ML20197G017
| ML20197G017 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1983 |
| From: | Black K NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | |
| References | |
| TASK-AE, TASK-N303 AEOD-N303, NUDOCS 8308150389 | |
| Download: ML20197G017 (16) | |
Text
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- g AEOD ENGINEERING EVALUATION REPORT
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LICENSEE: Consolidation Coal Company EE Report No. AE0D/N303 Date: June 10, 1983 Evaluator /
Contact:
K81ack
SUBJECT:
AMERICIUM CONTAMINATION RESULTING FROM RUPTURE OF WELL-LOGGING SOURCES EVENT DATE: September 22, 1982 SUMARY An event involving rupture of well-logging sources at Consolidation Coal Company resulted in contamination of their property with transuranics. Although the decontamination was accomplished with little or no impact on the public health and safety, the event aroused questions to AE00 concerning the financial capabilities of HMSS licensees to cope with contamination events as well as the potential need to store transuranic wastes for some per.iods of time.
(Transuranic wastes may not be buried at low level sites except with special variances.)
A study of the abilities of NMSS licensees to ensure clean-up of all onsite and offsite arer.s will be completed in early sumer. The study should answer the question of financial responsibilities.
The question of storage of TRU wastes has been broached by NRC to DOE with no positive response.
No recomendations have been made concerning this event.
DISCUSSION The Consolidation Coal Company reported by phone on September 22,'1982, that one or both of two Am-241 sources (250 mci each), lost down a well during well-logging operations, had been ruptured during recovery operations. Personnel on the drilling site and offsite areas were contaminated with americium residuals.
James Nicolosi, Region I, was contacted concerning the incident. He provided the following information:
Consolidation Coal was capable of bearing the expense of the clean-up.
It is estimated that the clean-up has cost on the order of 1.5 million dollars to date.
The contaminated soil clean-up criterion was 30 pCI/ gram. Five hundred to six hundred drums (55 gallon) of contaminated soil had been removed so far and an additional 100 drums would be excavated before the clean-up was completed.
(January 1983 data)
Washington State g' ave a variance to the U.S. Ecology license to permit U.S.
Ecology to receive and bury the Am-241 contaminated soil ~.
- Contamination was first discove' red dur'ng a routine survey with a GM (Victoreen) survey meter, as required by the license. The survey meter was not sensitive enough to detect the contamination in the drilling mud until a substantial amount of contamination ~had occurred.
(BernardSingerofNMSShasstated that if the drilling mud had been conta4ned and recirculated, as re ten to twelve drums of contaminated material would have resulted.) quired, only
- CR3oSI5o3TR)M IIepp This report supports ongodng AE00 and NRv.etivitied program o and does the position or requirements of the responsible NR L--
__ An information notice on this event has been sent out to the licensees.
Two facts are.important to consider:
Consolidation Coal, our licensee, was the owner of the property on which the contamination occurred, as well as being the well-logging license.
The clean-up costs would exceed $1 million.
Although the event would have resulted in a much lower degree of contamination had the proper procedures been followed, the accident did happen as is discussed above.
The clean-up was accomplished with little or no effect on public health and safety.
AE00 can envision circumstances where significantly greater problems could have been encountered in the clean-up operation. For example, consider a situation where the land on which the drilling was taking place was owned by A; the drilling was being l
done by.8, who owned the mineral rights; and our licensee was C.
In addition, assume that the no burial ground would accept the waste.
Although NRC has authority over our' licensee, we have no authority over non-licensees. We do not necessarily evaluate the' financial capability of our well-logging licensees. RegulationW(Attachment 1),"RadiationSafetyRequirements for Wireline Serv ~ ice Operations and Subsurf, ace Tracer Studies," a model state regulation that may be incorporated into the NRC~ regulations, does not discuss recovery from accidents of the sort experienced at Consolidation Coal. Regulation W does provide that no licensee may perform wireline service ~ operations without a written agreement with the well operator, well owner, drilling contractor, or land i
owner that some attempts will be made to recovery lost sources, and in the event the source cannot be recovered, appropriate requirements of the state will be met.
FINDINGS AE00 believes that, although the accident that occurred at Consolidated Coal is uniquel, the potential exists for well-logging events to result in some entity having to spend significant amounts of money.
In addition, the possibility exists that large volumes of transuranic-contaminated soil may have to be stored for a decade or more if approval for its disposal cannot be'obtained.
We note that RES,is evaluating decommissioning costs for fixed sites and the ways that NRC can assure that the, licensee could pay these costs.
Note that the type of event that occurred at Consolidation Coal would be not considered by RES since it did not happen at a fixed licensed site...
The Waste Management Division of NMSS is completing a s.tudy of the ability of NMSS licensees to ensure cleanup of all onsite and offsite contaminated areas. The study is ongoing and is scheduled to be comp 1.eted in early summer. The draft study will address the type of event that occurred at Consolidation Coal; the study should provide a bas.is for any NRC recommendations concerning financial responsibilities for its licensees.
AE00 found.that the subject of americium storage had been broached at a management level meeting between NRC and DOE. No positive response was received.
RECOMMENDATIONS No recommendations have been made as the result of this study.
IThere was an incident involving loss of plutonium source in. Michigan that resulted i
in NRC's well-logging licensee having to expend significant resources.
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PART W RADIATION SAFETY REQUIREMENTS FOR WIRELINE SERVICE OPERATIONS AND SUBSURFACE TRACER STUDIES i
Sec. W.1 Purpose. The regulations in this part establish radiation safety requirements for persons using sources of radiation for wireline service operations including mineral logging, rMioactive markers, and subsurface tracer studies.
The requirements of this part are in addition to, and not in substitution for, the requirements of Parts A, B, C, D, and J of these i
regulations.
1 Sec. W.2 Scope. The regulations in this part apply to all licensees or 4
registrants who use sources of radiation for wireline service operations including mineral logging, radioactive markers, or subsurface tracer j
studies.
Sec. W.3 Definitions. As used in this part, the following definitions apply
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" Field station" means a facility where radioactive sources may be stored or used and from which equipment is dispatched to temporary jobsites.
I
" Injection tool" means a device used for controlled subsurface ' injection of i
radioactive tracer material.
" Logging supervisor" means the individual who provides personal supervision of the utilization of sources of radiation at the well site.
" Logging tool" means a device used subsurface to perform well-logging.
" Mineral logging" means any logging performed for the purpose o't mineral exploration other than oil or gas.
" Personal supervision" means guidance and instruction by the supervisor who is physically present at the jobsite and watching the performance of the l
operation in such proximity that contact can be maintained and immediate assistance given as required.
i
" Radioactive marker" means ' radioactive material placed subsurface or on a' structure intended for subsurface use for the purpose of depth determi-nation or direction orientation.
4
" 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 4
source in well-logging operations.
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" Subsurface tracer study" means the release of a subs' nee tagged with radioactive material for the purpose of tracing the movement or position of i
the tagged substance in the well-bore or adjacent formation.
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' Temporary jobrit3 manna n locatien to which radioactiva matsriolo havo 8
been dispatch:d to perferm wireline service operations or subsurface tracer studies.
'Well-bore" means a drilled hole in which wireline service operations and subsurface tracer studies are performed.
t "Well-logging" means the lowering and raising of measuring devices or tools i
which may contain sources of radiation into well-bores or cavities for the purpose of obtaining information about the well and/or adjacent formations.
" Wireline" means a cable containing one or more electrical conductors which is used to lower and raise loggirg tools in the well-bore.
" Wireline service operation" means any evaluation or mechanical service which is performed in the well-bore using devices on a wireline.
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Sec. W.4 Prohibition. No licensee shall perform wireline service opera-tions with a sealed source (s) 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:
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(a in ttie We'nt a sealed 7s~ourc'e'Is lodged downhole, a reasonable effort
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at recovery will be made; and'
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6)' in the' event a decisioWis'inade to hbandon the sealed source downholii, the requirements of W.501(c) [and the name of any other State Agency having
. applicable regulations) shall be. net..
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Equipment Control I
l Sec. W.101 Limits on Levels of Radiation.
Sources of radiation shall be i
used, stored, and transported in such a manner that the transportation requirements of Part C and the dose limitation requirements of Part D of i
I these regulations are met..
I Sec. W.102 Storage Precautions.
(a)
Each source of radiation, except accelerators, shall be provided with a storage and/or transport container. The container shall be provided with a lock, or tamper seal for calibration sources, to prevent unauthorized i
removal of, or exposure to, the source of radiation.
i (b)
Sources of radiation shall be stored in a manner which will minimize
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danger frosi explosion and/or fire.
Sec. W.103 Transport Frecautions. Transport containers shall be phys-ically secured to the transporting vehicle to prevent accidental loss, tampering, or unauthorized removal.
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Sea. W.104 Radintion Survey In:truments.
(a)
The licensee or registrant shall maintain sufficient calibrated and.
operable radiation survey instruments at each field station to make physical radiation surveys as required by this part and by D.201 of these i
regulations.
Instru roentgen (2 58 x 10 p ntation shall be capable of measuring 0.1 milli-C/kg) per hour through at least 20 milliroentgens (5.16 x 10~6 C/kg) per hour.
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(b)
Each radiation survey instrument shall be calibrated:
(1) at intervals not to exceed 6 months and after each instrument servicing; (2) at energies and radiation levels appropriate for use; and 4
(3) so that accuracy within plus or minus 20 percent of the true radiation level can be demonstrated on each scale.
i (c)
Calibration records shall be maintained for a period of 2 years for i
inspection by the Agency.
Sec. W.105 Leak Testing of Sealed Soucces.
1 (a)
Requirements.
Each licensee using sealed sources of radioactive material shall have the sources tested for leakage. Records of leak test results shall be kept in units of microcuries and. maintained for. inspection l
by the Agency for 6, months after the next required leak test is performed j
or until transfer or disposal of the sealed source.
(b)
Method of Testing.
Tests for leakage shall be performed only by persons specifically authorized to perform such tests by th( Agency, the U.S. Nuclear Regulatory Commission, an Agreement State, or a Licensing State.
The test sample shall be taken from the surface of the source,.
source holder or from the surface of the device in which the source is stored or moun,ted and on which one might expect contamination to accum-ulate.
The test sample shall be analyzed for radioactive contamination,
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and the analysis shall be capable of detecting the presence of 0.005 micro-i curie (185 Bq) of radioactive material on the test sample.
(c)
_ Interval of Testing.' Each sealed source of radioactive material shall i
be tested at intervals not to exceed 6 months.
In the absence of a certi-ficate from a transferor indicating that a test has been made prior to the transfer, the sealed source shall not be put into use until tested.
If, for any reason, it is suspected that a sealed source may be leaking, it shall be removed from service immediately and tested for leakage as soon as practical.
(d)
Leaking or Contaminated Sources.
If the test reveals the presence of 0.005 microcurie (185 Bq) or more of leakage or contamination, the licensee shall immediately wi'thdraw the source from use and shall cause it to be decontaminated, repaired, or disposed of in accordance with these
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A report dzscribing tho equipm:nt involv d, tha test resulta, and tha c rrectiva cotion taken chall be filcd with tha Agency.
- (e)
Exemptions.
The following sources are exempted from the periodic leak test requirements of W.105(a) through (d):
(1) hydrogen-3 sources; (2) sources of radioactive material with a half-life of 30 days or less; (3) sealed sources of radioactive material in gaseous form; (4) sources of beta-and/or gamma-emitting radioactive material with an activity of 100 microcuries (3.7 HBq) or less; and (5) sources of alpha-emitting radioactive material with an activity of 10 microcuries (0.370 MBq) or less.
Sec. W.106 Quarterly Inventory.
Each. licensee or registrant shall conduct a quarterly physical inventory to account for all sources of radiation.
Records of inventories shall be maintainbd for 2 years from the date of the inventory for insp'ection by the Agency and shall include the quantities and kinds of sources of radiation, the location where sources of radiation are assigned, the date of the inventory, and the name of the individual conducting the inventory.
See. W.107 Utilization Records. Each licensee or registrant shall ma'in-tain current records, which shall be kept available for inspection by the Agency for 2 years from the date of the recorded event, showing the fol-lowing information for each source of radiation:
(a) make, model number, and a serial number or a description of each source of radiation used; (b) he identity of the well-logging supervisor or field unit to whom assigned; (c) locations where used and dates of use; and l
(d) in the case of tracer materials and radioactive markers, the utili-zation record shall indicate the radionuclide and activity used in a particular well.
Sec. V.108 Design, Performance, and Certification Criteria for Scaled Sources Used in Downhole Operations.
(a)
Each sealed source, except those containing radioactive material in gaseous form, used in downhole operations and manufactured after (insert a date one year after the effective date of this part) shall be certified by the manufacturer, or other testing organization acceptable to the Agency, to meet the following minimum criteria.
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(1) be cf doubly encaptulatcd conatruction;
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(2) contain radioactive material whose chemical and physical forms 1
are as insoluble sind non-dispersible as practical; and (3) hasbeenindividuallypressurgtestedtoatleast24,656 pounds I
per square inch absolute (170 MN/m ) without failure.
l (b) For sealed sources, except those containing radioactive material in gaseous form, acquired after [ insert a date one year after the effective date of this part], in the absence of a certificate from a transferor certifying that an individual sealed source meets the requirements of l
W.108(a), the sealed source shall not be put into use until such deter-minations and testing have been performed.
(c) Each sealed source, except those containing radioactive material in gaseous form, used in downhole operations after [ insert a date. two years after the effective date of this part) shall be certified by the manu-facturer, or other testing organization acceptable to the Agency, as meeting the sealed source perfomance requirements for oil well-logging as contained in the American National Standard N542, " Sealed Radioactive Sources, i
Classification" in effect on [the effec.t$ve date of this part).
(d) Certification documents shall be maintained for inspection by the
]
Agency for a period of 2 years after source disposal.
If the source is i
abandoned downhole, the certification documents shall be maintained until
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the Agency authorizes disposition.
1 Sec. W.109 Labeling.
(a) Each source, source holder, or logging tool containing radioactive material shall bear a durable, legible, and clearly visible marking or label, which has, as a minimum, the standard radiation caution -symbol, without the conventional color requirement, and the following wording:
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DANGER /
hADI0ACITYE j
i This labeling shall be on the smallest component transported as a separate piece of equipment.
(b)
Each transport container shall have permanently attached to it a j
durable, legible, and cicarly visible label which has, as a minimum, the standard radiation caution symbol and the following wording: ',
DANGER /
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RADI0 ACTIVE
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NCrrIFY CIVIL AUTHORITIES [0R NAME OF COMPANY) 1 l
1/ or CAUTION I
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W.110-W.201 Sec W.110 In centien and Maint nan n.
(a) 6 months, a program of inspection and mainten i
ging tools, source bandling tools, storage containers, transport con-tainers, and. injection tools to assure proper labeling and physical condi i
tion.
Records of inspection and maintenance shall be maintained for a period of 2 years for inspection by the Agency.
(b)
If any inspection conducted, pursuant to W.110(a) reveals damage labeling or components critical to radiation safety, the device shall be to removed from service until repairs have been ande.
(c) The repair, opening or modification of any sealed source shall be performed only by persons, specifically authorized to do so by the the U.S. Nuclear Regulatory Commission, an Agreement State, or a State.
I Requirements for Personnel Safety i
k Sec. W.201 Training Requirements.
i i
(a)
No licensee or registrant shall permit any individual to act as a
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logging supervisor as defined in this part until such individual has:
j (1)
Regulatory Commission, an Agreement State, or a demonstrated an understanding thereof; instruction in'the i
1 (2) read and received instruction in the regulations contained in' l
this part and the applicable sections of Parts A, D, and J of these regulations.or their equivalent, conditions of appropriate license or
, certificate of registration, and the l'icensee's or registrant's oper-i
'ating and emergency procedures, and demonstrated an understanding thereof; and 1
(3) demonstrated competence to use sources of radiation, related handling tools, and radiation survey instruments which will be used on j
the job.
(b) handling of sources of radiation until such individual has:N I.
(1) read or received instruction in the 1,1censee's or registrant's operating and'esergency procedures and demonstrated an understandin thereof; and i
(2) demonstrated competence to use the logging supervisor, the sources,of radiation, related handlin tools, and iadiation survey instruments which will be used on the job.
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(c)
Tha lic2ncas cr registrent shall maintain employco training reccedo fer inspoetion by tha Agsney for 2 yOars following termination of employment.
Sec. W.202 Operating and Emergency Procedures. The licensee's of regis-trant's operating and emergency procedures shall include instructions in at'
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least the following?
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(a) 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 standards established in Part D of these regulations; (b) methods and occasions for conducting radiation surveys; (c) methods and occasions, for locking and securing sources of radiation; (d) personnel monitoring and the use of personnel monitoring equipment; (e) transportation to temporary jobsites and field stations, including the
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packaging and placing of sources of radiation in vehicles, placarding of vehicles, and securing sources of radiation during transportation; (f)... inimizing expos ~m -
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I(g) procedure for notifyin5]r6 pef pe7s6nhel in the event'or an accident; s
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(h) maintenance of records; (1) inspection and' maintenance of source holders, logging tools, source handling tools, storage containers,' transport containers, and injection tools;
' [j)" ' procedure.to' be followe.dgthe evenf a seale'd source.is lodged
- downhole; and (k) procedures to be used for picking up, ' receiving, and opening packages containing radioactive material.
Sec W.203 Personnel Monitoring.
(a)
No licensee or registrant shall permit any individual to act as a logging supervisor or to assist in the handling of sources of radiation unless each such individual wears either a film badge or a thermo-luminescent dosimeter (TLD).
Each film badge or TLD shall be assigned to and worn by only one individual.
(b)
Personnel monitoring records shall be maintained for inspection until the Agency authorizes disposition.
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Precautionary Procedur:3 in Logging and Subrurfaco Traccr Op: rations Sec. W.301 Security.
l During each logging or tracer application, the log-ging supervisor or other designated employee shall maintain direct surveil-l lance of the operation to protect against unauthorized and/or unnecessary entry into a restricted area, as defined in Part 1 of these regulations.
_S_ec. W.302 Handling Tools.
The licensee shall provide and require the use i
of tools that.will assure remote bandling of sealed sources other than low-activity calibration sources.
Sec. W.303 Subsurface Tracer Studies.
i (a)
Protective gloves.and other appropriate protecti e 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.
(b)
No licensee shall cause the injection of radioactive material into potable aquifers without prior written authorization from the Agency [and any other. appropriate state Agency). '
Sec. W.304 Particle Accelerators. No licensee or regist ant shall permit above-ground testing of particle accelerators, designed for use in well-logging, which results in the production of radiation, except in areas or facilities controlled or ' shielded so that the requirements of D.101 and D.105 of these regulations, as applicable, are met.
i Radiation Surveys and Records Sec. W.401 Radiation Surveys.
(a)' Radiation surveys and/or calculations shall be made.and recorded for ea'h area where radioactive materials are stored.
c (b) Radiation surveys and/or calculations shall be made and recorded for the radiation levels in occupied positions and on the exterior of each vehicle used to transport radioactive material. Such surveys and/or calaulations shall include each source of radiation or combination of sources to be transported in the vehicle.
(c) After removal of the. sealed source from the logging tool and before departing the jobsite, the. logging tool detector shall be energized, or a survey meter used, to assure that the logging tool is free of contamina-tion.
(d) Radiation surveys shall be made and recorded at the jobsite or well-head for each tracer operation, except those using hydrogen-3, carbon-1'4, and sulfur-35. These surveys shall include measurements of radiation levels before and after the operation.
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(o) datos, the id:ntification of individual (s) making the fication of survey instrument (s) used, and an exact description of the location of the survey.
inspection by the Agency for 2 years after completion o
.Sec. W.402 Documents and Records Required at Field Stations.
licensee or registrant'shall maintain..for inspection by the Agency
- Each following documents'~and records for the specific devices ahd sources
, the at the field station:
(a) appropriate license, certificate of registration, or equivalent document;
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(b)_ operating knd,', emergencyJroceISEs7-(c) applicable a gulations; (d)
W.104; records of the latest survey instrument calibrations pursuant to (e) records of the latest leak test rhaults pursuant to W.105; (f) quarterly inventories required pursuant to W.106; (g) utilization records required pursuant to W.107; (h) records of inspection and maintenance required pursuant to W.110; and (1) survey records required pursuant to W.401.
See. W.403 Documents and Records Required at Temporary Jobs 5.tes.
licensee or registrant conducting operations at a temporary jobsite shall Each have the following documents and records available at that site for inspection by the Agency:
(a) operating and emergency procedures; (b) at the site; survey records required pursuant to W.401 for the period of operation (c) evidence of current calibration for the radiation survey instruments in use at the site; and (d) priate license, certificate of registration, or equivalen e
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E W.501 Notification See. W.501 Notification of Incidents. Abandonment, and Lost Sources.
(a) Notification of incidents and sources lost in other than downhole logging operations shall be made in acoordance with appropriate provisions of Part D of these regulations.
(b) Wbenever a sealed source or device containing radioactive material is lodged downhole, the licensee shall (1) monitor at the surface for the presence of radioactive contamin-ation with a radiation survey instrument or logging tool during logging tool recovery operations; and (2) notify the Agency immediately by telephone if radioactive contam-ination is detected at the surface or if the source appears to be damaged.
(c) When it becomes apparent that efforts to recover the radioactive t
source will not be successful, the licegsee shall (1) advise fhe well-operator of [the regulations of the appropriate State Agency regarding abandonment and) an appropriate method of abandonment, which shall include (i) the immobilization and sealing in place of the radioactive source with a, cement plug, (ii) the setting of a whipstock or other deflection d'evice, and (iii) the mounting of a permanent identification plaque, at the surface of the well, containing the appropriate information required by W.501.(d);
(2) notify M.e Agency'by telephone, giving the circumstances of the loss, and request approval of the proposed abandonment procedures; and (3) file a written report with the Agency within 30 days of the abandonment, setting forth the following information:
(i) date of occurrence and a brief description of attempts to recover the source, (ii) a description of the radioactive source involved, includ-ing radionuclide, quantity, and chemical and physical form, (iii) surface location and identification of well, (iv) results of efforts to immobilize and set the source in ~
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(v) dipth of th9 radioactiva sourcs, (vi) depth of the top of the cement plug, (vii) depth of the well, and (viii) information contained on the pemanent identification plaque.
(d)
Whenever a sealed source containing radioactive material is abandoned downhole, the licensee shall provide a permanent plaque 2/. for posting the well or well-bore. This plaque shall:
(1) be constructed of long-lasting material, stich as stainless steel or monel, and (2) contain the following information engraved on its face:
(i) the word " CAUTION",
(ii) the radiation symbol without the conventional color requirement,
-s (iii) the date of abandonment, (iv) the name of the well operator or well owner, (v) the well name and well identification number (s) or other designation, (vi) the sealed' source (s) by radionuclide and quabtity of
- activity, (vii) the source depth and the depth to the' top of the plug, and (viii) an appropriate warning, depending on the specific circumstances of each abandonment.1/
(e)
The licensee shall imnediately notify the Agency by telephone and subsequently by confirming' letter if the licensee knows or has reason to believe that radioactive material has been lost in or to an underground
,2f An example of a suggested plaque is shown in Appendix B of this part.
1/ Appropriate warnings may include: (a) "Do not drill below plug back depth"; (b) "Do not enlarge casirig"; or (c) "Do not re-enter the hole",
followed by the words, "before contacting the [ insert the name of the radiation control Agency),".
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potnbis watcr sourco. Such notice chall danignnto tha well locatien and shall describe the magnitude and extent of loss of radioactive material, assess the consequences of such loss, and explain efforts planned or being taken to mitigate these consequences.
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APPENDIX A SUBJECTS TO BE INCLUDED IN TRAINING COURSES FOR LOGGING SUPERVISORS e
I.
Fundamentals of Radiation Safety A. Characteristics of radiation B. Units of radiation dose and quantity of radioactivity C. Significanoe of radiation dose
- 1. Radiation protection standards
- 2. Biological effects of radiation doso D. Levels of radiation from sources of radiation E. Methods of minimizing radiation dose
- 1. Working time 2.. Working distances
- 3. Shielding
)
II. Radiation Detection Instrumentation to be Used A.
Use of radiation survey instru'ments
- 1. Operation
- 2. Calibration
- 3. Limitations B.
Survey techniques C.
Use of personnel' monitoring equipment III. Equipment to be Used A. Bandling equipment B. Sources of radiation C. Storage and control of equipment D. Operation and control of equipment IV. The Requirements of Pertisent Federal and State Regulations V.
The Licensee's or Registrant's Written Operating,and Emergency Procedures l
VI. The Licensee's or Registrant's Record Keeping Procedures O
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MliEBX52 fD Example of Plaquo far Idintifying Walls Containing Sealed Sources Containing Radicactivo Material Abandonsd Downhole O
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The size 'af the plaque sh'ould be convenient for use on active or inactive wells, e.g., a 7-inch squpre. Letter size of the word " CAUTION" should be approxir:ately twice the letter size of the' rest of the infornstion, e.g.,1/2-inch and 1/4-inch letter size, respectively.
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