Health Physics Questions and Answers - Question 385
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)