comprehensive hazard analysis. Generally, the availability of typical preventive or
mitigative features, such as the ventilation and filtration system, given the occurrence of a
DBA in DOE's non-reactor nuclear facilities will reduce potential public doses to well
within a small fraction of the EG. Thus, an approach that also uses frequency of release,
even if equally practical, would not generally result in different SSC classifications.
Moreover, requiring frequency-based calculations would result in enlarging the paper
process, thus undermining DOE's emphasis on comprehensive hazard analysis, without
significant payback in safety assurance on the operating floor.
The protection of the public and workers during normal operations is governed by 10 CFR
as considered a part of normal operations would also be governed by this regulation. This
is not to imply, however, that safety SSCs should be identified based on compliance with
10 CFR 835. It is inherent in the hazard analysis process described in this standard that a
comprehensive spectrum of accidents, including those that may have a higher likelihood,
be identified, evaluated, and analyzed. Any accidents that have a significant consequence
potential to the public or workers, independent of likelihood, must be thoroughly
evaluated, including the identification of any appropriate safety SSCs or administrative
Toxicological EGs are not specified. There is no industrial or regulatory precedent for SC
designation of SSCs in facilities or processes with only toxicological hazards. SS
designations, which are based on qualitative guidelines, can be triggered without
distinction from both radiological and toxicological hazards. However, controls for
toxicological releases, which trigger nuc lear accidents or have nuclear impacts, are
potential candidates for SC designation.