United States Nuclear Regulatory Commission - Protecting People and the Environment

Applicability of Access Controls for Spent Fuel Pools

HPPOS-016 PDR-9111210116

See the memorandum from L. B. Higginbotham to A. B. Davis dated July 9, 1980. Spent fuel pool areas are not high radiation areas due to the inaccessibility of highly radioactive materials stored in the pool. If a diver enters the pool or upon movement of highly radioactive materials stored in the pool, then proper health physics controls must be instituted. The health physics position was written in the context of 10 CFR 20.203, but it also applies to "new" 10 CFR 20.1601.

A review was made of the applicability of 10 CFR 20.203 (c) (2) [or 10 CFR 20.1601 (a)] to spent fuel pools. Materials in spent fuel pools that could cause an individual to receive a dose equivalent to the total body in excess of 100 mrem in one hour are normally ten or more feet below the surface of the pool. Under these conditions, spent fuel-pool areas are not high radiation areas due to their inaccessibility to personnel performing "above pool-surface duties", and therefore, the requirements of 10 CFR 20.203 (c) (2) [or 10 CFR 20.1601 (a)] do not apply.

However, when a diver enters the pool to perform "under pool-surface duties" or upon movement of highly radioactive materials stored in the pool, proper health physics controls must be instituted. See IE Information Notice No. 83-31 dated July 28, 1982 (HPPOS-002).

Regulatory references: 10 CFR 20.203, 10 CFR 20.1601, Regulatory Guide 8.38, Technical Specifications

Subject codes: 4.1

Applicability: Reactors

Page Last Reviewed/Updated Thursday, June 04, 2015