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).