Question 447: Is the spent fuel pool, when containing
irradiated fuel, required to be posted and controlled as a
Very High Radiation Area under any of the following
circumstances:
a. When there are no activities underway involving the
spent fuel pool?
b. When underwater manipulation of irradiated fuel or
other irradiated hardware is underway?
c. When diving operations in the spent fuel pool are
underway?
d. Are there other considerations that could affect
requirements for posting and controlling access to the
spent fuel pool?
Answer:
(a) No.
(b) No.
(c) The answer depends on the particular circumstances of
the diving operations. See discussion under (d) below.
(d) See Health Physics Position documents HPPOS-016 and
HPPOS-245 (NUREG / CR-5569) for additional information
concerning access controls for spent fuel pools and
HPPOS-002 for additional information concerning diving
operations in a spent fuel pool. These position documents
refer to 10 CFR 20.203 (c) of Part 20 prior to the 1991
revision with respect to posting and control of high
radiation areas; however, these positions continue to be
applicable with respect to posting and control of both high
and very high radiation areas under 10 CFR 20.1601, 10 CFR
20.1602, and 20.1902 (b) and (c) of the revised Part 20.
These position documents emphasize that 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 initiated. IE
Information Notice No. 90-33, dated May 9, 1990, provides
suggestions for radiological control considerations that
can help minimize the possibility of unexpected exposure
from radiation sources in spent fuel pools. (References:
10 CFR 20.1602, 10 CFR 20.1902, 10 CFR 20.1003).