Health Physics Questions and Answers - Question 450

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)