Hot Spot Interpretation

HPPOS-210 PDR-9111210371

See the memorandum from L. J. Cunningham to R. R. Bellamy (and others) dated March 8, 1990.

A licensee was cited for failure to provide hot spot tags as required by its internal procedures. Although a licensee can be cited for not following its own procedures, hot spot tags are not required in 10 CFR 20.203 nor are they alternatives to the conspicuous posting of radiation areas as required in the regulations. This health physics position also applies to "new" 10 CFR 20.1902.

A resident inspector cited a licensee against their procedures for failure to provide Hot Spot tags that could be identified from both sides as required by those procedures. In the inspection report, Section 10 CFR 20.203 (b) that requires radiation areas be conspicuously posted, was used as the basis for requiring Hot Spot tags to be identifiable from both sides.

Although, in this case, NRC agrees the licensee can be cited for not complying with their own procedures, NRC does not agree with the rationale in the inspection report. Hot spot tags are not required in 10 CFR 20.203 [or 10 CFR 20.1902] nor are they an acceptable alternative to conspicuous posting of radiation areas as required in the regulations. In addition, there is nothing in 10 CFR Part 20 that requires tags and postings to have the same information on both sides. This citation should not be mistaken as an NRC position on Hot Spot posting.

Resident inspectors are reviewing more health physics issues under the current inspection program than they did under the previous inspection program. A review scheme to ensure that technical positions taken by residents for HP issues are consistent with the regulations and established NRC positions may need to be established.

Regulatory references: 10 CFR 20.203, 10 CFR 20.1902

Subject codes: 4.2, 4.7

Applicability: Reactors