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          About NRC  Radiation Protection  How the NRC Protects You  Health Physics Positions Based on 10 CFR Part 20Health Physics Questions and Answers - Question 447

**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) 
      
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