TITLE 32: ENERGY CHAPTER II: DEPARTMENT OF NUCLEAR SAFETY SUBCHAPTER b: RADIATION PROTECTION PART 351 RADIATION SAFETY REQUIREMENTS FOR WIRELINE SERVICE OPERATIONS AND SUBSURFACE TRACER STUDIES Section 351.10 Purpose 351.20 Scope 351.30 Definitions 351.40 Prohibition 351.1010 Limits on Levels of Radiation 351.1020 Storage Precautions 351.1030 Transport Precautions 351.1040 Radiation Survey Instruments 351.1050 Leak Testing of Sealed Sources 351.1060 Quarterly Inventory 351.1070 Utilization Records 351.1080 Design and Performance Criteria for Sealed Sources Used in Downhole Operations 351.1090 Labeling 351.1100 Inspection and Maintenance 351.2010 Training Requirements 351.2020 Operating and Emergency Procedures 351.2030 Personnel Monitoring 351.3010 Security 351.3020 Handling Tools 351.3030 Subsurface Tracer Studies 351.3040 Particle Accelerators 351.4010 Radiation Surveys 351.4020 Documents and Records Required at Field Stations 351.4030 Documents and Records Required at Temporary Jobsites 351.5010 Notification of Incidents, Abandonment, and Lost Sources APPENDIX A Subjects To Be Included In Training Courses For Logging Supervisors APPENDIX B Example of Plaque for Identifying Wells Containing Sealed Sources Containing Radioactive Material Abandoned Downhole AUTHORITY: Implementing and authorized by Sections 6 and 6b of the Radiation Protection Act (Ill. Rev. Stat. 1989, ch. 111«, pars. 216 and 216b), and Section 5 of "AN ACT in relation to personnel radiation monitoring" (Ill. Rev. Stat. 1989, ch. 111«, par. 230.15). SOURCE: Adopted at 10 Ill. Reg. 17507, effective September 25, 1986; amended at 11 Ill. Reg. 5215, effective March 13, 1987; amended at 13 Ill. Reg. 13605, effective August 11, 1989; amended at 14 Ill. Reg. 13633, effective August 13, 1990. Section 351.10 Purpose The regulations in this Part establish radiation safety requirements for persons using sources of radiation for wireline service operations, including mineral logging, radioactive markers, and subsurface tracer studies. The requirements of this Part are in addition to, and not in substitution for, the requirements of 32 Ill. Adm. Code 310, 320, 330, 340, and 400. Section 351.20 Scope The regulations in this Part apply to all licensees or registrants who use sources of radiation for wireline service operations, including mineral logging, radioactive markers, or subsurface tracer studies. Section 351.30 Definitions As used in this Part, the following definitions apply: "Field station" means a facility where radiation sources may be stored or used and from which equipment is dispatched to temporary jobsites. "Irretrievable well-logging source" means any sealed source containing radioactive material that is pulled off or not connected to the wireline that suspends the source in the well and for which all reasonable effort at recovery has been expended. "Injection tool" means a device used for controlled subsurface injection of radioactive tracer material. "Logging supervisor" means the individual who provides personal supervision of the utilization of sources of radiation at the well site. "Logging tool" means a device used subsurface to perform well- logging. "Mineral logging" means any logging performed for the purpose of mineral exploration other than oil or gas. "Personal supervision" means guidance and instruction by the supervisor who is physically present at the jobsite and watching the performance of the operation in such proximity that visual contact can be maintained and immediate assistance given as required. "Radioactive marker" means radioactive material placed subsurface or on a structure intended for subsurface use for the purpose of depth determination or direction orientation. "Source holder" means a housing or assembly into which a radioactive source is placed for the purpose of facilitating the handling and use of the source in well-logging operations. "Subsurface tracer study" means the release of a substance tagged with radioactive material for the purpose of tracing the movement or position of the tagged substance in the well-bore or adjacent formation. "Temporary jobsite" means a location to which radioactive materials have been dispatched to perform wireline service operations or subsurface tracer studies. "Well-bore" means a drilled hole in which wireline service operations and subsurface tracer studies are performed. "Well-logging" means the lowering and raising of measuring devices or tools which may contain sources of radiation into well-bores or cavities for the purpose of obtaining information about the well and/or adjacent formations. "Wireline" means a cable containing one or more electrical conductors which is used to lower and raise logging tools in the well-bore. "Wireline service operation" means any evaluation or mechanical service which is performed in the well-bore using devices on a wireline. Section 351.40 Prohibition No licensee or registrant shall perform wireline service operations with a sealed source(s) unless, prior to commencement of the operation, the licensee has a written agreement with the well operator, well owner, drilling contractor, or land owner that: a) in the event a sealed source is lodged downhole, efforts at recovery will be made that are commensurate with the circumstances of the specific case, e.g., quantity and half-life of the isotope, depth of the source and presence of potable water aquifers; and b) in the event a decision is made to abandon the sealed source down- hole, the requirements of Section 351.5010(c) shall be met within 30 days after a decision by the licensee to abandon the source has been approved by the Department of Nuclear Safety (Department). Section 351.1010 Limits on Levels of Radiation Sources of radiation shall be used, stored, and transported in such a manner that the transportation requirements of 32 Ill. Adm. Code 330 and the dose limitation requirements of 32 Ill. Adm. Code 340 are met. Section 351.1020 Storage Precautions a) Each source of radiation, except accelerators, shall be provided with a storage and/or transport container. The container shall be provided with a lock, or tamper seal for calibration sources, to prevent unauthorized removal of, or exposure to, the source of radiation. b) When in storage, sources of radiation shall be isolated from flammable or explosive substances. Section 351.1030 Transport Precautions Transport containers shall be physically secured to the transporting vehicle to prevent accidental loss, tampering, or unauthorized removal. Section 351.1040 Radiation Survey Instruments a) The licensee or registrant shall maintain sufficient calibrated and operable radiation survey instruments at each field station to make physical radiation surveys as required by this Part and by 32 Ill. Adm. Code 340.2010. Instrumentation shall be capable of measuring 0.1 milliroentgen (2.58 x 10-8 C/kg) per hour through at least 20 milliroentgens (5.16 x 10-6 C/kg) per hour. b) Each radiation survey instrument shall be calibrated: 1) at intervals not to exceed six (6) months and after each instrument servicing (e.g., electronic repair); 2) at energies and radiation levels equivalent to those to be encountered during use; and 3) so that accuracy within plus or minus 20 percent of the true radiation level can be demonstrated on each scale. c) Calibration records shall be maintained for a period of two (2) years for inspection by the Department. Section 351.1050 Leak Testing of Sealed Sources a) Requirements. Each licensee or registrant using sealed sources of radioactive material shall have the sources tested for leakage. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the Department for two (2) years after the next required leak test is performed or until transfer or disposal of the sealed source. b) Method of Testing. Tests for leakage shall be performed only by persons specifically authorized to perform such tests by the Department, the U.S. Nuclear Regulatory Commission, an Agreement State, or a Licensing State. The test sample shall be taken from the surface of the source, source holder, or from the surface of the device in which the source is stored or mounted and on which one might expect contamination to accumulate. The test sample shall be analyzed for radioactive contamination, and the analysis shall be capable of detecting the presence of 0.005 microcurie (185 Bq) of radioactive material on the test sample. c) Interval of Testing. Each sealed source of radioactive material shall be tested at intervals not to exceed six (6) months. In the absence of a certificate from a transferor indicating that a test has been made prior to the transfer, the sealed source shall not be put into use until tested. If, for any reason, it is suspected that a sealed source may be leaking, it shall be removed from service immediately and tested for leakage. d) Leaking or Contaminated Sources. If the test reveals the presence of 0.005 microcurie (185 Bq) or more of leakage or contamination, the licensee shall immediately withdraw the source from use and shall cause it to be decontaminated, repaired, or disposed of in accordance with this Part. A report describing the equipment involved, the test results, and the corrective action taken shall be filed with the Department. e) Exemptions. The following sources are exempted from the periodic leak test requirements of Section 351.1050(a) through (d): 1) hydrogen-3 sources; 2) sources of radioactive material with a half-life of 30 days or less; 3) sealed sources of radioactive material in gaseous form; 4) sources of beta- and/or gamma-emitting radioactive material with an activity of 100 microcuries (3.7 MBq) or less; and 5) sources of alpha-emitting radioactive material with an activity of 10 microcuries (0.370 MBq) or less. Section 351.1060 Quarterly Inventory Each licensee or registrant shall conduct a quarterly physical inventory to account for all sources of radiation. If all sources are not accounted for during the inventory, the licensee or registrant shall notify the Department in accordance with the requirements of 32 Ill. Adm. Code 340.4020. Records of inventories shall be maintained for two (2) years from the date of inventory for inspection by the Department and shall include the quantities and kinds of sources of radiation, the location where sources of radiation are assigned, the date of the inventory, and the name of the individual conducting the inventory. Section 351.1070 Utilization Records Each licensee or registrant shall maintain current records, which shall be kept available for inspection by the Department for two (2) years from the date of the recorded event, showing the following information for each source of radiation: a) make, model number, and a serial number or a description of each source of radiation used; b) the identity of the well-logging supervisor or field unit to whom assigned; c) locations where used and dates of use; and d) in the case of tracer materials and radioactive markers, the utilization record shall indicate the radionuclide and activity used in a particular well. Section 351.1080 Design and Performance Criteria for Sealed Sources Used in Downhole Operations a) A licensee may not use a sealed source in well logging unless: 1) the sealed source is doubly encapsulated; 2) the sealed source contains radioactive material whose chemical and physical forms are insoluble and non- dispersible; and 3) a prototype of the sealed source has been tested and meets the performance standards for oil well logging sources contained in either the United States of America Standards Institute (USASI) Standard No. N5.10-1968 or the American National Standards Institute (ANSI) Standard No. N542-1977 (1978 edition), exclusive of subsequent amendments or editions. A copy of USASI Standard No. N5.10-1968 and ANSI Standard No. N542-1977 are available for public inspection at the Department's offices, 1035 Outer Park Drive, Springfield, Illinois. b) The requirements of subsection (a) do not apply to sealed sources that contain licensed material in gaseous form. (Source: Amended at 14 Ill. Reg. 13633, effective August 13, 1990) Section 351.1090 Labeling a) 1) Each source, source holder, or logging tool containing radioactive material shall bear a durable, legible, and clearly visible marking or label which has, as a minimum, the standard radiation caution symbol (as described in 32 Ill. Adm. Code 340.2030), without the conventional color requirement, and the following wording: DANGER* RADIOACTIVE *AGENCY NOTE: or CAUTION. 2) This labeling shall be on every component transported as a separate piece of equipment. b) Each transport container shall have permanently attached to it a durable, legible, and clearly visible label which has, as a minimum, the standard radiation caution symbol (as described in 32 Ill. Adm. Code 340.2030) and the following wording: DANGER* RADIOACTIVE NOTIFY CIVIL AUTHORITIES (OR NAME OF COMPANY) *AGENCY NOTE: or CAUTION. Section 351.1100 Inspection and Maintenance a) Each licensee or registrant shall conduct, at intervals not to exceed six (6) months, a program of inspection and maintenance of source holders, logging tools, source handling tools, storage containers, transport containers, and injection tools to assure proper labeling and physical condition. Records of inspection and maintenance shall be maintained for a period of two (2) years for inspection by the Department. b) If any inspection conducted pursuant to Section 351.1100(a) reveals damage to labeling or components which could result in release of radioactive material into the environment, or loss of control of radioactive material, or which could otherwise create a risk of increase in radiation exposure, the device shall be removed from service until repairs have been made. c) The repair, opening, or modification of any sealed source shall be performed only by persons specifically authorized to do so by the Department, the U.S. Nuclear Regulatory Commission, an Agreement State, or a Licensing State. Section 351.2010 Training Requirements a) No licensee or registrant shall permit any individual to act as a logging supervisor as defined in this Part until such individual has: 1) received 40 hours of instruction in the subjects outlined in Appendix A of this Part and has demonstrated to the satisfaction of the licensee or registrant an understanding thereof by successful completion of a written examination administered by the licensee or registrant; 2) read and received instruction in the regulations contained in this Part and the applicable Sections of 32 Ill. Adm. Code 310, 340, and 400 or the equivalent state or federal regulations, conditions of appropriate license or certificate of registration, and the licensee's or registrant's operating and emergency procedures, and demonstrated to the satisfaction of the licensee or registrant an understanding thereof; and 3) demonstrated to the satisfaction of the licensee or registrant competence to use sources of radiation, related handling tools, and radiation survey instruments which will be used on the job. b) No licensee or registrant shall permit any individual to assist in the handling of sources of radiation until such individual has: 1) read or received instruction in the licensee's or registrant's operating and emergency procedures and demonstrated to the satisfaction of the licensee or registrant an understanding thereof; and 2) demonstrated to the satisfaction of the licensee or registrant competence to use, under the personal supervision of the logging supervisor, the sources of radiation, related handling tools, and radiation survey instruments which will be used on the job. c) The licensee or registrant shall maintain employee training records for inspection by the Department for two (2) years following termination of employment. Section 351.2020 Operating and Emergency Procedures The licensee's or registrant's operating and emergency procedures shall include instructions in at least the following: a) handling and use of sources of radiation to be employed so that no individual is likely to be exposed to radiation doses in excess of the standards established in 32 Ill. Adm. Code 340; b) methods and occasions for conducting radiation surveys; c) methods and occasions for locking and securing sources of radiation; d) personnel monitoring and the use of personnel monitoring equipment; e) transportation to temporary jobsites and field stations, including the packaging and placing of sources of radiation in vehicles, placarding of vehicles, and securing sources of radiation during transportation; f) minimizing exposure of individuals in the event of an accident; g) procedure for notifying proper personnel in the event of an accident; h) maintenance of records; i) inspection and maintenance of source holders, logging tools, source handling tools, storage containers, transport containers, and injection tools; j) procedure to be followed in the event a sealed source is lodged downhole; and k) procedures to be used for picking up, receiving, and opening packages containing radioactive material. Section 351.2030 Personnel Monitoring a) No licensee or registrant shall permit any individual to act as a logging supervisor or to assist in the handling of sources of radiation unless each such individual wears either a film badge or a thermoluminescent dosimeter (TLD). Each film badge or TLD shall be assigned to and worn by only one individual. b) Personnel monitoring records shall be maintained for inspection until the Department authorizes disposition. Section 351.3010 Security During each logging or tracer application, the logging supervisor or other designated employee shall maintain direct surveillance of the operation to protect against unauthorized and/or unnecessary entry into a restricted area, as defined in 32 Ill. Adm. Code 310. Section 351.3020 Handling Tools The licensee or registrant shall provide and require the use of tools that will assure remote handling of sealed sources other than low-activity calibration sources. Section 351.3030 Subsurface Tracer Studies a) All personnel handling radioactive tracer material shall be required to use protective gloves, protective clothing and equipment which prevents the spread of contamination. Precautions shall be taken by the licensee or registrant to prevent ingestion or inhalation of radioactive material. b) No licensee or registrant shall cause the injection of radioactive material into potable aquifers without specific license authorization issued by the Department pursuant to 32 Ill. Adm. Code 330.250. Such authorization will be issued only if: 1) The applicant's proposed procedures will prevent tracer concentrations at the most exposed drinking water source or public water supply inlet from exceeding the Illinois Environmental Protection Agency's drinking water quality standards in 35 Ill. Adm. Code 604, and 2) The applicant's proposed procedures will be performed: A) on an underground injection well for which a U.S. Environmental Protection Agency underground injection control program permit has been issued pursuant to 40 CFR 124 or 40 CFR 144 revised as of July 1, 1988, or pursuant to 35 Ill. Adm. Code 705 or 62 Ill. Adm. Code 240, or B) on a well for which the Illinois Environmental Protection Agency has otherwise approved a subsurface radioactive tracer study pursuant to 35 Ill. Adm. Code 704, or C) on a well for which the Illinois Department of Mines and Minerals has otherwise approved a subsurface radioactive tracer study pursuant to 62 Ill. Adm. Code 240. (Source: Amended at 13 Ill. Reg. 13605, effective August 11, 1989) Section 351.3040 Particle Accelerators No licensee or registrant shall permit above-ground testing of particle accelerators, designed for use in well-logging, which results in the produc- tion of radiation, except in areas or facilities controlled or shielded so that the requirements of 32 Ill. Adm. Code 340.1010 and 340.1050, as applicable, are met. Section 351.4010 Radiation Surveys a) Radiation surveys and/or calculations shall be made and recorded for each area where radioactive materials are stored. b) Radiation surveys and/or calculations shall be made and recorded for the radiation levels in occupied positions and on the exterior of each vehicle used to transport radioactive material. Such surveys and/or calculations shall include each source of radiation or combination of sources to be transported in the vehicle. c) After removal of the sealed source from the logging tool and before departing the jobsite, the logging tool detector shall be energized, or a radiation survey meter used, to assure that the logging tool is free of contamination. d) Radiation surveys shall be made and recorded at the jobsite or wellhead for each tracer operation, except those using Hydrogen-3, Carbon-14, and Sulfur-35. These surveys shall include measurements of radiation levels before and after the operation. e) Records required pursuant to Section 351.4010(a) through (d) shall include the dates, the identification of individual(s) making the survey, the identification of survey instrument(s) used, and an exact description of the location of the survey. Records of these surveys shall be maintained for inspection by the Department for two (2) years after completion of the survey. Section 351.4020 Documents and Records Required at Field Stations Each licensee or registrant shall maintain, for inspection by the Department, the following documents and records for the specific devices and sources used at the field station: a) appropriate license, certificate of registration, or equivalent document issued by the Nuclear Regulatory Commission, an Agreement State, or Licensing State; b) operating and emergency procedures required by Section 351.2020; c) 32 Ill. Adm. Code 310, 320, 330, 340, 341, 351 and 400; d) records of the latest survey instrument calibrations pursuant to Section 351.1040; e) records of the latest leak test results pursuant to Section 341.1050; f) quarterly inventories required pursuant to Section 351.1060; g) utilization records required pursuant to Section 351.1070; h) records of inspection and maintenance required pursuant to Section 351.1100; and i) survey records required pursuant to Section 351.4010. Section 351.4030 Documents and Records Required at Temporary Jobsites Each licensee or registrant conducting operations at a temporary jobsite shall have the following documents and records available at that site for inspection by the Department: a) operating and emergency procedures required by Section 351.2020; b) survey records required pursuant to Section 351.4010 for the period of operation at the site; c) evidence of current calibration for the radiation survey instruments in use at the site; d) the licensee's radioactive material license, including all appropriate amendments; e) when operating in the state under reciprocity as provided for in 32 Ill. Adm. Code 330.900, a copy of the appropriate license, certificate of registration, or equivalent document(s); and f) the date of the latest test for leakage and contamination performed on the sealed source(s) and the results of the test(s). Section 351.5010 Notification of Incidents, Abandonment, and Lost Sources a) Whenever an incident as described in 32 Ill. Adm. Code 340.4030 or 340.4050 has occurred or whenever a source is lost, other than in downhole logging operations, notification shall be made to the Department in accordance with 32 Ill. Adm. Code 340.4020. b) Whenever a sealed source or device containing radioactive material is lodged downhole, the licensee or registrant shall: 1) monitor at the surface for the presence of radioactive contamination with a radiation survey instrument or logging tool during logging tool recovery operations; and 2) notify the Department immediately by telephone if radioactive contamination is detected at the surface or if the source appears to be damaged. c) When it becomes apparent that efforts to recover the radioactive source will not be successful, the licensee or registrant shall: 1) advise the well-operator of the regulations of the Illinois Department of Nuclear Safety regarding abandonment and a method of abandonment, which shall include: A) the immobilization and sealing in place of the radioactive source with a cement plug, B) the setting of a whipstock or other deflection device, and C) the mounting of a permanent identification plaque, at the surface of the well, containing the appropriate information required by Section 351.5010(d); 2) notify the Department immediately by telephone, and by mail within ten (10) calendar days, giving the circumstances of the loss, and requesting approval of the adopted abandonment procedures; and 3) file a written report with the Department within 30 days of the abandonment, setting forth the following information: A) date of occurrence and a brief description of attempts to recover the source; B) a description of the radioactive source involved, including radionuclide, quantity, and chemical and physical form; C) surface location, and identification of well; D) results of efforts to immobilize and seal the source in place; E) depth of the radioactive source; F) depth of the top of the cement plug; G) depth of the well; and H) information contained on the permanent identification plaque.* d) The Department will provide written approval of the request by the licensee pursuant to subsection (c)(2) if the Department determines that accepted industry methods for recovery have been unsuccessful and the proposed abandonment procedures satisfy the requirements of subsection (c)(1). e) Whenever a sealed source containing radioactive material is abandoned downhole, the licensee shall provide a permanent plaque* for posting the well or well-bore. This plaque shall: *AGENCY NOTE: An example of a suggested plaque is shown in Appendix B of this Part. 1) be constructed of long-lasting material, such as stainless steel or monel; and 2) contain the following information engraved on its face: A) the word "CAUTION"; B) the radiation symbol without the conventional color requirement; C) the date of abandonment; D) the name of the well operator or well owner; E) the well name and well identification number(s) or other designation; F) the sealed source(s) by radionuclide and quantity of activity; G) the source depth and the depth to the top of the plug; and H) an appropriate warning, depending on the specific circumstances of each abandonment.* *AGENCY NOTE: Appropriate warnings may include: "Do not drill below plug back depth"; "Do not enlarge casing"; or "Do not re-enter the hole" followed by the words, "before contacting the Illinois Department of Nuclear Safety". f) The licensee or registrant shall notify the Department immediately by telephone and by mail within ten (10) calendar days, if the licensee knows or has reason to believe that radioactive material has been lost in or to an underground potable water source. Such notice shall designate the well location and shall describe the magnitude and extent of loss of radioactive material, assess the health and environmental consequences of such loss, and explain efforts planned or being taken to mitigate these consequences. SECTION 351.APPENDIX A Subjects To Be Included In Training Courses For Logging Supervisors I) Fundamentals of Radiation Safety A) Characteristics of radiation B) Units of radiation dose and quantity of radioactivity C) Significance of radiation dose 1) Radiation protection standards 2) Biological effects of radiation dose D) Levels of radiation from sources of radiation E) Methods of minimizing radiation dose 1) Working time 2) Working distances 3) Shielding II) Radiation Detection Instrumentation to be Used A) Use of radiation survey instruments 1) Operation 2) Calibration 3) Limitations B) Survey Techniques C) Use of personnel monitoring equipment III) Equipment to be Used A) Handling equipment B) Sources of radiation C) Storage and control of equipment D) Operation and control of equipment IV) The Requirements of Pertinent Federal and State Regulations V) The Licensee's or Registrant's Written Operating and Emergency Procedures VI) The Licensee's or Registrant's Record Keeping Procedures SECTION 351.APPENDIX B Example of Plaque for Identifying Wells Containing Sealed Sources Containing Radioactive Material Abandoned Downhole The size of the plaque should be convenient for use on active or inactive wells, e.g., a 7-inch square. Letter size of the word "CAUTION" should be approximately twice the letter size of the rest of the information, e.g. 1/2-inch and 1/4-inch letter size, respectively. (Source: Added at 11 Ill. Reg. 5215, effective March 13, 1987)