U.S. Nuclear Regulatory Commission

Posting of Entrances to a Large Room or Building as a Radiation Area

HPPOS-036 PDR-9111210167

Title: Posting of Entrances to a Large Room or Building as

a Radiation Area

See the letter from J. P. O'Reilly to E. E. Utley (Carolina

Power and Light Company) dated January 27, 1984. The NRC

position is that posting practices for a large room or

building must adequately alert personnel to the presence of

radiation areas such that they may minimize exposures they

receive. Posting only entrances to reactor buildings does

not provide personnel with sufficient information for them

to be able to minimize exposures from the radiation areas

within the reactor building. The health physics position

was written in the context of 10 CFR 20.1, 20.6, 20.202,

and 20.203, but it also applies to the "new" 10 CFR 20 Part

20, Sections 20.1003, 20.1006, 20.1101 and 20.1902.

In a letter dated June 15, 1981, NRC stated that Violation

D of Inspection Report Nos. 50-325 / 80-45 and 50-324 / 80-43,

regarding radiation area posting of reactor buildings was

under review and that a final decision would be issued at a

later date. On October 7, 1981, in a letter to NRR, a

licensee requested a written interpretation of the

requirements set forth in the definition of a radiation

area in 10 CFR 20.202 (b) (2) [or 10 CFR 20.1003] and the

requirements for posting of a radiation area in 10 CFR

20.203 (b) [or 10 CFR 1902 (a)]. That request was

subsequently forwarded to Region II for evaluation and

action. The licensee's request that Violation D be

withdrawn and a request for interpretation were evaluated

by the NRC staff. The NRC position is that posting

practices must adequately alert personnel to the presence

of radiation areas such that they may minimize exposures.

The practice of posting only the entrances to a reactor

building does not provide personnel with sufficient

information for them to be able to minimize exposures from

the radiation areas within the reactor building.

The intent of 10 CFR 20.202 (b) (2) and 20.203 (b) [or 10

CFR 20.1003 and 20.1902 (a), respectively] is to alert

personnel to the presence of radiation and to aid them in

minimizing exposures. NRC realizes that circumstances of

each case must be evaluated to assure that posting

practices do not detract from this intent by: (1)

desensitizing personnel through over-posting, or (2)

failing to sufficiently alert personnel to the presence and

location of radiation areas. Thus, radiation area postings

should warn individuals in the vicinity of radiation areas

of specific radiological conditions in their immediate

vicinity. By the same token, it is also considered outside

of the regulations and counter-productive if substantial

areas which are not radiation areas are posted as such.

Since the regulations do not provide implementing details

such as whether a room or building containing a radiation

area may be posted at the entrance or whether every

discrete radiation area must be posted, the following is

used as guidance: Posting the entrances to a very large

room or building is inappropriate if most of the area is

not a radiation area and only discrete areas or individual

rooms actually meet the criteria for a radiation area. If

discrete areas or rooms within a large area or building can

be reasonably posted to alert individuals to radiation

areas, these discrete areas or rooms should be posted

individually.

The interpretation is the official NRC staff position, but

as such, is not binding on the Commission. Such binding

interpretations can only be issued by the Office of the

General Counsel pursuant to 10 CFR 20.6 [or 10 CFR

20.1006]. The office of the General Counsel normally refers

technical matters such as this issue to the NRC staff for

resolution. The licensee's letter of October 7, 1981,

enumerated six reasons for posting the entrances to

buildings as radiation areas instead of discrete areas

within the buildings. None of the reasons were sufficient

individually or collectively to effectively aid workers in

minimizing their exposure. They do not provide a

substitute for the information or worker awareness provided

by a posted sign that identifies the presence and

approximate boundary of specific radiation areas and do not

support ALARA as discussed in 10 CFR 20.1 (c) [or 10 CFR

20.1101 (b)]. NRC continues to maintain that most of the

area within the reactor building fails to meet the criteria

for a radiation area. Consequently, posting just the

entrances to the reactor building does not meet the intent

of the regulations.

Regulatory references: 10 CFR 20.202, 10 CFR 20.203, 10

CFR 20.1003, 10 CFR 20.1902

Subject codes: 4.2, 4.7

Applicability: All