Section III - Discussion III. DISCUSSION A. General As with any hazard communication program, it is important to identify and effectively communicate radiological hazards to individuals. A uniform system of radiation protection posting and labeling for radiological control is essential. The posting and labeling program is implemented to ensure that radiological hazards are adequately controlled in the workplace, thereby protecting the health and safety of workers, the public, and the environment. Both 10 CFR 835 and the RCM require that certain areas and items be posted or labeled for control of personnel exposure to radioactive material and ionizing radiation. Other DOE Orders, such as DOE Order 5480.4, "Environmental Protection, Safety, and Health Protection Standards" (DOE, 1984), invoke mandatory industry standards or other federal agency regulations that contain requirements for radiological control posting and labeling. Policies and requirements for the posting of radiological hazards should be described in formal procedures. The following sections describe the basic posting and labeling requirements applicable to DOE and its contractors' operations. B. Controlled Area Any area where access is managed to protect personnel from exposure to radioactive material or radiation fields "shall" be posted as a Controlled Area (10 CFR 835.602(a)). The requirements for posting Controlled Areas are based upon protecting individuals from inadvertent exposure to radioactive material or ionizing radiation fields in quantities that could exceed the dose equivalent limits for a member of the public (10 CFR 835.208). C. Radiological Buffer Area A Radiological Buffer Area shall be established within a Controlled Area to provide a secondary boundary to control the spread of radioactive material contamination (RCM 233). Posting of the Radiological Buffer Area also provides a mechanism to control the exposure of personnel to external radiation. The requirements for posting Radiological Buffer Areas are based upon protecting individuals who do not have radiological worker training from inadvertent exposure to radioactive material or ionizing radiation fields in quantities that require such training. D. Posting for Control of Exposure to External Radiation Radiation Areas "shall" be posted (10 CFR 835.603(a) and RCM 234.1). The posting of Radiation Areas is part of the system to maintain personnel exposures to levels that are as low as reasonably achievable (ALARA). High Radiation Areas "shall" be posted (10 CFR 835.603(b) and RCM 234.1). This intermediate level area designation indicates when rigid physical and administrative access controls are necessary to maintain personnel exposures ALARA. Very High Radiation Areas "shall" be posted (10 CFR 835.603(c) and RCM 234.1). This is the most stringent area designation for controlling personnel exposure to ionizing radiation. Posting and stringent physical and administrative access controls for these areas are required because of the real potential for individuals to exceed the dose limit in a very short time. In recognition of the fact that dose rates and the size of a source may vary significantly within posted Radiation and High Radiation Areas, Hot Spots shall be posted (RCM 234.1) to specifically identify to the worker the significant localized sources of radiation. This provides the worker the knowledge and opportunity to take appropriate actions to minimize exposure. Installed temporary shielding should be clearly marked or labeled to prevent its inadvertent removal or modification (RCM 314.5). Because the most minor adjustment or modification of temporary shielding can greatly increase radiation levels, all movements of temporary shielding should be strictly controlled. E. Posting for Control of Contamination Contamination and High Contamination Areas "shall" be posted (10 CFR 835.603(e & f) and RCM 235.1). Posting these areas is an important part of controlling the spread of unconfined radioactive material and managing personnel exposures to levels that are ALARA. Because of the potential for individuals to receive extremely high localized doses, areas where hot particles are or are likely to be present need to be identified to allow for individual exposures to be managed to levels that are ALARA. The presence of hot particles should be identified as part of the posting of a Contamination or High Contamination Area (RCM 348.4). Hot particles can deliver high localized doses and may not be detected during normal personal monitoring at exit areas. Controlling personnel exposure to radioactive material to levels that are ALARA requires the posting of areas with airborne radioactive material in concentrations approaching established limiting values. Airborne Radioactivity Areas "shall" be posted (10 CFR 835.603(d) and RCM 235.1). Areas of fixed radioactive material contamination that are located outside areas controlled for removable contamination need to be identified. The posting of these areas is required to prevent the inadvertent removal or spread of radioactive material and to limit any subsequent exposures to personnel. Outdoor areas where radioactive material contamination exists in a matrix, such as soil, need to be identified as part of the program to manage the exposure of workers and the public to levels that are ALARA (RCM 235.1). Areas identified as having underground items containing radioactive material, and which have not been released for unrestricted use, shall be posted as Under- ground Radioactive Material Areas (RCM 237.1). The identification of underground radioactive material is necessary to prevent the inadvertent excavation of buried radioactive material. F. Radioactive Material Areas and Radioactive Material Radioactive material located outside of Contamination, High Contamination, or Airborne Radioactivity Areas should be stored in locations posted as Radioactive Material Areas (RCM 236 and 414). The use of designated storage locations minimizes the potential for the loss of radiological control of radioactive material. When located outside of Contamination, High Contamination, or Airborne Radioactivity Areas, radioactive material shall be labeled (RCM 412.1). The requirements for labeling radioactive material are designed to control radioactive material and to limit personnel exposure to ionizing radiation to levels that are ALARA. Protective clothing designated for radiological use shall be identified by color, symbol, or appropriate labeling (RCM 461.1). The control of protective clothing is necessary to ensure that positive radioactive material and contamination controls are maintained.