ML20128M028
| ML20128M028 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20127B584 | List:
|
| References | |
| FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310549 | |
| Download: ML20128M028 (11) | |
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PRELIMINARY REGULATORY ANALYSIS I
10 CFR Part 39 LICENSES AND RADIATION SAFETY REQUIREMENTS FOR WELL-LOGGING OPERATIONS
- 1. STATEMENT OF THE PROBLEM Existing Commission regulations do not specify detailed safety requirements governing the use of licensed material in well-logging operations. Some general requirements pertaining to well-logging operations are addressed in 30 CFR Parts 20 and 30. Since there are about 50,000 wells logged each year in the oil, gas and mineral industry and about 5,000 workers are directly or indirectly involved in these operations, a uniform set of radiation safety requirements in the Commission's regulations appears necessary. At present, the Commission specifies safety requirements for these operations as ' license conditions for approximately 170 NRC licensees.
Typical radioactive sources used in well-logging operations include sealed sources containing americium-241 (0.25 curie to 20 curies) and cesium-137 (2 to 3 curies); and millicurie' quantities of short-lived tracer materials to label well fluids. NUREG-0714 estimated an average of 22 man-rems per well-logging license or an extrapolated collective dose of 1740 man-rem. A recent incident in Pennsylvania during recovery operations for a separated mineral-logging tool containing americium-241 at a coal field caused extensive con-l tamination and considerable cleanup expense (48 FR 2467).
In response to concerns expressed by several States with heavy oil and gas activities, a task force was established by the Conference of Radiation Control Program Directors to develop a set of radiation safety requirements for use of radioactive material in well-logging operations. The task force was composed
! of representatives from States, the affected industry, and federal agencies, Enclosure --
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including the NRC. In keeping with previous practices of the organization, the Conference adopted these requirements as Part W of the " Suggested State Regulations for Control of Radiation" (SSRCR). The State of Texas and several other States have already adopted Part W requirements as State regulations without substantive changes. Other Agreement States are also considering adopting Part W requirements.
Since many well-logging companies operate in both Agreement and non-Agreement States, compatible NRC requirements are needed to ensure uniformity between NRC and the Agreement State regulations.
- 2. OBJECTIVES This regulatory action focuses on the following objectives:
to provide a comprehensive and consistent set of regulations to assure radiation safety; to maintain compatibility between the NRC and the Agreement States in regulating these operations:
to encourage the Agreement States (that have not adopted Part W) to adopt similar regulations.
- 3. ALTERNATIVES The alternatives considered were as follows:
3.1 Maintain the Status Quo This alternative was considered unacceptable because it fails to provide legally binding safety requirements for well-logging operations. Further, licensees would not have a ready reference to the NRC's requirement or any additional amendments. Also, the alternative would make the reciprocity with Agreement States more difficult.
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3.2 Promulaate New Recuirements Based on Part W in NRC Regulations This alternative was considered acceptable because:
it provides a sound regulatory base defensible in legal actions;
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it provides compatability with the Agreement States safety require-ments and thus provides a simple mechanism for reciprocity; it provides licensees with the opportunity to suggest modifications of the regulations. '*
- 4. CONSE0VENCES 14 . 1 Costs 4.1.1 NRC Operations Anticipated costs to the NRC are expected to be low for this action. An esti-mated one professional staff year effort will be needed to support this rule-making activity. Additional costs include the cost of public'ation of the Federal Register Notices of Proposed and Final Rulemaking.
4.1.2 Other Government Agencies i .
I Agreement States would be asked to review the proposed rule. Each review would s
require, a total estimated staff time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. For the 26 Agreement States, the total review effort is estimated at approximately 200 person-hours.
4.1.3 Industry Approximately 160-170 licensees of the Commission would be affected by this i
proposed action. Each licensee would be required by the regulation to imple-ment the requirements in the areas of personnel safety, working practices, operating procedures and equipment. The total cost for implementation of all 04/26/84 ,
3 PREL REG ANALYSIS 10 CFR 39 LL
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requirements, if they were being implemented for the first time, woulc be
.acoroximately $1 million per year for NRC licensees or approximately $6,000 per licensee per year as shown in Table 1. However, most requirements are already-applied as licensing conditions; thus, the increase in cost to the affected licensees from this action would be approximately $80,000 per year for NRC licensees or approximately 5500 per licensee per year.
4.1. 4 Public There would be no associated cost to the public from this action.
4.2 Benefits 4.2.1 NRC Ooerations The benefits from this action are:
providing a comprehensive and consistent set of regulations to assure radiation safety; maintaining compatibility between the NRC and the Agreement States in regulating these operations; encouraging the Agreement States (that have not adopted Part W) to adopt similar regulations; providing a consistent regulatory program for decentralization of the Commission's licensing and enforcement programs.
4.4.2 Other Government Acencies Publication of the proposed and final rules would be cost reimbursable to the Office of the Federal Register.
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TABLE 1 Total Industry Cost for Implementing Part 39 .
. Costs No. of Unit cost units (or Total Section Content (or time) Freq/yr/ unit units /yr) cost /yr Remarks ;
39.1 - General Provisions ---------------------NoCost------------------------ Administrative procedure 39.13 - ~
39.15 . Written Agreement ---------------------NoCost------------------------ Currently required in Parts 30 and 70 39.31 Labels, etc ---------------------NoCost------------------------ Currently required in Parts 20 and 71 39.33 Detection Instruments $500/ event --
20 events /yr $10,000 1. Survey instruments are
'a currently required by Part 20 ;
- 2. Assumes 20 events per year "
that require consultant with high sensitivity instrumentation (unit cost includes transportation of "-
the consultant) 39.35
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Leak Test $40/ 2/yr 1700 sources $140,000 1. Currently required as ,
leak test Ilcense condition
- 2. Assumes 170 NRC licensees '.
with an average of 10 sources per licensee 39.37 Physical Inventory 6 min / 4/yr 1700 sources $6,800 1. Currently required as source license condition
- 2. Assumes $10/hr labor cost ;
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'I TABLE 1 (Continued)
Costs No. of l
Unit cost units (or Total ,
Section Content (or time) Freq/yr/ unit cost /yr units /yr) Remarks 39.39 Utilization Record 3 min / --
20,000 uses/yr $10,000 1. Currently required as use license condition
- 2. Assumes 20,000 well-l logging operations were l performed by MRC ,
. licensees ($10/hr)
- 39.41 Sealed Source $300/ 0.1 1700 sources $50,000 1. Most sources manufactured Performance source (10 yr life) after 1968 comply with .
-New Source the requirement
- 2. Assumes 10 years life for each source. '
- Old Source $500/ source 0.3 (replace 20 sources $3,500 1. Assumes 20 cesium sources,
- l In 3 years) which can not meet the t*
l requirements, must be
- replaced. -
39.43 Inspection, 30 min / 2/yr 1700 sources $17,000 1. Currently required as i-l Maintenance source _
license condition
- 2. Assumes $10/hr l 39.45 Tracer Studies $10/ study --
10,000 $100,000 1. Currently required as .
studies /yr license condition l 2. Assumes 50% of the 20,000 well-logging operations ,
involving tracer studies
- 39.47 Radioactive I hr/ 0.2 80 $800 1. Assumes 50% of 170 NRC Markers agreement (5 yr life) agreements licensees use markers -
l 2. Assumes $50/hr attorney fee "
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i TABLE 1 (Continued)
Costs No. of Unit cost units (or Total :
Section Content (or time) Freq/yr/ unit units /yr) cost /yr Remarks 39.49 Sinker Bars $10/ sinker 0.2 100 $200 Assume 10% of MRC licensees '-
bars (5 yr Ilfe) sinker bars and 6 sinker bars / licensee '-
39.51 Wells without $20/ event --
200 events /yr $4,000 1. Assumes 1% of 20,000 well i Surface Casing logged are uncased .'
39.61 $1,000/ 0.25 2,000 ;
Training $500,000 1. Currently required by person (4 yr period) persons Parts 19.12 and i, 30.33(a)(3) and as ,
licensing condition .
- 2. Assumes 2,000 workers ..
operate under NRC E.
IIcenses -
39.63 Operating and 100 hr/ 0.2 170 $70,000 1. Currently required as Emergency licensee (5 yr life) licensees ifcense conditions ;
Procedures 2. Assumes $20/hr for L' developing procedures ,
39.65 - Monitoring and ---------------------No Cost------------------------ Currently required by J' 39.67 Survey Part 20 39.69 Contamination 10 hr/ --
100 events /yr $10,000 1. Assumes 100 events of I' Control (continous event source recovery monitori.79) 2. Assumes $10/hr .
39.71 Security ---------------------No Cost------------------------ Currently required by
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-o TA8tE 1 (Continued) '
I Costs No. of i ,'
Unit cost units (or Total Section Content (or time) Freq/yr/ unit units /yr) cost /yr Remarks 39.73 - Documents $100/ --
170 $17,000 Currently required as 39.75 licensee ifcensees license condition 39.77 Notification. ---------------------No Cost------------------------ Currently required by Abandonment Parts 20, 30, and 70 -
39.91 Exemptions ---------------------No Cost------------------------ Administrative procedure ,
Total cost $1,000,000 co Already required $ 920,000 3 Net cost for implementing the rule $ 80,000 '
Total cost / licensee = $1,000,000 = $6,000 170
- Met cost / licensee = $80,000 = $500 170 :
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Agreement States would be able to, with a minimum effort, allow NRC licensees to conduct well-logging operations in their jurisdictions since the Federal and State Regulations would,be compatible.
4.2.3 I'ndustry The benefits to the industry are:
having a comprehensive set of requirements in the regulations with the opportunity to suggest modifications; having consistent requirements in all five NRC Regions; minimizing the effort required to obtain reciprocity for NRC licensees to operate in Agreement State or vice versa.
4.2.4 Public The public would be benefited from a comprehensive and consistent program that would assure radiation safety.
4.3 Impacts on Other Recuirements The recent rulemaking on the irretrievable well-logging source in Parts 30 and JO would be replaced by this rulemaking activity.
4.4 Constraints There are no constraints on this proposed rulemaking.
- 5. DECISION RATIONAL l
An assessment of the costs and benefits of the proposed rule leads to the con-l Clusion that there will be a positive impact from the uniformity of safety I
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requirements for well-logging operations. Costs associated with tnin action would be negligible. Therefore, the proposed aution is recommended.
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- 6. IMPLEMENTATION i No implementation problems are expected. The proposed regulations are similar-to the Part W of the Suggested State Regulations which has been developec by l representatives from industry, States and Federal agencies, including NRC.
l Public comments during the proposed rulemaking are expected to be supportive of the intent of these proposed rules.
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