United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 385: Do licensees have discretion regarding the

form and applicability of additional posting and barriers

for individual high radiation areas (HRAs) that are located

within a larger area posted and barricaded (e.g., with a

locked door) as an HRA or inside a posted HRA control

point? If licensees must post and barricade such

individual HRAs at each area's entrance, then "double

posting" results. Double posting has long been a concern

due to the confusion that it might create for workers. The

need to clearly identify to workers areas with high

radiation levels might be accomplished through posted

survey maps, "hot spot" stickers, or other means. In

addition to effectively accomplishing the need for

notifying workers of high radiation areas, these methods

may be preferable to posting and barricading each HRA,

located as described above, due to potential dose savings

that could result from fewer entries into the area solely

for the purpose of verifying the secondary postings and

barriers. This question is intended to establish

flexibility in implementation, appropriate to the

circumstances, to maintain control over access and inform

workers in an effective and efficient manner.



Answer: Power reactor licensee discretion and flexibility

with respect to posting and barriers for high radiation

areas is the same under revised Part 20 and applicable

Technical Specifications as it has been under old Part 20

and applicable Technical Specifications. Existing guidance

on control and posting of high radiation areas is contained

in the Health Physics Positions HPPOS) Data Base

(NUREG / CR-5569). The particular question of individual

HRAs that are located within a larger posted and barricaded

HRA or inside a posted HRA control point is addressed in

the documents identified as HPPOS-014 and HPPOS-066 in

NUREG / CR-5569. HPPOS-066 is IE Information Notice No.

84-82, "Guidance for Posting Radiation Areas," dated

November 19, 1985. Other related guidance is contained in

HPPOS-036, HPPOS-234, HPPOS-242, and HPPOS-210. This

guidance will continue to be applicable under the revised

Part 20. Regulatory Guide 8.38 also contains guidance on

this subject for nuclear power plants. For most material

licensees, posting and access control requirements

contained in 10 CFR Parts 20, 34, 35, and 36 should be

adequate. More detailed information and requirements would

be contained in individual licenses and license

applications. (References: 10 CFR 20.1601, 10 CFR

20.1902).









Page Last Reviewed/Updated Thursday, March 29, 2012