ML20024E682
| ML20024E682 | |
| Person / Time | |
|---|---|
| Issue date: | 08/09/1983 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20024E683 | List: |
| References | |
| RULE-PR-MISC NUDOCS 8308260292 | |
| Download: ML20024E682 (52) | |
Text
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o UNIT ED STATES f ';1 '.,.g[- )E NUCLEAR REGULATORY COMMISSION
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WASmNG T OfJ. D. C. 20555
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AUG 0 91993 MEMORANDUM FOR:
William J. Dircks Executive Director for Operations FROM:
Robert B. Minogue*, Director Office of Nuclear Regulatory Research
SUBJECT:
FINAL AMENDMENTS TO 10 CFR PARTS 30, 70 and 150 - IRRETRIEVABLE WELL-LOGGING SOURCES Attached for your signature is a notice of final rulemaking providing require-ments to be accomplished it,1 the event of an irretrievable well-logging source.
An irretrievable well-logging source is any source containing NRC licensed material that is pulled off or not connected to the wireline that suspends the source in the well and for,which all reasonable effort at recovery has been expended.
On September 28, 1978 the NRC published in the Federal Register (43 FR 44547) a notice of proposed rulemaking to establish requirements for an irretrievable well-logging source.
These changes to 10 CFR Parts 30 and 70 required:
an agreement between the well-lo (1) owneroro)erator(non-licensee)gger(Commissionlicensee)andthewell to accomplish certain abandonment proce-dures in t1e event of an irretrievable well-logging source; (2) sealing the well-logging source in place with a cement plug; (3) setting a deflection device at the top of that cement plug; (4) mounting a permanent identification plaque at the surface of the well; and (5) reporting the circumstances concerning the irretrievable source to the Commission and to pertinent State agencies within thirty days after the source had been abandoned.
Ten letters of comment were received in response to this notice.
All commenters expressed general agreement with the purpose of the proposed regulation.
However, the comments su express the intent of the regulation.ggested several improvements to better The analysis of these comments is included as Enclosure 6.
After careful consideration of the comments, several
Contact:
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William J. Dircks 2
minor changes were made in the proposed text of the rule.
These changes did not alter the )roposed rule in a substantive way which would require further consideration )y the Commission.
Approximately five well-logging tools containing sealed sources are abandoned
.eachyear. These abandonments have been reported for more than 20 years under i
existing license conditions and S 20.402 of the regulations.
A summary list-ing of these abandonments has been prepared and is attached (see Enclosure 7).
The issue of whether to apply the proposed requirements to previously abandoned sources was considered.
In a risk analysis (SECY-81-516), the additional radio-logical risk to public health and safety was considered if these procedures were not accomplished for previously abandoned well-logging sources.
This risk analysis concluded that the reduction in radiological risk did not warrant the action.
However, the risk analysis contained a recommendation that a notation be inserted in the records of each affected well.
A survey of the known abandonments was completed using existing NRC records.
States with known abandonments of NRC licensed well-logging sources were noti-affected well (see Enclosure 8)priate notation in their records for the fied and asked to make an appro In addition to the amendments to 10 CFR Parts 30 and 70, the Federal Register Notice also amends 10 CFR Part 150.
Section 150.20 currently references 6 30.56 but not 6 70.60.
The amendment to 6 150.20 corrects this omission.
Because the amendment to 6 150.20 is nonsubstantive and conforming in nature, good cause exists for omitting notice of proposed rulemaking and public comment thereon as unnecessary.
Formal request to and approval by OMB has been completed for the recordkeeping and reporting requirements.
I recommend that you sigr,i (under authority delegated in 10 CFR 1.40(c) and (d))
the enclosed notice of final rulemaking for 10 CFR Parts 30, 70, and 150 (Enclo-sure1). As provided in the "ED0 Procedures Manual" at page 11-20b, a draft entry for the Daily Staff Notes to. notify the Commission has been arepared for their information before submitting the final rule to the Federal Register (seeEnclosure4).
Following your approval of this rule change, I will notify the appropriate Congressional Committees (see Enclosure 2).
Copies of the notice of final rule-making will be distributed to affected licensees and other interested persons by the Office of Administration.
Coordination:
The Offices of Nuclear Material Safety and Safeguards, Statp Administration and the Regions concur Programs, Inspection and Enforcement,10 CFR Parts 30, 70, and 150.
in the attached final rulemaking for The Office I
William J. Dircks 3
ofExecutiveLegalDirectorhasnolegalobjection.
The Office of Public Affairs has prepared a draft public announcement (see Enclosure 3).
h+ i (). Olw ~~e Robert B. Minogue, Direc or Office of Nuclear Regulatory Research
Enclosures:
1.
Notice of Final Rulemaking 2.
Draf t Congressional Letter 3.
Draft Public Announcement 4.
Draft Daily Staff Note 5.
Draf t Regulatory Analysis 6.
Analysis of Public Comments 7.
Listing of Well-Logging Sources Lost Downhole 8.
Letter to States with Known Source Abandonments '
Approved for Publication In a final rule aublished March 19, 1982 (47 FR 11816), the Commission delegated to the ED0 10 C:R 1.40(c) and (d)) the autt asdefined(intheAPA(5U.S.C.551(4))subj,ioritytodevelopandpromulgaterules ect to the limitations in NRC Manual Chapter 0103 Organization and Functions, Office of the Executive Director for Operations, p,aragraphs 0213, 038, 039, and 0310.
The enclosed final rule entitled " Irretrievable Well-Logging Sources" amends 10 CFR Parts 30 and 70 to establish requirements for a well-logging licensee to follow certain procedures to protect'the source from damage and to report the incident.
The final rule also makes a conforming amendment to 10 CFR Part 150.
In issuing this final rule, the EDO is acting in accordance with the action of the Commission in approving the publication of the proposed rule (43 FR 44547; September 28,1978) which allowed the EDO to issue the final rule if substan-tive changes from the proposed rule were not required by the review and resolu-tion of public comments.
This final rule does not constitute a significant question of policy, nor does it amend regulations contained in 10 CFR Parts 0, 2, 7, 8, 9 Subpart C and 110.
I-therefore find that this final rule is within the scope of my rulemaking authority and am proceeding to issue it, effective thirty days from its date of publication in the Federal Register.
8-\\7s-63 kAU TW S-i? - F, 5 William J. Ultcks Date
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\\EyecutiveDirectorforOperations i
. William J. Dircks 4
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' d NUCLEAR REGULATORY COMMISSION 10 CFR PARTS 30, 70 AND 150 Irretrievable Well-Logging Sources AGENCY: Nuclear Regulatory Colmission.
ACTION:' Final rule.
SUMMARY
The Nuclear Regulatory Commission is amending its regulations to establish requirements to be accomplished in the event of an irretriev-able well-logging source (any sealed source containing licensed material that is pulled off or not connected to the wireline that suspends the source in the well for which all reasonable effort at recovery has been expended). The final rule establishes requirements for sealing and pro-tecting the well-logging source, identifying the well site, and reporting the occurrence.
The Commission believes that uniform and adequate safety requirements contained in this rule are necessary to ensure that no sub-sequent damage to the source occurs that might result in the dispersal of radioactive material.
EFFECTIVE DATE:
(
- ).
ADDRESSES:
Copies of the Regulatory Analysis and analysis of comments may be examined at the Commission's Public Document Room at 1717 H Street NW.,
Washington, OC 20555.
FOR FURTHER INFORMATION CONTACT:
Dr. Anthony N. Tse, Office of Nuclear Regulatory Research, Washington, DC 20555, telephone (301)443-7902.
- Date to be inserted is 30 days after publication in the Federal Regi. ster.
1 Encicoure f
. SUPPL'EMENTARY TNFORMATION: A well-logging operation consists of lowering into and raising from wells on a wireline a well-logging tool, a measur-ing device, which may contain sealed radioactive sources.
The purpose of the well-logging operation is to obtain inforrration ab9ut the underground
. strata.- Currently, the Commission has approximately 160-170 licensees authorized to conduct well-logging activities and over 50,000 wells are logged each year.
Sealed radioactive sources used 1n we11-logging opera-
~
.tions, typically contain' americium-241 or cesium-137 sources.
Occas'ionally a well-logging. tool containing a radioactive source becomes disconnected from the wireline., In some instances, the well-logging tool is unrecoverable and-is left in the well. An irretrievable well-logging source is, any sealed source containing licensed material that is pulled off or not connected to the wiraline that suspends the source >in the well and for which all reasonable effort at recovery has been expended. A review of records indicates that an average of five irretrievable well-logging sources has occurred yearly.
A well containing an irretrievable well-logging source could con-tinue:in production.. Operation _such as redrilling could be performed in
'that well. -If an irretrievable well-logging source was damaged by sub-sequent operation and radioactive material was brought to the surface, contamination of the well-site, drilling equipment, vehicles, and
- personnel could occur.
Currently,-the Commission treats the abandonment of an irretriev-able well-logging source as a condition of the well-logger's-license.
Th'e licensee is required to specify the procedures that will be used in
.the abandonment'and identification of an irretriev'able well-legging source.
Because_some logging com'panies operate on an interstate basis and because these activities are licensed by the Commission and the Agreement' States,_ uniformity in the content and application of abandon-ment; procedures is important.
In addition, legally binding requirements are required to assure that the well owner or operator performs the.
required actions when neither the owner or operator is the licensee.
L.-
2 l
This regulation is intended to provide the uniformity and assurance necessary to assure radiological safety in the event of an irretrievable well-logging source.
On September 28, 1978 the NRC published in the Federal Register (43 FR 44547) a notice of proposed rulemaking setting out amendments to 10 CFR Parts 30 and 70 that would require certain procedures be followed if a well-logging tool containing radioactive material was abandoned in These procedures include sealing the source in place with a i
a well.
cement plug, mounting a permanent identification plaque at the surface of the well and reporting the circumstances concerning the irretrievable source to the Commission and to pertinent State agencies within 30 days after the source had been abandoned. The notice provided for a 60-day public comment period.
All Ten letters of comment were received in response to the notice.
10 commenters expressed general agreement with the purpose of the proposed However, most commenters did express concern about some regulations.
aspect of the proposed amendments.
Six commenters observed that the definition of an irretrievable well-logging source required the Commission to determine when all reasonable effort at recovery had been expended.
These commenters complained that the Commission had neither the expertise nor the resources to make this Although it was never intended that the Commission determination.
unilaterally decide whether a source was irretrievable, the definition has been amended to delete the reference to unilateral Commission det Accordingly, the phrase "as deter-mination of the status of the source.
- However, mined by the Commission" has been deleted from the definition.
under SS 30.56(b) and 70.60(b) as revised, the Commission retains the authority to determine if "all reasonable effort at recovery has been expended" and may deny approval of the abandonment procedures if it feels that this condition has not been me.t.
Six commenters noted a discrepancy between the language of the pro-posed amendment and the intent of the amendment regarding a written agree-This agreement ment between the itcensee and the well owner or operator.
would require execution of the abandonment procedures when required and 3
4
These co= enters correctly noted that the within a specific tin,e period.
Accordingly, the language did not reflect the intent of the regulations.
regulations in 10 CFR 30.56(a) and 70.60(a) have been revised to clarify that a written agreement between the licensee and the well owner or opera-tor is required prior to commencement of well-logging activities and that agreement must assure implementation of proper abandonment procedures within thirty days after a well-logging source is declared irretrievable.
One commenter further stated that an executed agreement may be difficult to enforce since neithe*r the well owner nor the well operator The Commission considers the well-logger, as is a Commission licensee.
a licensee, responsible for ensuring compliance with the regulations or In view of for parsuing every legal avenue to achieve that compliance.
this licensee responsibility, the changes in the regulations proposed by i
this commenter are not adopted.
Five commenters noted that too much wording was required on the In particular, these commenters stated that much identification plaque.
of the information would be available in the report filed wit'h the State and Commission or that some information, such as the name and address of the well owner or operator may be incorrect by the time a well is The amendment as These comments were accepted in part.
reentered.
revised requires that the plaque contain only information that the Commis-sion considers essential to warn persons of the potential hazard that may be encountered when the well is reentered.
Three comme'nters suggested that the licensee have the option of reporting the incident to either the Commission or to the appropriate State regulatory authority. The Commission disagrees.
All Commission licensees are required to notify the Commission of incidents involving The Commission also believes that notification radioactive materials.
of the appropriate State regulatory agency is an important safety require-In addition, ment since a warning notation is needed in the well records.
the amendments in 10 CFR 30.56 and 70.60 specifically state the informa-In view of these considerations, tion that the report must contain.
notifications are required for both the Commission and the State regula-tory agency.
4
After careful consideration of the comments on the notice of pro-in final posed rulemaking, the Commission has adopted the amendments The requirements of SS 30.56(a) and 70.60(a) relating to agree-l owner or operator form.
cents between the well-logger (licensee) and the wel i
to the will not apply to job sites where operations have begun pr orTh effective date of these amendments.
ll 30.56(c), 30.56(d), 70.60(b), 70.60(c), and 70.60(d) will apply to a date of these well-logging sources abandoned after the effective In addition to the amendments to 10 CFR Parts 30 and 70, amendments.
Section 150.20 is also' amending 10 CFR Part 150 without public comment.The amendm j
currently references S 30.56, but not S 70.60.Because th ists for this difference.
conforming in nature, the Commission has found that good cause ex thereon, as emitting notice of proposed rulemaking, and public procedure d
t coincide unnecessary and for making the effective date of this amen men d 70.60.
with the effective date of'the amendments to SS 30.56 an PAPERWORK REDUCTION ACT STATEMENT h t are This, final rule amends information collection requirements t a SC 3510, et seq.).
1980 (44 U...
subject to the Paperwork Reduction Act of d Budget These requirements were approved by the Office of Management an Part 30 - 3150-0017; and Part 70 - 3150-0009.
under approval numbers:
REGULATORY ANALYSIS t
l The Commission has prepared a regulatory analysis for this r h
The regulatory analysis examines the costs and benefits of Interested persons may tion.
alternatives considered by the Commission.
Public Document Room, examine a copy of the regulatory analysis at theSingle copies
/
1717 H Street IN., Washington, DC.
Regulatory Research, obtained from Dr. Anthony N. Tse, Office of Nuclearl hone:
U.S. Nuclear Regulatory Commission, Washington, DC 20555, te (301)443-7902.
5
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LIST OF SUBJECTS IN 10' CFR PARTS 30, 70, 150
~
Part 30 - Byproduct material, Government contracts, Intergovernmental relations, Isotopes,. Nuclear materials, Penalty, Radiation protection,
-Reporting requirements.
Part 70 - Hazardous materials-transportation, Nuclear materials, Packaging and cont 9 ners, Penalty, Radiation protection, Reporting require-1 ments, Scientific equipment, Security measures, Special nuclear material.
Part 150 - Hazardous materials-transportation, Intergovernmental relations, Nuclear' materials, Penalty, Reporting requirements, Security measures, Source material, Special nuclear material.
- Under the authori,ty of the Atomic Energy Act of 1954, as amended,
~
the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the following amendments to 10 CFR Parts 30 and 70, and 150 are pubitsbed as a document subject to codification.
PART 30 - RULES OF GENERAL APPLICA81LITY TO DOMESTIC LICENSING OF BYPRODUCT KATERIAL 1.
The authority citation for Part 30 is revised to read as follows:
LAUTHORITY:
Secs. 81, 82, 161, 182, 183,'186, 68 Stat. 935, 948, 0
953,.954, 955, as amended, sec.'234, 83 Stat. 444, as amended (42 U.S.C.
~
2111, 2112, 2201, 2232, 2236, 2282); secs. 201, as amended, 202, 206,
-88 Stat. 1242, as amended, 11244,,1246 (42.U.S.C. 5841,-5842, 5846).
Section 30.7: also issued under Pub. L.95-601, sec.10,-92 Stat.
2951.(42 U.S.C. 5851). Section 30.34(b) also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234).
Section 30.61 also issued under sec. 187, 68 Stat. 955-(42 U.S.C. 2237).
For-purposesofsec.223,68 Stat.958,'asamended(42U.S.C2273)('
SS 30.3, 30.34(b) and.(c), 30.41(a) andL(c) and 30.53 are issued under-sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); and SS 30.36,
'30.51, 30.52,'30.55 and 30.56(b) and (c) are issued-under sec. 161o, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
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2.
A new paragraph (x) is added to S 30.4 to read as fo11cws:
$ 30.4 Definitions.
(x) ~" Irretrievable well-logging source" means any sealed source
- containing licensed material that'is pulled off or not connected to the
~
wireline that suspends the source in the well and for which all reason-
-able effort at recovery has been expended.
3.
A new S 30.56 is added to read as follows:
i 5 30.56' Well-logging operations using sealed sources.
(a) A licensee may perform well-logging operations with a sealed source only after the licensee executes a written agreement with the well owner or operator th'at, within thirty (30) days after a well-logging source has been classified as irretrievable, the following requirements i
will be implemented:
(1) Each irretrievable well-logging source must be immobilized and sealed in place with a cement plug.
(2) A whipstock or other deflection device must be set at some
~ point in the'well above the cement plug, unless the cement plug and source are not accessible to any subsequent drilling operations.
(3) A permanent identification plaque, constructed of long lasting material such as stainless steel,- brass, bronze, or monel, must be mounted at the surface of the well, unless the mounting of the plaque is not practical.
The' plaque must contain --
(i) The word " CAUTION";
(ii) A radiation symbol (the color requirement need not be met);
(iii) The date.the source was abandoned; (iv) The name of the well owner or well operator; (v) The well name and well identification number (s) or other designation; (vi) An identification-of the sealed source (s) by radionuclide and
. quantity of activity;
-(vii) The depth of the source and depth to the top of the plug; and (viii) An appropriate warning.
w 7
g uuwd Section 70.7 also issued under Pub. L.95-601, sec.10, 92 Stat.
2951-(42. U.S.C. 5851).
Section 70.21(g) also issued under sec.122, 68 Stat. 939 (42 U.S.C. 2152). Section 70.31 also issued under sec. 57d, Pub. L.93-377, 88 Stat. 475 (42 U.S.C. 2077).
Sections 70.36 and 70.44 also issued under sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234).
Section 70.61 also issued under secs. 186, 187, 68 Stat. 955 (42 U.S.C.
2236,2237).
Section 70.62 also issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138).
For the purposes of sec. 233, 68 Stat. 958, as amended (42 U.S.C.
2273); SS 70.3, 70.19(c), 70.24(a) and (b), 70.32(a)(3), (5), (6), and (d), 70'.36, 70.39(b) and (c), 70.41(a), 70.42(a) and (c), 70.56, 70.57(b),
(c), and (d), 70.58(a)-(g)(3), and (h)-(j) are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); SS 70.20a(d), 70.20b(c) and
.(e), 70.21(c), 70.24(b), 70.32(e) and (g), 70.56, 70.57(b) and (d) and 70.58(a)-(g)(3) and (h)-(j) are issued under sec. 1611,.68 Stat. 949, as amended (42 U.S.C. 2201'(1)); and SS 70.20b(d) and (e), 70.38, 70.51-70.55, 70.58(g)(4), (k), and (1),~70.59, and 70.60(b) and (c) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
5.
A new paragraph:(w) is added'to S 70.4 to read as follows:
S 70.4 Definitions.
(w) Irretrievable well-logging source" means any sealed source containing licensed material that is pulled off or not connected to the wireline that suspends'the source in the well.and for which all reason-able effort at recovery has been expended.
6.
A new S 70.60 is added under the center heading "Special Nuclear Material Control, Records,~ Reports and Inspections," to read as follows:
1 Well-l'gging operations using. sealed sources.
S 70.60 o
~(a) A licensee may-perform well-logging operations with a. sealed source only after the licensee executes a written agreement with the,
-well owner or operator that, within thirty (30) days after a well-logging i
. source has been classified as irretrievable, the following requ rements
- will be implemented:
9
t-
- J (b)' When a well-logging source becomes irretrievable, the licensee shall:
(1) Notify the Regional Administrator of the appropriate NRC Regional Office listed in Appendix D of Part 20 of this chapter of the circumstances of the loss by telephone; and (2) Obtain approval to implement abandonment procedures.
(c) The licensee shall, within 30 days after a well-logging source has been classified as irretrievable, make a report.in writing to the appropriate NRC Regional Office listed in Appendix D of Part 20 of this chapter. The licensee shall send a copy of the report to each appro-priate State agency that has authority over the particular well-drilling operation.
The report must contain the following information:
(1) Date of occurrence.
(2) A description of the irretrievable well-logging source involved, including radionuclide, quantity, and chemical and physical form.
(3) Surface location and identification of well.
(4) Results of efforts to immobilize and seal the source in place.
(5) Depth of source.
(6) Depth of the top of the cement plug.
(7) Depth of the well.
(8) Aiy other information (e.g., warning statement) contained on the permanent identification plaque.
(9) Notifications made to State gencies.
(10) A brief-description of the attempted recovery afforts.
(d) Any licensee or. applicant for a license may apply to the Commission for approval of proposed procedures to abandon an irretriev-able well-logging source in a manner not otherwise authorized in para-graph (a) of this section.
PART 70 - DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL 4.
The authority citation for Part 70 is revised to read as follows:
AUTHORITY:
Secs. 51, 53, 161, 182, 183, 68 Stat. 929, 930, 948,,953, 954, as amended (42 U.S.C. 2071, 2073, 2201, 2232, 2233); secs. 201, as amended, 202, 204, 206, 88 Stat 1242, as amended, 1244, 1245, 1246 (42 U.S.C. 5841, 5842, 5845, 5846).
8
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i (1) Each irretrievable well-logging source must be immobilized and sealed in place with a cement plug.
(2) A whipstock or other deflection device must be set at some
_ point in the well above the cement plug, unless the cement plug and source are not accessible to any subsequent drilling operations.
(3) A permanent identification plaque, constructed of long lasting material such as stainless steel, brass, bronze, or monel, must be mounted at the surface of the well, unless the mounting of the plaque is not practical.. The plaque must contain --
(i) The word " CAUTION";
(ii) A radiation sy'mbol (the color requirement need not be met);
(iii) The date the source was abandoned; (iv) The name of the well owner or well operator; (v) The well name and well identification number (s) or other designation; (vi) An identification of the sealed source (s) by radionuclide and quantity of activity; (vii) The depth'of the source and depth to the top of the plug; and (viii) An appropriate warning.
(b) When a well-logging source becomes irretrievable, the licensee shall:
(1) Notify the Regional Administrator of the appropriate NRC Regional Office listed in Appendix D of Part 20 of this chapter of the circumstances of the loss by telephone; and (2) Obtain approval to implement abandonment procedures.
(c) The licensee shall, within 30 days after a well-logging source has been classified as irretrievable, make a report in writing to the appropriate NR'C-Regional Office listed in Appendix D of Part 20 of this chapter.
The licensee shall send a copy of the report to each appro-
. priate State agency that has authority over the particular well-drilling operation; The report must contain the following information:
T(1) Date of occurrence.
'(2) A description of the irretrievable well-logging source involved, including radionuclide, quantity, and chemical and physic.a1 form.
(3) Surface location and identification of well.
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(4) 'Results of efforts to immobilize and seal the source in place.
(5)
Depth of source.
(6) Depth of the top of the cement plug.
(7)
Depth of the well.
(8) Any other information (e.g., warning statement) contained on the permanent identification plaque.
(9) Notifications made to State agencies (10) A brief description of the attempted recovery efforts.
(d) Any licensee or applicant for a license may apply to the Commis-
-sion for approval of proposed procedures to abandon an irretrievable well-logging source in a manner not otherwise authorized in paragraph (a) of this section.
PART 150 - EXEMPTIONS AND CONTINUED REGULATORY AUTHORITY IN AGREEMENT STATES AND IN OFFSHORE WATERS UNDER SECTION 274 7.
The authority citation ~for Part 150 is revised to read as follows:
AUTHORITY:
Sec. 161, 68 Stat. 948, as amended, sec. 274, 73 Stat.
688 (42 U.S.C. 2201, 2021); sec. 201, 88 Stat. 1242, as amended (42 U.S.C.
5841)
Sections 150.3, 150.15, 150.15a, 150.31, 150.32 also issued un' der secs. 11e(2), 81, 68 Stat. 923, 935, as amended, secs. 83, 84, 92 Stat.
3033, 3039 (42 U.S.C. 2014e(2), 2111, 2113, 2114).
Section 150.14 also issued under sec. 53, 68 Stat. 930, as amended (42 U.S.C. 2073).
Sec-tion 150.17a also issued.under sec. 122, 68 Stat. 939 (42 U.S.C._2152).
Section 150.30 also issued under sec.'234, 83 Stat. 444 (42 U.S.C. 2282).
For.the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
2273); SS 150.20(b)(2)-(4) and 150.21.are issued under sec. 161b, 68 Stat.
948, as amended (42 U.S.C. 2201(b)); 5 150.14 is issued under sec. 1631, 68 Stat. 949, as amended (42 U.S.C.,,2201(i)); and SS 150.16-150.19 and 150.20(b)(1) arel issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C.' 2201(o)).
i 8.
Remove the authority citations following SS 150.3, 150.14, 150.15,c150.15a,.150.30, 150.31, and 150.32.
11
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In S 150.20, the introductory text of paragraph (b) is revised 9.
to read as follows:
S 150.20 Recognition of Agreement State licenses._
(b). Notwithstanding any provision to the contrary in any specific license issued by an Agreement State to a person engaging in activities in a non-Agreement State or in o.ffshore waters under the general licenses provided in this section,,the general licenses providad in this section are subject to the provisions of SS 30.7(a) through (e); 30.14(d) and SS 30.34, 30.41, and 30.51 to 30.63, inclusive, of Part 30 of this chapter;
$ 40.7(a) through (e) and SS 40.41, 40.51,-40.61 to 40.63, inclusi've, 40.71' and 40.81 of Part 40 of this chapter; and S 70.7(a) through (e) and SS 70.32, 70.42, 70.51 to 70.56, inclusive, 70.60 to 70.62, inclu-sive, and 70.71 of Part 70 of this chapter; and to the provisions of In addi-Parts 19, 20, and 71 and Subpart B of Part 34 of this chapter.
tion, any person engaging in activities in non-Agreement. States or in off-shore waters under the general licenses pro'vided in this section:
Dated at Bethesda, Maryland, this -l'il day of b
983.
For the Nuclear.Regulato Commtssion.
Lk ur%
Jack W. Roe Acti Executive Director for Operations I
e, 12 L-l
The Honorable' Alan Simpson, Chairman Subcommittee on Nuclear Regulation
' Committee on Environment and Public Works
. United States Senate i
Washington, DC.-20510
Dear'Mr. Chairman:
The NRC'has sent to the Office of the Federal Register for publication the
- enclosed amendments to the Commission'.s rules in 10 CFR Parts 30, 70, and 150.
The. amendments establish requirements to be accomplished by licensees in the event of an irretrievable well-logging source.
An irretrievable well-logging source is-any source containing licensed material that is pulled off or not connected to the wireline that susaends the. source in the well and for which all reasonable. effort at recovery las been expended.
- This rulemaking requires:
.(1) anagreementbetweenthewell-logger (Commissionlicensee)andthewell owner or operator (non-licensee) to accomplish certain abandonment proce-dures in t.5e event of an irretrievable well-logging source; (2)' sealing the well-logging source in place with a cement plug;
_ (3) setting a~ deflection device in the well;
'(4) mounting a~ permanent identification plaque at the~ surface of the well; and (5) ' reporting the circumstances concer'ning the irretrievable source to the Commission and to pertinent State' agencies within thirty days after the source has-been abandoned.
These reguirements:are similar to requirements already in place in many States
. and p.rovide a uniform set of requirements for radiological safety in the event of an' irretrievable well-logging source.
Enclosed also.for your information is a copy of an announcement to be released to the public.
Sincerely, Robert B. Minogue, Director Office of Nuclear Regulatory Research
Enclosures:
- 1.
Notice?of rulemaking-
-2.
Public announcement 7
cc:-. Senator Gary Hart
NRC ISSUES' AMENDMENTS TO REGULATIONS REGARDING t
WELL-LOGGING-SOURCES LOST DOWNWELL t
i
,i The Nuclear Regulatory Commission is amending its regulations to establish uniform requirements for actions which must be taken in case a well-logging source is irre-trievably lost downwell.
A well-logging source is a scaled source containing a radioactive material which, with measuring devices, is 5oweredintothewellandthenretrievedinordertoobtain a graph'or log:of information about the well.
Well-logging
.is performed in oil, gas, mineral and geothermal wells.
10cca'sionally, a logging tool containing a sealed source is pulled off or otherwise lost downwell.
Records indicate that this has happened about 100 times in the past 20 years.
.. Any risk associated with these incidents is sufficiently small so as-not to cause.an undue health and' safety hazard.
Previously, licensees were required-to' spell out in their license application the~ actions'they would take in a-
- well-logging incident and these actions:were reviewed by NRC, before the application was approved.
The NRC believes that, e
ha m_' - -4
r-.
cin order to assure.that.the public is protected properly, uniform' actions to be taken should be, described in its regulations.
Under'the new amendments, licensees who use well-logging sources and irretrievably lose them are required, within 30 days, to:
(a) immobilize and seal the source in place in the well with a cement p,1ug;
(. b) set a "whipstock" o'r other deflection device in the well--except in instances where the cement plug and source are not accessible to any further drilling; (c)-pount a permanent identification plaque--with appropriate information--at the-surface of the well; and.
(d) report-the event in writing to the NRC and appro-priate State agencies.
The amendments to Part 30 and to Part 70 of NRC regula-tions will become effective on days after publication in the Federal Register on 9
O
_W9
'N.
w-.
7..
DAILY STAFF NOTES DIVISION OF RISK ANALYSIS 0FFICE OF NUCLEAR REGULATORY RESEARCH Final Rule to be signed by ED0
_, 1983, the Executive Director for Operations approved a final On rulewhichrevises10CFRParts30,70,and150.
This rule provides require-ments to be followed in the event of an irretrievable well-logging source.
This rule requires licensees to:
(1) Seal the well-logging source in place with a cement plug.
(2) Set a deflection device in the well.
(3) Mount a permanent identification plaque at the surface of the well.
(4) Report the circumstances concerning the irretrievable source to the Commission and to perti,ent State agencies within thirty days after the n
source has been abandoned.
~
This notice constitutes notice to the Commission that, in accordance with the rulemaking authority delegated to the E00, the E00 has received this final rule to the Office of the Secre-and proposes to forward it on tary for FR publication, unless otherwise directed by the Commission.
^
p l
s REGULATORY ANALYSIS j
10 CFR Parts 30 and 70
^
Irretrievable Well-logging Sources.
3 i.
1.
Statement of the Problem Existing Commission regulations do not address safety reyuiresents for irre-trievable well-logging sources. An evaluation of information on practices, procedures and regulation of~ licensed material in the well-logging industry suggested a need for uniform requirements for irretrievable well-logging sources to assure safety. -The Value/ Impact Analysis in Secy-78-411 indicated a positive value in the uniformity of safety requirements and, except for the expenditure of staff resource's for. generation of the regulation, negative impacts were nonexistent. Thisjregulatory analysis reaches a similar conclu-sion and recommends publishing'the final rule in the Federal Register. The final rule would be signed by 'the Exective Director for Operations under authority delegated in 10 CFR 1.40(d).
.y An irretrievable well-logging source is defined as any sealed ; source' contain-ing licensed material which is pulled off or not connected to its wireline in
. the' well and for which all reasonable effort-at recovery has been expended.
The Nrm, "well-logging," is used for operations consisting of the _louring and rat ng of measuring devices or " tools" into well-bores or cavi. ties for
- ]
i the purpose of obtaining information about the well and/or adjacent forma-tions. The term, " mineral-logging," is associated with logging performed for a
~
the purpose of mineral exploration (e.g., in coal fields) rather thari in oil or. gas wells, Approximately' 160-170 Commission licensees are authorized to conduct well-logging activities. These activities have been increasing'since the onset o,f
. overseas oil supply problems in the early 1970's. Over 50,000-wells are f
logged per year and a single well may be logged from l'to 15 times by a 1
'1
~ l l-
t M
~
combination of methods over its lifetime.
Secondary and tertiary oil recovery tethniques raise the issue of possible recntry of wells containing an abandoned source.
At present, the Commission treats abandonment of irretrievable well-logging sources as a condition of the well-logger's license and requires the ifcensee "to specify the abandonment.and identiffcation procedures that will be used for an indident of this type.
Since some logging companies operate on an inter-state basis and since these activities are licensed by the Commission and the i
.C-Agreement States, uniformity in content and application of abandonment and identification-procedures is important.
In addition, legally binding require-n.ents for the well-owner or the well-operator (when neither is the licensee) u are required 4to assure radiological safety.
.\\ radiological hazard 'could occur if an irretrievable well-logging source was damaged by subsequent operati'ons and the radioactive material was brought to the surface by some means. Well-logging sources typically used in these opera-tions contain americium-241/ beryllium (5 to 19 curies, half-life 458 years) and cesium-137 (several millicuries to 2 curies, half-life 30 years).
Rupture of these sources and subseguent return of the radioactive material to the surface The result-during drilling operations would present a contamination problem.
<ing contamination could require extensive decontamination of the well-site, drilling equipment, vehicles, and personnel.
Loggir.g tools represent a considerable financial investment and are not abandoned without serious attempts._t recovery when they become detached from the. wireline. The decision to abandon is usually governed by the economic a.spects of each incident, for example, the cost of the logging tool versus the cumulative cost of recovery attempts, abandonment procedures and well down-
' time. A r6 view of well-logging activities since 1958 showed an average of five irretri.evable well-logging incidents per year.
\\
b 2
i y
Ys
.Taking:no action to address irretrievable well-logging sburce incidents would continue.to treat' abandonment and identification procedures as a condition of the.vell-logger's license. The current situation does not provide assurance ci that 'icense conditions would be accomplished in the event of an abandonment
~because-refusal-by=the well-owner /well-operator to implement the abandonment'
- procedures is'not-addressed.
1 2
L2.
- Objectives Accordingly, the-final revision of the existing regulations focuses on the-following five objectives:
.Providing a-legally binding requirement for th'e well-owner /well-a.
x3~
operator to assure completion of abandonment procedurescfor any
-irretrievable well-logging source;
' b.
Preventing damage t'o the well-logging sealed source; p
-c.
LImmobilizing the:well-logging source;
- d.. Providing notice to persons wishing to reenter the well'of'the ex'istence of the irretrievable source.in the well; and~
e; l Reporting;the_ loss to the Commission and State Agencies having
~
,y
-jurisdiction.over the well.
L 3i Alternatives LThe: regulatory alternatives to assure long-term; containment of irretrievable
~
well-logging sources are:
a a.
Continuetto impose' requirements for irretrievable well-logging sources byfindividual license condition;
/ p y
.~
b.
Relyfon State and' local controls in the event of an irret'rievable-well-logging source; and
. Adoption of1the amendments to provide uniform safety-requirements
~
'c,
~
lbida-legalcommisment'toperformtheserequirements'forirretriev,-
~
o en c,
-able~well-logging ' sources.
0 3-
-Enclosure 5
~
S'
3.1 Individual license condition (status quo)
- This alternative was considered unacceptab1'e since it fails to provide a legally binding consent prior to commencement of well-logging operations by the nonlicensee 'well-owner or well-operator to implement abandonment proce-dures'needed_to assure prevention of damage to the source, immobilization of the source:and. posting of the well-site.
v i
L 3.2 State and local controls l
This alternative was considered unacceptable since:
f the legal authority for non-Agremeent States to address the radiological
~
aspects of well-drilling activities may La questionable because of the i
pre-emption of authority to the Commission in the Atomic Energy Act of 1954, as amended; i
safety requirements for well-logging sources may not be uniform in all cases;
' control ~of radiological' safety could not-be assured by pertinent agencies since there are'24 non-Agreement States; and individual State regulations would have to be implemented to require prior legally-binding consent for performing abandonment procedures for-irretrievable well-logging sources.
l3.3 Adopt the amendments This alternative was considered acceptable since; it:provides:a rule that contains. uniform and. adequate safety requirements to be accomplished in the event of.an irretrievable well-logging source;
~
4
it provides the well-logging licensees with a Federal regulation to use
.as a reference in their contractural arrangements with the well-owner or well-operator;.
it results in little incremental cost relative to Alternative 3.1 since recommended requirements are already conditions of most licenses;
.commenters generally supported the proposed rulemaking (43 FR 44547); and it relieves the license applicant of the burden of specifying acceptable procedures to be used in the event of an irretrievable well-logging source.
4.
' Consequences The ~ examination of possible alternative regulatory actions completed in Sec-tion 3 shows a clear advantage to adopting the proposed requirements for irre-
-trievable well-logging sources.
In this section, this analysis will focus on the consequences associated with this regulatory alternative.
14. 1 Discussion of the final amendments As-originally proposed September 28, 1978 (43 FR 44547), the amendments-to the regulations would establish requirements for:
preventing damage to the irretrievable well-logging source; immobilizing the source;-
mounting a permanent identification plaque at the well-site; and
-reporting the' incident to the Cummission and appropriate State Agencies.
4.1.1 Damage prevention SectionsI30.56(a)(1) and 70.60(a)(1) require immobilization and sealing in place of each' irretrievable well-logging source.with a cement plug.
Sections m
5
30.56(a)(2)'and 70.60(a)(2) require a deflection device to divert a drill bit should be well be reentered.
Sections 30.56(a)(3) and 70.60(a)(3) require a
. permanent identification plaque be mounted at the surface of the well tu pro-vide a' warning that an irretrievable well-logging source is below.
These requirements are the responsibility of the well-logger (Commission licensee). Since the well-logger' frequently is not the well-operator or well-owner, the amendments require an agreement that the procedures will be carried out by the well-operator or well-owner in.the event of an irretrievable well-icgging source.
The immobilization, protection and posting requirements pro-
. vide reasonable assurance of radiological safety and continued control.
The agreement between the w' ell-owner or operator and the well-logger provides
-assurance that the requirements will be accomplished when needed.
4.1.2 Reporting requirements Sections-30.56(b) and 70.60(b) require that each licensee notify the Commission by telephone and request approval to implement abandonment procedures after failure'of recovery efforts. This request substitutes for the report currently described and contained in the license application dealing with initial notifi-cations. -This request alerts the Commission's Regional Office of the occur-rence of a potential irretrievable well-logging source.
In a case of actual or possible dispersal of radioactive material, the Regional Office can take appro-priate action based on the nature of the incident.
This notification also provides the Commission ~with the knowledge that the requirements for-treating the irretrievable well-logging source are in process or about to be put in process.
Sections 30.56(c) and 70.60(c) require a written report within 30 days of an event with a copy to the appropriate State' Agency.
This report replaces a
' licensing cordition specifying similar_ actions. This information enables the Commission to determine if all safety requirements were fulfilled, perform an analysis'of the incident if needed and determine final disposition. Without-this,information, Regional field personnel would be needed to monitor the
-performance of the safety requirements. Without assurance that the safety 6-
_J
i requirements were fulfilled, there is less confidence in the long term conta n-m;nt characteristics of the source.
l 4.2 Costs / benefits of the final amendments 4
4.2.1 NRC operations i
i i
The amendments provide uniform safety requirements, a legal commitment by the idents and
- well-operator or well-owner to implement these requirements for inc f
An addi-more uniform long-term control of irretrievable well-logging scurces.
tional benefit is the slight simplification of the licensing process for the Also, the NRC's cognizance of each incident before materials licensing staff.
the well-logging source is determined to be irretrievable is an additional-t benefit.
i In addition to the cost'already incurred in developing the rule, an average.
~
l cost of $8,500 annually is estimated for the final rule in implementation.
i j
The recordkeeping requirement in SS~30.56(a) and 70.60(a) requires review dur-Confirmation of the ing routine NRC inspections of well-logging licensees.
l presence of an aoandonment clause for irretrievable well-logging sources in th' A review licensee's agreement records is sufficient to demonstrate compliance.
i
'of a representative sample of the licensee's records an hour per inspection.
If each' hour is assumed to cost 550 and about 160 licensees are inspected annually, this review results in an estimated annual cost of S8,000 to the NRC.
The permanent identification plaque specified in SS 30.56(a)(3) and 70.60(a)(3) is intended to warn, anyone reentering the well of -the presence.of an abandoned ided
. A description of the plaque is included in the' written report, prov source.
Additional NRC review of the by the licensee under SS 30.56(c) and 70.60(c).
However, an inspector could verify its presence in the plaque is unnecessary.
field during a routine inspection of the well-logging operation of a licensee.
At S50 per pro -
-An estimated I hour is needed for this verification activity.
fessional hour and 'five'such plaques per year, estimated cost to the ~NRC for' these plaques is S250.
7-
_-__--_.u
_2__--_
_._..__.m-.____..-_m
The' notification under SS 30.56(b) and 70.60(b) requires NRC Regional Staff y r re su d tS0 r r s
a our t s e t
n n tm ed cost of_5500 to the NRC. This cost is uneven since Regions III and IV have
[
'the higest rate.of well-logging sources.
- Review of each written report under'SS 30.56(c) and 70.60(c) rbquires one pro-fessional hour. 'At a rate of five reportable incidents annually and 550 per professional hour as assumed above, total estimated costs for this requirement are.approximately 5250 per year. These reports would be placed in the Regional Licensee files and summarized in the computer records of reportable incidents.
Additional costs associated with these activities are approximately 5500
. (approximately $100 per file / computer entry).
An additional one-time expense of $1200 under Billing Code 7950-01 for publica-
' tion of the final rulemaking'in the Federal Register is anticipated. Addi-tional costs and efforts associated with revisions to NRC Rules and Regulations a're also anticipated.
.4.2.2 Other government agencies
' Publication of the final rule will be cost-reimbursable for the Government
~Printi.ng Offi_ce, as noted above.
. State agencies having jurisdiction over well-drilling operations will. receive notifications and reports for future incidents of irretrievable well-logging Many States have. existing programs si.nce similar requirement's have sources.
been suggested by the Conference of Radiation Control Program Directors
'(" Suggested StateLRegulations for Control of Radiation, Part W").
Estimated rtimes for each State in which an incident occurs are simi ar to NRC staff l
= hours,;i.e., 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per incident.. In some States, for example 0klahoma or WyomingL more than one irretrievable well-logging source incident per year
~
Lcould be expected due.to heavy oil and gas exploration. The majority of States, however, average less than one incident per year based on data of
~
reported incidents. Previous experience has shown an average of five irre-trievable well-logging source incidents per year.
8 I-4.-
4.2.3 Industry.
Commission licensees are benefited by the contractural requirement in SS 30.56(a) and 70.60(a). The licensee has a reedy reference for these proce-
'dures regarding abandonment'and a Federal requirement to help the licensee fulfill current license conditions.
i ALsmall. additional benefit accrues to Commission licensees in the simplifica-An additional benefit results from uniform-tion of the NRC licensing process.
ity in content'and application of abandonment and identification procedures I
between_the NRC and the Agreement States.
The additional costs' to Commission licensees can be estimated if an average of The five irretrievable well-logging source incidents annually is postulated.
- costs to the _ oil and gas industry can also be estimated by making this
~
assumption.
An ' agreement-(contract) specifying rights and duties is a normal course of The business between the well-logger and the well owner or well operator.
requirements in.SS 30.56(a) and 70.60(a) add a standard clause or provision to
.this existing agre'ement.
4
'An upper estimate of the burden.which this requirement imposes on well-logging licensees can'be drawn if it is assumed that the licensee retains these agree-It is -
ments only for review by the NRC (instead of normal business records).
further assumed that'each of the 50,000 wells logged annually is covered by a separate agreement _and each agreement must have a clause inserted by the Each licensee has the standard clause drawn by a
- -licensee's clerical staff.
However, once drawn, the-professional at a rate of.550 per professional hour.
-clause is used repeat?dly. Preparing the standard clause requires 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the-professional's time.
Each licensee receives a burden of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of. professional time at a cost of Preparation of the standard clause results in a total.of 160 professional
- 550'.
Clerical support hours at an estimated cost of $8,000 for all 1_icensees.
9
_ - _ _ _ _ _ _ = _ - _
L needed to. insert this clause is aproximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per licensee at an esti-Addition of this standard clause to each of 160 licensees mated cost of $600.
results inLan estimated 4,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of clerical support time at an estimated
- total cost of $96,000.
If each' agreement is 1/4 inch thick, each licensee stores approximately 5 cubic Total storage results feet of_ records annually at an estimated cost of $1,000.
in approximately 800 cubic feet of records with a total storage cost to all licensees of-approximately S160,000.
The total upper estimate of the burden to each licensee is I hour of profes-sional time, 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of clerical support time, and 5 cubic feet of records Total estimated cost per licensee for this recordkeeping is 51,650.
annually.
This estimate of the burden and costs to-each well-logging licensee for record-keeping is considered to be hibh since the standard clause can be preprinted I
once drawn and agreements may cover more than one well (if operated by the same In addition, these agreements are normally retained by the licensee company).
.as a normal course of business recordkeeping for tax or other purposes.
~
If a well-logging tool becomes separated from its wireline during logging of a producing'well, costs associated with continued attempts to recover the tool would include lost production ~ time, rental costs of recovery, (" fishing") equip-Replacement costs for a.well-logging tool are estimated to~
ment-and crew time.
This cost must be balanced range from $25K to $100K with a me'dian of S40K.
against the accumulating costs of-attempted recovery.
~
A producing oil well may yield from 5 to 30 barrels of crude oil per day.
Assuming 30 barrels are produced daily at.529 to 534 per barrel, approximately Recovery crew and equip-
~S1,000 per day in estimated lost production results.
ment rentals are estimated at 53,000 per day based on the high range of esti-Total costs per day during attempted recovery are approximately mates obtained.
In 10, days, total recovery costs begin to exceed the replacement cost
$4,000.
of the well_ logging tool.
10
A Sections 30.56(a)(1) and 70.60(a)(1) require the placement of a cement plug to immobilize and. seal'the well-logging sources (tool) in place. Assuming that t
i the: depth to the well-logging tool is known with some uncrrtainty by the i
recovered length of wireline,;the. plug should cover the langth of the tool and
-that uncertainty. -A typical plug might be_100 feet to';rovide reasonable assur-
~
At an
.ance.that the well-logging tool was adequately sealed and immobilized.
assumed well-bore of-1 foot, less than 3 cubic yards of cement are required.
Placement of -the plug may require an sdditional. day's time for the crew and Total estimated cost for this_ requirement is S4,000.
equipment.
Sections 30.'56(a)'(2) and 70.60(a)(2) specify a deflection device to divert a drill bit should the-well be reentered. Total estimated cost of'this item is It can be placed by the crew providing the seal.as a portion of the 51,000.
-immobilization effort.
Sections 30.56(a)(3) and 70.60{a)(3) require a permanent identification plaque at the surface. of the well to provide a warning of the presence of the source.
An estimate of the cost for each identification plaque can be made if the plaque is assumed to be a stainless steel plate 7 inches square by 1/8 inch
. Fabrication of the: engraved
. thick engraved and installed at-the well site.
plate is expect'ed to cost no more than $250 baseduon reviews of NRC records of Installation of the plaque is. expected'to take less than past incidents.
Total
.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of a craftsman's time at an assumed rate of S30 per craft hour.
estimated cost of this plaque is'less than $300 per incident.
~
.The. telephone notification required in SS 30.56(b) and 70.60(b) may require 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of,a professional's time'for each incident. Assuming 550 per profes-sional hour, each licensee' experiencing ~an irretrievable well-logging source-This estimate is the incident incurs a cost of 5100 for this ' notification.
result of review of' existing NRC records for the time involved and the assump-
~
tion that-the radiation' safety officer or a similarf professional. makes the report.
The written report'provided by the' licensee under SS 30.56(c) and 70.60(c)
~ requires 10 items relating to the irretrievable well-logging source incident.
11
Review of reports submitted as a result of the existing license conditions indicates that the average licensee prepares a. letter containing the required I
Preparation of the report (letter) is assumed to require the information.
assembly of data gathered during the abandonment, preparation of the report and submittal to appropriate agencies. The assembly and preparation of the report from existing data required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the professional's time.
Typing and submittal of the re' port by clerical support personnel requires an additional Assuming $50 per professiona1 hour, the total estimated cost per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
i report is $200 for preparation and assembly. Assuming $20 per clerical support Each l
hour, the typing and submittal of each report costs an additional 580.
written report costs an estimated $280.
Total cost for abandoment of an irretrievable well-logging source is therefore l
estimated to be 55,680 ($4,000 + $1,000 + S300 + S100 + S280).
f Smaller well-logging companies (including one-truck operations) are subjected to the same requirements as larger companies. However, analysis of abandoned source incidents-indicates that less than one of these companies experiences an The burden of the economic losss of the well-logging abandonment each year.
tool exceeds the costs of these amendments for these smaller companies. Signi-ficant impacts on. smaller well-logging companies were not suggested in any of the comments received on the proposed rule.
i 4.2.4 Public i
l This rule will provide a benefit to the public by further reducing the risk of accidental contamination of existing supplies of oil, gas and minerals by rup-ture of irretrievable well-logging sources.
Economic impacts are negligible since the costs to the well-logging industry for lost well-logging tools far exceed those associated with these amendments.
Thus impacts on the costs for oil, gas or minerals associated with these amend-ments are very small.
12
"4.3-Risk of previously-abandoned well-logging sources r
The issue of possible reentry.of wells containing abandoned well-logging sources was examined in SECY-81-516.
This risk analysis concluded that the reduction in'the radiological risk did not warrant the effort of assuring that the aban-danment procedures specified in this rulemaking action be accomplished for previously abandoned sources. However, a surkey of previously abandoned well-logging sources has been completed,and notifications to the State agencies having jurisdiction has been made. A request for a notation in the well records of the presence of an abandoned source as appropriate, for each aban-l r
donment identified in the notification was made. No cases of abandoned sources being' drilled through as a result of reentering a well have been recorded.
j Thus, this rule will not be made retroactive.
4.4 Impacts on other requirements 4
1 A positive. impact in uniformity of requirements for irretrievable well-logging sources _was noted. This benefit should be helpful to regionalization of Commis-sion licensing and enforcement activities.
- No negative impacts on other requirements were noted.
L4.5 Constraints There are no constraints on this rulemaking activity in scheduling, enforceabil-ity, policy, institutional or legal considerations.
- 5.
Decision rationale An assessment of the costs and benefits of the amendments to 10 CFR Parts 30 and 70 leads t 1 the conclusion that there 'will be a positive impact from the uniformity of safety requirements for irretrievable well-logging sources.
Costs associated with this action are low. Therefore, the proposed action 1,s recommended. Our decision is supported by both the quantified cost data and a reasoned judgment on safety.
13
1
~.
. 6.
- Implementation
~
!8.11 Schedule b
The framework for implementation
.No implementation problems are anticipated.
4
.is:already well-established'in the current conditions.for well-logging licensees.
lNaterials licensing and en'forcement staffs are already familiar with these.
. requirements.
f 6.2-Relationship to other schedules
-The~ action willIbe followed by a-proposed incorporation of the requirements of theLSuggested State Regulations for the Control of Radiation, Part W as a pro-4 This action could'either be completed or dropped in
~
g.
posed Commission rule.
~ However, dropping this action would delay the promulga-
- favor of that' effort.
tion.lof:effectiv'e requirements'for-irretrievable well-logging sources until-final action is. completed on the more general well-logging rulemaking.
i
^
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14
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F
' Analysis of Public Comments 10 CFR Parts 30 and 70 Irretrievable Well-Logging Sources 1.
Paragraphs 30.4(x) and 70.4(w)
" Irretrievable well-logging source" means any sealed source containing licensed
{
mater.ial.that-is' pulled off or not connected to the wireline downwell and for which all reasonable effort at recovery, as determined by.the Commission, has L
been expended.
j Comments
. Letter 1:
"The Commission does not have nor should they require expertise in such decisions which are more effectively made between the operator and drilling l
permitting agency."
Letter 4:. "The ultimate expertise in the determination of what is a reasonable attempt _at-recovery lies with the combined knowledge of the licensee, the operator of _ the'well and the fishing tool operator."
Lletter 6:
"We.suggest that a.better wording would be to say 'as agreed by the
-Commission after consultation with the logging operatio'n' "-
~
Letter 8:
"The proposal, that the determindation as to when a logging source should be. deemed to be irretrievable be that of the Nuclear Regulatory Agency, should be carefully considered so that'no unusual delay would result with unnecessary losss of money to the oil operator."
Letter 9: - Furthermore, it is doubtful that the NRC has the manpower, at present, to make a site visit each' time a licensed source is lost downwell, in order to observe recovery. efforts...the well operator is:in the best position (to make the determination)..."
-Letter 10:
"We believe that the personnel drilling the well would be-in a
~
much better position-to determine if a logging tool is irretrievable or not due to familiarity with well conditions.
The new proposals have the potential to delay costly well operations without' adding significant safety benefits."
- Analysis Although it was; intended that the Commission would determine if a source is irretrievable only'after consultation with the various parties' involved, such as drilling operator, wel1-logging operator, fishing tool operator, etc., the staff. agrees that the proposed definition may be unduly restrictive.
Accordingly, the phrase "as determined by the Commission" has been deleted.
However, it should be noted that even with-this change, Paragraph'30.56(b) and 70.60(b), as revised, still' provide the Commission authority to determine if-
"all reasonable effort at recovery has been expended."
1
Action h
" Irretrievable well-logging LChangeParagraphs30.4(x)and.70.4(w)toread: source"zmeans any sealed s off-'or not connected to.the wireline that suspends-the source in the well and for which all reasonable effort at recovery has been expended."
2.
Paragraphs 30.56(a)-and 70.60(a) i "A licensee may perform well-logging operations with sealed sources only in
. wells forfwhich the well-operator or Nell owner has previously executed a
-written agreement that assures the implementation, within 30 days of an event
~
of an-irretrievable well-logging source...
- m Comments.
F~
" Insert the words 'with the licensee'_ after the word ' agreement.'
V Letter 1:
Replace 'within thirty (30) days of an event of an irretrievable well-logging
. source' with the-words 'within thirty (30) days 'after a lost source has been classified:as irretrievable.'"
i.'
d t-
."The 30-day time prescribed for completion of the aban onmen T'
Letter 4:
procedures should be' changed to 60 days with provision for 30. day extensions cas required."
"Some clarification, however, is needed in naming the party with i'
tLetter 5:
1which the agreement should be made, i.e., the Director of NRC Regional Office,
~
the responsible State agency or possibly'some other office of NRC."
"...previously-written agreement may-very well be dif ficult to Letter:6:
obtain.,The well operator,:in many cases, might be reluctant to sign such an agreement, although he would have every intention of complying with our request to the best of his ability."
... requires a written agreement but doe's _not specify the parties
- L'etter 7:
to_the agreementi..The phrase ' thirty (30) days of an event...' should be reworded to ' thirty.(30) days of final abandonment...'"
a "It is noted that'(the agreement).is between the well operator or well owner (a nonlicensee of the Commission) and the well-logging company (a
-Letter 9:
~
0 In the event such agreement is not honored by the well Commission-licensee).~
operator,-against whom does the NRC propose to take action?"
Analysis i
h
.T_he staff. agrees with the comments regarding classification of the part es w o.
must. execute the' written agreement, and the time period within which abandon-ment procedures must be implemented.
Accordingly, these sections have been e
. revised.
-Concerning the situation in which a well owner or operator fails to honor an agreement with the licensee, the licensee will be responsible.for ensuringIf the
'that?the. requirements in..the regulations are met.
} :.
2-v l
fails to_ honor the agreement, the licensee must pursue every legal avenue to ensure compliante, or face possible penalties for failure'to comply with the regulations.
Action Change Paragraphs 30.56(a) and 70.60(a) to read:
A licensee may perform well-logging operations with a sealed source only after the licensee executes a written agreement with the well owner or operator that, within 30 days after a well-logging source has been classified as irretrievable...
3.
Subparagraphs 30.56(a)(3) and 70.60(a)(3):
" Caution The mounting of a permanent identification plaque (containing:
Radioactive Material," radiation symbol without color requirement, "Irre-trievable Well-logging Source," date of occurrence, well-owner and the city and State where his main office is located, well name and number, radionuclide and quantity of activity, source depth, plug-back depth, and appropriate warning) at the surface of the well.
A.
Comments Letter 1:
" Delete the wordi'ng "radionuclide and quantity of activity, source depth, plug-back depth.
Such information is on public record and Licensee files.
Plaques should be kept as concise as possible."
Letter 2:
... difficult to put large amount of wording on identification plaque...In our opinion all that is necessary to put on the plaque is the word
" Caution" accompanied by the radiation symbol and the full name of the well and well owner, but not his address..."
Letter 5: _"...We suggest that a plaque containing all of the information requested is not necessary...This warning may easily and effectively be served
" Caution-Radioactive," radiation symbol without color
-by a plaque containing:
requirement, well owner, well name and number, city and State where the well records are maintained, and appropriate warning."
"...Seems to be quite wordy..." Cautions" seems to be adequate if Letter 6:
accompanied by radiation symbol... unnecessary to say Irretrievable Well-logging Source since it would be evident...(since) addresses change the name (of the well-owner) should be sufficient..."
...If we use too many words, the plaque will not be read.
I Letter 7:
suggest that 'and the city and State where his main office is located' be deleted."
Analysis The. staff partially agrees that some of the information required in theThat an proposed procedure is unnecessary.If it were retrievable, there would be no need is abandoned is self-evident.
The
" Radioactive Materials" after " Caution" is not needed.
for the plaque.
city and State where a well owner or operator's main office is located may be 3
r
Accordingly " Irretrievable
-incorrect by the time a well is reentered.
Well-logging Source, " Radioactive Materials," and city and State where his main office is located have been deleted.
The-staff does feel, however,_that the rest of the information is necessary to inform adequately any person who reenters the well of the potential hazaros that may be encountered downwell.
-B.
Comments 1This.commenter suggested t-hat a plaque may not be feasible if the Letter 2:
well is; capped below " plow depth," below the " mud line," or below the surface of the water in offshore areas.
"Since it would be meaningless to mount any type of permanent
~ Letter 4:
identification plaque at an undersea location, we recommend that the abandon-ment procedures...with the exception of the plaque, suffice..."
" Add the wording 'In the event the well is permanently abandoned or Letter 8:
-results-in a completion where the well head is not at the surface, such as an underwater completion, no such plaque shall be required.'"
This commenter remarks that a pla.que serves no purpose in cases Letter 9:
where the well casing is cut.off below plow' depth or below the ocean bottom.
"(For) abandonment where it is required to cut and cap the casing Letter 10:
below the surface to restore' the location...the identification cap could be (For) abandonment under water, there is no practical placed on the well cap.
way to erect an identification plaque under water, so it is proposed to use iron oxide,as a dye marker in the last cement plug in the well as an appro-
~
priate warning."
Analysis
-The. staff partially agrees with these comments.. ' Erecting a plaque is an The plaque serves important-aspect for controlling irretrievable sources.
to warn of a potential hazard downwell, and of the necessity for taking appro-Therefore, the staff feels that priate precautions in the drilling process.the plaque must be used unless In the. proposed regulation the term " surface of the well" is used, Proposed (Regulatory Guide 6.8, " Identification Plaque for Irretrievable Well-Logging Sources," as guidance, provides for welding or bolting the plaque to the For inactive wells the plaque could be well-head structure for active. wells.
Thus, the plaque could still welded or bolted-to the. top of the casing cap.
be mounted on the casing cap if the casing were cut off below ground level.
Finally, the staff does not believe that a cement plug should have.a color requirement.. It ' appears that this requirement would have little value because it is doubtful that the color would be noticed during subsequent drilling oper'ations.
4
y i
- C.
. Comments-V t.
"~.. lost sources at a well on leased property, the operator no Letter 4:
. longer.hasithe legal right to maintain a plaque after the. lease terminates,
[
~has._been cancelled, or has been relinquished."
i l'
...it is therefore impractical and may be virtually impossible-to I.
Letter 6:
maintain a-(permanent) plaque af ter 'the land is no' longer under lease by the
[
~
. operator.~.. "
i I,
t Analysis' i
I A' permanent plaque is meant to be a long-lasting warning. device that will
- remain 11egible.and in place,lif unattended, for the approximate life of the j
[
iwell.
- I-It=seems reasonable that if the plaque meets this requirement for permanency, j
.no maintenance is necessary, s
[
The permanent plaque is only one aspect.of. control for irretrievable well-When this. aspect is combined with immobilizing-the source, k
' logging sources.-setting a deflection device about the' source,_and notifying the appropr
[L
~
State agency of the incident,' the licensee has provided maximum assurance.
possible that a wellfoperator_ or owner. will be adequately alerted if reentry Thus even if the plaque were' obliterated or j
to a. closed well:is'necessary.
removed for.some reason, the>other. required procedures would still provide
' Periodic
' assurance that the presence of the source-downwell would be known.
F maintenance of the plaques is not_ prescribed.
' Action:
_p A-Subparagraphs _30.56(a)(3) and 70.60(a)(3) have been revised'to read:
F
- permanent ~ identification plaque,~ constructed of long
- lasting material such a stainless steel, brass, bronze,~.orf monel, must' be mounted at the surface of-The plaque must
.the well,.unless-the mounting of the plaque is not~ practical.'" Caut abandonment, the.name of the well owner or operator, the~ well name and well-contain:
p Lidentification number (s) or other designation,'the sealed source (s) by radio-l.
[nuclide and quantity of activity,'the source depth and depth to the top of.
~
the: plug,' and an appropriate warning.
- 4..
Paragraphs 30.56(b) and 70.60(b):
In.the event of failure of-recovery efforts-for a sealed source which' is i
' h ll
. pulled.of.f cr not connected to the wireline-downwell, sach l censee s a request by telephone, to the Director of_the appropriate Nuclear. Regulatory-Commission-Inspection and Enforcement Regional Office listed in Appendix D of.
Part'20-of'this' Chapter, that-the Commission make a determination that the source is irretrievable.
' Comments-
' " Replace the wording ' request by telephone,sto the Director' by Letter-1:
' notify by. telephone, the Director. '"
5
.p g
" Replace the wording that the Commission make a determination that the source l
is.' irretrievable' by that a source.has been irretrievably lost. '"
Letter 4: This commenter-suggested that the Commission only be informed of an l
irretrievable well-logging event and that the licensee and the well operator determine is a source if irretrievat'le rather than the_ Commission.
i Letter 5:
"Since the cost of the retrieving effort and risks involved in
-possible loss of the well itself by continued efforts are normally assumed by the owner ce operator, the final regulation should allow the operator an l~
~
r opportunity ~to_ provide input into the " irretrievability" decision making by
{
-the Commission..."
"10 CFR Sections 30.56(b) and.70.60(b) should be reworded to require l
Letter 6:
telephone reporting of the circumstances surrounding the loss and recovery efforts to be reported to the Regional NRC office, or the appropriate State Regulatory Office and that the source has been deemed to be irretrievable."
Letter 7: _"I fail to see how representatives of the Commission will be able to 'make a determination that the source is irretrievable'...The NRC and i
agreement states should retain the right to question the decision, not make the decision."
~ Letter 8:
... require that the circumstances surrounding the loss and recovery efforts be reported to the appropriate Regional Office.
If the NRC does not agree that appropriate action has been taken, it may make the further stipula-tions-within the bounds'of its authority."
...We believe that the personnel drilling the well would be in a
- Letter 10:
much better position to determine of a logging tool is retrievable or not due to-their familiarity with well conditions.
The new proposals have the poten-
-tial to delay costly well operations without adding significant safety benefits."
Analysis:
As discussed in Item 1 the staff ~ agrees that the well logger, well owner or operator,~ fishing tool operator, etc., who are at the well' site.are in the
~
The staff realizes best1 position to determine if a source is irretrievable.
that-any delays in the' well drilling. operation, as might occur if the Commis -
sion needed to travel to the'well site to make the determination, may be
~
Accordingly, this section has been changed to require
~
costly to the operation.
that-.the licensee notify the NRC of the incident and request approval for
-implementation of abandonment procedures. --It should be noted that the Commis--
-sion may. deny approval fo the abandonment. procedures, if it feels that all
' reasonable effort at recovery' has not been expended.
~Regarding well. owner or operator interests, the staff feel that the rule provides for well owner or operator input in ' determining if a. source is u
The notification by the licensee will be made after discus-irretrievable.
sions with the well owner'or operator.
The Commission.will need this infor-
-mation to approve implementation of abandonment procedures.
l-6
Action When a well-Paragraphs 30.56(b) and 70.60(b) have been reworded to read:
logging source becomes irretrievable, the licensee shall notify the Regional Administrator of the appropriate Nuclear Regulatory Commission Regional Office listed in Appendix 0 of Part 20 of this Chapter of the circumstances of the loss by telephone; and obtain approval to implement abandonment procedures.
5.
Paradraphs 30.56(c) and 70.60(c):
The licensee shall, within thirty (30) days of an event of an irretrievable well-logging source, make a report in writing to the appropriate NRC Regional Office listed in Appendix 0 of Part 20 of this Chapter with a copy each to the Director of Inspection and Enforcement, ~U.S. Nuclear-Regulatory Commission, Washington, DC 20555, and to the appropriate State agencies that have authority over the particular well-drilling operations, setting forth the following information:
Date of occurrence; A description of the irretrievable well-logging source involved, including (1)
(2) radionuclide, quantity, chemical, and physical form; Surface location and identification of well; (3)
Results of efforts to ilhmobilize and seal the source in place; (4)
(5) Depth of source; (6) Depth of top of the cement plug; Depth of well; Any other information (e.g., warning statement) contained on permanent (7)
(8) identification plaque; (9) Notifications made to State agencies; and (10) A brief description of the attempted recovery efforts.
Comment Commenter suggests deletion of subparagraphs (4), (7), and (10).
Subparagraphs (4) and (10) would have been covered and are on record with theS Letter 1:
_ permitting agency and have no value for the Commission record.
also has not relevancy in a Commission record.
"I "I do not see the purpose of reporting the depth of the well.
see no purpose in requiring...a 'brief description'...(it) would run to several Letter 7:
pages of unneeded information."
"In the first sentence of this paragraph, change ' thirty days (30)
Letter 8:
days' to ' sixty (60) days.'"
Analysis The information in the report would The staff disagrees with these comments.
provide the Commission with sufficient information to determine whether th required procedures are properly implemented.
The report must contain
' documentation for future inquiries into the event.The description of the enough information to meet the requirements.
7
7 recovery attempts need not be detailed, but provide enough information to demonstrate to the Commission that all reasonable effort to retrieve the source had been expended.
However, the requirement that a copy of the report
- be sent to the Director of Inspection and Enforcement has been deleted.
Regarding the time period in which the report must be made, the analysis in Item 2 applies.
' Action Change Paragraphs 30.56(c) and 70.60(c) to read:
The licensee shall, within 30 days after a well-logging source has been classified as irretrievable, make a report in writing to the appropriate NRC Regional Office listed in Appendix D of Part 20 of this Chapter.
The licensee shall send a copy of the report to each appropriate State agency that has authority over the particular well-drilling operation. The report must contain the following information....
6.
Paragraphs 30.56(d) and 70.60(d)
Any licensee or applicant for a license may apply to the Commission for approval of proposed methods to be used in lieu of any of the requirements of paragraphs (a), (b), and (c) of these sections for an irretrievable well-logging source.
Comment Letter 5:
This letter suggests that these paragraphs be changed to permit the well owner-or operator to intercede in his own behalf to propose abandonment procedures that differ from Paragraphs 30.56(a) and 70.60(a).
Justification for this change is based on well owner or operator responsibility for making decisions that involve the status of the well.
Analysis The staff partially disagrees with this comment.
Paragraphs 30.56(a) and 70.60(a) require that the well-logging company (the licensee) execute a written agree-ment with the well owner or operator to assure implementation of the required abandonment procedures.
At the time of the agreement the well owner or oper-ator should discuss with the well logger any problems with implementation of these required procedures.
If the well owner or operator feels that certain
-requirements cannot be met, the well owner or operator should discuss the changes with the well logger and could assist the well logger in its discussion with the NRC.
However, any changes must be approved in advance by the Commission.
Action Change Paragraphs 30.56(d) and 70.60(d) to readi Any licensee or applicant for a license may apply to the Commission for approval of proposed procedulres to abandon an irretrievable well-logging source in a manner not otherwise
' authorized in paragraph (a) of this section.
8
7.
General.
A.
Comment
"... mention is made of what action the Commission proposes to take l
d Letter 9:
.with regard to any request to reenter a well which has been previously p ugge and abandoned on a request to produce in a zone where an abandonment or a request to produce in a zone where an abandoned source resides."
i A_nalysis -
In cases in which a source is abandonded in a well, the source is considered lost and 'not possessed.'
Consequently, operations involving wells with irre-trievable sources, such as wells being pumped or redrilled, are not subject to i
It should be noted that 30.56(c) and 70.60(c) require that NRC regulations. abandonment of a well-logging source be reported to the appropriate S agency that has authority over well-drilling operations.. Normally this agency will inform a redrilling operation of the presence of an abandoned source.
Action No action needed.
~B.
Comment "The loss of radioactive sources over the side of a drilling vessel Letter 3:
should also be addressed."
Analysis The requirements specified in 30.56 and 70.60 refer only to well-logging The sources that are lodged downwell and are classified as irretrievable.
h
. sources are not lost in the usual sense of word, becasue the licensee knows t e The actual loss of a location of the source; it just cannot be retrieved. source, such a a vessel, is addressed in 10 CFR 20.402.
Although procedures are not speci-fied,.the licensee must describe the actions taken to retrieve the source for Thus no additional requirements are required for this Commission review.
situation.
Action No action needed.
C.
Comments
...it is recommended the Nuclear Regulatory Commission would include in the rule-making a provision exempting states from these regulations, Letter 1:
which already provide safeguards for well-logging devices..."
"We suggest with respect to these two sections that they be amended to allow such an incident to be reported either to the NRC Inspection and Letter 2:
9
s.-
.g n
Enforcement office or to th'e-State Nuclear Regulatory Agency for the state in which the incident occurred."
j"..'.WriereaStateregulatoryagencyhaspromulgatedrulescompatible J
t LLett'er 5:
~
twith these:NRC--proposed rules,- the Stateswculd be delegated the authority of
[-
the NRC..."
?
3.
Analysis I
~....
1:
1The staff-doesinot agree':that the licensee should have the option of notifying i
- either the NRC or a State Regulatory
- Agency or that:the NRC should-abrogate fits' authority. sThe staff believes that all NRC licensees,--including well-logging
- licensees,'should notify.the' Commission of certain incidents involving radio-
. L,
-: active materials. lFurther, notification of the appropriate State agency is 1
also.an)important safety factor since a warning notation is needed in the well-
~
records.
L Action' i
No action'~ neede'd.
~
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1
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,e.
RECORD OF WELL-LOGGINGf SOURCES LOST 00WNHOLE'
. Type.and amount
. Depth-
. Location Location -
Licensee.
Date of loss ~
of material (C1)
'(feet).
(county / area)-
-(state) a
? ~pprox. 8/57-Po-Be, 2.75
'1,038
-Not given A
McCullough Tool McCullough Tool.
LApprox. 6/3/58
~Po-Be, 3.87 3,385 Russell Kansas Seismograph 7/17/58.
Po-Be,1.05; 985 Robinson' Illinois McCullough Tool
.'2/11/59.-
Po-Be,L5.
-10,841
.Kleberg Texas.
Seismograph 11/11/59' Pu-Be, 5l
,3,009 Wa/ne Ohio
- Seismograph' 8/30/61 Co-60, 0.025 5,278 Potter Pennsylvania Seismograph 8/31/61
.Co-60, 0.025 5,200
' Potter.
McCullough Tool 10/24/61 Pu-Be, 5 3,000
'Puskegon..
'Schlumberger
_11/9/62-
. Pu-Be,' : 5
'585 Denning Washington Halliburton 1/15/63 Co-60, 0.0012 6,550 Horton Texas McCullough Tool 37/25/63-Pu-Be, 5 16,621 Lafayette Louisiana U.S.. Bureau of Reclamation 1
-11/20/63~
.Co-60, 0.024 411 Lake Mead' McCullough Tool 2/11/64
'Co-60, 4x10" 7,800 Beaver Oklahoma Eastern Well-2/25/64
-Ra-Be:(Not NRC)
?
Columbia Ohio Schlumberger 10/6/64 Pu-Be, 5 185-200 Gulf of Mexico Louisiana 100 mi.
E'
- n, Dresser Industries 1/13/65 Cs-137, 1 7,126 Rio Arriba New Mexico h
Halliburton 2/18/65 Cs-137, 0.5 7,427
?
Louisiana 6/11/6'S' Cs-137, 1 4,000
?
'Schlumberger-Halliburton 7/11/65 Pu-Be, 5 3,565 Phillipsburg' Kansas Schlumberger
~8/1/65 Cs-137, 1.5 11,105 12 miles off coast Oregon Seismograph 1/20/66 Cs-137, 0.031'.
1,556-Nevada' Test Site
.Schlumberger' 3/25/66 Pu-Be, 5 10,142 Acadia Louisiana
-(Continued)
Type and amount Depth
' Location Location Date of loss
.of material (Ci).
(feet)
(county / area)
-(state)
Licensee-4/30/66' Pu-Be,-5 14,000 Jeanerette
' Louisiana Schlumberger
~ 14,370 St. Mary Louisiana 5/7/66 Pu-Be, 5 5/10/66 Co-60, 9x10 E 6,886 Garden Island Louisiana
.i-
_Schlumberger' Halliburton Field.
7/26/66 Co-137, 1.5 8,200 Canton.
Oklahoma i
Schlumberger Dresser Industries.
10/17/66 Cs-137, 1 7,222 Oklahoma City Oklahoma 11/3/66 Cs-137,,1.5 12,229 Gulf of Mexico
?
Dresser Industries 7/28/67 Ir-192, 0.558 7,195 Lake Charles Louisiana Schlumberger 8/13/67 Cs-137, 1.5 2,983 Offshore
.Los Angeles Schlumberger Oklahoma 9/13/67 Cs-137, 1.5 3,520 Harper California Schlumberger
'9/18/67.
.Cs-137, 1.5 14,764 Taft 9/21/67
'Cs-137, 1.5 16,636 Bakersfield California Schlumberger Dresser Industries 10/3/67 Cs-137, 1 11,000
" offshore" Louisiana Schlumberger 11/28/67 Cs-137, 1 7,200 Moffat Colorado 1/4/68 Cs-137, 1.5 12,900 Cooke Inlet Alaska Lane-Wells 7/29/68 Pu-Be, 5 2,252 Gaines Texas Schlumberger 7/29/68-Am-Be, 5 2,252 Gaines Texas Schlumberger
.Schlumberger 8/13/68 Cs-137, 0.035 2,863 Nevada Test Site Seismograph Louisiana 9/6/68 Cs-137, 0.5 12,365 Offshore Gulf of Mexico Halliburton California Schlumberger '
9/23/68 Cs-137, 1.5 181 Fresno
~
L"
. _ _ _ ~
~:
T,
.17
^~
~'
" ~ ~
^
m.na.A.a
_2 m
o.
oa i
- [
'(Continue ~d)
~
Type and amount Depth Location
. Location.'
Licensee
.Date of loss of material-(Ci)
(feet)
(county / area)
(state) 1 Univ. of California.
~10/21/68 Am-241,'S 950 600 miles east North' Carolina of Cape flatteras Halliburton 12/6/68 Pu-Be, 5
-13,285 Kennedy Texas
^
tane-Wells 12/11/68 Cs-137, 1 9,258
. Warland
-Wyoming-Lane-Wells 1/31/69
.Cs-137,.1 1,140 Gilette Wyoming Univ. of California 4/23/69
-Am-241, 4.5 ocean bottom 200 miles offshore California.
(two. sources)
Schlumberger-5/20/69 Pu-Be,.5 11,637 Acadia Louisiana b.
Schlumberger
-11/4/69 Pu-Be, 5 1,096 Major.
Oklahoma Schlumberger
.-11/21/69 Cs-137, 1.5 3,748 Cambria Pennsylvania w
Dresser-Atlas 12/1/69 Cs-137, 1 8,630 Sabine Pass in Gulf of Mexico 4
Schlumberger 12/11/69 ts-137, 1.5 15,373 Gulf of Mexico Louisiana (offshore)
{
Eastern Well 1/5/70 Am-Be, 2.88 5,005-Guernsey Ohio 1
Halliburton 4/6/70 Cs-137, 0.5 8,660 Canadian Oklahoma Dresser Industries.
5/11/70-Pu-Be, 5 2,965 Crane Texas Dresser Industries 7/31/70 Cs-137, 1 7,810 Campbell Wyoming l
Eastern Well 8/21/70 Cs-137, 0.125 6,105
-Columbiana Ohio
~
. yoming W
Dresser Industries 12/12/70 Am-Be, 5 2,300 Park.
Dresser-Atlas-7/25/71 Cs-137, 2 16,753-Wayne Mississippi 6,227 Cody Wyoming Dresser-Atlas 11/19/71 Am-Be, 4 llalliburton 1/6/72 Pu-Be, 5 7,695 Pecos Texas i
j J '
b.'S:2;0xh S E i..:A_dl5.i5h.;_
- g. qNb 4._._..
,if f
e (Continued)
Type and amount Depth Location Location
' Licensee
~Date of-loss of material (Ci)
(feet),
(county / area)
_(state)
.Shelwell:
-5/26/73 Cs-137, 2 5,519 Guernsey Ohio J 6/3/73'
' Pu-Be, 11,964 Brazoria Texas
~
Schlumberger
?Halliburton 9/23/73 Pu-Be,_5 13,923 Harris Texas Piper Wel1 11/10/74 Cs-137, 2-5,280 Stark-Ohio Halliburton:
-5/6/74 Pu-Be, 5~
.4,000:
Los Angeles California
-SANDS.
6/4/74 Cs-137,'l 3,900 Indiana' Pennsylvania
- Schlumberger 7/10/74
.Cs-137,fl.5 8,420 Coal Oklahoma Am-Be, :16 Allegheny Nuclear 7/25/74 C's-137, 2 2,930 Giliver West Virginia
- Dresser-Atlas 8/2/74 Cs-137, 2
. approx. 600 Sheridan Wyoming
. Seismograph 8/16/74 Pu-Be', 4 73 Six Lakes Michigan Halliburton 8/28/74 Cs-137, 0.5 4,714 Coal Oklahoma SANDS 10/10/74 Cs-137, 1 6,140 Near Freeport Ohio Halliburton 12/20/74-
.Am-Be, 5
.7,000 Fresno California Schlumberger.
12/24/74
-Am-Be, 16 18,000 Somerset Pennsylvania Schlumberger' 3/10/75-Am-Be,= Total 100 ocean bottom 100 miles offshore Gulf of Mexico E
Dresser-Atlas
-3/10/75 Cs-137, 2
'14,100 Kettleman City California i
5/1'/75-Cs-137, 1 7,750~
Rio Arriba New Mexico 1
Dresser-Atlas Schlumberger-5/15/75 Cs-137, 1.5 14,993 Johnson Wyoming Dresser-Atlas
'6/22/75 Am-Be, 4.5 12,660 Ventura California Schlumberger-10/13/75 Cs-137, 1.5' 9,510 Blaine Oklahoma Seismograph 2/13/76
.Pu-Be, 4 1,221
. Spencer Indiana i
i s
.~.
~~
T.,YNC 2 ~~:~ ' D ? * ~.T:: ~ ~ ' ~ ~
"'~
. :i -
-(Continued)-
Type and' amount Depth location location Date of. loss-
.of material (Ci)
(feet)
(county / area)
(state)_
Licensee 8/20/76 Cs-137, 1.5-14,215 Sweetwater Wyoming Schlumberger Am-Be, 16 9/11/76 Cs-137, 1.5 14,50,5 offshore
?
Perfection 9/27/76 Cs-137,.2 5,335 Mahoning Ohio Schlumberger Am-Be, 3 11/6/76 Cs-137, 5'
-ocean bottom Gulf of Mexico Galveston, Texas 70 miles Schlumberger Ar-Be, 16 4
Schlumberger
.11/30/76' Cs-137, 1.5 11,580 offshore
?
Am-Be, 16 SAND Surveys, Inc.
12/24/76 Am-241, 2 3,963-Indiana Pennsylvania Dresser-Atlas 5/16/77 Cs-137,.2 6,500 Garfield Oklahoma 6/6/77 Cs-137, 1.5 13,737-
" offshore" Louisiana Schlumberger Am-Be, 16 Alaska Goodwell,'Inc.
7/19/77
?
?
?
G0 Wireline Services 9/2/77 Cs-137, 1.5 1,120 Garfield Oklahoma 780 Ar-Be, 5 2/2/78 Cs-137,'1.5
'13,413
" offshore" Texas Schlumberger Am-Se, 16 SAND Surveys, Inc.
2/19/78 Cs-137, 1 3,517 Cicarfield Pennsylvania 3/8/78 Cs-137, 1.5 9,882
" offshore" Texas 3/15/78 Cs-137, 1.5 13,000 "of f shore'.
Louisiana Schlumberger Dresser-Atlas 5/1/78 Cs-137, 2 10,000 Washakie Wyomingx Schlumberger 7/7/78 CS-137, 1.5 14,174 Ocean floor
?
Schlumberger Am-Be, 18 3
1 4
+
~ _ _
,f
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, 4+ -
3
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(Continued) r.,f' 4'
c Type ~and amount
. Depth Location Location
. Date of loss.
.of' material:(Ci)
(feet)
(county / area)
'(state) j Licensee Dresser-Atlas -
7/17/78 Cs-137, 2
?
Sheridan Wyom'ing
LtJ Am-Be 18
.SchlumbergerT 9/9/78
'Cs'-137, 1.5-11,660 Richland Montana 1 Am-Be, 16
'J,'
Schlumberger' 10/17/78
?
16,380 Roger Mills Oklahoma Welex 10/24/78 Cs-137, 0.5
?
Blaine Oklahoma
~ Schlumberger 2/13/79
.Cs-137, 1.5 9,943 Natrona Wyoming Am-Be, 16 GO Wireline' Services ~
9/23/79 Cs-137, 5 3,900 Ashtabula Ohio 4/29/80 Cs-137,~1.5 8,550
" offshore" Texas Schlumberger m:
-Am-Be, 16
.Schlumberger 5/16/80 Cs-137, 1.5 13,580
" offshore" Louisiana-lAm-Be, 16-
'Schlumberger 6/20/80 Cs-137, 1.5.,,
16,123 Carvin Oklahoma Schlumberger
~8/7/80 Cs-137, 1.5 14,230 Sweetwater Wyoming Century Geophysical 8/21/80 Cs-137, 0.025 55 Somerset Pennsylvania
'Schlumberger 8/25/80:
Cs-137, 1.5 3,164 Noble Ohio Am-Be, 16 Gearhart' Industries,.Inc.
1/23/81 Cs-137, 2 5,250 Tillman Oklahoma Dresser Industries, Inc.
'2/10/81 H-3, 6
.12,800
" offshore" Louisiana 1
.Schlumberger 2/6/81 10,575 Prudhoe Bay Alaska Schlumberger.
2/19/81 Cs-137, 1.5 9,341 Le Flore Oklahoma Dresser Industries,.Inc.
.'3/16/81 Cs-137, 2-1,600 Carter Oklahoma s
~
f.
y F-
? "
~.
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2 E C. t,d ar.7 7.;f.~ W ; % */* ~^
~
9g ' 2..M.Ti. j..:
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t
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f
=
+
Location f.;
Type and amount Depth' Location (state)
. teet)-
(county / area) 4
(
' Licenseek Date of loss of material (Cl)'
Alaska Gearhart Industries, Inc.
3/22/81 Cs-137, 0.017 12,456 Prudhoe Bay s
Arizona 4/26/81' Cs-137, 0.15 1,600 Las Grande West Virginia
-5/3/81 Cs-137, 2 4,900 West Union
-Dept.-of Interior Oklahoma Basin Surveys Inc.
5/6/81' Cs-137, 0.017 8,444 Ellis Oklahoma Gearhart Industries Inc.
Gearhart-Industries, Inc.
6/2/81 Cs-137, 2.
10,000 McClain Am-Be, 20 West Virginia i.
l~
Basin Surveys, Inc.
7/4/81 Cs-137, 2 2,913 Saltwell--
Utah 7/6/81 Cs-137, 2 6,374 Grand i
-Dresser Industries om-Be, 18 Louisiana Dresser Industries, Inc.
7/30/81-Cs-137, 2' 13,770 S. Marsh Is. _
Pennsylvania 55 Somerset.
8/21/81
'Cs-137, 0.025 cuahoma Century Geophysical Corp.
-Cs-137,.1.5 3,470?
Murray l
t B/24/81 q'
Schlumberger Am-Be, 16 Texas
" offshore"c Gearhart Industries, Inc.
8/25/81 Cs-137, 2?
approx.
14,800 "off:hore" Texas 9/11/81 Cs-137, 1.5 16,343 Schlumberger Am-Be, 16 Lodisiana
" offshore"
~
j 10/9/81 Cs-137, 1.5 15,918 Schlumberger Am-Be, 16 Louisiana
" offshore" 10/23/81 Cs-137, 2 15,000 Dresser Industries, Inc.
Am-Be, 18 Oklahoma Cimmaron
'11/8/81 CS-137, 2 approx.
Gearhart Industries, Inc.
Am-Be, 20 6,150 Pennsylvania 11/30/81 Cs-137, 2 4,016 Erie Gearhart Industries, Inc.
I I
3
'~
l ',
~ ~ " ~
~ =~^' ; " ; ~ '
':: ?'L:: i:5K%o. ~~:i;2'uf C ~ ~ ~ ~~" "
(Continued)
Location
-Type and amount Depth Location
.of material (Ci)
(feet)
(county / area)
(state)
Date of loss
-Licensee' Oklahoma q
12/7/81 Am-Be, 16 17,900 Caddo Oklahoma Custer.
.Schlumberger Dresser Industries, Inc.
_4/26/82 Cs-137, 2 approx.
11,000 5/3/82 Cs-137, 0.5
'12,312 Lincoln Wyoraing Halliburton Am-Be, 19 Loulsiana
" offshore" 5/14/82 Cs-137, 1.5 below Schlumberger Am-Be, 16 15,940 Penasylvania Scottsdale 7/3/82 Cs-137, 1.5 approx.
4,000 Seismograph Service Corp.
Utah 24/82 Co-60, 0.125 3,815 Moab co Texas Gulf Chemicals Co.
Arizona Showlow 9/ /82 Wellex e
L l
..