U.S. Nuclear Regulatory Commission
Access Control to High Radiation Areas at Nuclear Power Plants
HPPOS-234 PDR-9111210345
Title: Access Control to High Radiation Areas at Nuclear
Power Plants
See the memorandum from L. J. Cunningham to J. H. Joyner
(and others) dated August 2, 1991. A step-off pad (SOP) at
the access point to a high radiation area does not
constitute a barricade as required by Technical
Specifications. The health physics position was written in
the context of 10 CFR 20.203, but it also applies to "new"
10 CFR 20.1601.
Most Technical Specifications, in Section 6.12, "High
Radiation Area," require that each area in which the dose
rate is between 100 and 1000 mrem/hr be "barricaded and
conspicuously posted as a high radiation area ...." A
Region I licensee instituted a policy in which the
"barricade" consists of a SOP at the access to the high
radiation area. The area is roped off and posted but the
entry at the SOP is not roped off. The licensee maintained
that the SOP satisfies the barricading requirement in
Technical Specifications. This policy is used only in
situations where the area is a contamination area as well
as a high radiation area.
Technical Specifications with this barricade and posting
requirement provide a method for control of high radiation
areas that is an alternative to the method specified in 10
CFR 20.203 (c) (2) [or 10 CFR 20.1601 (a)]. Although not
explicitly stated, these controls are designed to prevent
inadvertent entry into the area. Controls specified in
Technical Specifications are intended to achieve the same
basic aim, namely prevention of inadvertent entry, but in a
different manner from that specified in Part 20. The
difference is to allow for the different nature of the
sources at nuclear power plants as well as the different
administrative controls and training found at such
facilities.
Inadvertent entry is interpreted in this context to mean
entry by an individual who is not paying sufficient
attention to postings and who may walk into the high
radiation area unless his or her attention is drawn to
these postings. The assumption is that if an individual's
attention is drawn to the postings, that individual will
recognize their implications and take appropriate action.
A barricade is one mechanism to accomplish this purpose.
The dictionary defines a barricade as "any barrier that
obstructs passage." A SOP is not a barrier to movement
into the area and therefore does not qualify as a barricade
required by Technical Specifications. Implicit in the
requirement for the barricade is that the barricade can be
partially taken down for periods of access. This is
acceptable as long as the access point is attended by an
individual who will prevent inadvertent / authorized access
to the high radiation area.
Regulatory references: 10 CFR 20.203, 10 CFR 20.1601,
Technical Specifications
Subject codes: 4.1, 4.7
Applicability: Reactors
