ML20203N697
| ML20203N697 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/1980 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610170199 | |
| Download: ML20203N697 (2) | |
Text
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[p.aeg'g' UNITED STATES y
NUCLEAR REGULATORY COMMISSION
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.I REGION 11 j*g 101 RAaRIETTA ST., N.W., SulTE 3100 ATLANTA, GEORGIA 303s3 MAR 071980 SSINS 9193 MD10RANDUM FOR: Radiation Support Section l
FROM:
A. F. Gibson, Chief, RSS, FF&MS, Branch
~
SUBJECT:
10 CFR 20.203(f) ENFORCEMENT GUIDANCE FOR CONTAINER. LABELS A label required pursuant to 10 CFR 20.203(f) shall bear the radiation caution symbol and the words " CAUTION, RADI0 ACTIVE MATERIAL". or " DANGER, RADIOACTIVE MATERIAL".
It,shall also provide sufficient information; as appropriate including radiation levels, kinds of material, estimates of activity, date i
for which acitivity is estimated, mass enrichment, etc., to permit individuals handling or using the container, or working in the vicinity thereof, to 'take precautions to avoid or minimize exposures.
There are numerous exceptions allowed by this regulation, but each ensures that the "sufficientinformation" i
portion of the requirement is maintained for worker safety.
Discovery of unlabeled containers is almost a certainty at any large facility such as a power plant. If an unlabeled container constitutes an isolated i
j aberrant occurance as opposed to an overall program deficiency in radioactive materials control, enforcement action may not be appropriate. The regulation goes to great lengths to ensure worker safety by requiring information be available to the individual handling the container, and this is the real i
point:
that worker safety be maintained.
Conversely, a very high radiation level container lef t unlabeled would be a strong indicator of weaknelts in i
the' licensee.'s radioactive material control program, as well as being a true radiation safety hazard.
l The elements necessary for a good program of control include an agressive attitude toward the identification of safety hazards associated with containers i
and expeditious labeling, or application of other control methods.
Radiation workars often become complacent in dealing with small quantities of radioactive material and a good program combats this attitude by insisting on vigilance by l
the Health Physics Staff at every level. The Health Physics Supervisor,.as well as technicians, must insist on labeling as a matter of routine.
should a noncompliance with 10 CFR 20.203(f) be suspected, ensure that control is not being exercised by one of the other niethods allowed in paragraph,(f)(3)
J of the section.
It may also be appropriate to include'in the discussion section
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of the Inspection Report the calculations you used to determine greater than l
Appendix C quantities were present in the container.
-l 86101701998003Oh PDR MISC N
8610170199 i
i
Radiation Support Section It is important to emphasize t,o the licensee that the purpose of 10 CFR 20.203(f) is to ensure adequate information is available, by whatever appropriate method, to enable a worker to handle radioactive materials safely and to minimize his exposure. A comprehensive and agressive radio-active material contr'ol program is essential to achieve this goal.
[
Albert F. Gibson, Chief Radiation Support Section cc:
J. P. Stohr J. P. Potter G. R. Jenkins