Radioactive Material Labeling

DOE-HDBK-1184-2004

NOTE: Although repeated exposure to STCs in unposted areas with airborne

radioactive materials could lead to a dose of up to 1500 mrem (CEDE) in a

year, DOE requirements in 10 CFR Part 835 specify initiation of individual

and workplace monitoring when annual exposures are expected to exceed

40 ACV-hours (100 mrem). In addition, 10 CFR Part 835 requires the

institution of the ALARA process when establishing workplace controls for

radiation exposure during routine operations. Thus, it is unlikely planned

exposures exceeding 100 mrem would occur without knowledge of either

the site or the facility's radiological protection organization.

If the STC contamination levels are elevated (e.g., surface contamination levels

exceed the 10 CFR 835 Appendix D values, but are less than 10 times those

values; exposures to airborne radioactivity could exceed 12 ACV-hours, but are

less than 120 ACV-hours, per week), more aggressive measures should be

implemented. Such measures may include both design features and administrative

controls, such as filtered ventilation systems, physical barriers to both individual

access and contamination spread, area decontamination, individual sign-in (written

or electronic), written procedures and/or radiological work permits, as appropriate,

designated access routes, etc. These controls should be considered in addition to

those discussed above for lower levels of contamination. Note that these levels

correspond to those levels defining a radiological area as provided in 10 CFR

835.2(a); therefore, specific actions are required to ensure compliance.

If STC contamination levels are very high (e.g., surface contamination levels

exceed ten times the 10 CFR 835 Appendix D values; airborne radioactivity levels

exceed ten times the ACV values), then the most aggressive contamination control

measures should be considered and implemented, consistent with the ALARA

process.

See section 3.2.1.2 for guidance relating to areas containing locations where tritium

is bound tightly to the surface and/or to the matrix below the surface.

6.2.7

Radioactive Material Labeling

Labeling of radioactive items and containers of radioactive material is required

under some circumstances to alert individuals to the radiological hazards

associated with those items or containers. DOE has provided appropriate guidance

for implementing these requirements in G 441.1-10, Posting and Labeling for

Radiological Control Guide, and in the RCS.

The thresholds under which radioactive material labeling is required are provided in

10 CFR 835.605, which requires labeling when the total quantity of radioactive

material exceeds one tenth of the 10 CFR 835 Appendix E values. Appendix E

does not currently provide a specific value for STCs, but does provide a value for

tritium. This value is applicable to radioactive items and containers of radioactive

material containing STCs.

It is often desirable to restrict access to STC-contaminated materials to specified

individuals or workgroups so as to limit the scope of the STC dose assessment

program. If this has been done, labels for STC-contaminated materials should

provide additional information that will allow individuals to identify the material as