ML20128M210

Environ Assessment for Proposed Regulation on Well Logging Operations

ML20128M210
Person / Time
Issue date:	04/08/1985
From:	NRC
To:
Shared Package
ML20127B584	List: ML20127B579 ML20127C194 ML20127C315 ML20128L968 ML20128L993 ML20128M001 ML20128M008 ML20128M016 ML20128M028 ML20128M042 ML20128M053 ML20128M061 ML20128M101 ML20128M110 ML20128M119 ML20128M135 ML20128M161 ML20128M172 ML20128M197 ML20128M205 ML20128M210 ML20128M221 ML20128M233 ML20128M267 ML20128M288 ML20128M302 ML20128M309 ML20128M332
References
FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310605
Download: ML20128M210 (5)

Text

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& ' 4 AE F TFOR ENVIRONMENTAL ASSESSMENT FOR PROPOSED REGULATION ON WELL-LOGGING OPERATIONS

• Identification of the Proposed Action The Nuclear Regulatory Commission is proposing a regulation that would specify radiation safety requirements for the use of licensed material in well-logging operations. The proposed regulation would provide: (1) comprehensive and consistent regulations applicable to well-logging operations by consolidating essential radiation safety requirements in a new Part 39, (2) uniform safety requirements in NRC and Agreement States' regulations, and (3) safety require-ments designed to reduce the likelihood of accidents involving the rupture of radioactive sources in well-logging operations.

The Need for the Proposed Action The proposed action is needed because the existing Commission regulations do not specify detailed safety requirements governing the use of licensed material in well-logging operations. Currently about 50,000 wells are logged each year in both the Agreement States and non-Agreement States in the oil, gas and mineral industry. About 5,000 workers are involved in these operations. A uniform set of radiation safety requirements in the Commission's regulations appears necessary to reduce the occupational exposure and the potential for accidents involving radiological hazard. At present, the Corrission specifies safety requirements for these operations as license conditions for the 173 NRC licensees (as of Noverber 1984).

• 50 FR 13797, April 8, 1985 g50530605850530 39 PDR

2 A major problem with the current practice is that radiation safety requirements applicable, to the industry are specified as license cer.ditions en a case-by-case basis rather than spelleo out in uniform regulations that are applicable to all licensees. This situation leads to the duplication of effort by the licensing agency and allows for discrepancies in requirements among the specific licenses issued by NRC ara the Agreement States. Problems in the consistent and uniform application of these requirements could become a greater concern because, under the NRC's program for the decentralization of material licensing actions, well-logging licenses are issued by the five NRC regional offices instead of NRC headquarters.

In response to concerns expressed by several states with extensive 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 the states, the affected industry, and federal agencies, 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 States of Arkansas, Kentucky, Oregon, and Texas have already adopted Part W requirements as state regulaticns without substantive changes. Other Agreement States are also considering adopting Part W requirements. Because many well-logging companies operate in both Agreement and non-Agreement States, ccrpatible NRC i

requirements are neeced to ensure uniformity between NRC and the Agreement l

State regulations.

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3 Though there are about 50,000 well-logging operations each year, the probabil-ity of an accident is very small. Nonetheless, accidents have occurred and additional safety requirements are needed to reduce even further the likelihood of an accident. There were five incidents which occurred between August 1982 and September 1983 involving radioactive sources used in well-logging operations. Three incidents involved the rupture of sources in uncontrolled workshop environments by workers performing machining or drilling operations.

~iwo incidents involved the rupture of sources in well holes during logging tool recovery operations. The cost associated with the cleanup of radioactive material from these incidents is estimated to be in excess of 1.5 million dollars.

Alternative Use of Resources In connection with the proposed action, the NRC has considered three alterna-tives: maintain the status quo; amend Parts 30, 40, and 70 based on Part W requirement; or promulgate a new part also based on Part W requirements, but dedicated to the well-logging operations. The third alternative is proposed because:

o It provides a sound regulatory base. Part W has been adopted by four Agreement States and used successfully.

o It provides compatibility with the Agreement States' safety requirements and thus provides a simple mechanist for reciprocity.

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4 o It provides licensees with the ppportunity to suggest modifications of the regulations.

o It provides a single location for safety requirements for using by-

,, product, source and special nuclear material in well-logging operations.

d" In the long run, it invol' es v the least costly and most efficient way of using NRC's and licensee's resources. Public resources will not be impacted significantly.

4 Environmental Impacts of the Proposed Action The proposed action would not significantly affect the quality of the human u

Environment. The proposed action is designed to control the use of licensed materials in well-logging operations and, therefore, would not have a ~ direct

- impact on the environment. However, the proposed action would reduce the occupational radiation exposures received by workers and would also reduce the chance and consequences of accidents involving the spread of radioactive

~m contamination in the environment. Furthermore, most of the proposed require w (~

ments are already being complied with by licensees because they are imposed by '

licensing conditions. Therefore, the proposed action wculd have no measurable negative environmental impact.

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5 Agencies and Persons Consulted yThe' proposed action has been reviewed -by the NRC staff Enc has beer, forwarded to 27 ' Agreement - States .for review. A proposed rule will be published and public comments will be requested.

Findings of No Significant Impact

-The Commission has determined not to prepare an environmental impact statement for the-proposed action because it would not have a significar.t effect on the quality of the human environment; the impact will be a beneficial, not a deleterious, one..

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