ML19305C583
| ML19305C583 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/2019 |
| From: | Jason Vonehr NRC Region 4 |
| To: | |
| Shared Package | |
| ML19305C662 | List: |
| References | |
| Download: ML19305C583 (26) | |
Text
U.S. NRC Safety Requirements Jason vonEhr Health Physicist U.S. NRC Region IV 7 October 2019 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Objectives for NRC Safety Requirements Presentation To introduce the foundation for NRCs Mission and Regulations as they apply to well logging To review the basics for the applicable regulations and where to find them To identify the basics and basis for licensing and applicable NRC guidance documents 2
U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
NRC Mission The NRCs mission is to license and regulate the Nations civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.
3
Principles of Good Regulation
- Independence
- Openness
- Efficiency
- Clarity
- Reliability NRC Strategic Plan FY2018-2022, NUREG-1614, Volume 7 4
Columns of Safety - Well Logging
- NRC Regulations - Title 10 of the Code of Federal Regulations (10 CFR) Parts 19, 20, 30, and 39
- DOT Regulations - 49 CFR 172-179
- NRC Reference 10 CFR 71.5
- License Conditions and Guidance Documents
- NUREG-1556, Volume 14, Revision 1 5
U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Brief Overview - 10 CFR Part 19 Notices, Instructions, and Reports to Workers:
Inspection and Investigations
- Posting of Notices
- Instructions to Workers (hazard awareness)
- Notifications and Reports to Individuals
- NRC/Licensee Inspection Interface
- Rights and responsibilities for workers, the licensee, et cetera 6
U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Brief Overview - 10 CFR Part 20 Standards for Protection Against Radiation
- Subpart A - General Administration
- Definitions, units, et al.
- Subpart B - Radiation Protection Program
- Subpart C - Occupational Dose Limits
- Subpart D - Public Dose Limits
- Subpart E - Radiological Criteria for License Termination
- Subpart F - Surveys and Monitoring
- Subpart G - Restricted Area/Controlling External Exposure 7
Brief Overview - 10 CFR Part 20 Continued
- Subpart H - Controlling Internal Exposure (Respiratory)
- Subpart I - Basic Security Provision
- Subpart J - Precautionary Procedures
- Posting and labeling rooms/containers
- Package receipt and opening
- Subpart K - Waste Disposal
- Subpart L - Records Creation & Retention
- Subpart M - Reports to the NRC 8
Brief Overview - 10 CFR Part 30 Rules of General Applicability to Domestic licensing of Byproduct Material
- 30.3 - Activities Requiring a License
- 30.7 - Employee Protection
- 30.9 / 30.10 - Completeness and Accuracy of Information & Deliberate Misconduct
- 30.12 / 30.13 - Exemptions for DOE, Common and Contract Carriers 9
U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Brief Overview - 10 CFR Part 30 Continued
- 30.14 - 30.22 - Exempt concentrations, quantities, and devices
- 30.31 / 30.22 - Types of licenses and Applications for licenses
- 30.34 - General Terms and Conditions
- 30.35 - Financial Assurance
- 30.36 - Expiration, Termination, and Decommissioning 10 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Brief Overview - 10 CFR Part 30 Continued
- 30.41 - Transfer of Radioactive Material
- 30.50 - Reporting Requirements
- 30.51 - Record Creation and Retention
- 30.52 - Inspection responsibility
- Afford the opportunity to inspect at all reasonable times,
- Shall make available records kept pursuant to the NRCs requirements upon reasonable notice 11 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Overview - 10 CFR Part 39 (1)
Licenses and Radiation Safety Requirements for Well Logging
- Subpart A - General Administration (e.g.
definitions)
- Subpart B - Specific Licensing Requirements
- Application Requirements
- Well Owner Agreement
- Subpart C - Equipment
- Labels, Security, and Transportation
- Radiation Detection Instruments
- Leak Testing of Sealed Sources (later: see License Condition) 12 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Overview - 10 CFR Part 39 (2)
Continued
- Subpart C - Equipment (Continued)
- Physical Inventories
- Records of Use (Utilization or Use Log)
- Design and Performance Criteria for sources
- Double encapsulation
- Insoluble and nondispersible (as practical)
- Grandfathered or ANSI/HPS N43.6-1997 requirements
- Exceptions for sources in gaseous form and energy compensation sources
- Inspection & Maintenance
- Subsurface Tracer Studies
- Protections, precautions, and fresh-water aquifer prohibition 13 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Overview - 10 CFR Part 39 (3)
Continued
- Subpart C - Equipment (Continued)
- Radioactive Markers/Uranium Sinker Bars
- Addl Requirement for sealed sources in fresh water aquifer without surface casing
- Energy Compensation Sources & Tritium Neutron Generator provisions/exceptions
- Subpart D - Radiation Safety Requirements
- Training for Logging Supervisor, Logging Assistant, initial &
refresher 14 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Overview - 10 CFR Part 39 (4)
Continued
- Subpart D - Rad Safety Req (Continued)
- Operating and Emergency Procedures
Handling and use of RAM
Handling and use of radioactive tracer materials
Methods and occasions for surveys
Minimization of radiation exposure, incl. from inhalation/ingestion
Security of RAM
Personnel monitoring & PM equipment
Transportation (packaging, placarding, security)
Receipt and opening of radioactive packages
Decontamination (for tracers)
Maintenance of records generating at temporary job sites
Inspection & maintenance program
Reporting to NRC 10 CFR Part 21 defects
Actions/reporting in case of an event (e.g. lodged sealed source)
Actions for a ruptured sealed source 15 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Overview - 10 CFR Part 39 (5)
Continued
- Subpart D - Rad Safety Req (Continued)
- Personnel Monitoring
- Radiation Surveys (Specific)
- Radiation Contamination Control
- Subpart E - Security, Records, Notifications
- Security at Temporary Job Sites
- Record Requirements at Field Offices and Temporary Job Sites
- ***Required Notifications (e.g. ruptured source, pre-notify for approval to abandon sources in-hole) 16 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
U.S. Department of Transportation Regulations The U.S. NRC and U.S. DOT Memorandum of Understanding: July 2, 1979 Cooperation between U.S. DOT, NRC, and Dept. of Homeland Security Provides authority for the NRC to inspect licensees against DOT requirements NRC Regulation: 10 CFR 71.5
References:
49 CFR Parts 107, 171-180, and 390-397 17
- Primary Considerations:
Types of sources being shipped Activity of sources being shipped Physical Form of radioactive material Type of package required Shipping & Transporting Radioactive Material 18
- Form of Material:
- Special Form
- Non-dispersible
- Encapsulated, solid metal, etc.
- High physical integrity
- Normal Form
- Readily Dispersible to environment
- Liquids, gasses, etc.
- Pose definite contamination hazard Shipping & Transporting Radioactive Material 19
- Package Requirements
- Type A
- Less stringent testing
- Activity limits apply (A1 & A2)
- Type B
- Very stringent testing &
certification
- Requires special approval and registration for use Shipping & Transporting Radioactive Material 20
License Conditions 21
License Conditions
- The NRC license provides additional restrictions and authorizations beyond the specificity of the regulations
- These include:
- Isotopes, form (sealed/unsealed, model of source/device if applicable), quantity, and authorized use
- Locations of use/storage (i.e. fixed facilities), Temporary Job Site authorization
- Identify the Radiation Safety Officer - normally the principle contact for the NRC
- Leak Test Requirement 22 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
License Conditions
- Other conditions restrict licensee:
- prevent non-routine maintenance or processes not normally authorized
- Limits Conditions of Use from the Sealed Source and Device Registry
- Tie Downs - Additional commitments made in License Application, Renewal, or Amendments
- Operating and Emergency Procedures
- Commitments to follow certain guidance document sections
- Decommissioning Records 23 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
NUREG-1556, Volume 14, Revision 1
- 293 pages of well-logging specific guidance
- How to file an application (Pg 33-127)
- Appendices (pg. 128-293):
- Forms for application
- Summaries of training and survey requirements
- Summary of notification requirements, and more 24
Objectives for NRC Safety Requirements Presentation To introduce the foundation for NRCs Mission and Regulations as they apply to well logging To review the basics for the applicable regulations and where to find them To identify the basics and basis for licensing and applicable NRC guidance documents 25 U.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment
Questions?