Attachment 1 Hazard Categorization of DOE Facilities

DOE-STD-1027-92

ATTACHMENT 1

HAZARD CATEGORIZATION OF DOE FACILITIES

The hazard categorization approach and criteria outlined below can be consistently applied

to all DOE nuclear facilities. It is based on a simple approach which is intended to meet

DOE Order 5480.23 requirements for a preliminary assessment and hazard categorization.

This approach is also intended to supplement the graded approach as discussed in

Section 4 of the guidance document. An interpretation of the Hazard Categories discussed

in the Order with detailed groundrules for each category, is given below.

General Groundrules

Facility Segmentation

In facility categorization, flexibility must be allowed in the definition of facility segments.

Many DOE facilities conduct a wide variety of activities in one facility, ranging from simple

assay or lab experiments to complex fluid flow separations. It is necessary to avoid placing

excessive requirements on simple or even trivial co-located operations. The concept of

independent facility segments should be applied where facility features preclude bringing

material together or causing harmful interaction from a common severe phenomenon.

It should be noted that DOE 5480.23 states that an analysis and categorization is to be

performed on "processes, operations, or activities" and not necessarily whole facilities. For

the purposes of hazard categorization and estimating hazardous material inventory, the

objective is to understand the available hazards that could interact and cause harm to

individuals or the environment. It is not desirable to estimate the potential consequences

from an inventory of hazardous materials when facility features would preclude bringing this

material together. Therefore, the standard permits the concept of facility segmentation

provided the hazardous material in one segment could not interact with hazardous materials

in other segments. For example, independence of HVAC and piping must exist in order to

demonstrate independence for facility segmentation purposes. This independence must be

demonstrated and places the "burden of proof" on the analyst.

Treatment of Sealed Sources, Commercially Available Products and DOT Shipping

Containers

Sealed radioactive sources that are engineered to pass the special form testing specified by

the Department of Transportation (DOT) in 49 CFR 173.469 or testing specified by ANSI

N43.6 "Sealed Radioactive Sources, Categorization," may be excluded from summation of a

facility's radioactive inventory. The facility must have documentation that the source or

prototypes of the source have been tested and passed the tests specified by DOT or ANSI.

Facilities must also have in place a source control policy that complies with DOE Notice

5400.9, "Sealed Source Control Policy" and the source control policy specified in Article 431

of the DOE RadCon Manual. Should a sealed radioactive source fail, as indicated by an

increase in the removable activity, the source shall be removed from service and handled in

accordance with the source control policy established for the facility.

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