NRC: Health Physics Questions and Answers - Question 66
Question 66: This question concerns restricted area limitations. At some sites for nuclear power plants the restricted area has been defined as the site boundary. In some areas routine public access was available with the understanding that, should the need arise, public use of these areas could be prohibited. Examples of this type of access include fishing, visitor centers, and farming. This type of use now appears to fall within the intent of the definition of controlled area and therefore, a new restricted area boundary located somewhat nearer the plant must be defined, in places where such uses exist.
The next physical boundary is a single fenced area, roughly corresponding to the security definition of owner controlled area. Station parking is routinely within this area and access is provided through openings in the single fence which are not continuously guarded. These openings are posted, "No Trespassing." The direct questions involved are:
a. Can this area (single fenced area) qualify as the restricted area boundary?
b. If so, are postings sufficient or would guards be required?
c. If posting is sufficient, what is the acceptable wording?
a. Yes, access to this area could be limited so as to meet the definition of a restricted area. However, it should be recognized that the dose received by an individual in a restricted area is an occupational dose that is subject to the occupational dose limits in Subpart C of the revised Part 20 (or to the occupational dose limits of 10 CFR 20.101 in the old Part 20) and the requirements in 10 CFR 19.12 on instructions to workers. (See definitions of "restricted area" and "occupational dose.")
b. Although neither posting nor guards are required specifically, access to a restricted area must, by definition, be controlled. In the situation described in the question, access control could be accomplished by posting or use of guards
c. Since posting is not specifically required (see b. above), the wording is left to the discretion of the licensee. NOTE: This answer also applies to research and test reactors, fuel fabrication plants, and major radioactive materials processors insofar as the conditions described in the question for nuclear power plants apply to these other facilities.
(References: 10 CFR 20.1003, 10 CFR 20.1201, 10 CFR 20.1206, 10 CFR 20.1207, 10 CFR 20.1208, 10 CFR 19.12)