Contaminated Material Control

DOE-HDBK-1184-2004

affected by STCs, and to take appropriate action to avoid exposure or facilitate

proper handling.

10 CFR 835.606 establishes several conditions under which labeling of radioactive

items and containers of radioactive material is not required. When using these

exceptions, caution should be exercised to ensure that individuals working in the

vicinity of radioactive items and containers of radioactive material are provided

appropriate information in the absence of radioactive material labels. For example,

inclusion of appropriate information on area postings or in employee training or pre-

job briefings may prove to be an effective substitute for radioactive material labeling

under the specified conditions.

Note that the 10 CFR Part 835 radioactive material labeling requirements are

applicable only to "items and containers." Piles and areas of granular solids, such

as soil and sand, are generally not considered to be "items" or "containers";

therefore, labeling of such piles and areas may not be required or practical.

However, consideration should be given to the need for posting such piles or areas

as contaminated areas consistent with 10 CFR 835.603. See DOE G 441.1-10 for

further guidance on application of the 10 CFR Part 835 posting requirements to

areas of soil and similar materials.

Another situation for which labeling may not be required by 10 CFR Part 835, but

for which labeling would be useful, is for materials that have been exposed to tritium

long enough for the tritum to bind tightly in the matrix of the material. Labels could

be used to warn individuals that operations performed on these materials that

generate particles could create an airborne radiological hazard.

6.2.8

Contaminated Material Control

Appropriate controls on the storage, use, and movement of materials contaminated

with STCs are necessary to limit the spread of STC contamination to other

materials, areas, and individuals. Such a spread would result in a need to expand

the scope of the STC monitoring program beyond its initial boundaries. This is

undesirable due to both the possible individual and environmental exposures that

may occur, and the relative expense and complexity of the STC monitoring and

control program.

Subpart L of 10 CFR 835 establishes DOE's regulatory requirements for control of

contaminated material and equipment. In general, the regulations require that

material and equipment that is located in a contamination, high contamination, or

airborne radioactivity area be monitored for the presence of surface contamination

prior to release to the controlled area. The regulations also establish provisions

allowing for release of contaminated materials under certain controlled conditions.

Material and equipment that is located in areas where STC contamination is known

to exist should be monitored consistent with the requirements of 10 CFR 835

Subpart L prior to release to the controlled area. The monitoring should be

performed consistent with Sections 3.1 and 3.2 of this handbook and should be

capable of identifying STC contamination at or below the 10 CFR 835 Appendix D

values.