ML20216G820
| ML20216G820 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1998 |
| From: | Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | |
| References | |
| OMB-3150-0130, OMB-3150-130, NUDOCS 9804200494 | |
| Download: ML20216G820 (15) | |
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PUBLIC DOCUMEtiT ROOM U. S. NUCLEAR REGULATORY COMMISSION Agency information Collection Activities: Proposed Collection; Comment request AGENCY:
U. S. Nuclesr Regulatory Commission (NRC)
ACTION:
Notice of pending NRC action to submit an information collection request to OMB and solicitation of public comment.
SUMMARY
- The NRC is preparing a submittal to OMB for review of continued approval of information colleMior;s under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35).
Information pertaining to the requirement to be submitted:
1.
The title of the information collection:
10 CFR Part 39 - Licenses and Radiation Safety Requiremerts for Well Logging 2.
Current OMB approval number: 3150-0130 C bg g A' g pf 3i
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9804200494 980402 PDR ORG EUSDMB PDR W
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3.
- How often the collection is required: Applications for new licenses and amendments may be submitted at any time. Applications for renewal are submitted every 10 years. Reports are submitted as events occur.
4.
Who is required or asked to report: Applicants for and holders of specific licenses authorizing the use of licensed radioactive material in well logging.
5.
The number of annual respondents: 51 NRC licensees and 102 Agreement State licensees.
6.
The number of hours needed annually to complete the requirement or request: Approximately 3.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> annually per respondent for applications
. and reports, plus approximately 214 hours0.00248 days <br />0.0594 hours <br />3.53836e-4 weeks <br />8.1427e-5 months <br /> annually per recordkeeper. The
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industry total burden is 11,094 annually for NRC licensees and 22,188 annually for Agreement State licensees.
7.
Abstract: NRC regulations in 10 CFR Part 39 establish radiation safety requirements for the use of radioactive material in well logging operations.
The information in the applications. reports and records is used by the NRC staff to ensure that the health and safety of the public is protected and that licensee possession and use of source and byproduct material is in compliance with license and regulatory requirements.
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- . Submit, by (insert date 60 days after publication in the Federal Reaister), comments that address the following questions:
1.
Is the proposed collection of information necessary for the NRC to properly perform its func',tions? Does the information have practical utility?
2.
Is the burden estimate accurate?
3.
Is there a way to enhance the quality, utility, and clarity of the information to be collected?
4.
How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms of information technology?
A copy of the draft supporting statement may be viewed free of charge at the NRC Public Document Room,2120 L Street, NW (lower level), Washington, DC. OMB clearance requests are available at the NRC worldwide web site (http://www.nrc. gov) under the FedWerid collection link on the home page tool bar. The document will be available on the NRC home page site for 60 days after the signature date of this notice.
4; Comments and questions about the information collection requirements may be directed to the '
NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 F33, Washington, DC, 20555-0001, or by telephone at.301-415-7233, or by Intemet electronic mail at BJS1@NRC. GOV.
Dated at Rockville, Maryland, this r O 7)cl day of 1998.
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i For the Nuclear Regulatory Commission.
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i SUPPORTING STATEMENT j
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10 CFR PART 39 8-LICENSES AND RADIATION SAFETY REQUIREMENTS F R.W LL LOGGING
- 1-:05 (3150-0130)
REV$SION C DOCu^iGT R00il i
Descriotion of the information Collection NRC regulations in 10 CFR Part 39 establish rules that specify radiation safety requirements for the use of licensed materialin welllogging operations. The regulations provide for comprehensive and consistent radiation safety requirements in NRC and Agreement State regulations, and safety requirements designed to reduce the likelihood of accidents involving the rupture of radioactive sources in viell logging operations.
A.
Astification 1.
Need for and Practical utility of the Information Collection Section 39.11 provides that an applicant for a specific license to use licensed material in well logging operations must submit NRC Form 313 " Application for Material License." The NRC materials licensing staff will review the information submitted on NRC Form 313 to determine whether an applicant for a license has training, experience, equipment, facilities, and procedures for the use oflicensed material that are adequate to protect the public health and safety.
The use of NRC Form 313 has been previously approved by OMB under clearance number 3150-0120, which should be referred to for information collection burden and supporting data.
Section 39.13 provides that an applicant must submit the following informatic"1 with the application:
39.13(b)
Schedu!e and description of training programs; 39.13(c) - Written operating and emergency procedures covering its radiation safety program; Intemal inspection program; 39.13(d) 39.13(e)
Description of overall organizational structure as it applies to radiation safety, incluJing specified delegations of responsibility and authority; 39.13(f)
(1) Description of proceduias for leak testing sealed scurces, or (2) Manufacturer and model number of a leak test kit This information is reviewed by the NRC staff to determine whether the training, radiation safety, and intemalinspection programs and procedures and the licensee's organizational structure will provide adequate protection of the public health and safety. The NRC review and the findings therefrom form the basis for NRC licensing decisions.
Section 39.13(d) provides that a licensee must keep internal inspection records for 3 years. These
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records are reviewed by NRC inspectors to verify that the licensee is maintaining an effective inspection program and that problems are being identified and corrected.
Sections 39.15(a) and (b) require that a licensee wishing to conduct wel! logging operations with a sealed source must first have, and retain as a record, a written agreement with the well owner or operator that identifies who will carry out respons:biUties with regard to recovery of sealed sources c
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2-which become stuck or lost in a well, performance of radiation rnonitoring, decontamination of site, equipment and personnel if necessary, and that within 30 days after a welllogging source has been classified as irretrievable, certain requirements will be implemented to immobilize and protect the separated welllogging tool and source. The licensee must retain a copy of the written agreement for 3 years after the completion of the welllogging operation. A permanent identification plaque must be mounted at the surface of the wellin which a welllogging source has been abandoned. In addition to a warning, the plaque must contain the date the source was abandoned, the name of the well owner or operator, the name and well identification number (s) or other designation, identification of the source by radionuclide and quantity of activity, and depth to the top of the plug.
The written agreement is needed to ensure that recovery or abandonment procedures will be implemented in the event of a stuck or irretrievable well logging source. The agreement binds the well owner or operator (non-licensee) to immobilizing the source with a cement plug, protecting it from subsequent dsmage with a drill deflecting device, and posting the wellhead with an appropriate plaque. Without this agreement, the well logger would be unable to complete recovery or abandonment procedures if the well owner or operator refused. The identification plaque is necessary to provide a warning to anyone reentering the well of the presence of the abandoned source and to provide information on the source and its location within the well.
Section 39.15(c) provides that a licensee or applicant may apply to the Commission for approval of proposed procedures to abandon an irretrievable well logging source in a manner other than that currently authorized. Such an application would be reviewed by NRC to determine whether the proposed procedures would provide an adequate margin of protection of the public health and safety.
Section 39.17 provides that NRC may require further statements after the filing of the application and before expiration of the license to enable NRC to determine whether the application should be granted or denied or whether a license should be modified or revoked. Such additional information is sometimes needed to clarify information submitted in the application, or to rectify deficiencies in proposed or existing programs for protection of the public health and safety, the common defense and security, or the environment.
The additional information submitted is reviewed by various NRC organizational units to assess the adequacy of the applicant's physical plant, procedures and plans for protection of the public health and safety, common defense and security, and the environment. The NRC review and the findings i
therefrom form the basis for NRC decisions concerning the issuance, modification, or revocation of licenses.
j Burden and cost associated with further statements is included in the burden and cost data for submittal of applications on NRC Form 313, and is covered by clearance number 3150-0120, which should be referred to for further burden and cost information.
Section 39 31(al requires that a licensee label (1) the source, the source holder, or the logging tool containing radioactive materials; and (2) the storage or transport container. The labels are needed to wam people that these devices or containers contain radioactive materials and that persons should notify civil authorities or the company if they find a laoeled device or container.
Section 39.33(d) provides that a licensee must maintain calibrauon records for a period of 3 years after the data of calibration of a survey instrument at each field station and temporary job site.
Calibration of radiation survey instruments is necessary to ensure that these instruments function properly.
. The information documents that the calibrations were performed. The records also permit NRC inspectors to verify that the licensee is keeping a calibrated and operable radiation survey instrument at each field station and temporary jobsite to make required radiation surveys.
Inspections are conducted at least every 3 years.
Section 39.35(a) requires the licensee to keep a record of the results of leak testing of sealed sources for 3 years after the leak test is performed. The leak testing is needed to ensure the sealed sources maintain their integrity.
The information contained in the records documents that the leak tests were performed. The information also permits NRC inspectors to verify that licensees have the source tested for leakage at least every 6 months and record the leak test results in units of microcuries. Inspections are I
conducted at least every 3 years.
Section 39.35(d)(2) provides for reporting of leak test failures by the licensee to the NRC within 5 days of receiving the test results. The reporting requirement is needed to inform the NRC that the licensee has taken actions to remove the leaking source from service and to check for radioactive contamination.
The information contained in the report allows NRC regional offices to determine, within approximately 1 week, whether an inspector should be sent to check potential problems that may affect public health and safety.
Section 39.37 provides for a licensee to keep records of each semiannual physical inventory to account for all licensed material received and possessed under the license. The record of inventory must be retained for 3 years. The information is needed to indicate that the licensee has conducted semiannual inventories to account for licensed material received and possessed under the license.
The information documents that sources possessed under the license were accounted for at the time of inventory. The information also permits NRC inspectors to verify that the licensee has conducted an inventory at least every 6 months. Inspections are conducted at least every 3 years.
Section 39.39 requires that a licensee keep utilization records ior sources of licensed material. The records must be retained for three years. This information permits the licensee to trace the history of the use of sources, radioactive markers, or unsealed licensed material if there are any questions concerning licensed material.
The information also peimits NRC inspectors to verify that the licensee is utilizing licensed material appropriate to particular well logging operations. Inspections are conducted at least every 3 years.
Section 39.43(a) requires that a licensee maintain a record of defects found and repairs made as a result of visual checks of source holders, logging tools, and source handling tools. The record must be retained for 3 years. The records are reviewed by NRC inspectors to ensure that the licensee is maintaining an effective program for identification and correction of defects.
Section 39.43(b) provides that a licensee must maintain records of semiannual inspections and maintenance for 3 years. The inspection and maintenance are needed to ensure that the sealed sources and source holders are in good working condition.
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, The information permits NRC inspectors to verify that the licensee conducted the required semiannualinspection and maintenance. Inspections are conducted at least every 3 years.
Section 39.61(a)(2) requires that the licensee provide copies of and instruction in the applicable NRC regulations in 10 CFR Parts 19,20, and 39, the NRC license under which the well logging will be performed, and the operating and emergency procedures, to each well logging supervisor.
Section 39.61(b)(2) requires that the licensee provide copies of and instruction in the licensee's operating and emergency procedures to erC1 well logging assistant.
These documents are needed to ensure that well logging supervisors and assistants have been given instruction in and have available for reference, the NRC requirements and the operating and emergency procedures needed for safe operation.
Section 39.61(d) requires that a licensee maintain records of training and of the annual safety review for each logging supervisor and logging assistant. The training records must include copies of written tests and dates of oral tests given. The records are needed to confirm that the logging supervisers and 199ging assistants received the required training. The training records must be retained until 3 years after termination of employment. Records of annual safety reviews must be retained for 3 years.
Section 39.63 requires that licensees maintain and follow written operating and emergency procedures that cover handling and use of licensed material, use of remote handling tools, surveys, control of personnel exposures, locking and securing of sources, personnel monitoring, transportation, receipt, tecordkeeping, inspection and maintenance, reporting, and actions in case of a stuck or ruptured source.
The information is used by the licensee and its employees to guide the handling and use of radioactive material in normal and emergency situations. Submission of the procedures is covered by Section 39.13(c). The procedures must be retained as a record until the Commission terminates the license, in accordance with 10 CFR 30.51(b).
Section 39.65(c) requires that a licensee keep records of badge, TLD and bioassay results until termirmtion of the license. The badge, TLD and bioassay results are needed to measure exposure received by workers during welllogging operations.
The information documents the radiation doses received by the licensee's employees. This information also permits NRC inspectors to verify that the licensee kept dosimetry and bioassay records. Inspections are conducted at least every 3 years.
Section 39.67(f) requires that a licensee must maintain radiation survey records for 3 years.
Radiatico survey records are needed to warn the workers of the level of radiation exposure at that location.
The information documents that the licensee conducted radiation surveys. The information also permits NRC inspectors to verify that the licensee complies with the survey requirements.
Inspections em conducted at least every 3 years.
Section 39.73 requ.res that a licensee maintain certain documents and records at each field station.
This information is needed so that the licensee's operating personnel can have easy access to the documents they need to perform the job safely. Also, when an NRC inspector inspects a field
. station, the information provides the inspector with indications that the licensee complies with NRC requirements.
These documents provide information on safety requirements and procedures to the licensee's personnel at the field station. The information also permits NRC inspectors to inspect these records at the field station, inspections are conducted at least every 3 years.
Section 39.75 requires that a licensee conducting operations at temporary jobsites maintain certain documents and records at each temporary jobsite. This information is needed so that the licensee's operating personnel can have easy access to the documents they need to perform the job safely.
The records provide information on safety requirements and procedures to the licensee's personnel at the temporary jobsite. The information also permits NRC inspectors to inspect these records at the temporary jobsite. Inspections are conducted at least every 3 years.
Section 39.77(a) requires that a licensee report immediately by telephone if a sealed source has been ruptured. Paragraph (b) reminds licensees to follow Part 20 reporting requirements for certain incidents. Requirements under 10 CFR Part 20 have been cleared under OMB No. 3150-0014. Paragraph (c) provides that licensees must notify NRC by telephone if a sealed source becomes irretrievable and file a written report on the abandonment of the sealed source. The alcensee must also notify the well owner or operator of the abandonment procedures. If abandonment procedures cannot be completed within 30 days, the licensee must request an extension of time. Paragraph (d) requires that the licensee must make a written report to NRC within 30 days after the source has been classified as irretrievable, and must send a copy of the written report to each State or Federal agency that issued permits or otherwise approved the drilling operation. This information collection is needed so that NRC regional offices would be informed of any incidents involving licensed materials, lost sources or irretrievable well logging sources.
The information permits NRC regional offices to make a determination whether an inspector should be dispatched to a site and to assure that corrective actions have been taken. When the licensee, in consultation with the well owner or operator, determines that a sealed source lost in a well becomes irretrievable, the licensee is required to notify NRC regional offices by telephone to request approval to implement abandonment procedures. The NRC regional office, based on the information supplied by the licensee, approves the abandonment if all reasonable efforts at recovery have been expended.
Section 39 91 provides that the Commission may grant exemptions from the requirements of 10 CFR Part 39 under specified conditions, upon the applici tion of any interested person or on its own initiative. Applications under this section are examined by the NRC materials licensing staff to determine whether the requested exemption is authorized by law and whether it will not endanger life or property or the common defense and security, and to determine if it is otherwise in the public interest.
2.
Agency Use of the Information The records that 10 CFR part 39 requires licensees to maintain are reviewed by the NRC staff during inspections, license renewals, and license amendment reviews to evaluate compliance with NRC radiation safety requirements for possession and use of licensed radioactive material in well logging.
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6-For example, internal inspection records are reviewed by NRC inspectors to verify that the licensee is maintaining an effective inspection program and that problems are being identified and corrected.
The written agreement with a well owner or operator is needed to ens' re that recovery or abandonment procedures will be implemented in the event of a stuck or irretrievable well logging source. The identification plaque is necessary to provide a warning to anyone reentering the well of the presence of the abandoned source and to provide information on the source and its location within the well. Labels required on the source, the source holder, or the logging tool containing radioactive materials, and the storage or transport container, are needed to warn people that these devices or containers contain radioactive materials and that persons should notify civil authorities or the company if they find a labeled device or container.
Calibration records are needed to permit NRC inspectors to verify that the licensee is keeping a calibrated and operable radiation survey instrument at each field station and temporary jobsite to make required radiation surveys. Similarly, records of the results of leak testing of sealed sources are reviewed by NRC inspectors to verify that licensees have the source tested for leakage at least every 6 months, to ensure the sealed sources maintain their integrity.
The required reports regarding ruptureo or irretrievable sources permit the NRC staff to make a determination whether an inspector should be dispatched to a site and to assure that corrective actions have been taken. When the licensee, in consultation with the well owner or operator, oetermines that a sealed source lost in a well becomes irretrievable, the licensee is required to notify NRC regional offices by telephone to request approval to implement abandonment procedures. The NRC regional office, based on the information supplied by the licensee, approves the abandonment if all reasonable efforts at recovery have been expended.
3.
Reduction of Burden Throuch Information Technoloov There are no legal obstacles to reducing the burden associated with this information collection.
Applicants and licensees are encouraged to use automated information technology when it would be beneficial to them. However, because of the types of information and the infrequency of submission, the applications and reports may not lend themselves readily to the use of automated information technology for submission.
4.
Effort to identifv Duolication and Use Similar Information The Information Requirements Control Automated System (IRCAS) was searched to determine duplication. None was found. There is no similar information availablo to the NRC.
5.
Effort to Reduce Small Business Burden The majority of licensees who use byproduct material are small businesses. Since the health and safety consequences of improper handling or use of radioactive byproduct material are the same for large and small entities, it is not possible to reduce the burden on small businesses by less frequent or less complete reporting, recordkeeping, or accounting and control procedures.
6.
Consecuences to Federal Procrams or Poliev Activities if the Collection is not Conducted or is Conducted Less Frecuentiv If the information were not conducted, or were conducted less frequently, NRC would not have the information needed to assure that licensees are conducting and will continue to conduct programs in a manner that will assure adequate protection of the public health and eafety. Required reports
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', are collected and evaluated on a continuing basis as events occur. Applications for new licenses and amendments are submitted only once. Applications for renewal oflicenses are submitted every 10 years. Information submitted in previous applications may be referenced without being resubmitted.
7.
Circumstances Which Justifv Variation from OMB Guidelines Contrary to the OMB Guidelines in 5 CFR 1320.5(d), Section 39.35(d)(2) requires that licensees submit a report to NRC within 5 days of a failed leak test. However, reporting would be required only if the test reveals the presence of 0.005 microcurie or more of removable radioactive material.
The report must be filed within 5 days to permit the NRC to ensure that the licensee has taken action to remove the leaking source from service and to check for radioactive contamination. It also permits NRC to determine whether inspection or other response may be required to deal with potential problems affecting the public health and safety.
Section 39.77(a) requires immediate telephone notification, with a written report within 30 days, because the loss of licensed material and rupture of a sealed source could cause extensive radioactive contamination. Immediate notification would permit NRC to judge the severity of the situation and consider whether NRC should take immediate action. The confirmatory letter within 30 days is needed to permit NRC to judge whethn the licensee has taken corrective actions and whether NRC should consider followup acihm.
j Section 39.77(c) requires licensees to notify NRC by telephone if a source becomes irretrievable and obtain NRC approval for abandoning a sealed source in a well. The requirement for prompt notification is needed to permit the NRC to judge whether all reasonable effort at recovery has been expended.
Section 39.77(d) requires that the licensee must make a written report to NRC within 30 days after i
the source has been classified as irretrievable. The written report within 30 days is needed to assure that the abandonment procedures are carried out promptly and satisfactorily. Furthermore, the report constitutes a record to alert state regulatory agencies that a sealed source is in the well if permission is requested to reenter the well.
8.
Consultations Outside the NRC An opportunity to comment on the information collection requirements in 10 CFR Part 39 is being provided in the Federal Register Notice published for this clearance extension.
9.
Eavment or Gift to Resoondents Not applicable.
- 10. Confidentiality of information None, except for proprietary information.
- 11. Sensitive Questions None.
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- 12. Estimated Burden and Burden Hour Cost Egoortina Raauirements No. of Licensee Licensee Staff Total Licensee Section Resoonses Annually Hours ner Submittal Burden Hours 39.11 See OMB Clearance No. 3150-0120 39.13(b),(c),(e),(f)
Included in 39.11 39.15(c) 1 5
5 39.17 included in 39.11 39.35(d)(2) 1 4
4 39.61(a)(2)&(b)(2) 510 0.25 127.5 39.63 included in 39.11 39.77(a) 1 12 12 39.77(b)
See OMB Clearance No. 3150-0014 39.77(c) 5 0.5 2.5 39.77(d) 5' 4.0 20 39.91 included in 39.11 171 Total 518
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Recordkaanina Reauirements No. of Annual Hours Section Records per Record Total Burden Hrs 39.13(d) 255 0.25 65 39.15(a)(&(b) 55 2.00 110 39.31(a) 510 0.05 25 39.33(d) 1,020 0.08 82 39.35(a) 510 0.08 41 39.37 510 0.08 41
- 39.39_
'38,250 0.03 1,148 39.43(a)&(b) 816 0.5 408
- 39.61(d) 510 0.75 380 39.63 Included in 39.11 39.65(c)
- 440 1.00 440 39.67(f) 38,250 =
0.16 6,120 39.73 153 1.00 153 39.75 38,250 0.05 1,910
- Total Number of Recordkeepers:
51 Total Recordkeeping Hours Annually:
10,923
-l TOTAL ANNUAL BURDEN HOURS - NRC LICENSEES:
11,094
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Agreement State Burden and Cost It is estimated that, for Agreement state licensees and applicants, there will be 1,036 responses and 342 burden hours annually,' there will be 102 recordkeepers and a recordkeeping burden of 21,846 hours0.00979 days <br />0.235 hours <br />0.0014 weeks <br />3.21903e-4 months <br /> annually, and the total Agreement State burden will be 22,188 hours0.00218 days <br />0.0522 hours <br />3.108466e-4 weeks <br />7.1534e-5 months <br />, at a cost of
$1,470,542.
- . Estimated Cost to the Public to Resoond Section Annual Cost to Resoond 39.11-See OMB Clearance No. 3150-0120 39.13(b),(c),(e),(f) included in 39.11 39.13(d) 8,125 39.15(a)&(b) 7,150 39.15(c) 625 39.17 included in 39.11 39.31(a) 1,625 39.33(d) 5,330 39.35(a) 2,665 39.35(d)(2) 500 39.37 2,665 39.39 74,620 39.43 26,520 39.61 40,638 39.63 Inclu:bd in 39.11 39.65(c) 28,600 39.67(f) 397,800 39.73 9,945 39.75 124,150 39.77 4,313 39.91 included in 39.11 TOTAL
$735,271 Source of Burden and Cost Data and Method of Estimatino Cost The estimates are based on submittals to NRC in past years. Cost to licensees and applicants is calculated at a rate of $125 per hour for technical or management time and $65 per hour for other time. These figures include salaries and overhead.
i 13.
Estimate of Other Costs None. For licensees under 10 CFR Part 39, it is most likely that purchases of equipment and services were made (1) prior to October 1,1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
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Estimated Annuali7ad Cost to the Federal Government
.- Annual Cost - NRC Staff Review (Professional effort - 173 hours0.002 days <br />0.0481 hours <br />2.86045e-4 weeks <br />6.58265e-5 months <br /> at $125/hr) = $21,625 for activities other than application review.
. Application review activities are accounted for and reported under NRC Form 313, OMB Clearance No. 3150-0120. These costs are fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and 171.
15.
Reason for Chance in Burden or Cost There is an overall increase in burden and cost because of the addition of Agreement State licensees, which wet a not included in the previous clearance. Burden estimates for some requirements have also been adjusted based on experience since the previous clearance. There is a net decrease in the burden and cost for NRC licensees because of a decrease in the number of NRC well logging licensees since the previous clearance.
16.
Publication for Statistical Use None.
17.
Reason for Not Disolavina the Exoiration Data t
The requirement is contained in a regulation. Amending the Code of Federal Regulations to display information that, in an annual publication, could become obsolete would be unduly burdensome -
and too difficult to keep current.
18.
Exceptions to the Certification Statement None.
B.
Collection of Information Emolovina Statistical Methods Statistical methods are not used in this collection of information.
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