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