ML20133G731
| ML20133G731 | |
| Person / Time | |
|---|---|
| Issue date: | 01/03/1997 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Cardwell C TEXAS, STATE OF |
| References | |
| NUDOCS 9701160144 | |
| Download: ML20133G731 (41) | |
Text
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Mrs. Cynthia C. Cardwell, Deputy Director
%N - 3 N Standards and Special Projects Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 Dear Mrs. Cardwell We have reviewed the proposed revisions to Part 36 of the Texas Regulations for Control of Radiation dated November 1996. The proposed rules were reviewed by comparison to the equivalent NRC regulations in 10 CFR Part 39. We acknowledged receipt of the proposed regulations on December 12,1996, by e-mail to yourself.
Based on the review we have no comments. :Under our current procedure, a finding that a rule satisfies compatibility requirements may only be made based on a review of the text of the final rule. However, we have determined that if the proposed rules are adopted without significant change, they would satisfy the_ compatibility requirements.
We request 'that when the proposed rules are adopted and published as final rules, a copy of the "as published" rules be provided to us for review. As requested in our All Agreement States Letter SP-96-027, "Recuest to Hiablioht Chanaes to Aareement State Reaulations Submitted to NRC for Comoatibility Review" (March 1,1996), please highlight the final changes and send one copy in a computer readable format,if possible.
If you have any questions regarding the review or any of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415-2322.
Sincerely, Original Signed Byt PAUL H. LOHAUS Paul H. Lohaus, Deputy Director Office of State Programs I
Distribution:
DIR RF (6S-309)
DCD (SP08)
RLBangart PDR (YES)
Plohaus RBlanton Texas File l
DOCUMENT NAME: G:\\RLB\\6S309LTR.RLB
'See previous concurrence.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
l Copy with attachment / enclosure "N" = No copy OFFICE OSP C
OSP:DD l
OGC OSP:D l
NAME RLBlanton:ma}
PLohaus FXCameron RLBangart DATE 12/20/96*
12/20/96*
1/2/97*
1/3/97*
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9701160144 970103 PDR STPRG ESGTX PDR
Mrs. Cynthia C. Cardwell, Deputy Director Standards and Special Projects Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 Dear Mrs. Cardwell We have reviewed the proposed revisions to Part 6 of the Texas Regulations for Control of Radiation dated November 1996. The propose rules were reviewed by comparison to the equivalent NRC regulations in 10 CFR Part 39. We acknowledged receipt of the proposed regulations on December 12,1996, by e-all to yourself.
Based on the review we have no comments. Under ur current procedure, a finding that a rule satisfies compatibility requirements may only bepade based on a review of the text of the final rule. However, we have determined that if the proposed rules are adopted without significant change, they would satisfy the co patibility requirements.
"We request that when the preposed rules are adopted and published as final rotos, a copy of the "as published" rules be provided to us for revie% As requested in our All Agreement States Letter SP-96-027, "Reauest to Hichliaht Chanaes to Aareement State Reaulations Submitted to NRC for Comoatibility Reviewi (March 1,1996), please highlight the final changes and send one copy in a computer readable format, if possible.
If you have any questions regarding the review or any of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415-2322.
Sincerely, Paul H. Lohaus, Deputy Director Office of State Programs l
Distribution:
DIR RF (6S-309)
DCD (SP08)
RLBangart PDR (YES)
Plohaus RBlanton Texas File DOCUMENT NAME: G:\\RLB\\6S309LTR.RLB
- See previous congurrence.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
Copy with attachment / enclosure "N" = No copy Oh
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o OFFICE OSP lC OSP:DD l
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NAME RLBlanton:maj PLohaus FXCameron RLBangart' ?
DATE 12/20/96*
12/20/96*
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Mrs. Cynthia C. Cardwell, Deputy Director Standards and Special Projects Bureau of Radiation Control Texas Department of Health i
1100 West 49th Street Austin, TX 78756-3189 i
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Dear Mrs. Cardwell i
j We have reviewed the proposed revisions to Pa{t 36 of the Texas Regulations for Controlof j
Radiation dated November 1996. The proposed, rules were reviewed by comparison to the equivalent NRC regulations in 10 CFR Part 39. We acknowledged receipt of the proposed j
regulations on December 12,1996, by e-mail to 'yourself.
I i
Based on the review we have no comments. Under our current procedure, a finding that a rule satisfies compatibility requirements may only'.be made based on a review of the text of the final rule. However, we have determined thatlif the proposed rules are adopted without i
.significant change, they would satisfy the compatibility requirements.
l
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We request that when the proposed rules are adopted and published as final rules, a copy j
of the "as published" rules be provided to us for review. As requested in our All Agreement
- States Letter SP-96-027, " Request to Highlight Changes to Agreement State Regulations
[
' Submitted to NRC for Compatibility Review" (March 1,1996), please highlight the final l
changes and send one copy in a computer readable format, if possible.
if you have any questions regarding the review or an\\y of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415-2322.
I Sincerely,
^
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Paul H. Lohaus, Deputy Director 4
j Office of State Programs
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NAME RLBlanton:maj.Pt \\D PLohaus & '
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January 3, 1997 Mrs. Cynthia C. Cardwell, Deputy Director Standards and Special Projects Bureau of Radiation Control Texas Department of Health 1100 West 49th Street
' Austin, TX 78756-3189 Dear Mrs. Cardwell We have reviewed the proposed revisions to Part 36 of the Texas Regulations for Control of Radiation dated November 1996. The proposed rules were reviewed by comparison to the equivalent NRC regulations in 10 CFR Part 39. We acknowledged receipt of the proposed regulations on December 12,1996, by e-mail to yourself.
Based on the review we have no comments. Under our current procedure, a finding that a rule satisfies compatibility requirements may only be made based on a review of the text of the final rule. However, we have determined that if the proposed rules are adopted withaut significant change, they would satisfy the compatibility requirements.
We request that when the proposed rules are adopted and published as final rules, a copy of the "as published" rules be provided to us for review. As requested in our All Agreernent States Letter SP-96-027, "Reauest to Hiohliaht Chanaes to Aareement State Reaulations Submitted to NRC for Comoatibility Review" (March 1,1996), please highlight the final changes and send one copy in a computer readable format, if possible.
If you have any questions regarding the review or any of the NRC rules used in the review, please contact me or Mr. Richard Blanton of my staff at (301) 415-2322.
,o Sincerely,,
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k nhW]r ul H. Lohaus, Deputy Director Office of State Programs
(7-94)
NRCMD 3.57 M
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BACKGROUND AND SIGNATURE TAB USE THIS SIDE OF THE SHEET TO PRECEDE THE BACKGROUND MATERIAL WHEN ASSEMBLING CORRESPONDENCE (USE REVERSE SIDE FOR SIGNATURE TAB)
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NRC FORM CD (7-94)
NRCMD 3.57 BACKGROUND AND SIGNATURE TAB USE THIS SIDE OF THE SHEET TO PRECEDE THE SIGNATURE PAGE WHEN ASSEMBLING CORRESPONDENCE (USE REVERSE SIDE FOR BACKGROUND TAB) ml 5\\
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l Rule Package: 1996 Proposed revisions TRCR Part 26 Diy Definition CEE Acceotable 2 Field station 39.2
[u]
2 Injection tool 39.2
[u]
2 Logging assistant 39.2
[u]
i 2 Logging supervisor 39.2
[u]
2 - Logging tool 39.2
[u]
2 Personal supervision 39.2
[u]
2 Radioactive marker 39.2
[u]
2 Sealed source see 30.4 2 Source holder 39.2
[u]
4 2 Subsurface tracer study 39.2
[u]
2 Surface casing for protecting fresh water 39.2
[*]'
2 Uranium sinker bar 39.2
[u]
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Rule Package: 1996 Proposed revisions TRCR Part 36 Diy NRC rule Rule subject State rule i
10 CFR Part 39 LICENSES AND RADIATION SAFETY REQUIREMENTS FOR WELL-LOGGING 1
39.2 Definitions
[36.3] See list above 2
39.15 Requirement for agreement with well owner
[36.4]
2 39.31 Labels, security, and transport precautions
[36.11,36.12,36.18]
2 39.33 Radiation detection instruments
[36.13]
2 39.35 Leak testing of sealed sources
[36.14]
2 39.37 Physicalinventory
[36.15]
2 39.39 Records of material use
[36.16]
2 39.41 Design and performance criteria for sealed sources
[36.17]
2 39.43 Inspection, maintenance and opening of a source or source holder
[36.19]
2 39.45 Subsurface tracer studies
[36.32]
2 39.49 Uranium sinker bars
[36.35]
2 39.51 Use of sealed source in well without surface casing
[*] See endnote 1 2
39.61 Training
[36.20]
2 39.63 Operating and emergency procedures
[36.21, Aooendix 36-C]
2 39.65 Personnel monitoring
[36.22]
2 39.67 Radiation surveys
[36.40]
2 39.69 Monitoring during recovery of lodged source
[none]
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Rule Package: 1996 Proposed revisions TRCR Part 36 Div NRC rule Rule subiect State rule 1
l 2
39.71 Security
[36.30]
}
2 39.73 Documents and records required at field stations
[36.41]
2 39.75 Documents and records required at temporary jobsites
[36.42]
i 2
39.77 Notification of incidents and lost sources; abandonment procedures for
[36.5012 irretrievable sources
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2'*
39.103 Criminal penalties (only required to have penalties)
[*]
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NOTES:
- 1. Definition " Surface casing for protecting fresh water" The definition is not required because the surface casing requirements are regulated by another State agency.
- 2. TRCR 36.50 1
Equivalent to 10 CFR 39.77, a Division 2 compatibility requirement.
- l This is a division 2 compatibility requirement only in that the State is expected to have criminal penalties. A Texas equivalent i
regulation was not submitted, but may exist elsewhere in the rules.
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Rule Package: 1996 TRCR Part 36 proposed 5
AGREEMENT STATE RULE REVIEW Texas 1996 proposed revision to TRCR Part 36 December 1996 EXPLANATION OF FINDINGS CODES IN THE COLUMN LABELED " ACCEPTABLE" OR " STATE RULE":
For definitions:
"[u]" means the definition was not changed in the proposed rulemaking. The existing definitions were not reviewed.
For regulations:
A State section number in brackets means the regulation was unchanged in substance by the proposed rulemaking. An underlined section number means the proposed change was found to be compatible, as explained in the ENDNOTE. A redlined section number means the proposed regulation was NOT found to be compatible, as explaned in the ENDNOTE. An entry of "[None]" means an equivalent regulation was not submitted.
For definitions and regulations "[*]" means see endnote.
Division 3 definitions and regulations were not reviewed.
Changes to definitions and regulations were considered " unchanged in substance " by the following specific changes:
A.
References to other regulations were deleted or the section number of the referenced regulation was changed (the accuracy of the regulation references was not reviewed).
B.
The provisions of a regulation resequenced.
C.
Non-substantive wording changes were made to conform the definition or regulation to the State editorial style.
For division 2 definitions and regulations, any difference that did not decrease the stringency (i.e., decrease the protectiveness or increase the flexibility) of proposed definition or regulation compared to the equivalent CFR definition or regulation was considered acceptable.
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TASK # - 6S309 DATE-12/10/96 MAIL CTRL. - 1996 1
TASK STARTED - 12/10/96 TASK DUE - 01/08/97 TASK COMPLETED -
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TASK DESCRIPTION - 11/96 LTR - PROPOSED REVISION TO TRCR PART 36 "RADIA-
)
TION SAFETY REQUIRMENTS F/WELL LOGGING..." FOR REVIEW
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l REQUESTING OFF. - TDOH REQUESTER - C. CARDWELL WITS -
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PERSON -
STAFF LEAD -
PROG. AREA -
PROJECT STATUS -
TX DUE DATE:
1/10/97 1
PLANNED ACC.
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l Texas Department of Health Patti J. Patterson. M.D.
1100 West 49th Street Carol S. Daniels Commissioner Austin. Texas 78756-3189 Deputy Conunissioner for Programs (512) 458-7111 Roy L. Hogan Radiation Control Deputy Comnussioner for Administration (512) 834-6688 TO:
Interested Persons FROM:
Cynthia C. Cardwell, Deputy Director Standards and Special Projects R
Division of Licensing, Registration, g
and Standards cn Bureau of Radiation Control
$T W
DATE:
November 1996 g
SUBJECT:
Proposed Revision to TRCR Part 36 Because of a petition for rulemaking submitted to the Texas Department of Health (TDH), the department is revising the Texas Regulations for Control of Radiation (TRCR) Part 36, " Radiation Safety Requirements for Well Logging Service Operations and Tracer Studies." In Appendix 36-A, " SUBJECTS TO BE INCLUDED IN TRAINING COURSES FOR WELL LOGGING SERVICE OPERATIONS AND/OR TRACER STUDIES,"
Item VIII, we are deleting the specific number of training hours for tracer studies. The rule will only require training for tracer studies in the subjects listed.
The word " downhole" is deleted in some subsections of the rule and replaced with words "well logging" because some calibration sources that are not used for logging the well are used downhole inside a logging tool. A requirement for notifying the department whenever there is reason to believe a sealed source or device containing radioactive material has been ruptured is added. This requirementsdn an item of compatibility with the United States Nuclear Regulatory Commission and as an Agreement State, Texas must adopt it. Other subsections of the proposed rule are changed to clarify and more adequately specify the requirements for well logging and/or tracer studies.
Please submit any written comments to me.by Friday, January 10, 1997, in writing or by email to ccardwel@brcl.tdh. state.tx.us. If you have any questions concerning the proposed rules, please contact Mrs.
Sonia I. Simmons at (512) 834-6688 or email to ssimmons@brel.tdh. state.tx.us.
In addition, a public hearmg will be held at 9:00 a.m., Wednesday, January 8,1997, in conference room N218, Texas Department of Health, Bureau of Radiation Control, located at the Exchange Building, 8407 Wall Street, Austin.
An Eval Emloynwn Oppornmuty Emimer
Page 2 November 1996 Thank you for your review and input.
Attachment LEGEND New language - underlined Deleted language - [ bold faced and bracketed]
Existing language or language without change - regular type i
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PART 36 RADIATION SAFETY REQUIREMENTS FOR WELL LOGGING SERVICE OPERATIONS AND TRACER STUDIES 36.1 Purnogg The mies in this part establish radiation safety requirements for persons using sources of radiation for well logging service operations, including radioactive markers, mineral exploration and tracer studies. The requirements of this part are in addition to, and not in substitution for, the requirements of Parts 11,12,13,21,22,35,41 and 42 of these rules.
i 36.2 Scone l
The rules in this part apply to all licensees or registrants who use sources of radiation for i
well logging service operations, radioactive markers, mineral exploration and tracer studies.
I t
36.3 Definitions As used in this part, the following definitions apply:
i
" Field station" means a facility where sources of radiation may be cored or used and from which equipment is dispatched to temporary job sites.
" Injection tool" means a device used for controlled injection of radioactive tracer material.
" Licensing State" means any state with rules equivalent to the Sunnested State Reculations l
l for Control of Radiation relating to, and an effective program for, the regulatory j
control of naturally occurring or accelerator-produced radioactive material (NARM) and has been designated as such by the Conference of Radiation Control Program Directors, Inc.
"I.ogging assistant (equipment operator)" means any individual who, under the personal supervision of a logging supervisor, handles sealed sources or tracers that are not in logging tools or shipping containers or who performs surveys required by 36.40.
"I.ogging supervisor (field engineer)" means the individual who provides personal supervision of the utilization of sources of radiation at temporary job sites.
)
"I.ogging tool" means a device used subsurface to perform well loggmg.
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SEPTEMBER 1996 36-1 PROPOSED i
l
9 36.3
" Mineral logging" means any logging performed for the purpose of mineral exploration other i
than oil or gas.
" Personal supervision" means guidance and instruction by the supervisor, who is physically present at the job site and in such proximity that visual contact can be maintained and immediate assistance given as required.
" Radiation safety officer" means an individual named by the licensee or registrant who has a knowledge of, responsibility for, and authority to enforce appropriate radiation protection rules, standards, and practices on behalf of the licensee and/or registrant; and who meets the requirements of 36.23.
" Radioactive marker" means radioactive material placed subsurface or upon a structure intended for subsurface use for the purpose of depth determmation or direction orientation.
" Residential location" means any area where structures in which people lodge or live are located, and the grounds on which these structures are located including, but not j
limited to, houses, apartments, condominiums, and garages.
" Service company" rnenns any contracted or subcontracted company that is present at the temporary job site, specifically, that company to which the licensees' equipment is connected and which is exposed to radioactive material.
" Source holder" means a housing or assembly into which a radioactive source is placed for the purpose of facilitating the handling and use of the source.
" Storage container" means a container designed to provide radiation safety and security when sources of radiation are being stored.
" Temporary job site" means a location where well loggirig;or tracer studies are performed other than the specific location (s) listed on a license'or certificate of registration.
" Tracer study" means the release of a substance tagged with radioactive material for the purpose of tracing the movement or position of the tagged substance in the wellbore, at the wellhead, or adjacent formation.
" Transport container" means a container that meets the regulations of the U.S. Department of Transportation (DOT) and is designed to provide radiation safety and security when sources of radiation ate being transported.
SEFFEMBER 1996 36-2 PROPOSED
'4
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36.3
" Uranium sinker bar" means a weight containing depleted uranium used to aid in the descent of a logging tool down toward the bottom of a wellbore.
" Wellbore" means a drilled hole in which wireline service operations are performed.
"Well logging" means all operations involving the lowering and raising of measuring devices or logging tools ([which] that may or may not contain sources of radiation) into wellbores or cavities for the purpcse of obtaining information about the well and/or adjacent formations.
" Wireline" means an armored steel cable contaming one or more electrical conductors used to lower and raise logging tools in the wellbore.
" Wireline service operation" means any mechanical service that is performed in the wellbore using devices that are lowered into the well on a wireline for purposes of evaluation.
14 Prohibition (a)
No licensee shall perform well logging service operations with a sealed source (s) in any well or wellbore unless, prior to commencement of the operation, the licensee has a written agreement with the well operator, well owner, drilling contractor, or land owner that specifies who will be responsible for ensurmg the following requirements are met:
(1) a reasonable effort at recovery will be made in the event a sealed source is lost or lodged downhole; (2) a person shall not attempt to recover a sealed source in a manner that, in the licensee's opinion, could result in a source mpture; (3) in the event the environment, any equipment,' or personnel are contaminated with radioactive material, decontammation to levels specified in 21.108 and 21.109 [21.302 and 21.1303] must be performed; and (4) the requirements of 36.50(c) shall be met in the event a decision is made to abandon the sealed source downhole.
(b)
No licensee shall perform tracer study operations with a substance tagged with radioactive material in any well or wellbore unless, prior to commencement of the operation, the licensee has a written agreement with the well operator, well owner, drilling contractor or land owner, and the service company to which the licensee's SEFFEMBER 1996 36-3 PROPOSED
... _. _. _. ~ _ _ _
1 s,
36.4(b)
J equipment is connected, as applicable, [whichl that specifies who will be responsible for ensuring the following requirements are met:
(1) in the event the service company's personnel or equipment are contamin=*~J with radioactive material, they must be decontammated in accordance with 21.109 [21.1303] before release from the job site or release for unrestricted use.
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(2) in the event the well head or job site are contaminatM with radioactive material, they must be decontaminarM in accordance with 21.108 [21.1302] to i
the concentration limits specified in Appandir 21-A, Table II, Column 2, with j
the units changed from pCi/ml to pCi/gm before release for unrestricted use.
i (3) in the event radioactive material is to be reversed from the well or the well j.
screens out, the licensee must have established procedures and equipment or facilities to do the following:
(i) reverse material into a preconstructed pit which is specifically j
established in the event of a screen out; or (ii) reverse matenal into suitable transport container (s) in the event of a screen out.
4 1
2 (c)
A copy of the written agreement [ pursuant to] in accordance with 36.4(a) or (b) shall i
be maintained for inspection by the Agency for a period of five years following completion of the well logging service operation or tracer study.
EQUIPMENT CONTROL q
36dQ T imits on 12vels of Radiation 4
Sources of radiation shall be used, stored, and trasiryoned in such a manner that the requirements of 21.1(b), 21.101, 21.103, 21.104, 21.105, 21.106 [Part 21 of these rules]
and 41.100, as applicable, are met.
i SEPTEMBER 1996 36 4 PROPOSED
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t 36.11.
l 36,11 Storane Precautiom F
j (a)
Each source of radiation, except accelerators, shall be prov'.ded with a storage and/or l
transport container. The container shall have a lock (or tamper seal for calibration sources) to prevent unauthorized removal of, or exposure to, the source of radiation.
i i
i (b)
Each area or room in which sources of radiation are stored shall be posted in accordance with 21.203(e) [21.902].
l (c)
Sources of radiation shall be stored downhole or in a bunker in order to minimim the danger from explosion and/or fire.*
l (d)
Sources of radiation may not be stored in residential locations. This rule does not apply to storage of radioactive material in a vehicle in transit for use at temporary job
}
sites, if the licensee complies with 36.40(b).
i (e)
Sources of radiation in storage shall be secured to prevent tampering, or removal by 4
unauthonzed individuals.
)
36_12 Transoort Precautions
-1 i
Transport containers shall be locked and physically secured to the transpothug vehicle to l
prevent shifting during transport, accidental loss, tampering, or unauthorized removal.
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3613 Radiation Survey Instruments (a)
The licensee or registrant shall maintain a sufficient number of calibrated and operable radiation survey instruments at each location where radioactive material is stored or used to make physical radiation surveys asgequired by this part and by c
21.201 [21.501]. Instrumentation shall be capable of measuring 0.1 milliroentgen per hour through at least 50 milliroentgens per hour.**
This requirement became effective January 1,1993.
1 Instrumentation capable of measunng 0.1 mR/hr through 50 mR/br may not be sufficient to determine compliance with the regulations of the U.S. Department of Transportation.
SEPTEMBER 1996 36-5 PROPOSED
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36.13(b) j (b)
A licensee using tracer material shall have available at each field stadon and i
temporary job site additional calibrated and operable radiation survey instmments sensitive enough to detect the radioactive surface contammation limits specified in 21.109 [21.1303].
(c)
Each radiation survey instmment shall be calibrated:
(1) by a person specifically licensed or registered by the Agency, another Agreement State or Licensing State or the U.S. Nuclear Regulatory Commission MRC) to perform such service; I
(2) at intervals not to exceed six months and after each survey instrument repair; (3) for the types of radiation used and at energies appropriate for use; and (4) at an accuracy within +/- 20 percent of the tme radiation level at each calibration point.
(d)
Calibration records shall be maintained for a period of five years from the date of calibration for inspection by the Agency.
M_L4 12ak Testine of Scaled Sources Sources of radioactive material shall be tested for leakage and contamination in accordance with 11.7. Records of leak tests shall be maintained for Agency inspection for five years from the date of the leak test.
l
)fL}j, Ouarterly Inventory Each licensee or registrant shall conduct a quarterly phys inventory to account for all sources of radiation received or possessed at intervals not to exceed three months. Records of inventories shall be maintained for five years from the date of the inventory for inspection by the Agency and shall includel (al the quantities and kinds of sources of radiation [,];
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Gd the location where sources of radiation are assigned [,];
{cl a unique identification of each source of radiation [,];
SEPTEMBER 1996 36-6 PROPOSED
4 36.13(b)
[dl the date of the inventory [,] and Isl the name of the individual conducting the inventory.
36.16 Utilization Records -
i Each licensee or registrant shall rnamtnin current records, [which] Ihat shall be kept available for inspection by the Agency for five years from the date of the recorded event, showing the following information for each source of radiation:
(a) identification of each source of radiation to include:
(1) the make and model number and/or serial number (or if absent, a description) of each sealed source used; or (2) the radionuclide and activity of tracer materials and radioactive markers used at a particular well site and the disposition of any unused tracer materials.
(b) the identity of the logging supervisor or individual who is responsible for receiving sources of radiation, to whom assigned; and (c) the locations where used and dates of use.
36.17 Desien and Performance Criteria for Scaled Sources Used In IDownhotel Well Imenine Ooerations (a)
Each sealed source manufactured after August 1,1992, (except those containing radioactive material in gaseous form) used in [ downhole] well loenine operations shall be certified at the time of manufacture to mee(the following minimum criteria:
(1) be of doubly encapsulated constmetion; (2) containa radioactive material with a chemical / physical form as insoluble and nondispersible as practicable; and (3) the sealed source's prototype has been tested and found to maintain its integrity after each of the following tests:
SEFFEMBER 1996 36-7 PROPOSED
36.16 (i) temperature. The test source must be held at -40' C for 20 mmutes, 600* C for one hour, and then be subject to a thermal shock test with a temperature drop from 600* C to 20' C within 15 seconds; (ii) impact. A 5 kilogram steel bammer, 2.5 centimeters in diameter, must be dropped from a height of 1 meter onto the test source; i
(iii) vibration. The test source must be subject to a vibration from 25 Hz to 500 Hz at 5 g amplitude for 30 minutes:
(iv) puncture. A 1 gram hammer and pin,0.3 centimeter pin diameter, must be dropped from a height of 1 meter onto the test source; and (v) pressure. The test source must be subjected to an external pressure of 24,600 pounds per square inch absolute (1.695 X 10' pascals) without leakage.
(b)
In the absence of prototype testing, as outlined in 36.17(aV3), scaled sources (except those containing radioactive material in gaseous form) used after January 1,1993, shall be certified to meet the requirements of 36.17(a).
(c)
Certification of source criteria as required by 36.17(a) and (b) shall be performed only by persons specifically authorized to do so by the Agency, another Agreement or Licensing State, or the U.S. Nuclear Regulatory Commission.
(d)
Certification documents shall be maintained by the licensee for inspection by the Agency for a period of five years after source disposal.
36dB 12belina k
(a)
Each source, source holder, or logging tool containing radioactive material other than exempt quantity, shall bear a durable, legible, and clearly visible marking or label that has, as a minimum, the standard radiation caution symbol with no color requireinent and the following wording:
SEFFEMBER 1996 36-8 PROPOSED
i 36.17(a)(3)(iii)
DANGER
- l RADIOACTIVE--DO NOT HANDLE F
NOTIFY CIVIL AUTHORITIES (OR NAME OF COMPANY)
This labeling shall be on the smallest component (i.e., source, source holder, or logging tool) that is transported as a separate piece of equipment.
(b)
[(i])
Each transport container shall have permanently attached to it a durable,
)
legible, and clearly visible label that has, as a mmimum, the standard radiation l
caution symbol and the following wording:
A I
DANGER
- i i
i 4
RADIOACTIVE NOTIFY CIVIL AUTHORITIES (OR NAME OF COMPANY) l (Gl
[(ii)] After August 1,1993, each transport container shall have attached to it a durable, legible, and clearly visible label (s) that has, as a minimum, the licensee's name, address, and telephone number, the radionuclide, its activity, and the assay date.
3112 Insnection and Maintenance (a)
Each licensee or registrant shall conduct, at intervag not to exceed six months, a program of visual inspection and maintenance of source holders (or sealed source, if there is no source holder), logging tools, source handling tools, storage containers, transport containers, and injection tools to assure proper labeling and physical condition. The inspection program may be performed concurrently with routine leak testing of scaled sources. Records of inspection and maintenance shall be maintained for a period of five years for inspection by the Agency.
or CAUTION SEPTEMBER 1996 36-9 PROPOSED
36.18(b)
(b)
If any inspection conducted pursuant to 36.19(a) reveals damage to labeling or components critical to radiation safety, the device shall be removed from service until repairs have been made.
(c)
Any operation, such as drilling, cutting, or chiseling on a source holder containing a sealed source, shall be performed on the source holder only by persons specifically licensed to do so by the Agency, another Agreement or Licensing State, or the U.S.
Nuclear Regulatory Commission.
(d)
The repair, opening, or modification of any sealed source shall be performed only by persons specifically licensed to do so by the Agency, another Agreement or Licensing State, or the U.S. Nuclear Regulatory Commision.
REQUIREMENTS FOR PERSONNEL SAFETY 36,20 Trainino Requimments (a)
No licensee or registrant shall permit any individual to act as a logging supervisor until such individual has:
(1) successfully completed in a course recogmzed by the Agency, another Agreement or Licensing State, or the U.S. Nuclear Regulatory Commission, at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of formal training in the subjects outlined in Appendix 36-A; (2) received copies of and instruction in:
(i) the rules contained in this part and the applicable sections of Parts 11, 21, and 22 of these rules 'or their equivalent; the conditions of the appropriate lice %nse or certificate of registration (ii) d
'(iii) the licensee's or registrant's operating and emergency procedures; (3) demonstrated understanding of the requirements in 36.20(a)(1) and (2) by successfully completing a written examination administered by the licensee or registrant; (4) completed two months of on-the-job training under the supervision of a logging supervisor; and SEPTEMBER 1996 36-10 PROPOSED
36.20 (5) demonstrated through a field evaluation, competence in the use of sources of radiation, related handling tools, and the type of radiation survey instruments that will be used in the job assignment.
(b)
No licensee or registrant shall permit any individual to act as a logging assistant until such individual has:
(1) received copies of and instruction in the applicable sections of Parts 11, 21, and 22 of these rules or their equivalent and the licensee's or registrant's operating and emergency procedures; l
(2) demonstrated understanding of the requirements in 36.20(b)(1) by successfully completing a written eynmmation administered by the licensee or registrant; l
and (3) demonstrated competence to use, under the personal supervision of the logging supervisor, the sources of radiation, related handling tools, and radiation survey instruments that will be used in the job assignment.
(c)
The licensee or registrant shall provide an annual radiation safety review for logging supervisors and logging assistants.
(d)
Each licensee or registrant shall maintain records that document that the requirements of 36.20(a), (b), and (c) are met. Such records shall be maintained for inspection by the Agency until the Agency authorizes their disposal.
36,21 Ooeratine and Emercency Procedures The licensee or registrant shall maintain written operating and emergency procedures that include descriptions of and directions in at least the item' 4i,sted in Appendix 36-C.
s 36.22 Personnel Monitorine I
(a)
In addition to the requirements of 21.202 I21.50ll, no licensee or registrant shall permit any individual to act as a logging supervisor or logging assistant unless that individual wears either a film badge or a thermolummescent dosimeter (TLD) at all times during well logging service operations and/or tracer studies utilizing sources of radiation. Each film badge or TLD shall be assigned to and worn by only one individual. Film badges must be replaced at least monthly and TLDs replaced at least quarterly. After replacement, each film badge or TLD must be returned to the SEPTEMBER 1996 36-11 PROPOSED i
36.20(b)(2) supplier for processing within 14 calendar days or as soon as practicable. In circumstances that make it impossible to return each film badge or TLD within 14 calendar days, such circumstances must be documented and available for review by the Agency.
(b)
When necessary in order to aid in determming the extent of an individual's exposure to concentrations of radioactive material, the Agency may require a licensee to make available to the individual appropriate bioassay services and to furnish a copy of the reports of such services to the Agency.
(c)
Personnel monitoring records shall be maintni-d for inspection by the Agency until the Agency authorizes their disposal.
36.23 Radiation Safety Officer (a)
A radiation safety officer (RSO) shall be designated for every license and certificate of registration issued by the Agency.
(b)
The RSO's documented qualifications shall include:
(1) possession of a high school diploma or a certificate of high school equivalency J
based on the GED test; (2) completion of the training and testing requirements of 36.20(a); and (3) two years of experience as a logging supervisor to include knowledge of well logging service operations and tracer studies.
(c)
The specific duties of the RSO include, but are not limited to, the following:
(1) to establish and oversee operating, emergency, and ALARA procedures, and to review them regularly to ensure that the procedures are current and conform
. with these rules; (2) to oversee and approve all phases of the training program for well logging service operations and/or tracer studies personnel so that appropriate and effective radiation protection practices are taught; (3) to ensure that required radiation surveys and leak tests are performed and documented in accordance with these rules, including any corrective measures when levels of radiation exceed established limits; SEFFEMBER 1996 36-12 PROPOSED
i 4
36.22(c)
-(4) to ensure that personnel monitoring is used properly by occupationally-exposed personnel, that records are kept of the monitoring results, and that timely notifications are made as required by Pan 22 of these rules; (5) to investigate and repon to the Agency each known or suspected case of radiation exposure to an individual or radiation level detected in excess of limits established by these rules and each theft or loss of source (s) of radiation, to determine the cause, and to take steps to prevent its recurrence; (6) to have a thorough knowledge of management policies and administrative procedures of the licensee or registrant; (7) to assume control and have the authority to institute corrective actions including shutdown of operations when m*mry in emergency situations or unsafe conditions; (8) to maintain records as required by these rules (see Appendix 36-D);
(9) to ensure the proper storing, labeling, transpon, and use of sources of radiation, storage, and/or transport containers; (10) to ensure that quarterly inventories are performed in accordance with 36.15; and (11) to ensure that personnel are complying with these rules, the conditions of the license or the registration, and the operating and emergency procedures of the licensee or registrant.
PRECAUTIONARY PROCEDURES IN WELL LOGGING AND TRACER OPERATIQNS 36 30 Security During each well logging or tracer application, the logging supervisor or other designated employee is responsible for protecting against unauthorized and/or unnecessary entry into a restricted area, as defined in Pan 11 of these rules.
SEFFEMBER 1996 36-13 PROPOSED
'9
1 36.23(c)(6) 36,31 Handline Tools l
The licensee shall provide and require the use of tools that will assure remote handling of sealed sources other than low activity calibration sources.
36.32 Tracer Studies j
(a)
Protective gloves and other appropriate protective clothing and equipment shall be used by all personnel handling radioactive tracer material. Precautions shall be taken to avoid ingestion or inhalation of radioactive material, and to avoid contamination of field stations, temporary job sites, vehicles, associated equipment, and clothing.
j i
No licensee sha'1 pennit the injection of radioactive material into usable quality (b) 1 groundwater [3,000 parts per million (ppm) total dissolved solids or less] without prior written authorization from the Agency.
36,33 Particle Accelerators No licensee or registrant shall permit above-ground testing of particle accelerators that results in the production of radiation except in areas or facilities controlled or shielded to meet the requirements of 21.101 [21.201] or 21.105 [21.301], as applicable.
3.6_M Radioactive Markers The licensee may use radioactive markers in wells only if the individual markers contain quantities of radioactive material not exceeding the quantities specified in Appendix 21-B
[ Appendix 41-F). The use of markers is subject only to the provisions of this section and 36.15.
SEPTEMBER 1996 36-14 PROPOSED
.o 1
1 l
36.32 j
36,35 Uranium Sinker Bars The licensee may use a depleted uranium sinker bar in well logging service operations only if j
it is legibly impressed with the following wording:
i i
DANGER
- i l
RADIOACTIVE-DEPLETED URANIUM NOTIFY CIVIL AUTHORITIES (OR NAME OF COMPANY) 2 i
RADIATION SURVEYS AND RECORDS 1
1 l
I 314Q Radiation Surveys i
I (a)
' Radiation surveys (and calculations, for neutron sources) shall be made and recorded for each area where radioactive materials are stored.
l (b)
Radiation surveys (and calculations, for neutron sources) of the radiation levels in occupied positions and on the exterior of each vehicle used to transport radioactive
~
materials shall be made and recorded. Such surveys (and calculations, for neutron sources) shall include each source of radiation and combination of sources of radiation l
transported in the vehicle.
j (c)
If the sealed source assembly is removed from the logging tool before departing the job site, a survey meter shall be used to verify that the logging tool is free of I
Contamination.
i l
(d) be damaged by an operation, the licensee shall imm%ation of the seale If the licensee has reason to believe that the encap ediately conduct a radiation survey, including a contamination survey, during and after the operation.
l (e)
Radiation surveys shall be made and recorded at the job site and/or well head for each i
tracer operation except for those utilizing hydrogen-3, carbon-14, sulfur-35, or l
krypton-85. These surveys shall include measurements of radiation levels before and j
after the operation.
I 1
or CAUTION i
i SEPTEMBER 1996 36-15 PROPOSED 1
i i
l
36.40 (f)
Records required pursuant to 36.40(a) through (e) shall also include the dates, the identification of individual (s) making the survey, the unique identification of survey instrument (s) used, radiation measurements in milliroentgen per hour (mR/hr),
calculations in millirem per hour, and an exact description of the location of the survey Records of these surveys shall be maintained for inspection by the Agency for two years after completion of the survey.
36.41 Records and Documents Reauired at Field Stations (a)
Each licensee or registrant maintaining field stations from which well logging service.
operations are conducted shall have [ copies of] the following records and documents available at each station for inspection by the Agency:
(1) a copy of the appropriate license or certificate of registration; (2) operating and emergency procedures; (3) applicable rules as listed in the license or certificate of registration; (4) survey records required pursuant to 36.40; (5) quarterly inventories tequired pursuant to 36.15; (6) utilization records required pursuant to 36.16; (7) records of inspection and maintenance required pursuant to 36.19; (8) records of the survey instrument calibration and leak test for the specific devices and sources at the field station; N
(9) records of personnel monitoring required pursuant to 36.22 for personnel employed at the field station; (10) training records required pursuant to 36.20; (11) shipping papers for the transportation of radioactive material; and (12) records of receipt, transfer and disposal of radioactive material at the field station.
SEPTEMBER 1996 36-16 PROPOSED
36.41(a)(2)
I (b) records required pursuant to 36.41(a)(1) through (12) shall be maintained in accordance with Appendix 36-D.
t 36,42 Records and Documents Reauired at Temoorary Job Sites l
Each licensee or registrant conducting well logging service operations at a temporary job site j
shall have the following records and documents available at that site for inspection by the Agency:
(a) a copy of the appropriate license or certificate of registration; J
(b) operating and emergency procedures; (c) survey records required pursuant to 36.40 for the period of operation at that site; i
(d) evidence of current calibration for the radiation survey instruments in use at the site; i
(e) a copy of the current leak test record for the sources in use; and 1
j (f)
' shipping papers for the transportation of radioactive material.
v NOTIFICATION 36.50 Notification ofIncidents and Lost Sources: Abandonment Procedures for Irretrievable Sources (a)
Notification of incidents and sources lost in other than downhole well logging operations shall be made in accordance with appropgate provisions of Part 21 of these rules.
(b)
Whenever there is reason to believe that a mealed source or a device containino radioactive material has been ructured the licensee shall notify the Aeency immedintely by telenhone and submit written notification within 30 days. The written notification shall desienata the followine:
{11 the well or other location:
{21 a descriotion of the mnenienda and extent of the ecenne of radioactive innterial:
SEPTEMBER 1996 36-17 PROPOSED
l 36.42(e) l an ascesement of the consecuences of the ruoture: and L41 and exolanntion of the efforts olanned or being t*en to mitieate these i
consequences (c)
Whenever a sealed source or device containing radioactive material is lost downhole, the licensee shall:
(1) monitor with a radiation survey instrument [or logging tool adjusted to detect gamma emissions from source (s) lost downhole], at the surface for the presence of radioactive conenmination durmg logging tool recovery (fishing) operations; and (2) notify the Agency immediately by telephone and submit written notification within 30 days if radioactive contamination is detected at the surface or if the i
source appears to be damaged.
(d)
When it becomes apparent that efforts to recover the radioactive source will not be successful, the licensee shall:
(1) advise the well operator of the Texas Railroad Commmsion rules regarding abandonment and an appropriate method of abandonment, [which] 1hg shall i
include:
(i) the immobilization and sealing in place of the radioactive source with a I
cement plug, (ii) the setting of a whipstock or other deflection device, and i
(iii) the mounting of a permanent identification plaque, containing information required by 36.50(d), atp surface of the well; (2) notify the Agency by telephone giving the circumstances of the loss; and (3)
' file a written report with the Agency within 30 days of the abandonment, setting forth the following information:
(i) date of occurrence, (ii) a description of the radioactive source involved, including radionuclide, activity, chemical and physical form, and serial number, l
SEFIEMBER 1996 36-18 PROPOSED
36.50(c)(3)
(iii) surface location and identification of well, (iv) results of efforts to immobilize and seal the source in place, (v) depth of the radioactive source, (vi) depth of the top of the cement plug, (vii) depth of the well, and (viii) information contained on the permanent identification plaque.
(e)
Whenever a sealed source comnimng radioactive material is abandoned downhole, the licensee shall provide a permanent plaque
- for posting the well or wellbore. This plaque shall:
(1) be constructed of long-lasting material such as stainless steel, brass, bronze, or monel. The size of the plaque should be convenient for use on active or inactive wells; e.g., a seven-inch square. Ietter size of the word
" CAUTION" should be approximately twice the letter size of the rest of the information; e.g.,1/2 inch and 1/4 inch letter size, respectively; and (2) contain the following engraved information on its face:
(i) the word " CAUTION,"
(ii) the radiation symbol (color not required),
(iii) the date of abandonment, (iv) the name of the well operator or we(owner, (v) the well name and well identification number (s) or other designation,
'(vi) radionuclide(s) and activity (ies) of the source (s),
(vii) the source depth and the plug back depth (depth to the top of the plug),
and An example of a suggested plaque is shown in Appendix 36-B.
SEPTEMBER 1996 36-19 PROPOSED
\\
36.50(d)(2)(v) 1 (viii) an appropriate warning, depending on the specific circumstances of each abandonment, such as the followinn:
(a)
"Do not drill below plug back depth,"qt (b)
"Do not enlarge casing," or (c)
"Do not re-enter hole," before contacting Bureau of Radiation Control, Texas Department of Health.
(f)
The licensee shall immediately notify the Agency by telephone and confirmmg letter if the licensee knows or has reason to believe that radioactive material has been lost in or to an underground potable water source. Such notice shall designate well location and describe the magnitude and extent of loss of radioactive material, consequences of such loss and efforts taken or planned to mitigate these consequences.
(gl In the event of an uncontrolled release of radioactive tracer material to the environment, the licensee shall notify the Agency by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and submit written notification within 30 days.
C k
SEFFEMBER 1996 36-20 PROPOSED l
t
=.
1 I
PART 36 Appendix 36-A l
SUBJECTS TO BE INCLUDED IN TRAINING COURSES FOR WFT T. LOGGING SERVICE OPERATIONS AND/OR TRACER STUDIES l
1.
Fundamentals of Radiation Safety A.
Characteristics of radiation l
B.
Units of radiation dose (rem) and activity l
l C.
Significance of radiation dose 1.
Radiation protection standards l
2.
Biological effects of radiation D.
Izvels of radiation from sources of radiation E.
Methods of controlling radiation dose 1.
Time 2.
Distance i
l 3.
Shielding l
F.
Radiation safety practices, including prevention of contamination and methods of decontamination G.
Discussion of ingestion, inhalation pathways I
i SEPTEMBER 1996 36-21 PROPOSED
... ~. -.
e i
\\
Appendix 36-A (Continued)
SUBJECTS TO BE INCLUDED IN TRAINING COURSES FOR WELL LOGGING SERVICE OPERATIONS AND/OR TRACER STUDIES II.
Radiation Detection Instrumentation to be Used A.
Use of radiation survey instruments 1.
Operation 2.
Calibration 3.
Limitations B.
Survey techniques C.
Use of personnel monitoring equipment 1.
Film badges 2.
Thermoluminescent dosimeters (TLDs) 3.
Pocket dosimeters III.
Equipment to be Used j
A.
. Handling equipment and remote handling tools B.
Sources of radiation C.
Storage [,] control, disposal, and transport of equipment and sources of radiation D:
' Operation and control of equipment E.
Maintenance of equipment SEFFEMBER 1996 36-22 PROPOSED
\\
Appendix 36-A (Continued)
SUBJECTS TO BE INCLUDED IN TRAINING COURSES FOR WELL LOGGING SERVICE OPERATIONS AND/OR TRACER STUDIES IV.
The Requirements of Pertinent Federal and State Regulations V.
The Licensee's or Registrant's Written Operating and Emergency Procedures VI.
The Licensee's or Registrant's Record Keeping Procedures VII.
Case Histories and Potential Consequences of Accidents in Well Logging Service Operations and Tracer Stolies VIII. Tracer Studies.
For individuals performing tracer studies, [; an additional 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of]traming is required in the following subjects:
i A.
sources of contammation, B.
contamination detection and control, C.
decontamination techniques and limits, D.
survey techniques for tracer materials, and E.
packaging requirements for transportation ofgadioactive materials, especially residual materials from tracer studies.
SEFFEMBER 1996 36-23 PROPOSED
7._.
i PART 36 Appendix 36-B I
EXAMPLE OF PLAOUE FOR IDENTIFYING WELLS CONTAINING 1
SEALED SOURCES OF RADIOACTIVE MATERIAL ABANDONED DOWNHOLE O
O B.I.G. OIL COMPANY UNIVERSITY NO.1234
'f CAUTION 'f ONE 2 CURIE CS 137 RADIOACTIVE SOURCE ABANDONED 3-3-75 AT 8400 FT. PLUG BACK DEPTH 8200 FT.
DO NOT RE-ENTER THIS WELL BEFORE CONTACTING 2%.
BUREAU OF RADIATION CONTROL TEXAS DEPARTMENT OF HEALTH O
O SEPIEMBER 1996 36-24 PROPOSED
l r
a.
PART 36 Appendix 36-D TIME REOUIREMENTS FOR RECORD KEEPING Soecific Time Interval Reauired Section Name of Record for Record Kecoine 36.4 Agreement with Weil Operator, 5 years Owner, Diilling Contractor, or Land Owner 36.13 Survey Instmment Calibration 5 years 36.14 Leak Test 5 years 36.15 Quarterly Inventory 5 years 36.16 Utilization Record 5 years 36.17 Cenification Document 5 years after source disposal 36.19 Inspection and Maintenance 5 years 36.20 Training and Testing Record Until disposal is authorized by the Agency 36.22 Personnel Monitoring Record Until disposal is authorized by the Agency 36.40 Radiation Surveys Until disposal is authonzed by the Agency Records For Receipts, Transfer 2 years or until disposal 36.41 and Disposal is authorized by the Agency SEPTEMBER 1996 36-27 PROPOSED
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- a PART 36 Appendix 36-C OPERATING AND EMERGENCY PROCEDURES The licensee's or registrant's operating and emergency procedures shall include descriptions of and instructions in at least the following:
(a) the bandline and use of sources of radiation in wells without surface casine for orotectine fresh water aauifers. if annaeuriate:
(b)
' handling and use of sources of radiation to be employed so that no individual is likely to be exposed to radiation doses in excess of the limits established in Part 21 of these rules. Every reasonable effort shall be made to keep radiation exposures and releases of radioactive material in soils and effluents to unrestricted areas as low as is reasonably achievable; (c) methods and occasions for conducting radiation surveys; (d) methods and occasions for locking and securing sources of radiation; (e) personnel monitoring and the use of personnel monitoring equipment, including bioassays; (f) removal of radioactive material from storage, transportation of radioactive material to field locations and temporary job sites, including packaging of sources of radiation in the vehicles, placarding of vehicles, securing sources of radiation during l
transportation, and return to storage; (g) minimi7mg exposure of individuals during routine use and in the event of an accident; (h) procedure for notifying proper personnel in the event of an accident or well excursion; (i) maintenance of records; 1
(j) use, inspection, and maintenance of source holders, logging tools, source handling tools, storage containers, transport containers, and injection tools; (k) proceduret to be followed in the event a sealed source is lost or lodged downhole; SEPTEMBER 1996 36-25 PROPOSED i
w
4 4
Appendix 36-C (Continued)
OPERATING AND EMERGENCY PROCEDURES 4
l (1) procedures to be used for picking up, receiving, handling, and opening packages containing radioactive material; (m) procedures to be used for surveys of temporary job sites and equipment, and i
decontamination of vehicles, associated equipment, and clothing following tracer studies; (n) storage and disposal of radioactive waste; (o) procedures for laundering conenminated clothing, if applicable; (p) licensee's or registrant's management structure; j
(q) posting of radiation areas and labeling radioactive material containers; (r) procedures to be followed in the event of an uncontrolled release of radioactive tracer material to the environment; and (s) actions to be taken if a sealed source is ruptured, including actions to prevent the spread of contamination and minimize inhalation and ingestion of radioactive material, and actions to obtain suitable radiation survey instruments as required by 36.13.
SEPTEMBER 1996 36-26 PROPOSED
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