Health Physics Questions and Answers - Question 448
Question 448: If irradiated hardware, suspended (e.g., on a lanyard) in the spent fuel pool, is potentially reading greater than 500 rads/hour at one meter (i.e., if it were removed from the pool), does access to this hardware require posting and control as a Very High Radiation Area?
Answer: No. See Section 4.2, "Materials," in Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants." Also see Health Physics Position document HPPOS-245 (NUREG / CR-5569). Although this position document was written to address access controls for spent fuel pool storage pools under the unrevised Part 20 requirements for high radiation areas, it also applies to these access controls under the revised Part 20 requirements for both high and very high radiation areas. The essential point is that although movement of radioactive material stored in the pool has the potential to create a high, or very high, radiation area around the pool, those areas are not created until movement of the material actually results in a radiation level, in an area that is accessible to individuals, that meets the dose criterion in the definitions of a high, or a very high, radiation area. NRC Information Notice No. 90-33, dated May 9, 1990, is also relevant. After providing reviews of a number of events in which sources of unexpected occupational radiation exposures were encountered in activities associated with spent fuel storage pools, this notice provides suggestions (which are not regulatory requirements) for radiological control considerations that can help minimize the possibility of unexpected exposures from radiation sources in these pools.
(References: 10 CFR 20.1602, 10 CFR 20.1601, 10 CFR 20.1003)