U.S. Nuclear Regulatory Commission

Access Controls for Spent Fuel Storage Pools

HPPOS-245 PDR-9111220092

Title: Access Controls for Spent Fuel Storage Pools

See the memorandum from L. J. Cunningham to J. H. Joyner

dated November 9, 1990. This memo provides guidance

concerning the "establishment of locked high radiation

areas." Radioactive materials that could result in dose

rates greater than 1000 mrem/hr are stored under water in a

spent fuel storage (SFS) pool. These radioactive materials

are sometimes contained in buckets hung from railings

around the SFS pool. It is assumed that when the materials

are stored in the pool, the dose rates above the pool in

the vicinity of the stored materials are less than 100

mrem/hr. The health physics position was written in the

context of 10 CFR 20.203, but it also applies to "new" 10

CFR 20.1601. HPPOS-106 contains a related topic.

HPPOS-016 states that because of the inaccessibility to

personnel of the area in which radioactive materials are

stored (under water), SFS pools are not considered to be

high radiation areas and therefore the requirements of 10

CFR 20.203 (c) (2) [or 10 CFR 20.1601 (a)] do not apply.

HPPOS-016 also states that when a diver enters the pool or

upon movement of highly radioactive materials stored in the

pool, proper health physics controls must be instituted.

Movement of radioactive material stored in the pool has the

potential to create a high radiation area around the pool;

however, a high radiation area is not created until

movement of the material actually results in a radiation

level, in an area that is accessible to personnel, that

could result in a dose in excess of 100 mrem in any one

hour. Therefore, the relative accessibility of radioactive

material stored in buckets hung from railings around the

pool is not applicable to the requirements of 10 CFR 20.203

(c) (2) [or 10 CFR 20.1601 (a)].

IE Information Notice 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 SFS pools. The suggestions

include: "Measures to ensure that highly radioactive

objects stored under water at one end of a line whose other

end is secured above the surface of the pool are not

unexpectedly pulled to the surface." Such measures may

include locking mechanisms that prevent inadvertent and

unauthorized withdrawal of such sources. This practice is

not a regulatory requirement; however, the requirements for

"Instructions to Workers" in 10 CFR 19.12 are applicable.

Workers in SFS pool areas must "be kept informed of the

storage, transfer, or use of radioactive materials" stored

in the pool and must be instructed in "precautions or

procedures to minimize exposure" that may result from this

method of storage. Appropriate formal training and posting

of signs that warn of the hazards of source withdrawal are

among the ways to meet this requirement.

Regulatory references: 10 CFR 19.12, 10 CFR 20.203, 10 CFR

20.1601

Subject codes: 4.1

Applicability: Reactors