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 �.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 �.1801 and �.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).