Radiation protection approach in oil and gas well logging

R S Gomes1, J D R Lopes Gomes1, M L L Costa1 and M V F E S Miranda2

Rua General Severiano 90 - 22290-901 - Rio de Janeiro/RJ, Brazil.

Rua Professor Luiz Freire 200 - 50740-540 - Recife/PE, Brazil.

E-mail: [email protected]

Abstract

Radiation sources have being widely used in industrial applications, however, their inappropriate use presents a large

potential for hazards to human health and the environment. These hazards can be minimized by development of

specific radiation protection rules and adequate procedures for handling, use and storage of radiation sources, which

should be established in a national normative framework. Recently, due to discovery of new oil and gas reservoirs on

the Brazilian continental shelf, especially in deepwater and in the pre-salt layer1, there has been a large and rapid

increase in the use of radiation sources for well logging in Brazil. However, only generic radiation protection

regulations have been used for licensing the use of radiation sources for well logging, but, these are not

comprehensive or technically suitable for this purpose. Therefore, it is necessary to establish specific safety

regulations for this purpose in Brazil. In this work, an assessment is presented of relevant radiation protection aspects

of radiation well logging, not covered by generic regulations, aiming to contribute to the future development of a

specific safety regulation for the licensing of radioactive facilities for oil and gas well logging in Brazil. The

conclusions of this work are divided into four groups, which include the specific requirements to control radiation

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Aggregation of rocks located offshore in a large portion of the Brazilian coast and with potential to accumulate oil.
It was called pre-salt because it forms a rock interval that ranges under an extensive layer of salt which, in certain
areas of the coast, can be as much as 2,000 meters thick. The distance between the surface of the sea and the oil
reservoirs under the salt layer, can be as much as 7,000 meters.
sources, to control radiation survey meters, to control the access to radiation workplaces and to control and identify

the workers occupationally exposed.

Keywords: regulations, radiation protection, regulatory guides, well logging

1. Introduction

The well logging operation aims to extract information on the physical properties that characterize the

rock formation around the well and to evaluate the nature of fluids that fill the pores of sedimentary rocks.

Through knowledge of these geological features, it becomes possible to assess the potential production of

oil and gas from the reservoir rocks.

Well logging operations in Brazil have had a large boom, as a consequence of new discoveries of oil and

gas on the Brazilian continental shelf, especially in deepwater and in the pre-salt layer, in recent years.

Therefore, there has been a large and rapid increase in the inventory of radioactive sources used for the

purpose of well logging in the country.

The Brazilian nuclear regulatory body - Comissão Nacional de Energia Nuclear (CNEN) - responsible for

the establishment of rules and regulations for radiation protection and nuclear safety, licensing and control

of all nuclear activity in Brazil, does not have a specific radioprotection regulatory standard for well

logging activities. Currently, only generic radiation protection standards are used, but they are not

comprehensive or technically suitable for well logging licensing purposes. Thus, establishment of a

specific regulation has become a pressing need.

This paper presents an assessment of relevant radiation protection aspects of radioactive well logging

aiming to contribute to improving the normative framework for the licensing process of radioactive

facilities in the oil and gas well logging industry in Brazil. This framework should define working

practices, safety procedures and protective measures applicable to all situations where radioactive sources

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are used for investigating the physical properties of geological formations, including minimizing the risk

of accidents involving such radiation sources.

2. Well Logging Operations and Facilities

The well logging bases, or well logging stations, are the facilities licensed by the regulatory body, where

the inventory of radioactive sources is stored. It is important to note that the radioactive sources are also

used at stations that perform calibrations of well logging tools. The onshore and offshore well logging

operations are performed in temporary jobsites on the oil and gas exploration platforms (well sites).

The nuclear well logging operation at well sites consists, basically in the assembling of logging tools

(electronic probes) on the rig floor, with the transfer of radioactive sources to the logging device.

Subsequently, the logging tool is lowered, by cable, into the already drilled well (wireline logging

operation) or connected to the oil-well drill string, near the drill bit, to perform logging during the drilling

(logging while drilling (LWD) operation), shown in the figure 1.

Figure 1. Well logging process and elements: (A) Logging While Drilling (LWD) and (B)

Wireline Logging.

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The logging tool incorporates specific electronics to detect and register radiations that are reflected or are

produced by the interaction of the primary beam with the material of the geological formation. These

sensors send data that are used to generate profiles of rock formation characteristics, such as type of rock,

porosity, density and hydrocarbon content [1].

The radiation sources generally used in well logging operations are Americium-Beryllium, commonly

referred to as Am–Be, with typical activities between 9.3 GBq (0.25 Ci) and 740 GBq (20 Ci) and

Cesium-137 (137Cs) with typical activities between 3.7 and 110 GBq (0.1 to 3 Ci).

Additionally, Californium-252 (252Cf) spontaneous fission sources, with activity around 0.7 GBq (20

mCi), have been used as a replacement for Am-Be sources in obtaining neutron beams. An accelerator-

driven neutron source can also be used for this purpose; however, this last option has high costs for

operation and maintenance.

It should be emphasized that these sources present sufficient activity to represent a significant health

hazard, unless adequately shielded and handled according to appropriate safety procedures. Furthermore,

there are potential adverse impacts due to contamination of the environment, of the geologic formation

and of the reservoir of oil and gas [2].

3. Relevant Radiation Safety Aspects

The purpose of this work is to point out relevant radiation safety aspects in the establishment of regulatory

standard for working practices, procedures and protective measures in well logging. A standard for this

type of operation should define the minimum radiation safety requirements for all users of ionizing

radiation during radioactive well logging.

As the best way to present the results of this work, the relevant radiation safety aspects of well logging not

covered in the Brazilian normative framework were divided into four groups, which include the specific

requirements to control radiation sources, to control radiation survey meters, to control workplaces and to

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control and identify the workers occupationally exposed. These radioprotection aspects are presented in

subsequent sections.

3.1. Radioactive Source Control

These requirements are intended to ensure that the licensee maintains control of all radioactive sources

that are in its possession, also ensuring that the integrity of encapsulation of gamma and neutron well

logging sources is not compromised. So, the requirements need to establish the adequate frequency of

performing tests of source integrity, taking into account the extreme environmental conditions

encountered during wireline and LWD operations.

3.1.1. Working Life of Radioactive Sources

Radioactive source certification is the process by which a radioactive source manufacturer checks the

source compliance with regulatory requirements, characterizing its properties (nuclide, activity at a certain

date, dimensions, etc.) and should include its recommended working life.

The recommended working life is the recommendation, established by the manufacturer of a sealed

radioactive source, of the period for which the sealed source can be used, while complying with its design

specifications. The manufacturer determines this period based on many parameters, such as the toxicity of

the source, the nominal activity, the radioactive source construction design, half-life, the environment in

which it is used, operational experience, etc.

The concept of recommended working life for sealed radioactive sources is established in radiation

protection requirements of some countries, among them Norway and Australia. In these countries, a

radioactive source that has exceeded its recommended working life, as specified by the manufacturer,

should not be used in well logging operations [3, 4].

Additionally, the well logging requirements of Australia recommend that, when the manufacturer does not
137
specify the working life, it should be defined as 15 (fifteen) years for sources of Am-Be and Cs and 5

(five) years for 252Cf.

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It should be noted that, when the recommended working life is exceeded, the radioactive source owner can

send it to the manufacturer, to perform an additional source assessment, based on regulatory requirements,

for the purpose of extending the recommended working life. In that case, a new certificate should be

issued. This complementary examination is called radioactive source recertification. Another possibility is

source re-encapsulation, also based on specific regulatory requirements.

In Brazil the concept of recommended working life is not used by the national nuclear regulatory body,

and there is no normative framework to prevent the use of radioactive sources beyond their safe working

life.

It should be noted that there is the possibility that, when radioactive sources exceed their working life and

cannot be used for well logging operations in countries that apply this concept, they could be transferred

to countries with weaker regulatory regimes. This also emphasizes the need to also establish the working

life concept in the Brazilian normative framework.

3.1.2. Leak Testing

The leak test (or wipe test) is a procedure in which an absorbent material is used to wipe the surface of a

container or equipment containing a sealed source. If radioactive material is leaking from the source, some

of it will adhere to the absorbent material.

The absorbent material should be analyzed in laboratories accredited by the nuclear regulatory body, since

the laboratory should have appropriate equipment to realize a quantitative analysis. The analysis must be

capable of detecting the presence of 185 Bq (0.005 microCurie) of radioactive material. According to the

ISO 9978 standard [5], if the wipe test reveals contamination levels in excess of 185 Bq, the source is not

considered to be leaktight and shall be removed immediately from service and the fact must be reported to

the regulatory body.

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The Brazilian regulatory standard requires that the Radioprotection Service of a radioactive facility should

establish and implement a monitoring program for radioactive sources, including tests to identify the

existence of contamination and leaks, without, however, explicitly define the periodicity of performance

of leak tests [6].

Due to the extreme conditions of temperature and pressure during well logging operations, it is necessary

to establish, in the specific radioprotection standard, the frequency for checking the integrity of sealed

radioactive sources used in these operations.

It is worth noting that this frequency should be greater than in other practices that use radioactive sources,

as a consequence of the adverse environmental conditions to which the sources are exposed, as well as due

to the frequent transport operations.

The periodicity of performing leak tests of radioactive sources used for well logging operations is annual

in Australia and South Africa and at intervals not exceeding 6 (six) months in the United States and

Nigeria [4, 7-9]. It is fully possible that a requirement to perform the leak tests every six months can be

established in Brazil, similarly to United States and Nigeria, taking into account the large number of

institutions and university laboratories that can supply kits to perform such leak tests and can analyze the

samples obtained.

The establishment by the regulatory body of an accreditation program should be emphasized, in order to

assess the technical capabilities of all laboratories performing the sample analyses.

Additionally, the future regulation should establish that, in the absence of evidence of tests performed at a

defined periodicity, the sealed source should no longer be used for well logging operations, until it is again

tested and the sample result is made available, demonstrating the integrity of the radioactive source.

3.1.3. Semi-Annual Inventory

Radiation sources used for oil and gas well logging are highly mobile being frequently transported

between field stations and remote well sites. Due to the possibility of these radioactive sources producing

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biological damage, the sources are transported according to suitable safety and security procedures and

only in shielded containers.

During transport, the sources are vulnerable to loss and theft. In order to ensure control of their radioactive

sources, the logging companies must have a system for accounting for sources and this system should be

able to quickly detect any deviation in the inventory.

Regardless of the accounting and record system used, it would be appropriate that each licensee perform a

semi-annual audit of the radiation sources including a determination of their physical presence and

locations.

This semi-annual inventory should be sent promptly to the regulatory body. The nuclear regulatory body

should have computerized systems to validate the current radiation source inventory, through the use of

the cross-checking of records of acquisition and movement of radioactive sources by each licensee.

Additionally, a reporting mechanism must be available in order to immediately notify the occurrence of

losses and thefts of radioactive sources to appropriate agencies and regulatory bodies, especially to enable

more expeditious investigation of the events.

3.1.4. Transport and Radioactive Source Storage at Offshore Exploration Platforms

The limited physical space on the offshore oil and gas exploration platforms represents a key

consideration in radiation safety procedures. Temporary radiation source storage usually demands the use

of controlled areas. However, the limited physical space on an offshore platform is not generally sufficient

to provide adequate distances to reduce the dose rate to acceptable values in surrounding areas [10]. It

should be noted that temporary source storage at the well site is necessary until the start of well logging

operations, or between operations.

In the Brazilian normative framework, safety conditions on temporary radioactive source storage have not

been established. Such conditions could include mandatory additional shielding, possibly supplied by a

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second container, aiming to compensate the limitations on the physical space. In any event, it is necessary

to establish a specific regulation on temporary storage, with the rules to be complied aiming to avoid

unintentional exposure of workers at offshore sites.

Additionally, the transport and/or storage containers should be equipped with a tracking device to

facilitate the radioactive source localization in case of a maritime accident during the transport from/to

offshore platforms, as established in Norwegian regulations [3]. It should be emphasized that similarly,

during onshore transportation of radioactive materials, the installation of these tracking devices should

also be required.

3.1.5. Workplaces

Well logging regulatory inspections in Brazil are performed, generally, at licensed stations. However,

since 2010, the performance of regulatory inspections at well logging temporary jobsites began. However,

adequate regulatory tools for the planning of the well site inspections do not exist, due to the features of

well logging that create a low predictability of occurrence of operations, as well as the requirement for

support from the well owner to perform the on-site inspection.

This makes necessary the development, by the regulatory body, of planning tools to perform on-site well

logging regulatory inspections. An assessment of the locations of previous operations performed by a

licensed company could be used to create a data bank to determine the likelihood of well logging

operations occurring in a specific future period. One possible approach is that the licensed facilities should

be required to submit a list of well logging workplaces periodically, maybe monthly.

Another way is to obtain information directly from the Brazilian oil and gas regulatory body (Agência

Nacional de Petróleo), who have information concerning the activities occurring at licensed oil and gas

exploration blocks.

Another important consideration is that Brazil is a continental country with a large area and lengthy

coastline. Often, well logging operations have been performed, for long periods, at sites located up to

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3000 km from their well logging stations, as shown in figure 2. Adequate safety and security controls are

very difficult when radioactive sources are operated so far from the responsible radioprotection services.

Better assessment of this is required. This may conclude that there is a need for licensing of a greater

number of well logging stations around the country, each with its own radioprotection service. In this way,

geographical constraints could be applied to the performance of operations with radioactive sources

associated with each well logging station.

Figure 2. Authorized oil and gas exploration blocks in Brazil and locations where well logging

station facilities are concentrated.

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3.2. Radiation Meter Control Requirements

Radiation monitoring instruments are necessary to perform procedures to protect health and minimize

hazards to life or property. Therefore, the licensed facilities must possess and maintain a sufficient number

of calibrated and operable radiation survey instruments, capable of detecting and providing measurements

of dose rates for neutron and gamma radiation.

3.2.1. Quantity of Radiation Survey Meters

The inventory of radiation meters should be compatible with the number of radioactive sources belonging

to the facility. However, the Brazilian normative framework does not specify the adequate number of

radiation monitoring instruments that a licensee should have in relation to its inventory of radioactive

sources. It should be noted that no international standard addresses this matter.

Conservatively, one can use the assumption that the whole inventory of radioactive sources would be

simultaneously in use for well logging operations at remote sites. On this basis, the number of sets of

instruments for radiation survey (gamma and neutron) available at the facility should be equal to the

number of radiation sources.

However, in respect of accelerator-driven neutron sources, due to their limited operating life time and

greater unavailability for maintenance, it is provisionally suggested that one set of survey equipment

should be available for every two neutron generators listed in the radiation source inventory.

Additionally, it should be emphasized that there is a need for additional equipment as replacements or

reserves to cover unavailability due to maintenance and periodic calibration. The experience of the

Brazilian well logging licensing team, based on the large number of regulatory inspections performed at

well logging stations and temporary job sites, points to the need to maintain an additional number of, at

least, the equivalent of 30% of equipment as replacement or backup.

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3.2.2. Personal Alarm Monitors

Personal alarm monitors should be mandatory safety equipment to be used by each well logger, since

these emit a warning signal when a predefined dose rate threshold has been exceeded. The Brazilian

normative framework only requires the use of such equipment by industrial radiographers. However, the

mandatory use should be extended to well logging teams.

3.2.3. Calibration of Equipment

Each radiation survey instrument used for radiation measurement must be adequately calibrated for the

type of radiation for which it is designed. These instruments must be calibrated prior to initial use and at

periodic intervals. Calibration certificates should be accepted by the regulatory body only when issued by

an accredited laboratory [11].

The Brazilian generic radioprotection standard does not define the calibration intervals. However, the

Brazilian nuclear regulatory body has used, for well logging facilities licensing, the recommendation of

the major equipment manufacturers that recalibration should be performed at intervals of not greater that

one year.

It is important to note that Nigerian and Australian standards establish that the calibration intervals cannot

exceed twelve months and that recalibration is required following damage or repairs [4, 9]. However, the

US standard for well logging defines six months for the recalibration period [8].

Due to the limited infrastructure for neutron calibration available in Brazil, it is feasible, in the future

regulation, for acceptance by the nuclear regulatory body of periodic calibration performed by the

equipment manufacturer at institutions outside Brazil. It should be noted that the current normative

framework does not recognize calibrations performed outside the country [6].

The annual interval between calibrations should be formally established in the future standard. This

periodicity, together with the checking routine, will ensure proper performance of the equipment. It should

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be emphasized that the licensed facilities should provide a radiation meters management program, in order

to demonstrate that the equipment calibration scheduling is distributed throughout the year, avoiding an

excessive amount of equipment being unavailable in a particular period.

3.2.4. Checking Routine

Routine performance checks are required before an instrument is used. These checks, when done properly,

ensure that the calibration has not drifted substantially and that the equipment is operating correctly. When

the radiation survey meter returns from calibration laboratory a standard reading is obtained by exposing

the instrument to a radiation field, normally a check source, in a reproducible geometry.

Instruments used to perform radiation monitoring must be performance-checked prior to operation. When

the performance checks are not within the expected range, the instrument should be taken out of service.

The maximum deviation is established as 20% when compared with the standard reading [12].

A check source may not be practical for neutron exposure rate instruments used in well logging. In these

cases, the licensee needs to develop compensatory methods to demonstrate that the instrument is operable

before use at the station and temporary job sites [12].

The Brazilian generic radioprotection standard only defines than the equipment must be properly subject

to checking. However, it is important that the regulation should establish the proper checking procedure.

3.2.5. Meter Dial Scale of Equipment

A radiation survey meter must be used during storage, handling, use and transport of well logging

radioactive sources in order to ensure that the sources are in their defined operating positions or in safe

shielded locations when not in use. For these purposes, the equipment should be scaled in appropriate

units and should be able to indicate expected radiation levels.

However, there are still old neutron counters operating in the country, generally the Ludlum Model 15,

which has a dial scaled in units of counts per minute (CPM). This makes it necessary to use specific charts

for conversion from CPM to dose rate (mSv/h). Generally, when this type of equipment is used, this

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conversion is not performed and area survey records are often registered, irregularly, in CPM units. It is

noted that it is impractical to perform this conversion during operations at well sites, but results recorded

as CPM are not readily interpreted. Thus, the national normative framework should prohibit the use of

obsolete equipment for dose rate measurement, in particular when the meter dial is in CPM units.

3.2.6. Semi-Annual Equipment Inventory

Each licensee should conduct a semi-annual physical inventory accounting for all equipment for

measuring and monitoring of radiation. This inventory should include information on the technical

condition of the equipment, including calibration at adequate periodicity, as well as the general condition

of each instrument belonging to the facility.

The equipment inventory should be sent to the regulatory body, which should have routines of cross-

checking with the inventory of radioactive sources, aiming to ensure that the number of items of

equipment in adequate working condition remains appropriate. It should be emphasized that, therewith,

the regulatory body would have a tool to base decisions on future radioactive source acquisition requests.

3.2.7. Mud Monitors

During LWD operations radioactive source integrity can be affected due to incidents occurring during the

drilling. Thus, the recirculation of contaminated drilling fluid (mud) could lead to potential radiation

exposure of workers. The installation of a radiation detector clamped in the mud circuit (mud monitor)

could ensure worker safety, warning when the radiation level in the mud circuit is increasing, due to loss

of source integrity, as shown in figure 3.

In Brazil, most well logging companies perform a procedure of periodic monitoring of the mud circuit,

usually every 8 or 12 hours, using area survey detectors. It should be emphasized that this procedure, even

when performed properly, can delay the identification of radiation leakages.

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It should be noted that when asked about the lack of mud monitoring during LWD operations, the well

logging companies argued that when a loss of integrity of a radioactive source occurs, during the interval

between periodic monitoring of the mud circuit, the detectors in the well logging tools would register

abnormal behavior or show a complete absence of signal. Thus, it is argued that continuous monitoring

during LWD operations does occur due to the detectors in the tool.

Figure 3. Mud circuit in logging while drilling operations. The installation of a monitor

clamped in the mud return line ensures worker safety during accidents with loss of integrity

of the radioactive source.

Although this argument seems acceptable, it should be noted that there can be problems with the tool

making it impossible to send the signal in real time. In particular, the oil companies do not disassemble the

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drill string, when near the programmed final depth, to repair or replace the logging tool, since, depending

on the depth, this disassembling action could take more than 2 days. Thus, the drilling goes on without

real time logging, with the logging data stored in the internal memory of the tool for later evaluation.

Therefore, the argument for continuous monitoring, performed by the tool´s detectors, ceases to be valid.

Thus, for the continuous monitoring of the drilling fluid, an appropriate monitor clamped in the mud

return line should be installed and operational.

It should be emphasized that during fishing jobs to recover a radioactive logging tool stuck in a well, the

use of mud monitors should be mandatory, taking into account the possibility of loss of integrity of

radioactive sources during this emergency procedure. Therefore, it is important that the regulation

establishes the number of dedicated mud monitors that should be available at well logging facilities that

perform LWD operations, taking into account their radioactive source inventory. The adequate number of

mud monitors should be based on similar rules to those applied to portable radiation survey meters.

If the sealed source cannot be retrieved, the licensee should notify the national regulatory body in order to

obtain approval to implement abandonment procedures [13]. The abandonment procedure should

comprise:

• The irretrievable well logging sources to be immobilized and sealed in place with a cement plug;

• The use of color additives for cement contrasting with the color of the surrounding rock

formations;

• Preventive steps to be taken against accidental access to the cemented source in future operations

in the field, mainly using a whipstock or other drill deflection device;

• A warning plaque containing the international radiation symbol and the relevant information on

the abandoned sources to be provided by the well owner to be mounted at the wellhead in a

permanent structure.

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A database should be maintained by the regulatory body in order to keep records of abandoned sources,

including, as a minimum, the relevant information on the abandoned radioactive source, geographical

coordinates and the depth where abandonment occurred.

3.3. Operational Area Control Requirements

The improper use of equipment and safety systems, as well as failures to performing radiation area

surveys are the main root causes of many accidents in oil and gas well logging resulting in radiation

exposures to members of the public and well logging workers, and environmental contamination [2, 14-

16].

3.3.1. Radiation Survey Procedures

The controlled areas should only be released for unrestricted use after verification that all radioactive

sources are fully shielded, through an appropriate radiation survey procedure.

A specific standard should define the frequency of radiation surveys of controlled areas in the well

logging station, including the source storage locations and the calibration tools area, describing the

procedures and the information required to be included in the record forms.

Usually, the well logging companies perform a quarterly radiation area survey at radioactive source

storage locations, although it should be emphasized that there is a need for area surveys whenever there is

an increase in the inventory of radioactive sources stored.

Additionally, a wall-mounted area monitor permanently operational shall be the installed, in order to

ensure the safety of storage locations for well logging, providing audible and visual alarms when preset

radiation thresholds are exceeded due to incorrect storage or handling. Simultaneous gamma and neutron

monitoring should be provided by the area monitor.

Tests to ensure that the area monitor is functioning properly should be carried out on a monthly basis,

similarly to procedures described for gamma irradiation facilities [17]; this is done by exposing the

monitor to a check source until the alarm sounds.

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Normally, the calibration tool area is an unrestricted area in the well logging station that is reclassified as a

controlled area only during the calibrations. After the calibration task is complete, a radiation survey

should be performed to ensure that the well logger removed the source from the tool to the shielded

container before reclassifying the calibration area again as an unrestricted area.

Taking into account that accidents may occur due to failures of the well loggers to perform a radiation

survey of the calibration area or of the source container, it may be necessary to define a specific area for

this operation that is adequately shielded and permanently classified as a controlled area.

3.3.2. Radioactive Source Storage Location at the Station

The Brazilian regulations do not define a basic design for the building where radioactive sources are

stored. So, there are different configurations of design for these facilities. However, they can be

characterized in four main groups, as shown in figure 4:

• Storage location below soil level, with the radioactive sources being stored outside the transport

shielding, in small individual steel tubes.

• Storage location below soil level, with the radioactive sources being stored inside the transport

shielding.

• Storage location below soil level, with the radioactive sources being stored inside the transport

shielding in individual enclosures.

• Storage location in a conventional maritime container coated with concrete (or borated concrete)

at the ground surface, with the radioactive sources being stored inside the transport shielding.

Although all of these designs, in their maximum licensed storage capacity, provide sufficient shielding to

reduce dose rates to levels below the limit for the public in adjacent unrestricted areas, these buildings

provide different degrees of exposure of workers entering in the premises to carry out operations of

removal and storage of radioactive sources.

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 Figure 4. Designs of Radioactive source storage at well logging stations. (a) Below soil level

outside the transport shielding, in small individual steel tubes. (b) Below soil level and inside

the shielding. (c) Below soil level and inside the shielding, but in individual enclosures. (d)

Storage in a conventional maritime container coated with concrete at the ground surface and

inside their shielding.

The operations of removal and storage in locations with configurations in which the radioactive sources

are stored outside of their transport shielding, causes radiation doses received by workers to be 10 times

higher, in comparison with other design layouts of storage locations [18].

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According to the principle of optimization, well logging facilities should be prohibited from building

storage facilities in which radioactive sources are stored outside the transport shielding.

3.4. Occupationally Exposed Worker Control Requirements

The well logging facilities are responsible for protecting occupationally exposed workers during activities

involving occupational exposures. However, it should be noted that it is the responsibility of

occupationally exposed workers to follow the rules, including safety and radiological protection

procedures, with participation in periodic training on safety and radiological protection that enables them

to safely conduct their work.

3.4.1. Radioactive Worker Identification

The need for greater formalization in the identification of occupationally exposed workers has been noted.

Individual records of each employee should be available, including their activities associated with

radiation sources.

The work schedule that is used at offshore and at jungle well logging activities, of 14 working days and 14

days off, can result in these workers not being included in the control of the radiation protection service,

since they return immediately to their states (Brazilian workers) or countries (foreign workers) of origin at

the end of work period.

This means that there should be an information exchange between the CNEN (Brazilian Nuclear

Regulatory Body) and the Ministry of Work (Brazilian Federal Supervisory Body of Work) in order to

prevent these contractor personnel performing activities with radioactive sources without being registered

by the radiation protection service of the well logging facility.

It should be emphasized that workers operating on a short term basis (itinerant workers) should not be

allowed to be occupationally exposed, except for specialists that can be hired to perform specific actions

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in an emergency situation involving radioactive sources. Even so, these professionals should act only

under the coordination of the radioprotection service of the well logging facility.

3.4.2. Radiation Safety Officer (RSO)

In Brazil, the radioprotection service should have a RSO certified by CNEN in each well logging facility.

The RSO is the person responsible for implementing the radiation protection program in the facility. As a

consequence of their responsibility, it is necessary that the RSO has independence and authority to stop an

operation with radioactive sources that they consider unsafe. Thus, the RSO should not be subordinate to

maintenance or operation groups in the facility.

In many facilities it has been observed that well logger engineers also have the responsibility of acting as

RSO. In general, the RSO responsibilities are postponed and performed with lower priority. It should be

noted that the accumulation of the RSO responsibilities by well loggers makes the RSO directly linked to

operational groups, which may be considered as contrary to the concept of independence of the RSO.

It is evident that it should be prohibited for a well logger to accumulate the radiation safety officer

responsibilities.

3.4.3. Training and Certification/Licensing of Workers

The establishment of adequate training programs is fundamental for the safe, secure and efficient

development of work with radioactive sources. However, there is a need for greater formalization in the

training of occupationally exposed workers.

The current Brazilian normative establishes that the instructors who provide training in radiation safety to

well logging workers shall have a specific CNEN certification as well logging RSO.

Generally, logging companies conduct remote training. However, such training often is not presented in

the worker primary language, clearly representing a low degree of importance given to this radioprotection

requirement. Thus, the new regulatory standard must establish guidelines and best practices for remote

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training courses, as well as establishing minimum periods of instruction for the initial training and

periodic retraining programs adequate to well logging.

Although remote training allows added flexibility while reducing costs, the training program must also

include hands-on training sessions in order to simulate logging operations and manipulate the associated

safety equipment.

There are two distinct categories of workers present in the operational area of well logging:

• Well logging engineers – who perform or supervise well logging operations and are responsible to

ensure compliance with the safety and security requirements during well logging operations;

• Well logging assistants – who use well logging equipment including sealed sources under the

direct supervision and in the physical presence of the logging engineer.

Taking into account the different responsibility of logging engineers and assistants, the training program

must include specific requirements for each category, as is required under the United States standard [8],

covering, as a minimum, radiation physics fundamentals, biological effects of radiation, principles of

radiation protection, radiation source applications, interaction of radiation with matter, radiation controls,

operational procedures, accident scenarios and emergency preparedness and response.

Additionally, the possibility of issuing a certificate/license to authorize a person to handle radioactive

sources should be studied, as is required under the Argentine standard [19].

Finally, as a complement to the training program, a periodic internal inspection program (maybe annual)

of the job performance of each well logging worker should be established. The audit of job performance

program should include an assessment, during well logging operations, of workers, aiming to evaluate that

there is adequate implementation of training for operational and emergency procedures.

3.4.4. Dosimeter Control Requirements

The provision of suitable dosimeters to workers, which is mandatory for anyone during their stay in

controlled areas, is a regulatory requirement with the purpose of assessing occupational doses.

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Due to the large number of well logging operations that are performed at sites distant from the well

logging stations, failures have been observed in the periodic provision of dosimeters, mainly in offshore

operations. Often, the dosimeters cannot be sent for readout at a laboratory within an acceptable period, as

a consequence, after 90 days, readout becomes impossible.

Often, the lack of return of dosimeters occurs because the workers disembark from the offshore platforms

and go directly to their residences in different states (or even different countries), not returning its

dosimeters to the well logging station. Thus, the future regulation should empower the regulatory body to

disqualify workers in cases of repeated occurrence of non-return.

Well logging facilities have commented that this failure has occurred because of logistical problems, but

repeated occurrence is a serious radioprotection problem, and difficulties of logistics are not an adequate

excuse for its existence.

On other hand, excessive and repeated use of dosimeters for visitors and others without control has

hindered the formal annotation of individual records of doses. Because of this, it should be established,

formally, the situations in which it is acceptable to use of not-nominal (not assigned to a specific

individual) dosimeters. As a suggestion:

• New workers can use not-nominal dosimeters, since the RSO has already requested the individual

dosimeters. However, they cannot use not-nominal dosimeters for a period exceeding one usual

period between readouts by the dosimetry laboratory.

• A worker, who has used a not-nominal dosimeter, should have the dose registered added to his

individual occupational dose record.

3.4.5. Neutron Dosimetry

At present, Brazil does not have sufficient infrastructure to provide neutron dosimetry by national

laboratories. Because of this, in order to legalize the current use of neutron dosimeters provided by

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laboratories not certified by CNEN, the regulatory standard should include a specific section establishing

that when there is no accredited laboratory in the country to provide individual dose monitoring, the

regulatory body will assess the appropriateness of using services provided by institutions in other

countries.

4. Conclusion

The well logging operation has the purpose of extracting information on the physical properties that

characterize the rock formation around the well and to evaluate the nature of fluids that fill the pores of

sedimentary rocks. Thus, it is relevant to the specific needs of the petroleum industry.

The lack of a specific regulatory standard for the licensing of radioactive well logging operations in Brazil

weakens the nuclear regulatory body in its aim of regulating and licensing the activity. Often the CNEN´s

regulatory professionals, for lack of a specific rule, have enlarged the interpretation of generic

radioprotection standards with the purpose of incorporating radiation protection procedures used in other

countries. However, these enlargements are not established in current Brazilian regulatory standards, a

fact that has generated questions and complaints by well logging facilities.

In this paper, recommendations are presented concerning relevant aspects of radiation protection in well

logging that are not covered by Brazilian generic radioprotection regulations, with discussion of specific

features that should form part of the future regulations, with the purpose of ensuring safety during

operations, taking into account specific requirements to control radiation sources, to control radiation

survey meters, to control the access to radiation workplaces and to control and identify the workers who

are occupationally exposed.

It should be noted that this is the appropriate moment for the expansion of regulatory tools in the well

logging area, especially when we take into account the increased prospecting for oil and gas on the

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Brazilian continental shelf, due to the increase in price of these commodities and the new frontiers of oil

exploration in deepwater and the Brazilian pre-salt layer.

Acknowledgments

The authors wish to thank Evaldo Luiz Correa da Costa for useful comments in the preparation of this

manuscript.

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