United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 450: Licensees are required to "secure from

unauthorized removal or access" licensed materials in

storage, and to "control and maintain constant

surveillance" of licensed materials not in storage, in

controlled or unrestricted areas. The following questions

relate to the security and control of licensed materials in

controlled areas only, i.e., the questions are not intended

to address unrestricted areas:



a. Would the provisions for security and control be met if

the licensed materials are appropriately labeled or marked

(e.g., in accordance with §20.1904) and are located within

an area to which access is controlled through the use of

barrier ropes and signs restricting access by unauthorized

personnel?



b. Would the provisions for security and control be met if

the licensed materials were located in an area as described

in "a", above, that was located within a Part 50 licensee

security protected area?



c. If the area described in "a", above, was posted with

radiological caution signs (e.g., "Caution, Radiation

Area"), would such an area actually be a restricted area,

and therefore the provisions of §20.1801 and §20.1802 would

not apply?

Answer:

(a) No. To secure the material from unauthorized removal

means to make certain, to guarantee, and to ensure that

there is no unauthorized removal of the material. Using

nothing but ropes and signs to control access to the

licensed materials does not secure stored material from

unauthorized removal in accordance with 10 CFR 20.1801 and

does not "maintain constant surveillance" of the material

in accordance with 10 CFR 20.1802.



(b) No. This use of barrier ropes and signs within a

Part 50 licensee security protected area does not

necessarily secure the licensed material from unauthorized

removal from that area (in accordance with 10 CFR 20.1801

for stored material) and does not provide the constant

surveillance of the material (in accordance with 10 CFR

20.1802 for material that is not in storage). Individuals

who are authorized to enter the security protected area are

not necessarily authorized to remove the licensed material

and, as indicated in the answer to (a), above, this use of

ropes and barriers does not secure the material from

unauthorized use.



c) No, not necessarily. Simply posting the area

described in part (a) of the question with a "radiological

caution sign", such as "Caution, Radiation Area," does not,

in the absence of other measures for access control, result

in the creation of a "restricted area" and, thereby, make

the provisions of 10 CFR 20.1801 and 20.1802 inapplicable.

However, the provisions of 10 CFR 20.1801 and 20.1802 would

not apply to the area described in part (a), above, if that

area is contained within a radiation area within a

restricted area, access to which is adequately controlled.

(References: 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR

20.1003, 10 CFR 20.1904).

Page Last Reviewed/Updated Thursday, March 29, 2012