Halliburton Energy Services

Section

Radiation, Sealed Sources, and

Abandonment

Radioactive Source Considerations

Note: This section deals primarily with U.S. fishing operations. Although radioactive
source considerations vary from country to country, the following information may be
used as a guideline when fishing any sealed sources.
All personnel involved with fishing tools with radioactive sources must know existing radiation hazards
and recommended procedures for handling radioactive materials. Refer to Section 8-9 of the HES
Radiation Safety Procedures and Radiation Protection Program (Form 4227, Rev 0) and the section
Agreement With Well Owner or Operator from Title 10 of the Code of Federal Regulations (CFR),
Part 39, 39.15 (United States Nuclear Regulatory Commision Regulations).

Note: Immediately alert the division safety officer if the customer wants to try a
destructive fishing procedure.

CAUTION During fishing operations, Halliburton personnel must monitor the radiation level of the
mud flowline with a survey meter to verify the integrity of the downhole source in the
stuck. Alternatively, a logging tool such as a natural gamma ray tool, CSNG, for
example, can be used to monitor the radiation levels in mud pits.
Refer to Figure 2-1 for the action to take in the event a tool containing radioactive material becomes
lodged downhole. The Well Logging Supervisor (WLS) is responsible for completing each action. The
flowchart in Figure 2-1 refers to pages in this section where the WLS can find more information on the
steps in the flowchart. These steps and information are taken from Section 8-9 of the HES Radiation
Safety Procedures and Radiation Protection Program (Form 4227, Rev 0).

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 Arrive on
location Ensure transport
Tool to be containers
No
abandoned? available for
sources
Written Have job
agreement ticket/work Yes
No
with well order signed
owner? (2-3) Visually
Ensure RRP contacts inspect source
Yes CRSO before for damage
abandonment
(2-8)
Proceed with
well logging
operations
Ensure RRP completes
Review w/client NRC
Radiation Tool
39.15 and Retrieved (2-11)
Tool with
abandonment
radioactive source
examples (2-1, 2-13)
is stuck

Notify RRP Continue with

(2-7) logging
Ensure Halliburton Ensure well owner operations
CRSO obtains obtains permission
permission from from drilling
Remain on radiation regulatory permitting regulatory
site agency agency
Perform leak test on
source upon returning
to district office

Advise client of Refer to Emergency

responsibility per Notification List Abandon per
CFR 39.15 (2-8) plan
(2-8) (2-13)

Ensure RRP completes Ensure RRP completes

Radiation-Rpt Report of Radioactive
(2-9) Any criteria
No A Material Abandonment
on list met?
(2-12)

Yes
Monitor
A
Flowline

Ensure RRP Ensure CRSO has

contacts CRSO B plaque made and
(2-8) delivered to well
owner
Shut down operations
immediately if radioactive
contamination is detected

Return to logging
operations
Fishing
operations No A
>24 hours?

Yes

Note: Numbers in parentheses refer to page

numbers in this document.

Figure 2-1: Actions in response to tool with radioactive material becoming lodged downhole

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Applicable Federal Nuclear Regulatory Commission
Regulations
This section provides an exerpt from 39.15, Title 10 of the CFR. As required by these regulations, the
customer must sign an agreement before any fishing procedures begin. The customer must read the
legal terms provided on the back of the field ticket and sign in the box labeled Customer or customers
agent signature on the front of the field ticket. A sample of the field ticket is found in Figures 2-2 and
2-3.

39.15, Title 10-- Agreement With Well Owner or Operator

(a) A licensee may perform well logging with a sealed source only after the licensee has a written
agreement with the employing well owner or operator. This written agreement must identify who
will meet the following requirements.
1. If a sealed source becomes lodged in the well, a reasonable effort will be made to recover it.
2. A person may not attempt to recover a sealed source in a manner that, in the licensees opinion,
could result in its rupture.
3. The radiation monitoring required in 39.69(a) will be performed.
39.69(a) Radioactive contamination control.
If the licensee detects evidence that a sealed source has ruptured or
licensed materials have caused contamination, the licensee shall
initiate immediately the emergency procedures required by 39.63 (or
as discussed in Form 4227 and Section 2 of this manual.)
4. If the environment, any equipment, or personnel are contaminated with licensed material, they
must be decontaminated before release from the site or release for unrestricted use; and
5. If the sealed source is classified as irretrievable after reasonable efforts at recovery have been
expended, the following requirements must be implemented within 30 days:
i) Each irretrievable well logging source must be immobilized and sealed in place with a
cement plug.
ii) A mechanical device to prevent inadvertent intrusion on the source must be set at some
point in the well above the cement plug, unless the cement plug and source are not
accessible to any subsequent drilling operations; and
iii) A permanent identification plaque, constructed of long-lasting material such as stainless
steel, brass, bronze, or monel, must be mounted at the surface of the well, unless the
mounting of the plaque is not practical. The size of the plaque must be at least 7 inches (17
cm) square and 1/8-inch (3 mm) thick. The plaque must contain --
(A) The word CAUTION;
(B) The radiation symbol (the color requirement in 20.1901(a) need not be met);
(C) The date the source was abandoned;
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 (D) The name of the well owner or well operator, as appropriate;
(E) The well name and well identification number(s) or other designation;
(F) An identification of the sealed source(s) by radionuclide and quantity;
(G) The depth of the source and depth to the top of the plug; and
(H) An appropriate warning, such as, DO NOT RE-ENTER THIS WELL.
(b) The licensee shall retain a copy of the written agreement for 3 years after the completion of the
well logging operation.
(c) A licensee may apply, pursuant to 39.91, for Commission approval, on a case-by-case basis, of
proposed procedures to abandon an irretrievable well logging source in a manner not otherwise
authorized in paragraph (a)(5) of 39.15, 10 CFR (Refer to this section for paragraph (a)(5) of
39.15, 10 CFR.)
39.91 Applications for exemptions.
The Commission may, upon application of any interested person or upon its
own initiative, grant such exemptions from the requirements of the regulations
in this part as it determines are authorized by law and will not endanger life or
property or the common defense and security and are otherwise in the public
interest.
(d) A written agreement between the licensee and the well owner or operator is not required if the
licensee and the well owner or operator are part of the same corporate structure or otherwise
similarly affiliated. However, the licensee shall still otherwise meet the requirements in paragraphs
(a)(1) through (a)(5) of 39.15, 10 CFR.

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 Customer must
sign here before
any logging
procedures
begin.

Figure 2-2: Sample Field Ticket for Customer Signature

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Figure 2-3: Terms and Conditions (Back of field ticket)

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Fishing Sealed Sources or Radioactive Tools
Special consideration is necessary in the event logging tools containing radioactive materials become
lodged downhole. Fishing operations must be conducted according to HES Radiation Safety Procedures
and Radiation Protection Program Section 8-9 (Form 4227, Rev 0).
Refer to Figure 2-1 for a concise overview of steps to take when tools containing radioactive materials
become lodged downhole. Figure 2-1 contains references to sections in this document where the user
can find more specific information about the steps in the flowchart.

General Guidelines
In the event logging tools containing radioactive materials become lodged downhole, the Well Logging
Supervisor must

Notify RRP who will contact the CRSO as stated in Notification of Radiation Incidents, page 2-7 in
this section. The CRSO will then contact applicable regulatory agencies.

Ensure the RRP completes RADIATION-RPT. Refer to RADIATION-RPT Incident Report, page
2-9 this section.

Maintain contact with operator advising of responsibilities as per Applicable Federal Nuclear
Regulatory Commission Regulations, page 2-3 this section.

Remain on location during all fishing operations.

Continually monitor the fluids circulating from the well at the surface for radiation by using a low
level beta/gamma survey meter. If possible, in addition to the survey meter, a gamma logging tool
should be placed in the mud return path and the output recorded.

Shut down operations immediately if radioactive contamination is detected and confirmed during
fishing. This is extremely important as further activity can spread the contamination.

Follow the appropriate procedures for source removal and storage as outlined in Section 5 of Form
4227 if retrieval operations are successful.

Visually inspect source for signs of obvious damage such as abrasions or disfigurement from
pressure.

Perform a leak test on the source upon returning to district office.

Notification of Radiation Incidents

In the event a tool containing a sealed source is lodged downhole, a Well Logging Supervisor (WLS) is
responsible for initiating the notification procedures. The WLS must contact the local radiation
responsible person (RRP). It is the responsibility of the RRP to report all accidents or unplanned
incidents involving radioactive materials or radiation-producing equipment in his/her approved
facilities to the Corporate Radiation Safety Officer (CRSO) by telephone. In addition, he/she must also
report all incidents involving his/her radioactive materials or radiation producing equipment registered
on his/her inventory that may occur outside his/her approved facilities.

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 The RRP will contact the RSO when necessary and complete and send the appropriate formatted
incident memo, providing the details of the stuck radioactive material. The RSO will contact the
licensing agency as required by regulation.
The RRP will contact the CRSO when any of the following criteria are met.

Emergency Notification to CRSO

Customer initiates a fishing operation contrary to Halliburtons recommendations.

Customer refuses to initiate an advised fishing operation.

Source or radioactive tool is stuck in an open hole and the cable or weak point has been broken.

Source or radioactive tool is lodged downhole in Alabama jurisdiction (land or inland waters).

Source or radioactive tool is in danger of being damaged.

Source or radioactive tool is not recovered on the first fishing attempt.

Source or radioactive tool is not retrieved within 24 hours.

Abandonment of the source or radioactive tool is imminent.

Mud returns show an increase in radioactivity.

Advisement to Well Owner or operator

The WLS must remain in contact with the well operator and offer recommendations regarding safe,
nondestructive fishing procedures. Advise the client of his responsibility as per CFR 39.15. Refer to
Applicable Federal Nuclear Regulatory Commission Regulations, this section. Make the operator
aware that fishing procedures could damage the source, and the possible consequences of
contamination associated with a ruptured source.

CRSO Contact Information

To contact a CRSO 24 hours a day, use the following options:
Jeff Pettigrew
Work-Houston, TX: 281-496-8319 (Leave Urgent Voice Mail After Hours)
Fax-Houston, TX: 281-496-8394
MEMOID: ESG.GVRZ301 or ESG.JEFFPET
After Hours/Holidays/Weekends:
Nationwide Pager 800-443-7243, Pager ID 063767, Enter Your Phone Number
Home Phone: 281-856-6105

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 Steve Woods
Work-Duncan, OK: 405-251-3936 (Leave Urgent Voice Mail After Hours)
Fax-Duncan, OK: 405-251-3969
MEMOID: ESG.GVRZ131 or ESG.STEVEWO
After Hours/Holidays/Weekends:
Nationwide Pager 800-443-7243, Pager ID 063381, Enter Your Phone Number
Home Phone: 405-622-3523 (Leave Message on Machine)
OR
Duncan - 405/251-3760, ask for Radiation Emergency Contact.
Houston - 281/496-8100, ask for Radiation Emergency Contact.

Note: The RSO will determine what type of notification, if any, is required for
regulatory authorities. DO NOT begin any fishing operations in Alabama or
abandonment procedures in any state until authorized by the CRSO.

Reporting Procedures

RADIATION-RPT Incident Report

After contacting RSO, the local responsible person or other designee completes a formatted memo in
the GESG Global Mailbox entitled RADIATION-RPT. The following instructions detail how to
complete the report.
1. Sign on to MEMO - Press PF5 to Create memo
2. Go to Command line. Type include and press enter
3. Go to Include from MEMOID line and type GESG and press enter
4. Copy RADIATION-RPT for inclusion by typing C and pressing enter. Press PF3 to exit
5. The RADIATION-RPT Memo is now in your mailbox.
6. Complete required information on the memo. See Figure 2-4 for example of report.

Note Once the NWA is selected, the memo will automatically copy the NWA Asset
Manager, NWA HSE personnel, and RSOs. Any other persons to be copied (cc:) (up to
4) should be added.

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Figure 2-4: Example of Report of Incidents Involving Radiation

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 Stuck Tool Retrieval Report
1. Follow same procedure as for the initial report, (RADIATION-RPT) only this time, select RAD
TOOL RTRD report.
2. Complete request information on memo. See Figure 2-5 below for example.

Figure 2-5: Radiation Tool Retrieved

Source Abandonment Report

1. Follow same procedure as for the initial report, only this time, select R/A MATL ABND report.
2. Complete required information in memo. See Figure 2-6 for example.

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Figure 2-6: Report of Radioactive Material Abandonment

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Sealed Source Abandonment
If, after making all reasonable attempts to recover a tool containing a radioactive source, the source
remains stuck in the well, the source shall be classified as irretrievable. All abandonments must be
approved prior to commencement by the appropriate regulatory agency. If a source is classified as
irretrievable, the WLS shall:

Contact the RRP. The RRP shall then contact the RSO.

Discuss with the client the requirements of the applicable regulations regarding the safe
abandonment of radioactive sources. Refer to Applicable Federal Nuclear Regulatory Commission
Regulations, this section.

In conjunction with the client or his representative, develop an abandonment plan which shall
include:
Method of immobilizing and sealing in place with a cement plug, placement of an indrillable object
to serve as a deflection device (unless cement plug is not accessible to any subsequent drilling
operations), the placement of an identification plaque (if practical), and plans for the well after the
abandonment. (P&A, sidetrack, produce at a shallower depth/etc.).

Contact the RRP with the proposed abandonment details and pertinent well information. The RRP
should notify the RSO.

Ensure that the appropriate regulatory agency is notified and permission for the abandonment is
requested.

Ensure RRP notifies of agencys response to request for permission.
If the permission is denied, the RSO will discuss alternatives with the appropriate individuals and
submit an abandonment plan to the regulatory agencies.

Report final details of abandonment to RRP.
The RSO shall obtain a well plaque and supply to the client. The RSO shall notify in writing the
regulatory agency responsible for the licensing of radioactive materials within 30 days of the
completion of the abandonment.

Note It is the responsibility of the client to notify the regulatory agency responsible for
the drilling and production of oil and gas wells. (Texas Railroad Commission,
Oklahoma Corporation Commission, Oil and Gas Board, etc.).

Typical Abandonments
The following examples are intended to aid the client, the WLS, and the CRSO in the development of
an abandonment plan. All abandonments shall be approved by the regulatory agencies prior to their
implementation.

Source and Tool Below the Producing Zone

This is usually the simplest abandonment procedures. Since the tool is below the producing zone, it is
cemented in place and a 200 foot cement plug is set above the tool. Then a deflection device is set

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 above the plug. Refer to Figure 2-7. A plaque with the information required in 10 CFR, part 39.15 is
prepared and mounted on the surface. Typical deflection devices include a whipstock, inverted drill
bit, drill collars, or steel ball bearings. Halliburton also offers the bottom hole kickoff assembly tool
that creates a false bottom, or mechanical plug, in the open hole that prevents cement plugs from
sliding downhole. This solution is superior to the standard whipstock device. A plug of less than 200
feet may be set, if there is not enough hole below the producing zone.

Note This option is also practical when the well is going to be plugged and abandoned.

Source and Tool Above the Producing Zone

If the tool and source are left above the producing zone and you are able to run casing past the tool,
then the tool may be cemented in place behind casing. In this case, a deflection device is not practical.
After the tool is cemented in place, a gamma-ray log must be run to verify the actual location of the
source. Refer to Figure 2-8. The customer will need to document the depth of the sources in all files
associated with the well. Perforating operations should not be conducted 200 feet above or below the
sources. Again a plaque is mounted on the surface.

Source and Tool in the Producing Zone

In this case, the tool may be cemented in place and a 200 foot cement plug set above the tool. Then the
deflection device is set and the well is side tracked. Refer to Figure 2-9. The sidetracked hole should
not be drilled within 15 feet of the source. Again, a plaque is prepared and mounted on the surface.

Other Abandonment Considerations

If a client so desires to develop an alternative abandonment plan, the client may do so. However, like
all abandonments, the procedures must be approved by the appropriate regulatory agency prior to its
implementation.
Before fishing for a radioactive source, the WLS immediately should contact the RRP officer, who will
contact the division and corporate RSO. All contact between Halliburton and governmental agencies
will be through the corporate RSO, unless other arrangements have been made.
In most states, Halliburton can perform multiple fishing attempts before notifying the state or the
Nuclear Regulatory Commission (NRC). However, Alabama requires prior notification before any
fishing attempts can be performed. In Kansas and Colorado, the State agency must be notified if the
tool has not been recovered within 24 hours. Most states require notification only if the tool will be
abandoned.
There are no regulations that require a minimum number of fishing attempts before a tool containing
radioactive sources can be abandoned. The regulations state that all reasonable fishing attempts should
be made prior to abandonment. No further fishing attempts should be made if the source integrity will
be endangered. The decision to abandon the tool is made after all other options have been exhausted.

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Figure 2-7: Source and Tool Below the Producing Zone

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Figure 2-8: Source and Tool Above the Producing Zone

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Figure 2-9: Source and Tool in the Producing Zone

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 However, if the customer has instrument protection, please refer to HES Logging/Perforating Price
Schedule which requires a minimum of three complete attempts for it to apply. An exerpt follows.
Instrument Protection
In certain areas Halliburton may offer instrument protection which offers limited
protection to the customer against the responsibility for loss of Halliburton downhole
equipment. Instrument protection may not be offered under abormal logging
conditions. Instrument protection is not available for thru-drillpipe, Coil Tubing
Conveyed, Offshore & Inland water, ToolPusher, HEAT SUITE, NMR equipment, or
third party services.
When subsurface tools and/or instruments are lost in a well due to hole conditions and
cannot be recovered by fishing operations, the replacement cost will be covered by the
following protection charge per service run in the well. Instrument protection charges
are applicable to each service performed on each trip to a well. When instrument
protection is available but not desired, customer must so indicate on the contract prior
to the commencement of operations.
The customer must make every reasonable effort to recover tools or instruments for
this protection to apply. A reasonable fishing effort is at least three complete attempts
to the top of the fish to recover the lost equipment, exclusive of attempts to recover
cable. If the customer is unable to make a fishing effort due to any cause beyond the
control of Halliburton, then instrument protection shall not apply.
Equipment covered by instrument protection shall include the cable head and all
equipment below the cable head. Instrument protection does not cover cost of repair
of recovered equipment, which will be charged as Equipment Lost or Damaged
above.

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