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 |  DOE-STD -3009-94 Appendix A 10-7 per year, realistically calculated. Unmitigated release is meant to consider material quantity, form, location, dispersability, and interaction with available energy sources, but not to consider safety features (e.g., ventilation systems, fire suppression, etc.) which would prevent or mitigate a release. Final dose estimations representing the anticipated behavior of the facility under accident conditions should be based on the mitigated design basis accidents (DBAs), wherein full or partial functionality of SC SSCs is assumed. In cases where the designated SC SSC are not capable of performing their required safety function without significant upgrade (i.e., backfit) other compensatory measures such as material-at-risk (MAR) limits may be implemented in the facility and incorporated into the DSA. Comparison of the unmitigated consequences for a limited subset of potential accidents to the EG is performed to determine if the need for designation of SC SSCs exists. If the EG value is approached by the unmitigated consequences of a release scenario, a need for SC SSC designation is indicated. SC SSCs are only one of many layers of hardware- and administrative-based controls that are incorporated into a DOE operation for the protection of the public, worker, and environment consistent with the precepts of the defense- in-depth philosophy. The SC designation merely helps to focus a higher level of attention and requirements on this select subset of all controls intended for the protection of the public. If the need for SC designation is determined, all preventive and mitigative features associated with the sequence of failures that result in a given release scenario, as well as any features whose functionality is assumed a s part of the scenario definition itself are candidates for SC SSC designation. The process of designating one or more safety SSCs as SC is judgment-based and depends on many factors such as effectiveness, a general preference of preventive over mitigative and passive over active, relative reliability, and cost considerations. A.3 DOSE COMPARISON CALCULATIONS General discussion is provided for source term calculation and dose estimation, as well as prescriptive guidance for the latter. The intent is that calculations be based on reasonably conservative estimates of the various input parameters. The dose estimate is that received during a 2- hour (with the exception mentioned earlier) exposure to plume, as discussed in section A.3.3, considering inhalation, direct shine, and ground shine. Other slow developing release pathways, such as ingestion of contaminated food, water supply contamination, or resuspension are not included. However, quick release accidents involving other pathways, such as a major tank rupture, which could release large amounts of radioactivity in liquid form to water pathways, should be considered. In this case, real potential uptake locations should be the evaluation points. The airborne pathway is of primary interest for nonreactor nuclear facilities. This position is supported by NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licenses," which states that "for all materials of greatest interest for fuel cycle and other radio active material licenses, the dose from the inhalation pathway will dominate the (overall) dose." For some types of facilities such as waste storage, the surface and groundwater pathways may be more important, but accident releases usually would be expected to develop more slowly than airborne releases. More Page A-3 | 
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