ML20128M101
| ML20128M101 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1984 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Gillespie F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20127B584 | List:
|
| References | |
| FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310574 | |
| Download: ML20128M101 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION T3 DCT 0 5 1984
[ o REGION 11 (),
3 E. 101 M ARIETTA STR EET, N.W.
i 8 ATLANTA, GEORGIA 30303
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MEMORANDUM FOR: F. Gillespie, Director Division of Risk Analysis and Operations Office of Nuclear Regulatory Research FROM: J. Philip Stohr, Director Division of Radiation Safety and Safeguards
SUBJECT:
PROPOSED RULE ON WELL LOGGING OPERATIONS, 10 CFR 39, (YOUR MEMO, 9/18/84)
In response, to, your, request for review and/or concurrence on the subject document, we; con. cur but offer additional comments as follows:
General Comments:
- 1. This proposed regulatic,n appears to be timely based on recent incidents.
Publication for comment in the Federal Register should not be delayed for resolution of minor differences.
Specific Comments:
1 ~. S39.13(b)(5) would require a- written or oral test to qualify a logging supervisor. We believe that both written and oral testing should be required to formalize the training and to provide documented verification of the extent of comprehension.
- 2. S39.15(a) requires that the licensee agree with the well owner or operator concerning S39.15(b). We suggest that (b)(3) require that "all onsite subcontractors must also be subject to these conditions," since the well operator or owner may otherwise have little or no control over certain persons and equipment leaving'the drillsite.
- 3. S39.33(b) implies that a consulting service is not a "second party." Revise to read, " consulting service or other second party."
- 4. S39.35(d)(1) implies that 10 CFR 20 is sufficient to control decontamination, repair, or disposal of a leaking source. We suggest revision to require that these functions be oerformed by an authorized NRC or Agreement State licensee in accordance with 10 CFR 20." Many well logging licensees are not qualified to repair leaking sources.
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- 5. S39.45. Add (c) to indicate that subsurface tracer studies in different wells - at different times in a single field are considered to be field 8505310574 PR 850530 PDR PDR 39
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-flooding studies ' subject to 10 CFR 30 license ~ conditions rather than 10 CFR 39.
- 6. S39.61(a)(4). See_ comment 1. above con ning $39.13(b)(5).
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'J. Philip Stohr cc: A. N. Tse, RES 4
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