ML20128M119

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Draft Commission Paper Recommending Approval of Encl Rulemaking Package for 10CFR39, Licenses & Radiation Safety Requirements for Well Logging Operations
ML20128M119
Person / Time
Issue date: 11/20/1984
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20127B584 List:
References
FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310581
Download: ML20128M119 (4)


Text

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i NY 20 M4 For: . The Comissioners -

Fron: Willian J. Dircks Executive Director for Operations

Subject:

' PROPOSED RULE ON LICENSES AND RADIATION SAFETY REOUIREMENTS FOR UELL-LOGGING OPERATIONS (NEW 10 CFR PART 39)

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Purpose:

.To obtain Commission approval of a notice of proposed ruleraking.

Background:

Licensed materials are used in the oil and gas industry to obtain information on the properties of underground formations. This technique involves lowering a sealed radioactive source, with an associated radiation detector,

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into a well on a wire line. A log of the well is produced by recording the way in which radiation emitted from the source is reflected back from the underground formation to the detector. Americium-241 and Cesium-137 are most commonly used for this purpose. There are currently 173 NRC licensees and about 400 Agreement State licensees authorized to use radioactive materials in well-logging operations.

Except for irretrievable well-logging scurces, current NRC regulations do not contain specific radiation. safety re-quirements related to the use of licensed materials in well-logging operations. Moreover, except for the general

Contact:

. Anthony N. Tse 443-7902 5310581 850 @

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.. safety requirements specified in 10 CFR Parts 20, 30, 40 and 70, these operations are regulated only through condi-tions on each individual license imposed on a case-by-case basis. This duplicates effort and may lead to discrepan-cies in requirements among licenses issued by NRC Regional Offices and the Agreement States.

Recognizing the need for comprehensive and consistent radiation safety stardards, the Conference of Radiation Control Program Directors established a task force in 1974 to develop necessary standards for well-logging operations.

The task force was composed of representatives from States, industry, and Federal agencies, including NRC. By 1981, a set of nodel regulations was proposed to the Conference by the task force and the Corference adopted the well-logging requirements as Part W of the " Suggested State Regulations for Control of Radiation." Four Agreement States (Arkansas, Kentucky, Oregon, and Texas) have already adopted Part W requirerents as State regulations without significant changes. Several other Agreement States are considering adopting Part W requirements.

Discussion: The staff is proposing to amend the NRC regulations to add

-10 CFR Part 39, a new part dedicated exclusively to well-logging operations. The proposed rule would: (1) provide comprehensive and consistent regulations appli-cable to well-logging operations; (2) incorporate safety requirements similar to Part W of the Suggested State Regulations; (3) include requirements designed to reduce the likelihood of incidents involving the rupture of radioactive contamination; and (4) incorporate existing regulations on irretrievable well-logging sources now found in Parts 30 and 70. A new part is proposed because well-logging operations use byproduct material, source material, and special nuclear material. Thus, if these well-logging requirements were not included in one part, they would have to be duplicated more or less in Parts 30 and 70 as well as in Part 40.

This action involves no new resources requirements.

Recommendations: That the Commission:

1. Approve the notice of proposed rulemaking (Enclosure
1) which would add 10 CFR Part 39 pertaining to l

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[ radiation safety requirements in well-logging t operations, i

-2. - Certify that this rule, if adopted,~will not have a significant economic impact upon a substantial number.

of small entities as required by the Regulatory Flexibility Act of 1980.

3. Note.

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a. The proposed rule will be published in the Federal Register and previde for a 90-day comnent-period;
b. The appropriate Congressional Comnittees will be informed (Enclosure 2);

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c. A public announcement will be issued (Enclosure 3);
- d. The staff has prepared a draft regulatory analysis (Enclosure 4). The analysis indicates that the economic impact to small entities would be small;
e. The staff has prepared a draft environmental impact assessment-(Enclosure 5). The assessment concludes that the proposed action would not significantly affect the quality of the human environment;
f. This proposed rule contains information collection requirements subject to the Paperwork
Reduction Act of 1980 (44'USC 3501 et seq.).
- This rule has been submitted to,the Office of Management and Budget for review and approval of

- the paperwork. requirements;

g. The Chief Counsel for Advecacy of the Small Business Administration will be informed of the Certification regarding economic impact on small entities and the reasons for-it as required by the Regulatory Flexibility Act; 1

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i. Agreement States have been given a draft of the proposed rule for review and coment and will be informed when the proposed rule is published.

The final rule would be made a matter of compatability for Agreement States.

(Siped) William J.Dircks William J. Dircks Executive Director for Operations

Enclosures:

1. Notice of Proposed Rulemaking
2. Draft Congressional Letter
3. Draft Public Announcement
4. Draft Regulatory Analysis
5. Draft Environmental Assessment Distribution:

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