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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).