RADIATION CONTROL PROGRAM
The following information is needed to evaluate license applications for the use of radioactive material in wireline operations and subsurface tracer operations. This information is intended only as general guidance and should not be considered as containing all the information that may be required for a particular application.
Throughout this page, we have included references to Title 25 Texas Administrative Code (TAC) §289. You may use these references to better understand the requirements.
RSO Qualifications for Well Logging
Qualifications for an individual designated as RSO for Well Logging operations are outlined in Title 25 Texas Administrative Code §289.253(r).
A high school diploma or a certificate of high school equivalency based on the GED test. Acceptable alternate documentation of the educational requirement would be a college transcript, resume or other written statement affirming high school graduation or formal education beyond high school.
Completion of the training and testing requirements of TAC §289.253(o)(1).
Provide documentation that the designated individual has two years of experience as a logging supervisor to include knowledge of well logging service operations and/or tracer studies.
BRC Accepted Radiation Safety Training Course List
A list of accepted radiation safety training courses is available as a courtesy to you. We do not recommend one course over another. It is a resource for you to use to find the course that best suits your needs or used to verify previous training documentation for new radiography employees.
The list of Accepted Radiation Safety Training Courses is divided into use categories; Industrial Radiography, Well Logging and Tracer Studies, Well Logging Only, Portable Gauge, Fixed Gauge, Spinning Pipe and X-ray Fluorescence.
The requirements of the following sections of Title 25, Texas Administrative Code (TAC), Chapter 289 apply to the use of radioactive material in moisture/density, spinning pipe and fixed gauge operations and x-ray fluorescence analyzers:
§289.201 General Provisions for Radioactive Material
§289.202 Standards for Protection Against Radiation from Radioactive Material
§289.203 Notices, Instructions, and Reports to Workers; Inspections
§289.204 Fees for Certificates of Registration, Radioactive Material Licenses, Emergency Planning and Implementation, and Other Regulatory Services
§289.205 Hearing and Enforcement Procedures
§289.251 Exemptions, General Licenses, and General License Acknowledgements
§289.252 Licensing of Radioactive Material
§289.253 Radiation Safety Requirements For Well Logging Service Operations and Tracer Studies
§289.257 Packaging and Transportation of Radioactive Material
Radiation Control will provide one printed copy of the applicable sections of the rules. It is the licensee's responsibility to ensure that its facility and any additional authorized sites are provided with copies of the applicable rules. These rules may be duplicated or can be downloaded from this site. For a charge, you may request rules on disk or additional hard copies.
Completing the Application
NAME AND MAILING ADDRESS OF APPLICANT: Enter the company name and mailing address. The name (or DBA) should correspond to the name on BRC Form 252-1. The applicant is the organization or person legally responsible for the possession and use of the radioactive material. The address specified here must be your mailing address for correspondence. This may or may not be the same as the address where the material will be stored or used.
NOTE: Radiation Control will not issue a license addressed to a company or person residing outside the state of Texas.
LOCATIONS WHERE RADIOACTIVE MATERIAL WILL BE USED: Specify all locations of storage or use by designating the street address, city, and state, or by designating a descriptive address (i.e. 5 miles east on Highway 10, Anytown, State). A post office box address is not acceptable. Also, indicate whether the radioactive material will be used at temporary job sites throughout Texas.
LOCATION WHERE RECORDS WILL BE KEPT: Provide the appropriate information even if it is the same as the mailing address.
If applying for additional authorized use/storage sites, specify which site will be designated as the main site (e.g., home office or office location of the Radiation Safety Officer - RSO). Copies of all required records need to be maintained for Radiation Control review at the designated main site. Additionally, if the records location is different from the radioactive material storage site, the site will be billed as an additional authorized use site.
RADIATION SAFETY OFFICER (RSO): The RSO is the person designated to be responsible for the day-to-day radiation safety program. The RSO maintains all records required by the Radiation Control rules, and is the primary contact with Radiation Control on matters pertaining to the license and the use of radioactive materials. The RSO must have the authority to enforce radiation safety policy, suspend activities deemed unsafe, and require remedial action when necessary. Submit the qualifications outlined above for RSO qualifications.
RADIOACTIVE MATERIALS DATA:
(a) List by isotope, such as "Cesium-137 (137Cs)," "Americium-241 (241Am)."
(b) Provide the manufacturer's name(s) and the model number(s) of the sealed source(s). For tracer material, indicate the form of the material, such as "liquid or micro-spheres." Also, indicate how tracer material will be accepted (e.g., ready to use individual unit quantities).
(c) Specify the maximum number of sealed sources of each isotope to be possessed. Include the activity for each sealed source and the total activity of each isotope to be possessed. For tracer materials indicate the maximum total activity requested and the maximum single unit activity requested.
(d) Describe in detail, the intended use of the sealed source or tracer material.
NOTE: Financial assurance determinations will be based upon the requested radioactive material. Review your obligations related to financial assurance in 25 TAC §289.252(gg).
CERTIFICATION: The application shall be dated and signed by a representative of the corporation or legal entity who is authorized to sign official documents and to certify that the application contains information that is true and correct to the best of the applicant's knowledge and belief. All unsigned applications will be returned for proper signature.
STORAGE FACILITY: In accordance with 25 TAC §289.253(f)(3) and (4), Radiation Contorl will not accept applications for wireline operations where storage is on a vehicle or the transport container is chained to a structural part of a building. Sources of radiation can not be stored such that they will be exposed to flammable or explosive materials or be stored in a residential location.
Sources of radiation shall be stored in one of two approved methods; downhole or bunker.
Provide a description of each facility where the radioactive material will be stored. The storage facility may be described by narrative, drawings, or both. Describe the storage facility in relation to its surroundings. Indicate the location of neighboring businesses and/or residences in relation to your facility and show where the radioactive material will be stored in your facility. Indicate the specific distance the radioactive material will be located from occupied or residential areas. If applicable, include the position(s) of any work stations in the vicinity of the storage area along with an approximation of time spent at each station within one work week.
Provide a detailed description of the radioactive material storage area. Indicate construction materials used in the storage area, dimensions of the facility, including wall thickness or depth of pit.
Include a description of the location of warning signs around the storage area. Indicate what security is provided to prevent unauthorized access to and/or use of the radioactive material.
If the property where the applicant proposes to store and/or use the radioactive material is leased or rented by the applicant, provide documentation (signed by the owner) for each site not owned by the applicant that the owner is aware that the applicant will be storing and/or using radioactive material [25 TAC §289.252(e)(9)].
Applicants who propose to use unsealed radioactive material must provide a description of the facilities used to receive shipments of radioactive material, space should be provided at the storage facility for the receipt and opening of packages of tracer material, if receipt is taken at the storage facility. If tracer material will only be received on-site, indicate such.
Describe the facilities used for decontamination of personnel and equipment and how contamination levels will be controlled and maintained to As Low As Reasonably Achievable, reference 25 TAC §289.202(ddd)(5). If the applicant proposes to launder contaminated clothing, a description must be provided of the laundry facilities showing the means of retaining wash water and where wash water will be released when analysis has determined that 25 TAC §289.202(gg) release limits will not be exceeded.
Furnish calculated exposure levels for the proposed storage areas based on the maximum loading of the storage bunker/pit in accordance with 25 TAC §289.253(y)(1).
OPERATING, SAFETY AND EMERGENCY PROCEDURES: A radiation safety manual is necessary to describe company policy and positions relative to all areas of radiation safety. This manual must demonstrate that the applicant subscribes to the ALARA principle and outline appropriate protocols to support that position. In addition to the items required by 25 TAC §289.253(p), the manual should include, but not be limited to, the following information:
Management Structure and Responsibilities - Provide a description of the management structure and the RSO's position in that structure, including specific delegation of authority and responsibility for the program.
Radiation Safety Officer's Duties - Explain the RSO's responsibilities and duties in the company, with emphasis on overseeing the radiation safety program. Describe records (i.e., administration, radiation surveys, periodic field inspections, etc.) that will be administered and maintained by the RSO. Reference 25 TAC §289.253(r)(3).
Personnel Monitoring - Describe the type (film badge, thermoluminescent dosimeter (TLD), etc.) and type of radiation detected. Identify the provider of this service, and the exchange frequency of the personnel monitoring devices. Provide procedures on where, when, and how personnel monitoring will be worn. Elaborate on how personnel monitoring devices will be protected from inadvertent contamination. In addition to whole body monitoring, extremity monitoring should also be considered. If extremity monitoring is not to be used, provide justification why this method of personnel monitoring will not be used. 25 TAC §289.253(q)
If unsealed sources of radioactive material are used, indicate what bioassays are performed and under what conditions a bioassay will be performed. This should include periodic bioassays, to determine routine exposure, and special bioassays, performed after accidental exposures. Indicate the frequency of the periodic bioassay. This section should also provide action levels as determined by the bioassay results and the actions to be taken when action levels are reached.
If you wish to perform your own bioassays, include in your procedures the use of a thyroid phantom for exposure determination. Identify what instrumentation is used and the interval of calibrations. Indicate how you determine the minimum detectable limits of the system. Provide procedures for how the sample is analyzed from the time of collection to disposal of the sample.
Posting of Areas and Containers - A description of storage area signs, temporary job site postings, device/tool labeling, and transport container labeling should be provided. Procedures should be written requiring that these signs and labels be checked at a specified interval. These procedures should also describe the type of information that is required on these signs and labels (e.g., 25 TAC §289.253(m). Also, specify where items required by 25 TAC §289.203(b) will be posted.
Handling Procedures - Describe the procedure for removing radioactive material from storage, initial entry of information onto a utilization log [25 TAC §289.253(k)], using radioactive material in the field, to include identification and establishing of a restricted area and providing security of that area. Discuss procedures for returning the source and/or material to the storage location. This should include the completion of the utilization log showing who returned the source/material and when it was returned. It is advisable for the RSO to acknowledge that the radioactive material was returned.
Describe procedures for handling sealed sources. [25 TAC §289.253(e) and (bb)(4)]
1. Procedures for storing and transporting to well site. [25 TAC 289.253(f)(5), (g), (y) and §289.257]
2. Procedures for loading a logging tool, placing a tool in well, removing a tool from well and unloading source. If applicable, procedures should also be written addressing the storage, transport and use of logging tools that house a non-removable source of radiation. If your operations will be utilizing Measurement While Drilling (MWD) equipment, additional procedures should be written for shielding the source(s) during drill bit replacement. Use of time, distance, and shielding during all phases of handling.
3. Radiation survey procedures from the time the source is removed from storage until it is returned to storage. [25 TAC §289.253(y)]
4. Procedures for the establishment and maintenance of the restricted area. [25 TAC §289.253(s)]
5. Procedures for the required use of remote handling tools. [25 TAC §289.253(t)]
6. Procedure for recording the survey of the logging tool, source shield. [25 TAC §289.253(y)(3)]
Describe the procedures for handling tracer materials. [25 TAC §289.253(u)] These should include at least the following:
1. Procedures for storing and transporting to well site. [25 TAC §289.253(f)(5), (g), (y) and §289.257]
2. Methods of using tracer materials and precautions taken to avoid injection into fresh water zones. [25 TAC §289.253(u)(2)]
3. Procedures for handling tracer material to avoid contamination including use of handling tools, special apparel worn, precautions taken to prevent inhalation of volatile materials such as Iodine, and use of time, distance and shielding during handling. [25 TAC §289.253(u)(1)]
4. Radiation survey procedures before, and after the operation and method of recording the final surveys, including vehicle surveys. [25 TAC §289.253(h)(2) and (y)(5)]
5. Procedures to clean up spills, decontaminate personnel, decontaminate equipment, decontaminate clothing and shoes and to dispose of contaminated items including contaminated equipment which may not be owned by your company. (i.e., pump trucks or propant mixers).
6. Procedures for the collection and disposal of radioactive material (both solids and liquids) at the well site, including excess material used at the well site. This includes the excursion or reversal from a well (See Part I below).
Transportation Procedures [25 TAC §289.253(e)] - Describe how and where the source/material transport container is secured to the vehicle. Indicate how the vehicle will be placarded. Indicate what shipping papers are required and where they will be located in the vehicle. Describe when and how vehicle surveys will be performed and how and where they will be recorded. Reference 25 TAC §289.253(y)(2) and (6), and §289.257.
For operations using unsealed radioactive material, provide procedures for transporting radioactive material to and from the well site. These procedures should describe acceptable packaging and storage prior to transport. Procedures should also include methods of transporting radioactive waste and contaminated equipment (including clothing) back to the licensee's facilities.
Radiation Surveys - Discuss when and where physical gamma radiation surveys and neutron survey calculations must be performed. [25 TAC §289.202(p) and §289.253(y)] Indicate how records of all surveys will be maintained. The applicant should include a copy of all survey forms.
These procedures should include a description of the meters and appropriate probes used in contamination surveys and wipe surveys, and should provide appropriate release limits [25 TAC §289.202(gg), (ccc) or (eee)]. Surveys for restricted areas should include surveys for personnel leaving the restricted area, periodic (state the frequency) wipe surveys of all facilities in the restricted area, and equipment leaving the restricted area. Periodic (state the period) surveys and wipe surveys of unrestricted areas (e.g., offices, personal vehicles, workers' homes) should also be performed.
Contamination Control - Formal procedures must be established for radioactive contamination. This should not just be for contamination at the well site, but also for personnel, equipment and the applicant's permanent facilities. Reference 25 TAC §289.202(ddd)(5).
These procedures should discuss contamination limits for personnel, equipment and permanent facilities and the methods used to remove, reduce and prevent contamination from occurring. Specific instructions in how to effectively decontaminate, equipment, personnel, vehicles, facilities, and ground surfaces, without the generation of mixed waste, should be thoroughly discussed. Provide guidance and instructions on how to assay and/or calculate fluids for concentrations of contaminants.
Explicit instructions should be provided for handling and laundering of contaminated clothing. Specific procedures should be included to prevent contaminated clothing from leaving the facility (to ensure any clothing is not taken to the worker's home or to a commercial laundry). Procedures need to be written for the collection of contaminated articles (paper towels, scrub brushes, etc.) and waste water used during decontamination procedures.
If contaminated waste is not returned to a broker of radioactive waste, disposal may be accomplished by satisfying 25 TAC §289.202(fff)(4) and submitting all information requested in Regulatory Guide 6.6, available upon request from the BRC.
Emergency Procedures - Discuss actions to be taken by the authorized user when emergency situations involving radioactive material occur. These situations could involve damage or rupture of a sealed source, vagrancy of a restricted area at a temporary job site by non-radiation workers, the theft of the source and/or material, the loss of a sealed source in the well bore, a vehicle accident, loss or damage to an employee's personnel monitoring device, over exposure, contamination of personnel, equipment, facilities, homes, vehicles, and ground surfaces. For all emergency procedures involving the potential for contamination, procedures should include actions to prevent the spread of contamination and minimize inhalation and ingestion of radioactive material. Include in all emergency procedures a discussion of the actions to be taken by the RSO when emergency situations occur. Formulate procedures for the notification of proper personnel in the event of an accident or well excursion. Include a listing of emergency telephone numbers of persons to be contacted in those situations.
In the event of an excursion or other type of reversal requiring that material be pumped out of the well bore, large quantities of material will be returned to the surface that contain radioactive material. This contaminated material must be removed from the environment or, isolated in a manner that will reduce the concentration of each radionuclide in the material below the limits established in 25 TAC §289.202(eee).
If the applicant proposes to use unsealed radioactive material for subsurface operations, detailed procedures must be developed in the event of an uncontrolled release of radioactive material to the environment. In addition to the potential concerns in emergency situations, the applicant should include procedures for obtaining representative samples of the material out of the well bore, subjecting those samples to analysis at a laboratory acceptable to the BRC, and maintain copies of all laboratory analyses for review by the BRC. These procedures should also discuss how to restrict access to and how to post the pit area until laboratory analysis indicates that the concentration of the radioactive material has dropped below 25 TAC §289.202(eee) limits. These procedures should also indicate that the BRC must be notified within 30 days of the excursion. This notification will include, but not be limited to, the name and location of the well, the name and address of the well owner, the name and address of the surface owner, and a copy of a letter from the surface owner authorizing the disposal of the contaminated material. Finally, these procedures should discuss the method(s) used to dispose of the contaminated material.
Records Management - Provide a description of all records that will be maintained at field stations and at temporary job sites to document operations involving the use of radioactive material. Records should include, but not be limited to, all records mandated by 25 TAC §289.253. Indicate where items required by 25 TAC §289.203(b)(1) will be posted.
Provide a copy of the document, which will be signed by the well operator, well owner, drilling contractor, or land owner that specifies all the requirements found in 25 TAC §289.253(d).
Include procedures for the logging supervisor to follow regarding obtaining the proper signatures prior to the beginning of well logging or tracer activities. Copies of completed agreements must be maintained by the licensee for a period of five years following completion of operations. [25 TAC §289.253(d)(3)]
Equipment Maintenance and Inspection Procedures [25 TAC §289.253(n)] - Describe routine maintenance and inspections to be performed on the equipment. Indicate what items (at least, but not limited to, source holders, logging tools, injector tools, source handling tools, storage containers and transport containers) are to be checked and how the maintenance and/or inspection will be documented. Indicate what actions will be taken if equipment is found to be out of specifications. [25 TAC §289.253(n)(2)] Establish a specific interval for the maintenance and/or inspection to be performed. The quarterly inventory required by 25 TAC §289.253(j) will also be included here. Include samples of all forms used to document completion of maintenance and inspection functions.
RADIATION DETECTION INSTRUMENTATION: Radiation survey meters shall be available for the applicant to perform surveys and demonstrate compliance with 25 TAC §289.202(p) and for accident response. Procedures should be written providing personnel with instructions on the proper use and maintenance of radiation detection instrumentation.
The applicant must provide the manufacturer, model number, range, and types of each survey instrument to be possessed. Indicate who will be calibrating the instrument and at what interval.
If a survey instrument is to be calibrated by a service firm, the firm should be licensed or registered by Radiation Control, the United States Nuclear Regulatory Commission, or another agreement state.
If the applicant wants to calibrate their own survey instrument at the their facility, a detailed description of the instrument calibration procedures for all meter ranges must be provided. Regulatory Guide 5.2, "Guide for Preparation of Survey Instrument Calibration Applications."
For operations using unsealed radioactive material, radiation survey instruments must be sensitive enough to detect the radioactive surface contamination limits specified in 25 TAC §289.202. As a minimum, survey instrumentation should be equipped with a thin-end window or "pancake" Geiger-Mueller detector in order to perform surveys to demonstrate compliance with the regulations. Further, a suitable "known" source, not necessarily traceable to NIST standards, e.g., Tc-99, should be used to periodically verify consistency of the response of the thin-end window detector.
LEAK TESTING: Sealed sources shall be leak tested every six months in accordance with 25 TAC §289.201(g). Indicate what option you will follow. Options for your leak testing program are:
1. Using a commercial leak test provider licensed by Radiation Control, the United States Nuclear Regulatory Commission, or another agreement state, provide the name of the leak test provider.
Identify who will use the commercial leak test kits to perform leak tests. If the applicant performs the leak tests, include specific instructions in the operating, safety, and emergency procedures on how the tests are to be performed. Including precautions for cross-contamination prevention and procedures for preparing the kit for shipment.
2. Request authorization to perform leak test analysis for your facility. If you intend on performing analysis of your own leak tests, you must submit detailed information requested by Regulatory Guide 5.1, "Guide for the Preparation of Leak Test Applications."
Records indicating that leak tests have been performed and the results of the leak tests must be maintained for inspection by Radiation Control in accordance with 25 TAC §289.201(g)(7).
TRAINING AND EXPERIENCE - In the training program description include the sequence of events from the time of hiring through the designation of individuals as logging assistants and logging supervisors. Since 25 TAC §289.253(o)(1) and (2) have specific training requirements for logging assistants and logging supervisors, clearly differentiate between the training programs for logging supervisors and that for assistants. In addition, differentiate between the training, evaluation and examinations given to individuals with no previous training and experience and that given to individuals with previous training and experience.
Orientation Training - Provide an outline of the initial orientation training and instruction to be given to prospective logging assistants. Provide a list of prerequisites of attendees. (e.g., high school diploma.)
Training of personnel in the topics covered in 25 TAC §289.253(bb)(1) must be performed by a Radiation Control accepted instructor. Provide the name of the service company which will provide this training for your personnel.
Field Testing and Training - Provide a description of the field examination given to prospective logging supervisors and assistants. The examination should be given in the field and demonstrate the individual's knowledge and ability to perform logging activities and related tasks in compliance with the licensee's operating and emergency procedures and regulatory requirements.
Previously Trained Logging Supervisors and Assistants
1. Provide an outline of the instruction given to individuals with previous logging training.
2. Include a description of the examination they will be given.
On-the-Job Training (OJT) - In addition to the radiation safety training required above, describe OJT provided to all users of radioactive material. This description should include the duration of the training, the person(s) providing the training and respective qualifications. Provide a commitment that OJT will be for a minimum of two months full-time equivalent under the supervision of a fully trained logging supervisor.
Periodic Training - Provide a discussion of periodic training, including the frequency of the training and by whom the periodic training will be conducted. Periodic refresher training should be conducted at least annually. The periodic training should provide a review of radiation safety principles, state regulations, the licensee's/registrant's procedures, company policies on radiation safety practices and a discussion of any new regulatory requirements. Records containing the names of the attendees, subject matter, instructor and date must be maintained for this training.
For individuals who will assist in handling radioactive material and are not classified as logging supervisors, less training is required. These individuals must be under the direct supervision of a logging supervisor at all times while they are handling or assisting in the handling of radioactive material. Discuss how the applicant will document that these individuals have read or received instruction in the applicant's operating and emergency procedures and have demonstrated that they understand them. Discuss how the applicant will document that these individuals are competent to use the radioactive material, related handling tools and radiation survey meters that will be employed in his assignment.
For an individual without previous training and experience to be designated as a logging assistant, the following training and evaluation must be conducted:
A. Instruction in the applicable rules of 25 TAC §289.201, §289.202, §289.203 and §289.253 and the licensee's operating and emergency procedures.
B. Demonstration of understanding of applicable rules and operating and emergency procedures by successfully completing a written examination.
C. Demonstration of competence to use sources of radiation and related equipment.
The written examination and documentation of competence of this training must be designed to demonstrate the individual's understanding of the company's unique operating and emergency procedures, license and the applicable rules. Submit an example of the examination to be used on logging assistants and the form used to document the evaluation of logging assistant's competence.
For an individual to be designated as a logging supervisor, the individual must have successfully completed the following training and experience:
A. Classroom instruction in the topics in 25 TAC §289.253(bb)(1).
B. A minimum of two months of on-the-job training as a logging assistant. Pass a field examination given at the end of on-the-job training to assure that the individual is competent to perform all radiographic operations. The applicant must maintain a record of the field examination and score in the logging supervisor's personnel file or training file.
For an individual who has been a logging supervisor for another licensee, the current licensee has the responsibility for determining the individual's competence to act as a logging supervisor. The individual must receive formal initial orientation instruction and testing similar to that given to a prospective logging assistant, including instruction in the licensee's operating and emergency procedures, the license conditions and the use of the licensee's equipment. Provide a description of the practical examination given to experienced logging supervisors. This examination should be a practical demonstration of the prospective logging supervisor's knowledge of and ability to perform well logging/tracer studies and related tasks in compliance with the licensee's radiation safety program and regulatory requirements.
WASTE DISPOSAL - The applicant must describe how the radioactive material will be disposed when it is no longer needed or can no longer be used. If contaminated waste is not sent to a broker of radioactive waste, disposal may be accomplished by satisfying 25 TAC §289.202(fff)(4), if applicable. Those wishing to dispose of radioactive waste in accordance with 25 TAC §289.202(fff)(4) should request a copy of Regulatory Guide 6.6, "Guide for the Preparation of License Amendment Requests for the Disposal of Short-Lived Radioactive Waste" from Radiation Control.
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