
FOR NRC LICENSEES
Section
Description
39.15(a)&(b)
Requirements for a
Specific License
Radioactive material
labeling requirements
Training requirements
39.49 - Included in
39.31(a)
39.61(a)-(c)&(b)
Number of
Respondents
22
Responses Per
Respondents
10
Total
Responses/yr
220
Burden
Hrs/response
1
Total Burden
hr/yr
220
0
0
0
0
0
22
10
220
.25
Total
440
55
275
NRC Licensees’ Burden and Cost
It is estimated that, for NRC licensees and applicants, there will be 5 responses with a reporting burden of 16 hours annually, there
will be 22 recordkeepers with a recordkeeping burden of 4,659 hours annually, and there will be 22 respondents with a third-party
disclosure burden of 275 hours annually. The NRC licensees’ total burden is estimated to be 4,950 hours (16 hrs reporting + 4,659
hrs recordkeeping + 275 hrs third-party disclosure) at a cost of $1,435,500 [4,950 hours (NRC licensees’ total burden) x $290/hr].
11
TABLE 4
ANNUAL INFORMATION COLLECTION BURDENS ASSOCIATED WITH
REPORTING REQUIREMENTS OF 10 CFR PART 39 FOR AGREEMENT STATE LICENSEES
Section
39.11 - See OMB clearance No.
3150-0120
39.13(b), (c), (e), (f) - See OMB
clearance No. 3150-0120
39.15(c)
39.17 - See OMB clearance No.
3150-0120
39.35(d)(2)
39.43(c)&(d) - See OMB clearance
No.3150-0120
Description
Number of
Respondents
Application for
specific
License
Requirements
for a specific
license
Requirements
for abandoning
a well logging
source
Requirements
for a specific
license
Leak testing of
sealed sources
Sealed source
inspection and
maintenance
Total
Burden
Responses
Per
Respondent
Total
Responses/yr
Burden
Hrs/response
0
0
0
0
0
0
0
0
6
1
6
5
30
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
0
39.45(b) - See OMB clearance No.
3150-0120
Subsurface
tracer studies
0
0
0
0
0
39.51 - See OMB clearance
No.3150-0120
Use of a
sealed source
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
39.53 - See OMB clearance No.
3150-0120
39.63 - See OMB clearance No.
3150-0120
39.69(a) - See OMB clearance No.
3150-0120
Energy
Compensation
Source
Operating and
Emergency
procedures
Radioactive
Contamination
12
Section
39.77(a)
39.77(b) - See OMB clearance Nos.
3150-0014 & 0017
39.77(c)
39.77(d) 39.91- See OMB clearance No.
3150-0017
Description
Responses
Per
Respondent
Total
Responses/yr
Burden
Hrs/response
0
0
0
12
0
0
0
0
0
0
6
1
6
0.5
3
6
1
6
7
42
0
0
0
0
0
Number of
Respondents
Control
Ruptured
sealed source
Incident
reporting
requirements
Requirements
for abandoning
a well logging
source
Incident
reporting
requirements
Applications for
Exemption
Total
18
13
Total
Burden
75
TABLE 5
ANNUAL INFORMATION COLLECTION BURDENS ASSOCIATED WITH RECORDKEEPING REQUIREMENTS OF 10 CFR PART
39 FOR AGREEMENT STATE LICENSEES
Section
Description
39.13(d)
39.31(a)
39.33(d)
39.35(a)
39.37
39.39 (a) and (b)
39.43(a)&(b)
39.61(d)
39.65(a)-(c)
39.67(a)-(f)
39.73
39.75
Requirements
for a specific
license
Radioactive
material
labeling
requirements
Radiation
detection
instruments
Leak testing of
sealed sources
Physical
Inventory
Records
requirements
Sealed source
inspection and
maintenance
Training
requirements
Personnel
monitoring
Radiation
surveys
Documents at
field stations
Documents at
temporary
Number of
Recordkeepers
Burden Hrs
Per Recordkeeper
Total
Burden
161
1.25
201
161
0.5
80
161
1.6
258
3 years
161
0.8
129
3 years
161
0.8
129
3 years
161
22.5
3,622
3 years
161
7.7
1,240
3 years
161
7.5
1,208
3 years
161
8.6
1,385
Until Commission
authorizes disposition
161
120
19,320
3 years
161
3
483
161
37.5
6,038
14
Record Retention Period
3 years
Section
Description
39.77(c)(2) - Included in 39.15(a)&(c)
Number of
Recordkeepers
Burden Hrs
Per Recordkeeper
Total
Burden
0
0
0
jobsites
Requirements
for abandoning
a well logging
source
Total
Record Retention Period
34,092
TABLE 6
ANNUAL THIRD-PARTY DISCLOSURE REQUIREMENTS OF 10 CFR PART 39
FOR AGREEMENT STATE LICENSEES
Section
Description
39.15(a)&(b)
Requirements for a
Specific License
Radioactive material
labeling requirements
Training requirements
39.49 - Included in
39.31(a)
39.61(a)-(c)
Number of
Respondents
161
Responses Per
Respondents
10
Total
Responses/yr
1,610
Burden
Hrs/response
1
Total Burden
hr/yr
1,610
0
0
0
0
0
161
10
1,610
3,220
.25
402
2,012
Total
Agreement State Licensees’ Burden and Cost
It is estimated that, for Agreement State licensees and applicants, there will be 18 responses and a reporting burden of 75 hours
annually, there will be 161 recordkeepers and a recordkeeping burden of 34,092 hours annually, and there will be 161 respondents
with a third-party disclosure burden of 2,012 hours annually. The Agreement State licensees’ total burden will be 36,179 hours (75
hrs reporting + 34,092 hrs recordkeeping + 2,012 hrs third-party disclosure) at a cost
$10,491,910 [36,179 hours (AS licensees’ total burden) x $290/hr].
15
Appendix A- Description of Information Collection Requirements for 10 CFR Part 39
Section 39.11 provides that an applicant for a specific license to use licensed
material in well logging operations must submit NRC Form 313, “Application for
Material License.” The NRC materials licensing staff will review the information
submitted on NRC Form 313 to determine whether an applicant for a license has
adequate training, experience, equipment, facilities, and procedures for the use of
licensed material to protect the public health and safety.
The use of NRC Form 313 is approved by OMB under clearance number
3150-0120, which should be referred to for information collection burden and
supporting data.
Section 39.13 provides that an applicant must submit the following information with
the application:
39.13(b) -
A description of training programs that specifies initial training, onthe-job training and annual safety reviews to be provided by the
licensee;
39.13(c) - Written operating and emergency procedures covering important
safety aspects of the radiation safety program;
39.13(d) - Internal inspection program;
39.13(e) Description of overall organizational structure as it applies to
radiation safety responsibilities in well logging, including specified
delegations of responsibility and authority;
39.13(f) (1) Description of procedures for leak testing sealed sources, or
(2) Manufacturer and model number of the leak test kits to be
used.
This information is reviewed by the NRC staff to determine whether the training,
radiation safety, and internal inspection programs and procedures and the
licensee's organizational structure will provide adequate protection of the public
health and safety. The NRC review and the findings of this information form the
basis for NRC licensing decisions.
Section 39.13(d) provides that a licensee must keep annual internal inspection of
the job performance records for each logging supervisor for 3 years. These records
are reviewed by NRC inspectors to verify that the licensee is maintaining an
effective inspection program and that problems are being identified and corrected.
Sections 39.15(a) and (b) requires that a licensee wishing to conduct well logging
operations with a sealed source must first have, and retain as a record, a written
agreement with the well owner or operator that identifies who will: carry out
responsibilities with regard to recovery of sealed sources which become lodged or
lost in a well; perform radiation monitoring; decontaminate the site, equipment, and
personnel, if necessary; and that within 30 days after a well logging source has
been classified as irretrievable, certain requirements will be implemented to
immobilize and protect the separated well logging tool and source. The licensee
16
must retain a copy of the written agreement for 3 years after the completion of the
well logging operation. A permanent identification plaque must be mounted at the
surface of the well in which a well logging source has been abandoned. In addition
to a warning, the plaque must contain: the date the sealed source was abandoned,
the name of the well owner or operator, the well name and well identification
number(s) or other designation, identification of the source by radionuclide and
quantity of activity, and the depth of the source and the depth to the top of the plug.
The written agreement is needed to ensure that recovery or abandonment
procedures will be implemented in the event of a lodged or irretrievable well logging
source. The agreement binds the well owner or operator (non licensee) to
immobilizing the source with a cement plug, protecting it from subsequent damage
with a drill deflecting device, and posting the wellhead with an appropriate plaque.
Without this agreement, the well logger would be unable to complete recovery or
abandonment procedures if the well owner or operator refused. The identification
plaque is necessary to warn anyone reentering the well about the presence of the
abandoned source and to provide information on the source and its location within
the well.
Section 39.15(c) provides that a licensee or applicant may apply to the Commission
for approval of proposed procedures to abandon an irretrievable well logging source
in a manner other than that currently authorized. Such an application would be
reviewed by the NRC to determine whether the proposed procedures would provide
an adequate margin of protection to the environment, public health and safety.
Section 39.17 provides that the NRC may require further statements, signed under
oath or affirmation, after the filing of the application and before expiration of the
license to enable the NRC to determine whether a license should be modified or
revoked. Such additional information is sometimes needed to clarify information or
to rectify deficiencies in existing programs for protection of the public health and
safety, the common defense and security, or protection of the environment.
The additional information submitted is reviewed by the NRC staff to assess the
adequacy of the applicant's physical plant, procedures and plans for protection of
the public health and safety, common defense and security, and protection of the
environment. The NRC review and the findings based on this information form the
basis for NRC decisions concerning the issuance, amendment, or revocation of a
license.
Section 39.31(a) requires that a licensee label (1) the source, the source holder, or
the logging tool containing radioactive materials; and (2) the storage or transport
container. The labels are needed to warn people that these devices or containers
contain radioactive materials and that persons should notify civil authorities or the
company if they find a labeled device or container.
Section 39.33(d) provides that a licensee must maintain calibration records for a
period of 3 years for each installation and temporary job site, after the date of
calibration of a survey instrument. Calibration of radiation survey instruments is
necessary to ensure that these instruments function properly.
17
The information documents that the calibrations were performed. The records also
permit NRC inspectors to verify that the licensee is keeping a calibrated and
operable radiation survey instrument at each field station and temporary job site to
make required radiation surveys. Inspections are conducted at least every 3 years.
Section 39.35(a) requires the licensee to keep a record of the results of leak testing
of sealed sources for 3 years after the leak test is performed and record the leak test
results in units of microcuries.
The information documents that the leak tests were performed periodically. The
records also permit NRC inspectors to verify that the licensee is performing the leak
tests.
Section 39.35(d)(2) provides for reporting of leak test failures by the licensee to the
NRC within 5 days of receiving the test results. The reporting requirement is needed
to inform the NRC that the licensee has taken actions to remove the leaking sealed
source from service and to check for radioactive contamination.
The information contained in the report allows NRC regional offices to determine,
within approximately 1 week, whether an inspector should be sent to check potential
problems that may adversely affect public health and safety.
Section 39.37 provides for a licensee to keep records of each semiannual physical
inventory to account for all licensed material received and possessed under the
license. The record of inventory must be retained for 3 years. The information is
needed to indicate that the licensee has conducted semiannual inventories to
account for licensed material received and possessed under the license.
The information documents that sources possessed under the license were
accounted for at the time of inventory. The information also permits NRC inspectors
to verify that the licensee has conducted an inventory at least every 6 months.
Section 39.39 (a) & (b) requires that a licensee keep utilization records for sealed
and unsealed sources of licensed material. The records must be retained for 3 years.
This information permits the licensee to trace the history of the use of sources,
radioactive markers, or unsealed licensed material if there are any questions
concerning licensed material.
The information also permits NRC inspectors to verify that the licensee is utilizing
licensed material appropriate to particular well logging operations.
Section 39.43(a) requires that a licensee maintain a record of defects found and
repairs made as a result of visual checks of source holders, logging tools, and source
handling tools. The record must be retained for 3 years. The records are reviewed by
NRC inspectors to ensure that the licensee is maintaining an effective program for
identification and correction of defects.
Section 39.43(b) provides that a licensee must maintain records of semiannual
inspections and maintenance for 3 years. The inspection and maintenance are
needed to ensure that the sealed sources and source holders are in good working
condition.
18
The information permits NRC inspectors to verify that the licensee conducted the
required semiannual inspection and maintenance.
Section 39.43(c) prohibits the licensee from removing a sealed source from a source
holder or logging tool and performing maintenance on a sealed source or holders in
which sealed sources are contained without written procedures developed pursuant
to Section 39.63 that have been approved either by the Commission pursuant to
Section 39.13(c) or by an Agreement State. The procedures are submitted with NRC
Form 313, the submission is covered under OMB clearance number 3150-0120.
Section 39.43(d) requires that licensees may not perform any operation, such as
drilling, cutting, or chiseling, on a stuck sealed source unless approved by the
Commission or an Agreement State.
Section 39.45(b) A licensee may not knowingly inject licensed material into
freshwater aquifers unless specifically authorized to do so by the Commission,
Section 39.49 requires the licensee using a uranium sinker bar in well logging
applications to properly display a caution marker indicating it is radioactive depleted
uranium to inform persons to notify civil authorities or the company if the bar is found.
The labels are needed to warn people that the bars are radioactive.
Section 39.51 The licensee may use a sealed source in a well without a surface
casing for protecting freshwater aquifers only if the licensee follows a procedure for
reducing the probability of the source becoming lodged in the well. The procedure
must be approved by the Commission pursuant to Section 39.13(c) or by an
Agreement State.
Section 39.53 provides that a licensee may use an energy compensation source
(ECS), contained within a logging tool or other tool components, only if the ECS
contains quantities of licensed material not exceeding 3.7 MBq [100 microcuries].
When used in well logging applications with a surface casing for protecting
freshwater aquifers, use of the ECS is subject to the requirements of Sections 39.35,
39.37, and 39.39. When used in well logging applications without a surface casing
for protecting freshwater aquifers, use of the ECS is subject to the requirements of
Sections 39.15, 39.35, 39.37, 39.39, 39.51, and 39.77.
Section 39.61(a) states that the licensee may not permit an individual to act as a
logging supervisor until that person(1) Has completed training in the subjects outlined
in paragraph (e) of this section; (2) Has received copies of, and instruction in (i) The
NRC regulations contained in the applicable sections of parts 19, 20, and 39 of this
chapter; (ii) The NRC license under which the logging supervisor will perform well
logging; and (iii) The licensee's operating and emergency procedures required by §
39.63; (3) Has completed on-the-job training and demonstrated competence in the
use of licensed materials, remote handling tools, and radiation survey instruments by
a field evaluation; and (4) Has demonstrated understanding of the requirements in
paragraphs (a) (1) and (2) of this section by successfully completing a written test.
Section 39.61(b) states that the licensee may not permit an individual to act as a
logging assistant until that person (1) Has received instruction in applicable sections
of parts 19 and 20 of this chapter; (2) Has received copies of, and instruction in, the
19
licensee's operating and emergency procedures required by
§39.63; (3) Has demonstrated understanding of the materials listed in paragraphs (b)
(1) and (2) of this section by successfully completing a written or oral test; and
(4) Has received instruction in the use of licensed materials, remote handling tools,
and radiation survey instruments, as appropriate for the logging assistant's intended
job responsibilities.
Section 39.61(c) requires that a licensee provide safety reviews for logging
supervisors and logging assistants at least once during each calendar year.
Section 39.61(d) requires that a licensee maintain records of training and of the
annual safety review for each logging supervisor and logging assistant. The training
records must include copies of written tests and dates of oral tests given. The
records are needed to confirm that the logging supervisors and logging assistants
received the required training. The training records must be retained until 3 years
after termination of employment. Records of annual safety reviews must be retained
for 3 years.
Section 39.63 requires that licensees maintain and follow written operating and
emergency procedures that cover: handling and use of licensed material, use of
remote handling tools, surveys, control of personnel exposures, locking and securing
of sources, personnel monitoring, transportation, receipt, recordkeeping, inspection
and maintenance, reporting, and actions in case of a stuck or ruptured source.
The information is used by the licensee and its employees to guide the handling and
use of radioactive material in normal and emergency situations. Submission of the
procedures is covered by Section 39.13(c). The procedures must be retained as a
record until the Commission terminates the license. The procedures are submitted
with the Form 313, the submission is covered under OMB clearance number 31500120
Section 39.65(a)-(c) requires that a licensee keep records of personnel dosimeter
and bioassay results until the Commission authorizes disposition. The personnel
dosimeter and bioassay results are needed to measure exposure received by
workers during well logging operations.
The information documents the radiation doses received by the licensee's
employees. This information also permits NRC inspectors to verify that the licensee
kept dosimetry and bioassay records.
Section 39.67(f) requires the results of surveys required under paragraphs (a)
through (e) of this section must be recorded and must include the date of the survey,
the name of the individual making the survey, the identification of the survey,
instrument used, and the location of the survey. The licensee shall retain records of
surveys for inspection by the Commission for 3 years after they are made.
The information documents that the licensee conducted radiation surveys. The
information also permits NRC inspectors to verify that the licensee complies with the
survey requirements.
Section 39.69(a) requires that a licensee initiate emergency procedures as required
by Section 39.63 procedures. The procedures are submitted with the Form 313, the
20
submission is covered under OMB clearance number 3150-0120. These procedures
may include reporting as required under Section 39.77.
Section 39.73 requires that a licensee maintain certain documents and records at
each field station. This information is needed at the site so that the licensee's
operating personnel can have easy access to the documents they need to perform
the job safely. Also, when an NRC inspector inspects a field station, the information
provides the inspector with indications that the licensee complies with NRC
requirements.
Section 39.75 requires that a licensee conducting operations at temporary job sites
maintain certain the following documents and records at the temporary job site until
the well logging operating is completed. The documents include operating and
emergency procedures required by Section 39.63, evidence of latest calibration of
the radiation survey instruments in use at the site required by Section 39.33, and the
latest survey records required by Sections 39.67(b), (c), and (e).
Section 39.77(a) requires that a licensee shall immediately notify the appropriate
NRC Regional Office by telephone and subsequently, within 30 days, by confirmation
in writing, using an appropriate method listed in § 30.6(a) of this chapter, if the
licensee knows or has reason to believe that a sealed source has been ruptured. The
written confirmation must designate the well or other location, describe the
magnitude and extent of the escape of licensed materials, assess the consequences
of the rupture, and explain efforts planned or being taken to mitigate these
consequences.
Section 39.77(b) reminds licensees to follow Parts 20 and 30 reporting requirements
for certain incidents. Requirements under Parts 20 and 30 have been cleared under
OMB clearance numbers 3150-0014 and 3150-0017, respectively.
Section 39.77(c) provides If a sealed source becomes lodged in a well, and when it
becomes apparent that efforts to recover the sealed source will not be successful,
the licensee shall (1) Notify the appropriate NRC Regional Office by telephone of the
circumstances that resulted in the inability to retrieve the source and
(i) Obtain NRC approval to implement abandonment procedures; or
(ii) That the licensee implemented abandonment before receiving NRC approval
because the licensee believed there was an immediate threat to public health and
safety; and (2) Advise the well owner or operator, as appropriate, of the
abandonment procedures under § 39.15 (a) or (c); and (3) Either ensure that
abandonment procedures are implemented within 30 days after the sealed source
has been classified as irretrievable or request an extension of time if unable to
complete the abandonment procedures.
21
Section 39.77(d) requires that the licensee shall, within 30 days after a sealed source
has been classified as irretrievable, make a report in writing to the appropriate NRC
Regional Office. The licensee shall send a copy of the report to each appropriate
State or Federal agency that issued permits or otherwise approved of the drilling
operation. The report must contain the following information: (1) date of occurrence;
(2) a description of the irretrievable well logging source involved including the
radionuclide and its quantity, chemical, and physical form; (3) surface location and
identification of the well; (4) results of efforts to immobilize and seal the source in
place; (5) a brief description of the attempted recovery effort; (6) depth of the source;
(7) depth of the top of the cement plug; (8) depth of the well; (9) the immediate threat
to public health and safety justification for implementing abandonment if prior NRC
approval was not obtained in accordance with paragraph (c)(1)(ii) of this section; (10)
any other information, such as a warning statement, contained on the permanent
identification plaque; and nmss/dmsst/(11) State and Federal agencies receiving
copy of this report.
Section 39.91 provides that the Commission may grant exemptions from the
requirements of Part 39 under specified conditions, upon the application of any
interested person or on its own initiative. Applications under this section are
examined by the NRC materials licensing staff to determine whether the requested
exemption is authorized by law and whether it will not endanger life or property or the
common defense and security, and to determine if it is otherwise in the public
interest. Burden and cost has been approved under OMB clearance number
3150-0017.
22
GUIDANCE DOCUMENTS FOR
10 CFR PART 39
LICENSES AND RADIATION SAFETY REQUIREMENTS FOR WELL LOGGING
(3150-0130)
Document
ADAMS accession No
NUREG-1556 Vol. 20 Guidance
About Administrative Licensing
Procedures
ML20318A384
23
| File Type | application/pdf |
| File Modified | 2023-11-09 |
| File Created | 2023-11-06 |