U.S. Nuclear Regulatory Commission

Applicability of Access Controls for Spent Fuel Pools

HPPOS-016 PDR-9111210116

Title: Applicability of Access Controls for Spent Fuel

Pools

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