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Re:"Container" definition



Not to be factious, but...

In my experience, the definition of container is most dependent upon your
regulatory "environment."

If you work at a "flagship" site, then container means most logical items such
as boxes, bags, bottles, buckets, etc.

However, if you've ever had the pleasure of working at a NRC Watch-List site,
then container (for enforcement purposes) can mean just about anything
imaginable, such as: mobile carts, certain tables, drawers, shelves, or anything
that resembles a "bin."

On a similar note: A major limitation to 10CFR20 is that there exists no
labeling exception for items or containers of radioactive material used,
handled, or stored in rad areas appropriately posted and controlled.  10CFR835
(DOE) has such an exception, and subsequently, items/containers in a radioactive
material area or a contamination area do not necessarily require a rad label
(provided no addition exposure risks beyond the area postings).

Rodney Bauman, CHP, RRPT
rodney_bauman@wssrap-host.wssrap.com


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