ML20249A993

Environ Assessment & Finding of No Significant Impact & Notice of Opportunity for Hearing Re Protechnics Intl,Inc Field Flood Tracer Study in Oil Reservoir at Green Valley Unit,Noble County,Ok

ML20249A993
Person / Time
Issue date:	06/16/1998
From:	Steven Baggett NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20249A994	List: ML20249A993
References
NUDOCS 9806190247
Download: ML20249A993 (7)

Text

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(7590-01-P]

L NUCLEAR REGULATORY COMMISSION

[ Texas License LO3835]

l Pyrotechnics International, Inc. - Houston, Texas: Field Flood Tracer Study; Finding of No Significant Impact and Notice of Opportunity for a Hearing -

l The U.S. Nuclear Regulatory Commission is considering authorizing Pyrotechnics l International, Inc. (ProTechnicaJ to conduct a field flood tracer study in an oil reservoir located at the Green Valley Unit, Noble County, Oklahoma near Stillwater, Oklahoma.

ENVIRONMENTAL ASSESSMENT l identification of the Prooosed Action The proposed action is authorizing Pyrotechnics to conduct a field flood tracer study using hydrogen-3 in an oil reservoir located at the Green Valley Unit, Noble County, Oklahoma, near the town of Stillwater, Oklahoma. Pyrotechnics, with offices in Houston, Texas, is f authorized by the State of Texas, under Texas License LO3835, to conduct field flood tracer  ;

activities in caand gas reserve:rs at temporary jobsites within that State. NRC's regulations in 10 CFR 150.20 " Reciprocity - Recognition of Agreement State Licenses," states, in part, p i

.,. any person holding a specific license from an Agreement State where the licensee maintains an office for directing the licensed activity ... is granted a general license to conduct the same activity in ... Non-Agreement States ... (provided] the specific Agreement State license [does not] limit the authorized activity to a specific installation or location." Because the Texas license authorizes Pyrotechnics to use the requested radioisotopes in field flood tracer studies at

- temporary jobsites, Pyrotechnics qualifies for the generallicense. Paragraph (b)(1) of 10 CFR

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Part'150.20 further states," .. [any person] shall . . before engaging in each activity ... file an NRC Form-241," Report of Proposed Activities in Non-Agreement States" " with NRC.

Pyrotechnics met this requirement with a submission dated April 22,1998.

On January 13,1997 (62 FR.1662), NRC published a final rule in the Federal Register amending 10 CFR 150.20. The amendment, primarily intended to clarify requirements conceming activities conducted at areas of exclusive federaljurisdiction within Agreement l

States, also revised 10 CFR 150.20(b) to make clear that licensees operating pursuant to the rule must comply with all NRC regulations applicable to materials licensees.10 CFR Part 51 '

specifies the environmental protection regulations applicable to NRC's licensing activities and implements section 102(2) of the National Environmental Policy Act of 1969, as amended.

' Section 51.21 provides that all licensing actions require an environmental assessment except those identified in 10 CFR 51.20 as requiring an environmental impact statement or those identified in 10 CFR 51.22(c) as categorical exclusions. The use of radioactive tracers in field flood studies is not identified in either section. Therefore, an environmental assessment must be prepared. Paragraph 51.60(b)(1)(vi) requires that an applicant submit an environmental report with any request for use of radioactive tracers in field flood studies. Pyrotechnics submitted an environmental report in a letter dated April 1,1998.

The Need for the Proposed Action The action is to determine if the licensee's request to perform activities under the generallicense should be approved or denied. Field flood tracer studies are conducted in conjunction with enhanced recovery of oil and natural gas, commonly referred to as enhanced oil recovery (EOR).

The oil from a producing well in a new reservoir initially flows because of the pressure exerted by water and gas in the reservoir. As oil production continues the reservoir pressure l declines unless fluids are injected into the reservoir to maintain the pressure. The average l

recovery from primary production, with and without prec;ure maintenance, is 20 to 30 percent of the original oil in place. Oil production can be increased through a secondary recovery l

1 technique called waterflooding, which ie the injection of water through injection wells to push the oil toward production wells. Further enhancements in oil production may occur with the use of so-called tertiary recovery methods in which steam, sulfactants (soaps), or other compounds or -

gases are injected into the reservoir.

Radioactive tracers are used to define the movement of liquids or gases injected into an oil and gas reservoir to enhance recovery and to monitor reservoir performance. The water-soluble or gaseous tracer is introduced into a reservoir with the injected fluid. Both radioactive and nonradioactive tracers may be used. The tracer is placed in the injection well, where it is diluted and swept into the reservoir by injection liquid or gas. The diluted tracer is subsequently recovered at produc%n wells and is monitored by sampling the recovered fluids.

In evaluating reservoir performance, it is desirable to determine the source of the injected fluid being collected at a production well. It is frequently desirable, therefore, to employ several tracers, using a different tracer in each of a number of injection wells.

Environmentalimoacts of the Procosed Action NRC published NUREGICR-3467.," Environmental Assessment of the Use of Radionuclides as Tracers in the Enhanced Recovery of Oil and Gas" in November 1983. This

generic environmental assessment (EA) evalur the use of 16 different radioisotopes, used in certain activity ranges, as interwell tracers in field :looding for EOR operations. A typica!

l operation using radioisotopes for interwell tracing ;vas analyzed from the standpoint of three I

stages of operation: aboveground, subsurface, a' i recovery and disposal. Doses to workers who handle radioactive tracers and to membert the public were estimated for normal and accidental exposure scenarios. For the isotope E oTechnics requested authorization to use, .

NUREG/CR-3467 analyzed the use of up to 30 curies of hydrogen-3. The Pyrotechnics submittal only requests at. theorization to use up to 2 curies of hydrogen-3, well within the bounds of the generic assessment. The NUREG estimated the national radiologicalimpact on the use .

of radioisotopes as interwell tracers in EOR projects to be a collective dose equivalent of less than 16 man-rem /yr. Accidental exposures were estimated to contribute little to the total. The Pyrotechnics proposal, which only includes one radioisotope and only a small percentage of the total activity evaluated in the NUREG for that radioisotope, will result in a lower collective dose equivalent.

Alternatives Denial of Pyrotechnics request is a possible alternative to the proposed action. This would avoid any of the environmentalimpacts associated with the use of radioactive tracers.

However, the proposed action is nevertheless reasonable because its environmental impacts are so small and it will provide benefits such as assisting to meet U.S. energy needs.

Aaencies'and Persons Consulted '

.~.

Y Ms.' Pam Bishop of the State of Oklahoma, Department of Environmental Quality (DEO),-

was contacted on June 2,' 1998, to discuss Pyrotechnics field flood tracer study reciprocity request and its potential environmental impacts, in a letter dated June 8,1998, Ms. Bishop

- indicated that the DEQ had no objections to the tracer study.

Conclusion The NRC staff concludes that the environmental impacts associated with ProTech'nics proposed request to conduct a field flood tracer study using hydrogen-3 in an oil reservoir located at the Green Valley Unit, Noble County, Oklahoma, are expected to be insignificant.

FINDING OF NO SIGNIFICANT IMPACT 1:

The Commission previously prepared an EA related to the use of certain quantities of radionuclides as tracers in field flood operations for the enhanced recovery of oil and gas. On the basis of the assessment, the Commission concluded that environmental impacts that would be created by such actions would not be significant and do not warrant the preparation of an l

Environmental Impact Statement. Because Pyrotechnics' request is within the bounds of that I' EA, it has been determined that a Finding of No Significant impact is appropriate.

The generic EA is made available"as NUREG/CR-3467. Copies of NUREG/CR-3467 .

may be purcha' sed from the Superintendent of Documents, U.S. Government Printing Office, D- - P.O.' Box 37082, Washington, DC 20402-9328. Copies are also available from the National y1 - -

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Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161. A copy and Pyrotechnics' submittal are also available for inspection and copying for a fee in the NRC Public Document Room,2120 L Street, NW. (Lower Level), Washington, DC 20555-0001.

l l

! OPPORTUNITY FOR A HEARING l

Any person whose interest may be affected by the approval of this action may file a request for a hearing. Any request for hearing must be filed with the Office of the Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555, within 30 days of the publication of this notice in the Federal Register; be served on the NRC staff (Executive Director for Operations, One White Flint North,11555 Rockville Pike, Rockville, Maryland 20852), and on the licensee (Pyrotechnics Intemational, Inc.,1160 Dairy Ashford, Suite 444, Houston, TX 77079); and must comply with the requirements for requesting a hearing set forth in the Commission's regulations, id CFR Part 2, Subpart L, "Information Hearing Procedures for Adjudications in Materials Licensing Proceedings."

These requirements, which the request must address in detail, are:

1. The interest of the requestor in the proceeding;

2. How that interest may be affected by the results of the proceeding (including the reasons why the requestor should be permitted a hearing);

3. The requestor's areas of concem about the licensing activity that is the subject matter of the proceedirig; and

4. The circumstances establishing that the request for hearing is timely - that is, filed within 30 days of the date of this notice.

A f

in addressing how the requestor's interest may be affected b) the proceeding, the request should de&cribe the nature of.the requestor's right under the Atomic Energy Act .

of 1954, as amended, to be made a' party to the proceeding; the nature and extent of the

. requestors property, financial, or other (i.e., health, safety) interest in the proceeding; and the

. possible effect of any order that may be entered in the proceeding upon the requestors interest.

Dated at Rockville, Maryland, this /4 day of *C . 1998.

FOR THE NUCLEAR REGULATORY COMMISSION -

W" Stdven L. Baifett, Acting Chief Materials Safety Branch Division of industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards.

.i DISTRIBUTION

-NRC Central File IMNS r/f NMSS r/f

. PDR: YEShNO DOCUMENT NAME: 1:\PTCFONSI.JBC t'oml-C/ W % hu f b M e fpif ft To receive a copy of this document, indicate in the box:

~ "C"a Copy w/o att/ encl. "E" = Co sy w/att/ encl."N" = No copy OFC- MSB C.- MSB C MSB NAME- BM/il Nhtt - LWbmper DATE hl // /98 [/ / f /98 /- /b OFF6clAL RECORD COPY IMNS/SEC

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, pyg,g NRC HLF CEMTER COPY v _- - -- .- _ _-

In addressing how the requestofs interest may be affected by the proceeding, the request should describe the nature of the requestors right under the Atomic Energy Act of 1954, as amended, to be made a party to the proceeding; the nature and extent of the requestors property, financial, or other (i.e., health, safety) interest in the proceeding; and the poss'ible effect of any order that may be entered in the proceeding upon the requestors interest.

Dated at Rockville, Maryland, this /6 day of IA .1998.

FOR THE NUCLEAR REGULATORY COMMISSION Steven L. Baggett, Acting Chief -

Materials Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards.

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