Re: posting requirements

[LIPTONW@detroitedison.com]

You wrote: 
 
Two points are in order. 
 
1.  There is no requirement to post restricted areas.  Just lock the  
door to prevent access to the radioactive material and the area is,  
by definition, a restricted area. 
 
2.  The  CRAM posting is required for the presence of 10x Appendix C  
quantities.  So if I have a researcher using 5 mCi of P-33 (5x  
Appendix C) and I label the door, have I mislead workers and members  
of the public?  If a researcher conducts an experiment once a month  
should the room be posted during the experiment, and unposted after  
the waste is removed?  I don't believe (and I expect that no one out  
there believes) that we should waste our time posting and unposting  
facilities as the activity levels rise above and below the posting  
threshold.  
 
While I agree that using the radiation symbol for non radioactive  
work is "blatantly misleading" and should be discouraged, keep  
in mind that this could be considered an extension of accepted  
practices depending on one's perspective. 
 
 On 30 Apr 98 at 9:42, Boyd H Rose wrote: 
 
>      Misposting an area as a restricted area or non-radioactive 
>      items as radioactive for the unrelated purpose of deterring 
>      theft or vandalism is blatantly misleading and invites mistrust 
>      and suspicion of one's safety program by both workers and 
>      members of the public regardless of the regulator's position. 
>  
>      Additionally, if any of us as safety professionals actually 
>      knows of such a practice and does not challenge the practice, 
>      we would be derelict in our professional responsibilities as 
>      well as in violation of our professional ethics. 
Kent N. Lambert, M.S., CHP 
lambert@auhs.edu 
Allegheny University of the Health Sciences 
Hahnemann Division 
Radiation Physics and Safety, MS 106 
Broad and Vine Streets 
Philadelphia, PA  19102-1192 
 
215-762-8768 (voice) 
215-762-7683 (fax)   
 
The person who originated this string has a good point, in that I can't find 
any specific NRC regulation which prohibits using a radiation symbol when it 
is not required, and I agree with the above response that common sense
should 
prevail.   
 
Some guidance is available in the NRC response to the issue of posting a 
"radiation area"; see IE Information Notice No. 84-82, "Guidance for Posting 
Radiation Areas".  Some nuclear power plants were posting one "radiation
area" 
sign at the entrance to the reactor building, instead of posting the 
individual radiation areas within.  The NRC states, here, that this is 
unacceptable, since it does not meet the intent of the regulation, which is:
 
"to alert personnel to the presence of radiation and to aid them in
minimizing 
exposures."  Most licensees, however post at levels lower than the
regulatory 
levels, to assure compliance.  The same reasoning should apply to posting 
rooms containing licensed material.  I've never heard of a violation for
this 
practice.  However, it is unacceptable to post an area when there is no 
radiological hazard present, to fulfill some other purpose, such as theft 
prevention.  
 
Regarding whether it is necessary to depost and repost rooms with
intermittent 
use of radioactive material, again, common sense should prevail.  If the
room 
is used by one group, which is aware of the status, changing postings may
not 
be necessary.  Maintaining strictly accurate postings may be appropriate, 
however, if there are some individuals who are only allowed to enter the
room 
when no radioactive material is present.  
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com