Question 66: This question concerns restricted area
limitations. At some sites for nuclear power plants the
restricted area has been defined as the site boundary. In
some areas routine public access was available with the
understanding that, should the need arise, public use of
these areas could be prohibited. Examples of this type of
access include fishing, visitor centers, and farming. This
type of use now appears to fall within the intent of the
definition of controlled area and therefore, a new
restricted area boundary located somewhat nearer the plant
must be defined, in places where such uses exist.
The next physical boundary is a single fenced area, roughly
corresponding to the security definition of owner
controlled area. Station parking is routinely within this
area and access is provided through openings in the single
fence which are not continuously guarded. These openings
are posted, "No Trespassing." The direct questions
involved are:
a. Can this area (single fenced area) qualify as the
restricted area boundary?
b. If so, are postings sufficient or would guards be
required?
c. If posting is sufficient, what is the acceptable
wording?
Answer:
a. Yes, access to this area could be limited so as to meet
the definition of a restricted area. However, it should be
recognized that the dose received by an individual in a
restricted area is an occupational dose that is subject to
the occupational dose limits in Subpart C of the revised
Part 20 (or to the occupational dose limits of 10 CFR
20.101 in the old Part 20) and the requirements in 10 CFR
19.12 on instructions to workers. (See definitions of
"restricted area" and "occupational dose.")
b. Although neither posting nor guards are required
specifically, access to a restricted area must, by
definition, be controlled. In the situation described in
the question, access control could be accomplished by
posting or use of guards
c. Since posting is not specifically required (see b.
above), the wording is left to the discretion of the
licensee.
NOTE: This answer also applies to research and test
reactors, fuel fabrication plants, and major radioactive
materials processors insofar as the conditions described in
the question for nuclear power plants apply to these other
facilities. (References: 10 CFR 20.1003, 10 CFR 20.1201,
10 CFR 20.1206, 10 CFR 20.1207, 10 CFR 20.1208, 10 CFR
19.12)