Health Physics Questions and Answers - Question 77
Question 77: Representatives of the nuclear power industry are concerned that the additional terms provided in the revised rule to describe the "real estate" in and around commercial power plants seems to be overlapping. This could lead to confusion. Access to these various areas may also affect the category to which individuals working within these areas are assigned. At nuclear power plants, either the "protected area" or "radiation controlled area" may serve as the "restricted area." Although workers granted unescorted access entering the "protected area" may not be directly monitored for radiation exposure, they must be considered as "occupationally exposed." At least minimal "radiation worker" training is required for these workers consistent with the regulations. "Controlled areas" would typically extend to the "site boundary" or "owner controlled area." Does the NRC staff have any comments on this matter?
Answer: Each licensee should carefully document how the licensees local "area" terms correspond to the area terms in 10 CFR Part 20 (restricted, controlled, and unrestricted areas). Under both old and revised Part 20, anyone who enters a restricted area is subject to the occupational dose limits and must receive appropriate instructions in accordance with 10 CFR 19.12. Workers can also be occupationally exposed (and, therefore, subject to the occupational dose limits) in controlled and unrestricted areas (i.e., areas outside restricted areas) depending (in accordance with the definition of "occupational dose") on the nature of the work they are doing and regardless of the area they are in outside a "restricted area."
(References: 10 CFR 20.1003, 10 CFR 20.1201).