Question 77: Representatives of the nuclear power industry
are concerned that the additional terms provided in the
revised rule to describe the "real estate" in and around
commercial power plants seems to be overlapping. This
could lead to confusion. Access to these various areas may
also affect the category to which individuals working
within these areas are assigned. At nuclear power plants,
either the "protected area" or "radiation controlled area"
may serve as the "restricted area." Although workers
granted unescorted access entering the "protected area" may
not be directly monitored for radiation exposure, they must
be considered as "occupationally exposed." At least
minimal "radiation worker" training is required for these
workers consistent with the regulations. "Controlled
areas" would typically extend to the "site boundary" or
"owner controlled area." Does the NRC staff have any
comments on this matter?
Answer: Each licensee should carefully document how the
licensees local "area" terms correspond to the area terms
in 10 CFR Part 20 (restricted, controlled, and unrestricted
areas). Under both old and revised Part 20, anyone who
enters a restricted area is subject to the occupational
dose limits and must receive appropriate instructions in
accordance with 10 CFR 19.12. Workers can also be
occupationally exposed (and, therefore, subject to the
occupational dose limits) in controlled and unrestricted
areas (i.e., areas outside restricted areas) depending (in
accordance with the definition of "occupational dose") on
the nature of the work they are doing and regardless of the
area they are in outside a "restricted area." (References:
10 CFR 20.1003, 10 CFR 20.1201).