ML20217K457
| ML20217K457 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1997 |
| From: | Camper L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20217K433 | List: |
| References | |
| NUDOCS 9708150258 | |
| Download: ML20217K457 (8) | |
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[7590-01 P]
NUCLEAR REGULATORY COMMISSION
[ Texas License LO3835]
ProTechnics International, Inc. - Houston, Texas: Field Flood Tracer Study; Finding of No Significant impact and Notice of Opportunity for a Hearing The U.S. Nuclear Regulatory Commission is considering authorizing ProTechnics international, Inc. (ProTechnics) to conduct a field flood tracer study in an oil reservoir located at the NE Perry Unit, Noble County, Oklahoma near Stillwater, Oklahoma.
ENVIRONMENTAL ASSESSMENT Identification of the Prooosed Action The proposed action is authorizing ProTechnics to conduct a field flood tracer study using cobalt-60 and hydrogen-3 in an oil reservoir located at the NE Perry Unit, Noble County, Oklahoma, near the town of Stillwater, Oklahoma. ProTechnics, with offices in Houston, Texas, is authorized by the State of Texas, under Texas License LO3835, to conduct field flood tracer activities in oil and gas reservoirs at temporary jobsites within that State. NRC's regulstions in 10 CFR 150.20, " Reciprocity - Recognition of Agreement State Licenses," states, in part, ". .
any person holding a specific license from an Agreement State where the licensee maintains an office for directing the licensed activity, . is hereby granted a general license to conduct the same activity in non-Agreement States . . Provided, That the specific license does not limit the activity authorized by (the] general license to specified installations or locations." Because the Texas license authorizes ProTechnics to use the requested radioisotopes in field flood tracer
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studies at temporary jobsites, ProTechnics qualifies for the general license. Paragraph (b) of n
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2 10 CFR Part 150.20 further states, "In addition, any person engaging in activities in non.
Agreement States ... under the general license ... shall, ... before engaging in each such activity, file ... Form 241 (revised), " Report of Proposed Activities in Non-Agreement States" ..."
with NRC. ProTechnics met this requirement with a submission dated April 18,1997.
On January 13,1997 (62 FR 1662), NRC published a final rule in the Federal Reaister amending 10 CFR 150.20. The amendment, primarily intended to clarify requirements conceming activities conducted at areas of exclusive federal jurisdiction within Agreement 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 Envire mental 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. ProTechnics submitted an environmental report in a letter dated May 27,1997.
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3 The Need for the Prooosed Action .
The action is to determine if the licensee's request to periorm ac'.ivities under the General license shodd be approved or denied. Field flood tracer afedies 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 wellin a new reservoir initially flows because of the pressure exerted by water and gas in the reservoir. As oil production continues the reservoir pressure declines unless fluids are injected into the reservoir to maintain the pressure. The average recovery from primary production, with and without pressure maintenance, is 20 to 30 percent of the original oilin place. Oil production can be increased through a secondary recovery technique called waterflooding, which is 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 inju,ted 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 production wells and is monitored by sampling the recovered fluids.
4 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 Prooosed Action NRC published NUREG/CR-3467," Environmental Assessment of the Use of Radionuclides as Tracers in the Enhanced Recovery of Oil and Gas"in November 1383. This generic environmental assessment (EA) evaluated the use of 16 different radioisotopes, used in certain activity ranges, as interwell tracers in field flooding for EOR operations. A typical operation using radioisotopes for interviell tracing was analyzed from the standpoint of three stages of operation: abovegrotnd, subsurface, and recovery and disposal. Doses to workers who handle radioactive tracers and to members of the public were estimated for normal and accidental exposure scenarios. For the two isotopes ProTechnics requested authorization to use, NUREG/CR.3467 analyzed the use of up to 300 millicuries of cobalt-60 and up to 30 curies of hydrogen-3. The ProTechnics submittal only requests authorization to use up to 23 millicuries of cobalt-60 and 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-remlyr. Accidental exposures were estimated to contribute little to the total. The ProTechnics proposal, which only includes two radioisotopes and only a small percentage of the total activity evaluated in the NUREG for those two radioisotopes, will result in a lower collectivo dese equivalent.
I 5-Alternatives Denial of Protechnics request is a possible altemative to the proposed action. This would avoid any of the environmental impacts associated with the use of radioactive tracers.
However, the proposed action is nevertheiess reasonable because its environmental impacts are so small and it will provide benefits such as assisting to meet U.S. energy needs.
Aoencies and Persons Consuhed Ms. Pam Dewoody of the State of Oklahoma, Department of Environmental Quality (DEO), was contacted on July 22,1997, to discuss ProTechnics field flood tracer study reciprocity request and its potential environmentalimpacts. In a letter dated August 6,1997, Ms. Dewoody indicated that the DEQ had no objections to the tracer study.
Conclusion The NRC staff concludes that the environmental impacts associated with ProTechnics proposed request to conduct a field flood tracer study using cobalt-60 and hydrogen-3 in an oil
- reservoir located at the NE Perry Unit, Noble County, Oklahoma, are expected to be insignificant.
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FINDING OF NO SIGNIFICANT IMPACT 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 creat6d by such actions would not be significant and do not warrant the preparation of an EnvironmentalImpact Statement, Because ProTechnics' request is within the bounds of that 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 NUREGICR-3467 may be purchased from the Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328. Copies are also available from the National Technical information Service,5285 Port Royal Road, Springfield, VA 22161. A copy and Protechnics' submittal are also available for inspection and copying fcr a fee in the NRC Public Document Room,2120 L Street, NW. (Lower Level), Washington, DC 20555-0001.
OPPORTUNITY FOR A HEARING Any person whose interest may be affected by the approval of this actiori 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 (ProTechnics Intemational, Inc.,1160 Dairy Ashford, Suite 444, Houston, TX
7 77079); and must comply with the requirements for requesting a hearing set forth in the Commission's regulations,10 CFR Part 2, Subpart L "Information Hearing Procedures for Adjudications in Materials Licensing Proceedings."
J These requirements, which the request must address in detail, are:
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- 1. The interest of the requestor in the proceeding; t
- 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 concern about the licensing activity that is the subject
- matter of the proceeding; and a
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8 4, The circumstances establishing that the request for hearing is timely - that is, filed within 30 days of the date of this notice, in addressing how the requestors 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) inte est 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 //b day of 997 FOR THE NUCLEAR REGULATORY COMMISSION 1
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% A, Larry . Ci mper, Chief, Qwsf Medical, Academic, and Commercial Use Safety Branch, Division of Industrial and Medical Nuclear Safety, Office of Nuclear Material Safety and Safeguards
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