From Callaway

1, yes.  "Non-exempt" by you definition is "Accountable".  "Exempt" by your 
definition is "Custodial".

2.  Mostly the 10CFR30 tables. We have some specific commitments on Licensable 
Quantities, however some other factors such as Generally Licensed or some State 
Regulations make a source Accountable.

3. Accountable sources are inventoried semiannually, and are required to have 
10CFR20.1904 labeling. Custodial sources are inventoried annually and require 
radioactive material labeling. Accountable sources must be locked or guarded 
outside the Protected Area. Both types must be stored as designed (normally in 
a locked and labeled Source Locker when not in use.

Questions or comments call or email Dewey at Callaway.

314-225-1061
Dewey

Sent from my iPhone

On Mar 20, 2014, at 3:32 PM, "Sutton, Craig" 
<[email protected]<mailto:[email protected]>> wrote:

EXTERNAL SENDER. Do not click on links or open attachments that are not 
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________________________________

DCPP would like to know the following regarding non-exempt radioactive sources 
at your site:



 1.  Does your site make a distinction procedurally or physically, (such as a 
different marking), between exempt and non-exempt radioactive sources?



 1.  If so, what limit do you use as the basis for identifying a source as 
non-exempt?
 (i.e., 10 CFR 30.70/71, 10 CFR 20 Appendix C, etc.)



 1.  If so, what is the distinction used (marking, location, procedural 
controls, etc.)?




Respectfully,
Craig D. Sutton
Radioactive Materials Engineer
Pacific Gas & Electric Company
Diablo Canyon Power Plant
MS 104/2/216
PO Box 56
Avila Beach, CA 93424

P: 805.545.4208 | C: 805.748.0603 | [email protected]<mailto:[email protected]>


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