ML20207B476
| ML20207B476 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/1999 |
| From: | Haisfield M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137R858 | List: |
| References | |
| FRN-64FR19089, RULE-PR-39 AG14-1-001, AG14-1-1, NUDOCS 9906010040 | |
| Download: ML20207B476 (10) | |
Text
_ _ _ _ - _ _ _ _ _ _ _ - -
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UNITED STATES
/M 1
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20665-0001 t,,..... p May 18, 1999 MEMORANDUM TO:
Nuclear Document System (NUDOCS)
FROM:
Mark Haisfield Rulemaking and Guidance Branch Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
REGULATORY 'rilSTORY (64 FR 19089)
Attached for your processing are the regulatory documents (PDR and CF) comprising the regulatory history of the Notice of Proposed Rulemaking entitled " Energy Compensation Sources for Well Logging and Other Clarifications" which proposed amendments to 10 CFR Part 39 (AG14-1). This notice was published in the Federal Reaister on April 19,1999 (64 FR 19089).
If you have any questions or if I can be of further assistance, please call me at 415-6196.
Attachment:
Regulatory History Documents for e
the Proposed Rule (AG14-1)
(including this cover memo) cc:
Betty Golden
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tjR!LLING/ LOGGING Logging While Drilling David Allen Dave Bergt David Best Bnan Clark lan Falconer The engineering of well logging sensors onto lean-Michel Hache Real-time logging while-drilling presents a drillcollars is stimulating a revolution in Crain Kienitz typical engineenne challenge: Take an eust.
logging and drilling. It gwes the daller more Marc lesage inn technology-wel) logging-and adapt et comprehensive real-time information, and John Rasmus to do the same tob under much harsher gives the geologist a look at the formatsons Claude Roulet (onditions. A tough task on several counts.
while invasion is taking place.
Peter Wraight Survnabihtv: A wirehne logging tool has This technology will arrect logging hard-Sugar Land. Texas to endure the occasional jolt when tnpping ware, onterpretation methodology, ecnomics in and out of the hole, but only intermittent-of dnlling and loggong. and the roles played Iy while making its measurements. Logging-bv dnllers, geologists, petrophvsscists and s hile-driIIing tools have to give their best log analysts. It is expected to attord savings performance under the most adverse condi-for oil companies by increasing the etiicien-tions oi sudden, briei shocks up to 1,000 g-cy and effectiveness of their dulling pro-milliseconds Ig msli vertically, laterally and l
grams.
torsionallv for the life of the bit run-mavbe This article introduces the Prospector
- more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. In one well, loggsng-loggingmhsle-drilling (LWD ~ stem. which while-drilling tools may work for as many provides measurements oiresu,...y, neu-hours as a wireline tool does in two years.
tron, density and spectral gamma ray from They must survive and give good data even new tools built into specsal dnII collars. It when the bottom hole assembly is in reso.
can be run simultaneousIV with Anadnll's nance, that is, when it vibrates and bends rneasurements-while-drilling (MWDJ sys-like a drive shaft out of balance. Additional-tems and can access Anadrill's mud-pulse Iy, they must survive the erosive effects of relemettv and the Advisor' surface system.
mud laden with cuttmgs and sand.
We explain how the LWD system is engi-Telemetry: A wireline tool communicates neered, how it integrares real-nme dn/ ling through a cable that easily conveys all the and logging ontormation, and its comple-iniormanon. Life is more complicated for mentanty with warehne measurements. The lhe LWD tool. Real-time data can on!y be Prospector system ss a rapsd/v evohing tech-sent by mud pulse telemetry, which has a nology. This article appears as the system much lower bandwidth and bit rate than enters commerctalization. Further develop-cable telemetry-about 3 bits per second for ments will re< pond to industrv demands and Anadrill's MWD-XL3'svstem2, compared to the perennial drive of research and engi-100 kilobits per second for wireline. This neering.
hmits the real-time transmission capacity, so nonessential data are stored in a downhole memory that is read when the LWD tools tor asmung in preparanon ci ih, article. thanks to reach the surface. The oil company there-Bruce sovie. wisharn t rank. chrean cabana. serev fore must decide, before logging, which Huchstal. Roger kww and E rik RheinAnudsen and %ke data il needs in real time.
sheppard. sugar Land. lew Sampi ng: The wireline engineer logs at the optimal Sampling rate for the tool suite
- Mark of sc hlurnhe'*
'^^'d""
and borehole conditions-data are sampled incrementally versus depth every 1.2,2 or 6 inches. Logging while-drilling tools samde data at regular time intervals: the rate is set s
Oilfield Review
~
MWDI MWDH CCon/ieurations tor at the surface and can be changed oniv the bottomhole when the tools return to the surface. The assembly ancludsnn sampling rate versus depth is the ratio of the
',^#N$,'dr,ft time sampling mterval and drill bit rate of Finneo Compensated uwD n.] and sec.
penetration (ROP), or, in a wiper trip, of the Stabihzers
-Density Neuuon-<
ond-generation Anvo speed the dnll stnna is lowered or raised in witti Windows (CDN) Tool lisvstems. The tools the hole. LWD tools, therefore, need a way GCm a Rays At$
turbfne*.
to acc mm date changes in survey speed Battenes are used to, nee page 12 for how LWD tools do thist.
backup and for logeing f urthermore, real time sniormation sampling w hen the turbene is not rate is limited by the mud telemetry.
Telemetry operat,nc. tot exam-Packagmg: A witehne tool operates alone h,#
in the borehole. accommodating only to the D
r Navigation A1WDI sn that at hJs a borehole diameter, deviation and mud prop-Gamma -(
h-Gamma ses sub that measures naw dnlling mechan.
ertses. Logging-while-dnlling tools have to Ray tit inside a drill collar, permit relatively uni-Ray bendeng moment. seie force at bit, pressure form fluid flow, and be designed 50 that
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derrerentialacross bit, wear points can be quickly and cheaply and tnaxial vsbrationt replaced. They must be versatile enough to Compensated
- als has a m dular function in a vanety of bottom-hole assem-
-Dual Resistivity-d*5'8" *hiCh * #5 P
blies and make-cp combinations.
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(CDR) Tool
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{,",,',%g To meet these challenges, Schlumberger Prosoccror sntem has assembled a team of engineers in Sugar 6W and 8-ench col.
Land, Texas from its Wireline and Anadnll lars. In srs entroductory divisions. In two years, they developed two y"",,00"y", new logging toolst4 that are combinable I*
Resistavstv lCDR*l tool with Anadrill's MWD systemL* (le/l). In a Drilling with the AfwDI svarem single output, the drilling engineer and well
-Mechanics and the CDR and site geologist can have all MWD data plus 1
-Sub compensated Density six new formation measurements from two W
^Q,'CO(('[
new tools, the Compensated Dual Resistivi-
,n ty (CDR) and the Compensated Density
- Wu na* iwoinmwinerm amplitude. the maum.
A riar. B Allen D Best D. Bonner 5. lundt L Lufmg M Pidcock C and Daudev L "Cuh Canada improves tA rit acc cierarm measurnt en a ( and rii.uimn and Nms M 11ertmmaec.euc Propagaton togging Drdlms With MWD Techmques.* Petroleum fnameer eur. n - radh + e% *. A m n ntLiuss a
- laumu 1 sm nas tne paw maun te as a shen us a hile Deannu lets and iaperiment paper bFE internal.onalto. no 9 (5eorember 1988h 16 24 tilIi 7. presented at the bird sPE Annual Techmcal 250 g s taume 2 n An ai r elevatam ni son u o a fumerence and imbihinon. Houston, October 2 po, a description of AnadnH's MWDi system:
roughts a< hieved in ur ppmu a tuul ham a herunt 14HM Bates TR fr and Martm CA:*Muhnensor Measure-u ot. several teve onto a na'd s rt.u e ments.whde Didlinn Tool improves Ordimg Econo.
u
- 2. For haws or mun.puhe telenwt'C t tark B Lulmat M. lundt L Ross M and Best D: *A mics." Of & Cas fournal82, no.12 (March 19.19840 Dehannes R *sutus Mann "WD TM knnkm Pan Dual Depth kruutwav Measurement for f f WD."
119 137.
2-Data Transmminn. tvernJeum ingmeer inter.
7,anw,,nn, u, pie menry.S, nth Annual SPsM A 6 For an overview a MWD sechnology:
nasermalho no to Ottonee 14MMr an.54
% mim,um." 5an Aninmo.1esas June 5 8.1988.
Desbrandes R " Status Report: MWD Technology Part p,,,,,., A 1-Data Acoussinon and Downhole Recording and 4 ham M Wambt R M.H.enbach E. RhemAnudsen i Procesung." Petroleum ingmeer freernahonalbo, no.
and Best D -f nemainn Porourv Measurement Whde 9 fSepicmber 1988t 27 33.
DriHmu " frJosa reuns or the benry Nenth Annual SPWt A Svmtmaunt." San Antomo. Texas, lune 5 8' Desbranses R. rescience 2.
W R "Sim Report MWD Technolony Part 5 n a Ananrdr second seneration MWD sys-s Engineerinsem' anonas:60. no. I1 (November 19880
% lake W ann Smle B "MWDil Anadedl's Setond t sererarnm Meaasurement Whde Drdimg Tool."
. Ikdbona arwi Pungsma luumal1 (Decem0er 1988t 23-MS Volume I Number !
1
Logging While Drilling Schlumberger Wireline & Testing and Anadrill have integrated their wireline logging and measurement-while-drilling (MWD) expertise to develop and introduce logging while drilling (LWD).
LWD resistivity, neutron, density and gamma ray tools in drill collars can be run simultaneously with the Anadrill MWD system, using mud pulse telemetry to transfer the downhole recorded data to surface. Merging the wcil-known MWD directional and drilling mechanics data with LWD data in real time has powerful synergistic applications for drilling optimization and formation evaluation. This synergy minimizes drilling costs and improves safety. Real-time information at the rig site or in the client's office improves drilling and geological decisions. The weII can be steered to identified targets, and an optimum formation evaluation program can be planned as soon as the drill bit reaches the formation.
An astensk (*)is used throughout this document to denote a mark of Schlumberger.
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Battery (Ray, for resistivity from attenuation-ted from a 7.5-curie americium-beryl-l
- i amma ray deep).
I um source. The quantities of hydro-G
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The CDR tool has upper and lower gen in the formation,in the form of l
6 --i transmitters that fire alternately (Fig 5).
water-or oil-filled porosity, primanly Electronics The average of these phase shifts and control the rate at which the neutrons d
attenuations for the upward and down-slow down to epithermal and tnermal v
ward propagating waves provides a energies. Neutrons are detected in
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Mud measurement with borehole compen.
near-and f ar-spacing detectors, and channel I
9 E
sation similar in principle to that of the ratio processing is used for borehole Receivers <
y Transmitters BHC Borehole Compensated Sonic compensation. The energy of the tool. Borehole compensation reduces detected neutrons is predominantly l
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borehole effects in rugose holes, epithermal because a high percent-t improves vertical response, increases age of the incoming thermal neutron
] l) measurement accuracy and provides flux is absorbed as it passes through gp quality control for the log.
the 1-in. [25-mm) steel wall of the drill
{
The CDR tool can detect 6-in.
collar. Also, a wrap of cadmium under
[15.2-cm] beds. Shoulder bed effects, the detector banks shields them from Fgure 3. The CDR foolprowdes resishvity and however,willcause R sp and Rad o thermal neutrons arriving from the t
gamma ray bps while dri/Hg. taking advantage read too low in a thin, resistive bed inner mud channel. This mainly epi-with conductive shoulder beds, and a thermal detection practically elimi-ud[ are a
ra ve r ces es mate o/ rcssstiv#y.
small correction for bed thickness is nates adverse effects caused by required to obtain Rs. A major advan-
]
tage of the CDR tool is its abil.ty to Table 1. LWD Mechanical Specifications Table 1 shows mecnanical specifi-measure R, in thin beds before inva-Nomnal cameter 6.5-n API B n API l
cations for LWD tools. New 6h-and sion occurs. Once thin beds are Bit see range 8.5 to 10 n 12 25 to 17.5 n 8%in. collars will be introduced with deeply invaded, there is no reliable Mame weight on bit 50.000 lom 80.000 lom higher flow rate specifications. Table 2 method for obtaining true resistivity.
Mam@mng load 330 m WMW gives specifications of MWD collars.
The physics of measurements Mame w ram 600 gahn 1 2 gam n The CDR toolis an electromagnetic rnade by the CDN tool (Fio. 6) k simi-
'O propagation tool built into a drill collar lar to that of cc'rc&onding wire:ine g
(Fig. 3) It has many simitanties to dual services. For the neutron porosity Rotaung 4.5*D00 ft en00 ft induction tools and is used for similar measurement, fast neutrons are emit-cpplications. The tool responds to conductivity rather than resistivity.
Table 2. MWD Specifications operates in water-or oil-base muds Drm conar OHnj 7
8 9
and r avides two depths of investiga-tion..t has bet'.er Vertical resolution but Length MWD cot:ar only 32.5 ft:
32.5 t 32.5 fit a shallower depth of investigation than Length PRS (5!:er sa) 2.7 ft 23n 2 7 ft dual induction too s.
Lengin DWOB sub 4 4 ft 4n 4.3 ft The CDR tool broadcasts a 2-MHz 10 5n 5n 5 6 in electromagnetic wave and measures Momentof nema E7 n 170 4 n 273 8 in.
the phase shift and attenuation of the Equivalent bending su+tness" 6 42 n x 2 81 n 7.56 n x 2 Bl in.
8.5 n x 3 n wave between two receivers (Fig. 4).
Mud flow rate 210 to 750 gaumin 210 to 1200 gai/minn 350 to 1200 gavmin These quantities are transformed into Pressure crop (at 13 lbm/ga')
29 psi at 210 gavmin 29 psi at 210 gaumn 50 psi at 350 gaum n 371 psr at 750 gavmin 371 psi at 750 gal! min 590 psi at 1200 gavmin two independent resistivities that pro.
Mammum tempe'ature 30FF [150"C]
302*F(150*C) 302'F[150*C]
vide the two depths of investigation.
Maximum sand content 1% by volume 1% by volume 1% by volume The phase shift is transformed into Mainme solid content 3% by volume 3% by volume 3% by volume shallow resistivity (Rps, for resistivity from phase shift-sha!iow), the attenua-2 Length may vary shgnty from one cotar to anoiner. A 1.t: saver sub is usually used at tne bottom of Ine collar tion is transformed into deep resistivity n 3}t conar. 00 x 10 n Recommended range is 2'O to 750 gavmin Flows of 750 to 1200 gat / min can De accommooated depenong upon sond'sanc contents
. 1 :
3
".. e 5.
e Society of Petroleum Engineers SPE 27226 Operational and Environmental Safety With Nuclear LWD Tools J.D. Aitken
- and J.M. Holenka,* Schlumberger/Anadrill, and D.E. Torbett and K.W. Turner,'
Schlumberger Well Services
- SPE Members copynght 1994. Society of Petroleum Engmeers. Ire.
This paper was prepared for presentaten at the Second internstenal conference on Heanh. Safety & Environment in on & Gas Exploration & Production held in Jakarta. Indonese.
2647 January 1994.
This paper was selected for presentaten by an SPE Program Commmee foHowine revow of information contamed in an abstract submmed by the author (s) Contents of the paper, as presented have not been reviewed by the Socoty of Petroleum Engmeers and are sub9ect to correcten by the author (s). The materal. as presented. does not necessarHy reflect i
any ponnen of the Society of Petroleum Engmeets, no othcers. or members. Papers presented at SPE meetmos are subsect to pubicaten review by Editonal Commmees of the Society
(
I of Petroioum Engmoers. Permissen to copy a restncted to en abstract of r at more than 300 words. Illustratens may not be coped. The abstract should contaen conspcuous acknowledgment f
of wher2 and by whom the paper is presented. wnte ubranen. SPE. P.O. Box 833836,Rchardson. TX75063 3836 USA Telen. 163245 SPEUT.
1 Abstr:ct operator is required, by regulation and the need to protect both the safety of operations and the environment, to make every After several decades of use, resistivity, formation density and eff rt to recover them, neutron porosity measurements are considered fundamental to formation evaluation. In the last decade,loggir.g-while-drilling Logging tools containing radioactive sources are most (LWD) fonnation density and neutron porosity tools utilizing commonly conveyed on wireline cable. Similar tools, mn as chemical radioactive sources have been added to resistivity, part of the BIIA (bottomhole assembly) and performing gimma ray, directional and other drilling parameter tools run logging measurements while drilling (LWD) have been ts pirt of the bottomhole assembly (BilA) during drilling.
recently introduced. While retrieving stuck wireline tools is These drill-collar mounted formation evaluation tools are now routinely successful, retrieving a stuck BHA may present safely and reliably delivering high-quality data.
greater difficulties. The ability to recover radioactive sources fr m LWD tools stuck downhole makes it easy for the Field experience with one such tool, an LWD formation Perator to fish for or abandon the BHA without regulatory or density-neutron porosity tool with wireline-retrievable logging envimnmental roblems.
P sources, is discussed. The paper gives statistics that show the success in retrieving sources from LWD tools in stuck One currently available nuclear LWD tool, the CDN*
bottomhole assemblies. A number of operational safety Compensated Neutron Density tool (which exists in 6 8/2-in.
techniques have been enhanced, resulting in a reliable and safe and 8-in. sizes),is equipped with retrievable logging sources.
system. A new source retrieval and communications tool Afier retrieval of the logging sources, extremely small significantly enhances the tool's operational efficiency, amounts of radioactive material are left in the tool in the form In the unlikely event that downhole conditions prevent of reference sources for the measurement system, but these retrieval of the chemical radioactive sources from the LWD pose little regulatory problem in most countries outside the tool, safe, well-established and accepted abandonment United States, and no significant environmental prob!em.
procedures are given.
I troduction For more than 30 years, wircline well logging measurements Radioactive material is introduced into openhole (uncased) oil using nuclear techniques have become fundamental to the end gas wells in the form of sealed sources in various evaluation of hydrocarbon reservoirs. In addition to measuring me:suring instruments (logging tools) for the purpose of defining the lithology and fluid content of reservoirs. If tools containing radioactive sources become stuck in the hole, the
- Mark of Schlumberger 233
1 C
'i 2
OPERATIONAL AND ENVIRONMENTAL SAFETY WITH NUCLEAR LWD TOOLS
- n U j 8 % ou t j in Y. o 3 %.y 1 EP evalurtior, of hydrocarbon reservoirs. In addition to measuring which (as a mixture) emits neutrons and 15Q ;
{
o the formation's natural gamma rays, the basic openhole porosity measurements (figure 2). 24 gamma rays, is used as a source of neutrons in fort.
n nuclear measurements are: (1) formation bulk density using a chemical source of gamma rays and (2) formation porosity emitter of alpha particles (2 protons + 2 using a chemical source of neutrons. These have been low-energy (60 kev) gamma rays. The alpha particles extensively described in the literature.i.2.3 interact with the beryllium with the emission of neutrons j
Modern wireline density logging tools have extended their f around 5 MeV. 241Am oxide and beryllium are not measurement ability to include a lithology indicator based on water-soluble. The neutron logging source used m the photoelectric absorption of low-energy gamma rays.'J This is DN tool contains 7.5 Ci of americium-beryllium achieved through spectroscopic gamma ray measurements, which require gain stabilization of the detector system using In addition to these logging sources, two extremely small extremely small chemical sources of radiation in addition to sources, one containing less than 1 pCi (microcurie) of 137Cs, the regular logging sources.
the other containing iess than 50 pCi of 241 Am, are used as The CDN tool discussed in this paper was designed to produce energy s eferences in the spectroscopic gamma ray calibrated data of high quality for use in quantitative formation measurements. They are placed in intimate contact with the evaluation. The density section contains a spectroscopic detector crystals. The Am reference source is used in one gamma ray measurement yielding both density and lithology getect r where cesium,s 662 kev gamma ray emission
'"I*'*5
- th the basic measurement. Alpha particles information. The neutron section contains a compensated neutron measurement. Both sections use measurement physics emitted by 24 Am are absorbed by the source s metalhc identical to those of current wireline tools.6 encapsulation, and the only extemal radiation from the Am reference source is of 60 kev gamma rays.
Field experience confirms that the density and neutron porosity measurements of the CDN tool, combmed w,th The IAEA (International Atomic Energy Agency), the i
resistisity and, spectral gamma ray measurements obtamed international regulatory body for the use of radioactive material, stipulates that all logging sources must be from the CDR Compensated Dual Resistivity tool,7 provide reliable and accurate petrophysical evaluations.
manufactured according to a stringent ISO (International Standards Organization) quality specification,8 a summary of This breakthrough in LWD logging technology coincides with which is given in Table 1. These encapsulated sources a large increase in drilling extended reach, high deviation and comfortably withstand all conditions encountered in normal horizontal wells. The ability to log such wells in combination well operations and, as an added precaution, are leak-tested on with directional measurements while drilling (MWD) and a regular basis to ensure their integrity, steerable motor systems, gives the operator the ability to review and control a well's progress in real time and direct the Reference sources, which form part of the detection system well to its target.
and are within the pressure housing of the tool, are currently also manufactured to the same ISO specification. liowever, as LWD is also being used to log wells where wireline logging they are not subject to well pressure, and dismounting detector has historically been difficult or time consuming, due to assemblies on a regular basis for leak testing mignt damage difficult hole conditions or complex well profiles.
them, reference sources are generally exempted from regular For the above reasons, the use of LWD logging tools leak testing. Leak tests are performed every time a detector containing radioactive sources in extremely difficult well package is dismounted for repair.
conditions is increasing.
Safety features of the CDN LWD tool Radiation sources used in the CDN In addition to high-quality measurements, radiation safety was The chemical sources of radiation used in the CDN tool are a principal g al f the CDN design team.' Recognizing that BilAs can become stuck while drilling, a retrievable source
- 1) Ces.ium 137 (137Cs) emits gamma rays of 662 kev (Kil system was considered an essential part of the tool design.
Removing the logging sources from the BliA allows the electron volts) and Beta particles of around 200 kev. The operator much greater freedom in the techniques utilized to beta particles are stopped by the source encapsulation and free the BliA and greatly reduces the restrictions on the gamma ray emission is used in fotmation bulk density subsequent well operations if the BliA is abandoned.
measurements (figure 1), 337Cs is a highly soluble radioactive material. For this reason, the material used in To achieve this, the 248Am neutron and 137Cs density sources CDN logging sources is in the form of cesium chloride are connected together by a flexible connector. This dual-fused in a glass or ceramic material which is insoluble.
source assembly is fitted with a standard profile fishing head, The density logging source used in the CDN tool contains which can be engaged with a wireline fishing tool (figure 3).
1.7 Ci (Curies) of 137Cs.
This assembly is placed in the tool through the drill collar
- 2) A mixture of radioactive americium 241 (24 Am) oxide bore, rather than loaded from the outside through a cavity in powder and beryllium powder compressed into a pellet, the collar.
LWD tools must be manipulated by the rig floor crew as part of the BIIA. By regulation, only trained radiation workers, J
Mark of schlumterger 234
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Introduction 1
Electrical welllogging was introduced to the oil industry ried on from station to station until the entire log was over half a century ago. Since that time, many additional recorded. A portion of this first log is shown in Fig.1-1.
and improved logging devices have been developed and put into general use.
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/.Pg_ftDRONN,w sa, e,wM; As the science of well logging advanced, the art of in-terpreting the data also advanced. Today, the detailed T "EY ""_ g: 2).,
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analysis of a carefully chosen suite of wireline services t J provides a method of deriving or mferring accurate values
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g' -"Q This document therefore presents a review of these well j.
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logging methods and interpretation techniques. The
,_. j various openhole services offered by Schlumberger are lp. p.. Y]~
gg discussed in some detail, together with essential methods yM mgg of interpretation and basic applications. The discussion O '../M. f[ ( *'
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is kept as brief and clear as possible, with a minimum
%]' $ M of derivational mathematics. it is hoped that the document will serve as a useful 5sm a 5t gL p$'Q, ., % pg,: % y. handbook for anyone interested in well logging. For those l .y who may be interested in more detailed material, the t : MM, qit . ^ AF7Q references at the end of each chapter and the other well M 8 logging literature can be consulted. %Ag ,',L 59 $n4,3 ghf d id. h, [} [@r%j% HISTORY 'N ~J $f
- 2 The first electrical log was recorded in 1927 in a well in
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7 d lO the small oil field of Pechelbronn, in Alsace, a province f of northeastern France. This log, a single graph of the gd N. ?T .AJ q m electrical resistivity of the rock formations cut by the borehole, was recorded by the " station" method. The @r tv.Y F. - s. WA s._ downhole measurement instrument (called sonde) was stopped at periodic intervals in the borehole, measurements were made, and the calculated resistivity was hand-plotted on a graph. This procedure was car. Fig.1 1-The first log: points plotted on graph paper by Henri Doll. 1-1 ~
- LOG INTERPMETA TION PRINCIPLE $/A PPl.lCA TIONS a
in 1929, electrical resistivity logging was introduced on that the neutron gained acceptance as a porosity measure-a commercial basis in Venezuela, the United States, and ment. The Dual Porosity neutron tool combines those two { Russia, and soon afterwards in the Dutch East Indies. neutron measurements into a single tool. The usefulness of the resistivity measurement for correla-Early attempts at porosity determination employed tion purposes and for identification of potential microresistivity measurements. The Microlog tool, in-i hydrocarbon-bearing strata was quickly recognized by the troduced in the early 1950's, uses a miniature linear ar-oil industry. ray of three electrodes imbedded in the face of an in-In 1931 the spontaneous potential (SP) measurement sulating pad, which is applied to the borehole wall. A i was included with the resistivity curve on the electrical borehole caliper is provided by the arm carrying the elec-log. In the same year, the Schlumberger brothers, Marcel trode pad and an opposite backup arm. and Conrad, perfected a method of continuous recording The Microlog recording is also useful to delineate and the first pen recorder was developed. permeable beds, and other microresistivity devices help The photographic-film recorder was introduced in establish the resistivity profile from the invad:d zone near 1936. By then, the electrical log consisted of the SP curve the borehole to the noninvaded virgin forriation. The and short normal, long normal, and long lateral resistivity Microlaterolog tool vas developed for salt mads in 1953. curves. This combination was predominant in logging ac-The MicroProximity log and MicroSFL' log hase tivity from 1936 to the late 1950's. Afler about 1946, these follow ed. curves were recorded simultaneously, in 1951, the laterolog tool, the first fo:used deep-The development of a dipmeter log began in the early investigating resistivity device, was introduced. It uses a 1930's with the anisotropy dipmeter tool. The three-arm focusing system to constrain the surveying current (emit-dipmeter device, with an associated photoclinometer, was ted from a central electrode) to substantially a horizon-introduced in 1943; it permitted both the direction and tal disc for some distance from the sonde. Focused angle of the formation dip to be determined. Each arm resistivity logs are well adapted for investigation of thin j contained an SP sensor. In 1946, the SP sensors were beds drilled with low-resistivity muds. The laterolog replaced by short resistivity devices; this made dip device quickly supplanted conventional resistivity logs in measurements possible in wells where the SP had little salt muds and highly resistive formations. correlatable detail. Over the years, several laterolog tools were developed The first continuously recording electrical dipmeter and used commercially. Today, the DLL* duallaterolog sonde, w hich used three microresistivity arrays and con-tool, which consists of deep laterolog and shallow tained a fluxgate compass, followed in the mid-1950's. laterolog measurements, is the standard. It is usually run Since then, numerous developments have further refin-with a MicroSFL device as well. ed the measurement of formation dip. Today, a four-arm in freshwater muds, the original electrical log has been dipmeter tool records 10 microresistivity curves replaced by the induction log. The induction log was simultancously, and a triaxial accelerometer and developed in 1949, as an outgrowth of wartime work with magnetometers provide highly accurate information on mine detectors, for use in oil-base mud. However, its tool deviation and azimuth. The processing of these data superiority over the electrical log in freshwater muds was into formation dip information is now done exclusively soon recognized. with electronic computers. By 1956, a five-coilinduction device was combined with The gamma ray (GR) and neutron tools represented the SP curve and a 16-in. normal to make the induction-the first use of radioactive properties in welllogging and electrical tool, in 1959, the five-coil device was replaced the first use of downhole electronics. Unlike SP and by one with a six-coil array with deeper investigation, resistivity tools, they are able to log formations through The DIL* dual induction log, introduced in 1963, is steel casing, as well as in air-or gas-filled holes or in oil-now the standard. It consists of deep induction, medium based muds. The neutron log was described by Pontecor-induction, and shallow resistivity measurements. The yo in 1941. shallow resistivity-measuring device is now a focused In combination with the GR log, a neutron log resistivity device - a Laterolog 8 on the 1963 tool and enhances lithological interpretations and well-to-well an SFL device on current tools. A new dual induction stratigraphic correlations. After about 1949, attention log, the Phasor* induction, proudes improsed thin. bed was given to the neutron log as a porosity indicator. response, deeper depth of investigation, and greater However, the early neutron logs were greatly influenced dynamic resistivity range. by the borehole environment, it was not until the in-Since the 1930's, logging cables has e been used to lower troduction of the SNP sidewall neutron porosity toolin geophones into wells to measure long-interval acoustic 1962 and the CNL* compensated neutron tool in 1970 travel times from sound sources at the surface.
- Mark of Schlumberger 1-2 lE 2
/?~ l q f fff ? E~ o 5 l %,.....f RULEMAKING ISSUE (Information) May 28, 1997 SECY-97-111 FOR: The Commissioners FROM: L. Joseph Callan Executive Director for Operations
SUBJECT:
RULEMAKING PLAN: ENERGY COMPENSATION SOURCES FOR WELL LOGGING AND CLARIFICATIONS - CHANGES TO 10 CFR PART 39. PURPOSE: To inform the Commission that the staff's draft Rulemaking Plan that would modify well logging requirements to reflect the use of new well logging technology has been forwarded to the Agreement States for their comment. Other changes are also being proposed to improve, clarify, and update Part 39. BACKGROUND: Part 39 provides the licensing and radiation safety requirements for well logging. The basic regulation was promulgated about 10 years ago when the technology required drilling to stop while parts of the drilling pieces were removed before lowering the logging tool down a well. More recent technology allows well logging to be accomplished during drilling. This technology requires a small radioactive source referred to as an energy compensation source. or ECS. Well logging licensees have identified concerns with the current well logging requirements that were written for the larger-curie sources. AGREEMENT STATE IMPLEMENTATION ISSUES: Agreement State licensees should benefit from these changes in a manner similar to NRC licensees. We do not anticipate any Agreement State issues. This rulemaking would be a compatibility level II. that is, the Agreement States must adopt these requirements, but they could be more stringent if they desire. CONTACTS: NOTE: TO BE MADE PUBLICLY AVAIALBLE IN Bruce Carrico. NMSS. 415-7826 5 WORKING DAYS FRoM THE DATE OF THIS PAPER Mark Haisfield. RES. 415-6196 b$){p $$\\ h
4 I - The Commissioners C00RDINATIONi The Office of the General Counsel has no legal objection to the draft Rulemaking Plan. The Office of the Chief Financial Officer has no objection to the resource estimates in the draft Rulemaking Plan. The Office of the Chief _ Information Officer has reviewed the draft Rulemaking Plan for information technology and information management implications and concurs in it. However. the plan impacts information collection requirements that must - be submitted to the Office of Management and Budget for review and approval. RESOURCES: Resources to complete the rulemaking are included in the current budget. 1 L. J eph Callan Executive Director for Operations
Attachment:
Draft Rulemaking Plan DISTRIBUTION: Commissioners oGC oCAA oIG oPA ' oCA CIo CFo EDo SECY~ L_
Draft Rulemaking Plan ENERGY COMPENSATION SOURCES FOR WELL LOGGING AND I CLARIFICATIONS - CHANGES TO 10 CFR PART 39 Reaulatory Problem. The licensing and radiation safety requirements for well logging are provided in 10 CFR Part 39. The basic regulation was promulgated about 10 years ago. Since then newer technology has been developed that was not envisioned when the rule was written. Portions of the existing regulations are overly burdensome and can be modified with minimal im)act to public health and safety. In addition, there are other sections that s1ould be changed to improve, clarify and update Part 39. Current Recuirements and Prooosed Chanaes. The princ1)al objective of the proposed rulemaking is to revise Part 39 to accommodate tie small radioactive sources that are now used in some well logging applications. When Part 39 was promulgated, the technology required drilling to stop while parts of the drilling pieces were removed before lowering the logging tool down a well, More recent technology referred to as ) " logging while drilling." allows well logging to be accomplished during drilling. This technology requires a small energy compensation source, or ECS. A second innovation separates the ECS and the logging tool from the larger well logging source to allow easier retrieval of the well logging i source if the drill stem becomes unretrievable. The ECS is a small source (less than 0.0001 curie) com)ared to the normal 3-to-20 curie sources used in well logging. Part 39 las no specific provisions for these small sources because the writers of the existing rule did not envision this technology. Many of the requirements in Part 39 when a) plied to an ECS. are not necessary to protect public health and safety and tie environment and may not be appropriate for an ECS. Because the existing regulations do not allow for variations based on the strength of the radioactive source licensees who use an ECS must meet all the requirements of Part 39. Examples of unnecessary requirements deal with well abandonment (Sections 39.15 and 39.77) leak testing (Section 39.35), design and performance criteria for sealed sources (Section 39.41), and monitoring of sources lodged in a well (Section 39.69). The NRC staff is proposing that only sections dealing with physical inventory (Section 39.37) and records of material use (Section 39.39) should apply for the use of an ECS. Therefore, the NRC staff is proposing to modify the regulations in Part 39 to define an ECS and provide appropriate regulations for using ECSs in well logging. The most significant change would exempt an ECS from the costly procedures for well abandonment. Well abandonment, in addition to specific reporting and approval requirements, requires that the source be immobilized and sealed in place with a cement plug. that the cement plug be protected from inadvertent intrusion, and that a permanent )laque be mounted at the surface of the well. Also, the well itself may not )e able to be used for its original purpose.
i The NRC staff is proposing to limit quantities of licensed material in an ECS to 3.7 MBq [100 microcuries]. This will provide licensees flexibility in the design of ECSs while limiting the source to levels that the Commission has already evaluated for other products and found to be of no significant impact to public health and safety. Current ECSs typically use u) to 50 microcuries of Am-241. The NRC has already authorized the distriaution of gas and aerosol detectors under Section 32.26 containing more than 100 microcuries of.Am-241 to persons exempt from an NRC license. I 'Several other changes would be proposed to improve, clarify, and update Part 39 requirements. 1. As with the changes being proposed for an ECS. tritium neutron generator target sources should not be required to meet all of the requirements in Part 39. Tritium neutron generator sources typically contain less than 20 curies of tritium which is less hazardous than the typical cesium or americium sources currently being used in well logging applications. The tritium sources only produce a significant neutron stream when a voltage is applied. For well logging applications, the NRC staff is proposing that the tritium neutron generator targets be subject to the requirements of Part 39 except for the sections dealing with well abandonment (Sections 39.15 and 39.77) and the sealed source design and performance criteria (Section 39.41). l As discussed below, the potential hazard of these sources does not warrant the existing requirements for well abandonment in the event that the source becomes lost. In addition. the requirements associated with sealed sources for well logging were not intended for tritium neutron generator target sources, but Part 39 has not been clarified to reflect appropriate requirements for using this type of source in well logging. The NRC staff is preposing to limit quantities of tritium to 1.110 MBq [30 curies] for tritium neutron generator targets. The current use of tritium neutron generator targets for well logging applications have not exceeded 20 curies. The 30-curie limit would allow licensees flexibility in new designs, while maintaining the tritium within an environmentally safe level. These sources are used for well logging in oil and gas wells. Since a surface casing is used to protect fresh water aquifers, the only potential exposure hazard these sources would present is to the workers. Exposure would only be a problem if the source were ruptured and the tritium were ingested in significant quantities. If a tritium source were lost, it would be contained within thousands of cubic feet of drilling mud. This drilling mud contains hazardous chemicals and is controlled and monitored as part of the drilling operations. Therefore the NRC staff believes that eliminating costly requirements for these sources will not significantly impact public health and safety. 2. Section 39.77 provides the requirements for notification and procedures for abandoning irretrievable well logging sources. This section specifies that NRC approval must be obtained prior to implementing abaridonment procedures. In some circumstances, such as high well pressures that could 2
lead to. fires or explosions, the delay required to notify NRC may cause an immediate threat. This section should be modified to allow immediate abandonment, without prior NRC approval, if a delay could cause an immediate threat to public health and safety. The NRC would be notified after the fact. '3. Section 39.15 provides requirements for abandoning irretrievable sealed sources. This section would be modified to provide performance-based criteria for inadvertent intrusion on the source. This would allow licensees greater procedural latitude while continuing to ensure source integrity. The current requirements may be more restrictive than is necessary for licensees to 3rotect an abandoned source, depending upon the individual well abandonment. or example, if a significant amount of drilling equipment is abandoned with the well.-this equipment maybe effective in preventing inadvertent intrusion on the source, but might not meet the requirements of Section 39.15. Paragraph (a)(5)(ii) of Section 39.15 has arescriptive requirements for irretrievable well logging sources, specifying t1e use of a mechanical device at a specific location within the abandoned well. The NRC staff is proposing that licensees " prevent inadvertent intrusion on the source." which would' require that the source be protected but allow licensees the flexibility to determine the best method. This proposed change would not affect the i requirement in (a)(5)(i) for a well logging source to be immobilized with a cement plug or the requirement in (a)(5)(iii) for a permanent plaque. 3 4. The NRC issued a generic exemption from the current design and performance criteria for sealed sources in 1989. This' exemption allows the use of older sealed sources, that have not demonstrated that they meet current criteria, to be used for well logging. This exemption is currently in use. but is not included in Part 39. The regulations would be modified to make this existing procedure an NRC regulation. Sealed sources that were in use before July 14, 1989. may use design and performance criteria from the United States of America Standards Institute (USASI) N5.10-1968 or the criteria in Section 39.41. The use of the USASI standard is based on an NRC Notice of Generic Exemption issued on July 25, 1989 (54 FR 30883). Sealed sources manufactured after July 14, 1989 had to . continue to meet the requirements of Section 39.41. NRC regulations have not incorporated the USASI N5.10-1968 requirements for older sealed sources. The primary difference between the two standards is that the new standard includes a vibration test that was included for consistency with international i standards. The USASI standard considered a vibration test and concluded that, to pass the other requirements, the source would be so rugged there was no reason to include a vibration test. The enmation to allow the use of the USASI standard was to avoid a situation in w1ich well logging licensees might be unnecessarily forced out of business.and have to dispose of their sources because the original source manufacturers failed to demonstrate that these sources meet criteria that became effective in 1989. The NRC determined that sealed source models -subject to the USASI standard would not adversely affect public health and 3
safety. Because many of these older sealed sources contain radioactive l material with half-lives that allow their continued use (i.e., cesium-137 and americium-241 have half-lives of 30 and 458 years respectively), this modification to the regulations is appropriate. 5. Section 39.35 specifies leak testing requirements for sealed sources. and paragraph (e) specifies exemptions from the testing requirements. The existing leak testing requirements should clarify that the requirements ap)1y to the radiation that is capable of escaping the source encapsulation. ratler than the radioactive element or material itself. For example, although Am-241 emits both alpha and gamma radiation, when encapsulated in stainless steel (e.g. an ECS source) only the gamma radiation can pass through the capsule. 6. Sections of Part 39 that contain dates that hve passed would be updated to reduce confusion. Sections 39.33 and 39.49 contain requirements that were dependent upon dates that have passed and are no longer appropriate. For clarity and to avoid confusion, these sections should be updated to remove requirements that are no longer appropriate. 7. Sections of Part 39 will be updated to conform with the agency's metric policy. Sections 39.15. 39.33. 39.35, and 39.41 contain units of measure that do not comply with the NRC metrication policy. The policy is to state the metric units first, with English units, if desired in brackets. Assessment of Imoacts on Licensees and Cost Effectiveness. This rulemaking, compared to current requirements, would provide relief to NRC and Agreement State licensees who use an ECS or a tritium neutron generator target for well logging without a significant impact on health and safety. Other revisions to Part 39 would reduce confusion, and may reduce costs, for NRC and Agreement State licensees. A review of some typical well abandonments has shown that wells have been abandoned with only the ECS present at costs that range from 100's of thousands of dollars to over a million dollars. Since NRC resources to amend 10 CFR Part 39 are estimated to be about one staff year, this is a cost . effective one-time use of resources. OGC Analysis. The principal objective of the proposed rule is to change the current regulations to reflect the use of new technology that allows logging operations to be done concurrently with drilling. This rule would more appropriately regulate small energy compensation sources. The rule would modify the abandonment procedures for inadvertent intrusion on the source using performance-based criteria, modify the abandonment procedures for tritium neutron generator target sources to avoid costly abandonments since 4 l
4 this hazard does not warrant the use of the existing procedures, and modify well abandonment procedures when an immediate threat to public health and safety.is involved. The pro)osed rule would also update sections of 10 CFR Part 39 that contain dates w1ich have passed and implement the metric system. OGC has not identified any Paperwork Reduction Act issues and does not believe this action constitutes a." major rule" pursuant to the Small Business Regulatory Fairness Enforcement Act of 1996. 0GC believes that the rule does not constitute a backfit pursuant to 10 CFR 50.109: therefore, a backfit - analysis is not necessary. However, OGC believes that the NRC staff must develop an environental assessment pursuant to 10 CFR 51.21. In all other respects. 0GC has not identified any potential legal complications or known bases for a legal objection to the rulemaking. Aareement Stat. Imolementation Issues. Agreement State licensees should benefit from these changes in a manner similar to NRC licensees. We do not anticipate any Agreement State issues. This rulemaking would be a compatibility level'II, that is, the Agreement States would need to adopt these requirements, but could be more stringent, if, they desire. Sucoortina Documents. This rulemaking would require a Regulatory Analysis that would estimate .the cost savings to both the NRC and licensees for each of the proposed changes. The information provided in the Regulatory Analysis for each change concerning' the impact on small entities would be. sufficient to support a Regulatory Flexibility Analysis or a certification that the proposed rule would not have a significant economic impact on a substantial number of small entities. No backfit analysis will be needed because the rulemaking would not affect Part 50 licensees. An OMB Clearance Package will be needed because the rulemaking is expected to reduce reporting or recordkeeping requirements. An Environmental Assessment would be needed to show, as NRC staff currently believe, that there is no significant impact to public health and safety in treating an ECS or a tritium neutron generator target with less stringent regulatory requirements than the larger well logging sources and the other changes discussed. 1 Resources. The estimated resources to com)lete this rulemaking would be about one staff year divided among RES, NMSS, Region IV, and OGC. Contractor support will be expended to assist in areparing the Environmental Assessment and the Regulatory Analysis. VRC staff estimates this effort at about $60,000. These resources are included in the current budget. 5
n Lead Office Staff and Staff From Sucoortina Offices. Lead Office - Pro.iect Manaaement Concurrina Official ~ RES _ -- Mark Haisfield Joseph Murphy Technical Suocort Offices NMSS - Bruce Carrico. Donald Cool Region IV - Anthony Gaines Ross Scarano OGC - Maria' Schwartz Stuart Treby ' Steerina Grouo. No steering group will be used on this rulemaking. The working group is identified above. Enhanced Public Particioation. The Agreement States would be allowed 45 days for input on this draft Rulemaking Plan. This rulemaking will also be available on both the NRC electronic bulletin board at FedWorld and NRC's interactive rulemaking web site to facilitate public dialogue. Both the FedWorld bulletin board and the interactive web site allow users to review comments and questions submitted by others and also provides a mechanism for NRC to respond electronically, where placed on FedWorld.pproved Rulemaking Plan' and the proposed rule will be appropriate. The a EDO or Commission Issuance. It is recommended that the EDO issue the proposed and final rule. This action does not constitute a significant question of policy, and falls within the ED0's authority, If significant policy issues are raised during the public comment period, a SECY Paper will be prepared for the final rule. 6
Schedules. Draft Rulemaking Plan for_ Office concurrence (allow 20 days for Office review) March 1997 Draft Rulemaking Plan to the Agreement States and CRCPD for comment, and SECY Paper to the Commission for information June 1997 SECY Paper, including draft Rulemaking Plan, with disposition of Agreement State comments for Office concurrence (allow 20 days) September 1997 SECY Paper, for ap3roval of Rulemaking Plan, to EDO October 1997 Approval of final Rulemaking Plan to initiate rulemaking and publish final Rulemaking Plan on Bulletin Board December 1997 Proposed rulemaking package for Office concurrence June 1998 Proposed rulemaking Jackage to the.EDO August 1998 Proposed rule publisled (60 day comment period) and submittal of OMB Clearance Package to OMB October 1998 Final rule published July 1999 e 7 ,}}