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NSTP 2002-2 Methodology for Final Hazard Categorization for Nuclear Facilities from Category 3 to Radiological (11/13/02).

0 CFR 830 Subpart B requires that all DOE nuclear facilities categorized as HC-3 or above have a DOE
approved safety basis compliant with the requirements of Subpart B. The rule requires the use of DOESTD-
1027-92 (STD- 1027) as the methodology for categorizing DOE nuclear facilities. STD- 1027 requires
a preliminary categorization be established on the basis of the inventory of radionuclides in a facility or
involved in an activity. It also permits a safety analyses (see STD-1027 section 3.1.2) to establish a final
hazard categorization that may be different from the preliminary. STD-1027 defines a method for
establishing how to go from a preliminary categorization of HC-2 to a final categorization of HC-3. But it
does not define a method for establishing how to go from a preliminary categorization of HC-3 to a final
categorization of radiological (below HC-3). Previously, several Interpretation memos for DOE Order
5480.23 (now canceled) addressed this issue. However, these Interpretation memos have no standing under
10 CFR 830 Subpart B. In accordance with STD- 1027 section 3.1.2, hazard categorization is finalized after a hazard analysis has
been performed as discussed in section 4 of the Standard, and is based on the facility and activities  described in the Documented Safety Analysis (DSA). If the facility mission, processes, or life cycle stage of the facility changes, then the DSA must be revised to reflect the current facility status and activities. This analysis may result in a different final hazard categorization.