Paint the information on the casks. I would post them, not label them.
From: [email protected] [mailto:[email protected]] On Behalf Of Creamer, Charles E Sent: Thursday, September 18, 2014 7:37 AM To: '[email protected]' Subject: Powernet: Dry Cask HI-STORM Rad Tagging? *** This is an EXTERNAL email. Exercise caution. DO NOT open attachments or click links from unknown senders or unexpected email. *** Site Management is wanting to remove the tags due to the weathering of them and the more casks we get, the harder it becomes to maintain all of the labels Currently the TVA sites label these due to the 10CFR20.1904 requirements on labeling containers. To me the question comes down to whether these are containers or a separate licensed entity. Below is what section 20.1904 and 20 1905 state. § 20.1904 Labeling containers. (a) The licensee shall ensure that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words "CAUTION, RADIOACTIVE MATERIAL" or "DANGER, RADIOACTIVE MATERIAL." The label must also provide sufficient information (such as the radionuclide(s) present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of materials, and mass enrichment) to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposures. (b) Each licensee shall, prior to removal or disposal of empty uncontaminated containers to unrestricted areas, remove or deface the radioactive material label or otherwise clearly indicate that the container no longer contains radioactive materials. § 20.1905 Exemptions to labeling requirements. A licensee is not required to label- (a) Containers holding licensed material in quantities less than the quantities listed in appendix C to part 20; or (b) Containers holding licensed material in concentrations less than those specified in table 3 of appendix B to part 20; or (c) Containers attended by an individual who takes the precautions necessary to prevent the exposure of individuals in excess of the limits established by this part; or (d) Containers when they are in transport and packaged and labeled in accordance with the regulations of the Department of Transportation,3<http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1905.html#N_1_201905> or (e) Containers that are accessible only to individuals authorized to handle or use them, or to work in the vicinity of the containers, if the contents are identified to these individuals by a readily available written record (examples of containers of this type are containers in locations such as water-filled canals, storage vaults, or hot cells). The record must be retained as long as the containers are in use for the purpose indicated on the record; or (f) Installed manufacturing or process equipment, such as reactor components, piping, and tanks; or (g) Containers holding licensed material (other than sealed sources that are either specifically or generally licensed) at a facility licensed under Parts 50 or 52 of this chapter, not including non-power reactors, that are within an area posted under the requirements in § 20.1902 if the containers are: (1) Conspicuously marked (such as by providing a system of color coding of containers) commensurate with the radiological hazard; (2) Accessible only to individuals who have sufficient instruction to minimize radiation exposure while handling or working in the vicinity of the containers; and (3) Subject to plant procedures to ensure they are appropriately labeled, as specified at § 20.1904 before being removed from the posted area. If your station is utilizing Dry cask fuel storage, do you label Hi-Storms that are stored on the ISFSI pad in accordance with 20.1904 or the exemption in 20.1905? If not, how do you justify not labeling them and what controls would you use? If so, what do you used to label them that holds up to the weather? Chuck Creamer Charles E. Creamer Health Physicist Tennessee Valley Authority Browns Ferry Nuclear Plant P.O. Box 2000 (Mail Stop NAB-1G-BFN) Decatur, Al. 35609-2000 Phone: 256-729-2983 Fax: 256-729-3101 Pager: 1-800-323-4853, pin 30-053 mailto:[email protected] REMEMBER - You don't know what you don't know This electronic message transmission contains information which may be TVA SENSITIVE, TVA RESTRICTED or TVA CONFIDENTIAL. Any misuse or unauthorized disclosure can result in both civil and criminal penalties. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify me immediately by email and delete the original message.
