T/AST/045 – Issue 1
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1.1 Her Majesty’s Nuclear Installations Inspectorate (NII) of the Health and Safety Executive (HSE) has the responsibility for regulating the safety of nuclear installations in the United Kingdom. The Safety Assessment Principles for Nuclear Facilities (SAPs) [1] provide a framework to guide NII’s decision making in the nuclear permissioning process. The SAPs are supported by Technical assessment Guides (TAGs) that provide guidance on the interpretation of the principles to assist assessors in the exercise of their professional regulatory judgements about the adequacy of safety submissions.
1.2 This TAG provides guidance on the radiological analysis of faults, including Targets 4 – 9 which lay down numerical criteria for fault frequencies, radiation doses and risks to employees and others. The background to these Targets and an explanation of the associated Basic Safety Levels (BSLs) and Basic Safety Objectives (BSOs) are given in the Explanatory Note on the Numerical Targets and Legal Limits 2.
2.1 The Nuclear Installations Act 1965 (as amended) permits the Health and Safety Executive to attach to the site licence conditions as may appear to be necessary or desirable in the interests of safety. Licence Condition 14 (Safety documentation) requires licensees to make adequate arrangements for the production and assessment of safety case documentation to justify safety during design, construction, manufacture, commissioning, operation and decommissioning phases of the installation. Safety case documentation is also relevant to Licence Conditions 15 (Periodic Review), 19 (Construction or installation of new plant), 20 (Modification to design of plant under construction), 21 (Commissioning), 22 (Modification or experiment on existing plant) and 23 (Operating rules). Radiological analysis of the consequences of faults forms an important component of these safety cases.
2.2 In the UK the operators of nuclear installations, in common with other employers, must comply with the general provisions of the Health and Safety at Work etc. Act 1974 (HSW Act) 3. In particular it is their duty:
1) to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all their employees (Section 2 of the HSW Act); and
2) to conduct their undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in their employment who may be affected are not thereby exposed to risks to their health or safety (Section 3 of the HSW Act).
An assessment of the radiological consequences of faults is an important input into decisions on reasonably practicable measures to ensure the safety of persons on and off the licensed site.
Part of the specification for the update of the Safety Assessment Principles was to consider the Reactor, Decommissioning and Storage Safety Reference Levels published by the Western European Nuclear Regulators’ Association (WENRA), and IAEA Standards, Guidance and Documents. The update of this Technical Assessment Guide also considers the WENRA and IAEA publications for specific applicability.
3.1 The Fundamental Principles 5 and 6 highlight the need for all reasonably practicable measures in order to control radiation risks so that no individual bears an unacceptable risk of harm and also to prevent and mitigate nuclear or radiation accidents. These Fundamental Principles underpin the fault analysis SAPs FA.1 – FA.24 and the supporting paragraphs; the radiation protection SAPs; and also Numerical Targets 4 – 9 for fault conditions, which are relevant to this guidance. They are given in paragraphs 594 – 628 and include the following numerical BSL and BSO targets:
| Design basis fault sequences – any person | Target 4 |
|---|---|
The targets for the effective dose received by any person arising from a design basis fault sequence are: On-siteBSL: 20 mSv for initiating fault frequencies exceeding 1 x 10-3 pa BSO: 0.1 mSv Off-siteBSL: 1 mSv for initiating fault frequencies exceeding 1 x 10-3 pa BSO: 0.01 mSv |
|
| Individual risk of death from on-site accidents – any person on the site | Target 5 |
|---|---|
The targets for the individual risk of death to a person on the site, from on-site accidents that result in exposure to ionising radiation, are: BSL: 1 x 10-4 pa |
|
| Frequency dose targets for any single accident – any person on the site | Target 6 | |
|---|---|---|
The targets for the predicted frequency of any single accident in the facility, which could give doses to a person on the site, are: |
||
Effective dose, mSv |
Predicted frequency per annum |
|
2 - 20 |
BSL 1 x 10-1 |
BSO 1 x 10-3 |
| Individual risk to people off the site from accidents | Target 7 |
|---|---|
The targets for the individual risk of death to a person off the site, from on-site accidents that result in exposure to ionising radiation, are: BSL: 1 x 10-4 pa |
|
| Frequency dose targets for accidents on an individual facility – any person off the site | Target 8 | |
|---|---|---|
The targets for the total predicted frequencies of accidents on an individual facility, which could give doses to a person off the site, are: |
||
Effective dose, mSv |
Predicted frequency per annum |
|
0.1 - 1 |
BSL 1 |
BSO 1 x 10-2 |
| Total risk of 100 or more fatalities | Target 9 |
|---|---|
The targets for the total risk of 100 or more fatalities, either immediate or eventual, from on-site accidents that result in exposure to ionising radiation, are: BSL: 1 x 10-5 pa |
|
3.2 The following WENRA Reference Levels 4 are relevant for this TAG:
1. “The design basis shall have as an objective the prevention or, if this fails, the mitigation of consequences resulting from anticipated operational occurrences and design basis accident conditions. Design provisions shall be made to ensure that potential radiation doses to the public and the site personnel do not exceed prescribed limits and are as low as reasonably achievable.” (Appendix E - Design Basis Envelope for Existing Reactors, Section 1)
In the SAPs the prescribed limits for the potential radiation doses to employees on the site and persons off the site from accident conditions are expressed in terms of Basic Safety Levels, some of which are legal limits. The predicted doses for a new facility or activity should at least meet the BSLs and must be ALARP.
2. “Demonstration of reasonable conservatism and safety margins - The initial and boundary conditions shall be specified with conservatism.“ (Appendix E - Design Basis Envelope for Existing Reactors, Section 8)
3. “PSA shall be based on a realistic modelling of plant response, using data relevant for the design, and taking into account human action to the extent assumed in operating and accident procedures.“ (Appendix O – Probabilistic Safety Analysis, Section 1)
The SAPs and this TAG state that the radiological analysis supporting the Design Basis Analysis should be on a conservative basis whereas the Probabilistic Safety Analysis and Severe Accident Analysis should be on a best estimate basis.
3.3 One of the requirements of IAEA’s safety document on the design of nuclear power plants 5 is
“To take all reasonably practicable measures to prevent accidents in nuclear installations and to mitigate their consequences should they occur; to ensure with a high level of confidence that, for all possible accidents taken into account in the design of the installation, including those of very low probability, any radiological consequences would be minor and below prescribed limits; and to ensure that the likelihood of accidents with serious radiological consequences is extremely low. “
As indicated in 3.1, the prescribed limits are expressed in terms of Basic Safety Levels and Basic Safety Objectives. Also the predicted doses for a new facility or activity should at least meet the BSLs and must be ALARP.
3.4 The IAEA document also states that a conservative approach should be adopted for design basis analysis and a best estimate approach for the Probabilistic Safety Analysis and the Severe Accident Analysis. These approaches for the radiological analyses are highlighted in this TAG.
4.1 Numerical Targets 4 – 9 and the supporting text in paragraphs 594 – 628 1 are concerned with the predicted radiation doses and the associated risks to persons on and off the site during fault conditions in a facility on the licensed site. The doses in these targets are expressed in terms of mSv which is appropriate for relatively low doses received over a relatively long period of time. However, the assessor should be aware that for relatively high doses received in a relatively short time, the dose expressed in terms of mGy (or sub units) is more relevant. Guidance in this TAG is confined to the radiological analyses that support the nuclear safety analyses for the facility. Guidance on other aspects is provided in other TAGs 6,7,8.
4.2 The assessment of the predicted doses/risks aims to establish whether the actual doses/risks are likely to be within levels that should be met and also the extent to which the doses/risks have been shown to be ALARP. It is HSE’s policy that a new facility should at least meet the BSLs. Assessors should use their judgement and discretion to ensure that the assessment is proportionate and targeted. The depth and scope to which this guidance is employed should be on a case by case basis.
4.3 The radiological analysis involves the predictions of doses to persons on the site and off the site from faults affecting the facility and is an input to three types of analysis, namely
Faults lacking the potential to lead to doses > 0.1 mSv to a person on the site or > 0.01 mSv to a person off site are regarded as part of normal operation and excluded from the fault analysis (SAP para 504). The results of the radiological analyses should be judged against Numerical Targets 4 – 9.
4.4 The assessors should ensure that the licensee reduces the predicted doses to ALARP levels by applying the hierarchy of control measures, which is highlighted in Reg. 8(2) of IRR99 and in paragraph 146 of the SAPs, together with recognised good practices rather than by the inappropriate refinement of the parameters used in the radiological analyses.
4.5 Guidance is provided in the following sections on the general aspects of predicting doses to persons on and off the site and also on the different approaches normally adopted in the radiological analyses supporting the DBA, PSA and SAA.
4.6 The models for estimating doses to persons on the site, usually to the operators in the facility of interest, are generally specific to the nature of the operations being undertaken and the associated fault conditions. Simple bounding estimates for the doses should normally be sufficient particularly if the calculated doses are subject to relatively large uncertainties. Doses associated with the recovery actions following faults should be excluded. The assessor should be aware of the principles and guidance for the protection of persons on-site in the event of a radiological accident 9.
4.7 The assessor should consider the licensees’ models on a case by case basis. Doses from all pathways should be considered for all faults analysed. The calculation of the dose to a person should be based on radiation levels, airborne contamination levels and exposure times. Attenuation provided by any shielding and the use of personal protective equipment may be taken into account if it is reasonable to expect it to be worn.
4.8 The assumed response by the operators should be consistent with, for example, the time taken to recognise the fault condition, the radiation levels, the extent of likely contamination and the defined roles and responsibilities of the operators. Where the assumptions appear to be optimistic, particularly for the most limiting high consequence faults, the assessor should seek evidence of the feasibility of the operator response e.g. evacuation times.
4.9 The radiological consequences to a person off the site may arise from several different exposure pathways e.g. direct shine, inhalation and ingestion from radioactivity released off the site. A person off the site may also be exposed to direct shine if there is a significant release of radioactivity within the facility or if there is a significant increase in the radiation levels in the facility e.g. as a result of a criticality accident. In the case of a release of radioactivity within the facility the estimated direct shine dose to a person off the site would include the following factors:
4.10 If there is a release of radioactivity outside the facility the determination of the associated doses from direct shine, inhalation, and ingestion and from deposited radioactivity normally requires knowledge of how the radioactivity is dispersed off the site. The important parameters can generally be broken down into the following components:
The following paragraphs provide advice to assessors on the approach which is expected to be followed by licensees in their radiological analysis.
4.11 The source term:-
4.12 The features of the release:-
4.13 Atmospheric dispersion:-
4.14 Dose estimation:-
4.15 For assessment against Targets 5 and 7 (i.e. the risk of death to individuals on and off the site respectively) the risk estimates should be derived from the radiological consequences in terms of dose and suitable dose/risk conversion factors. At relatively low doses the most appropriate factors are the ICRP recommendations 11, namely 4% per Sv for workers and 5% per Sv for members of the general population. Since the factors are subject to review from time to time, assessors should to be aware of the most up to date authoritative guidance. For high doses received in a relatively short period of time the most appropriate factors increase and at very high dose levels the risk are invariably fatal, in which case the risk of death is the frequency of the associated fault.
4.16 Where the dose/risk conversion factors used are lower than those recommended by authoritative bodies e.g. ICRP and HPA/RPD, the assessor should examine the underlying assumptions and seek an adequate justification.
4.17 The SAPs for design basis analysis are given in paragraphs 512 – 526 and 598 – 601 including Target 4. FA.7 and paragraphs 521 - 524 are particularly relevant for the radiological analysis. The analysis should demonstrate that for most DBAs, sufficient physical barriers will be maintained to reduce so far as is reasonably practicable, the doses to persons on and off the site. In the most severe design basis accident, no person on the site should receive a dose in excess of 500 mSv and no person off the site should a dose greater than 100 mSv. Generally, the larger the potential consequences of an accident, the smaller should be its frequency. This is illustrated in Target 4 which identifies the relevant BSL and BSO values for ranges of fault frequencies and radiological consequences.
4.18 Principle FA.7 states that the ‘analysis of design basis fault sequences should use appropriate tools and techniques, and be performed on a conservative basis to demonstrate that consequences are ALARP’. The assessor should ensure that the radiological analysis predicts the maximum effective dose to a person on the site and to a person off the site directly downwind of the release. It should be assumed for off site releases that ‘the person remains at the point of greatest dose or the maximum duration, although for extended faults a more realistic occupancy may be assumed after a suitable interval.’ (SAP para 601(a))
4.19 The person most at risk on the site is likely to be an operator in the facility. The assessor should ensure that the assumptions made for the operator’s response to each fault take account of the operational conditions likely to prevail in the event of the fault and are conservative but not overly pessimistic.
4.20 The radiological analysis should be conservative and assume
4.21 Where a methodology other than that recognised by the UK ADMLC is used, the assessor should seek to establish that the consequences are not unduly lower than those predicted by the UK ADMLC methods. Appendix 1 presents typical values for the input parameters for a code based on the R-91 dispersion model used for the DBA off-site radiological analysis.
4.22 The PSA predictions of the doses to persons on the site and persons off the site should be based on a best estimate approach. Alternatively, licensees may wish to use reasonably conservative assumptions. A general guide to off-site consequences and estimation of risks to the public for PSA (Level 3) can be found in IAEA Safety Series No. 50-P-12 12.
4.23 The assessor should ensure that the assumptions made for the operators’ response to the fault takes account of the operational conditions likely to prevail in the event of the fault and are best estimates. The operator should be assumed to be situated at the point of maximum potential exposure and realistic occupancy factors should be used to determine the exposure time.
4.24 The determination of risk to individuals is based on estimations of the radiological consequence and frequency for each of the identified fault sequences. The radiological analysis will clarify the dose band to which each fault sequence should be allocated. The frequency associated with the fault sequence should be below the respective BSL and be ALARP.
4.25 The assessor should ensure that the off site radiological consequences for identified fault sequences have been determined in an appropriate manner. Co-operation is likely to be required between the fault studies specialists and the radiological protection specialists since the former assess the validity of the frequencies.
4.26 Best-estimate methods and data should preferably be used for the radiological analysis in the PSA and should
4.27 Where the licensee’s approach differs significantly from the above, the assessor should seek justification to ensure that the dose predictions are not unduly optimistic.
4.28 The objective for the Licensees in performing a PSA is to estimate the radiological consequence and frequency for each of the fault sequences they have identified. The radiological analysis will determine which of the Target 8 dose bands the fault sequence is allocated. The frequency associated with the fault sequence should be below the respective BSL and must be ALARP.
4.29 The assessor will need to form a judgement on the depth and breadth of the assessment of the licensee’s case in order to be satisfied that consequences have been derived in an appropriate way. In some cases the assessor may wish to perform independent calculations e.g. using a code such as PC Cosyma (an EC code) to check the claims made by the licensee. If independent calculations are performed, it must be borne in mind that differences in the results of less than an order of magnitude may not be significant.
4.30 Appendix 1 presents typical values for the input parameters for a code based on the R-91 dispersion model used for the PSA off-site radiological analysis.
4.31 Severe accidents are defined as those fault sequences that lead either to consequences exceeding the highest radiological doses given in the BSLs in Target 4 or to a substantial unintended relocation of radioactive material within the facility which places a demand on the remaining physical barriers. (SAP para 543).
4.32 The ‘100 or more deaths’ in Target 9 include those arising from the immediate effects of accidents and also the longer term stochastic effects. It is the total for all severe accidents and also includes on and off site fatalities, in contrast to the other targets where the on and off site consequences have their respective BSL and BSO levels.
4.33 The analysis should determine the risks from severe accidents to demonstrate that no sudden escalation of consequences just beyond the design basis (i.e. no ‘cliff edge’ effects). Sensitivity studies, which include systematic variation of the parameters used in the radiological analysis, should be performed to identify the important parameters for the demonstration.
4.34 The assessor should consider whether the results of the analysis show the need for additional features to be incorporated in the plant design to reduce the risks so far as is reasonably practicable.
4.35 The radiological analysis should generally be carried out using best estimate assumptions, methods and data. Where this is not possible, reasonably conservative assumptions should be made to take account of the uncertainties in the understanding of the physical processes being modelled.
4.36 The assessor should ensure that the calculations adopt a best estimate approach with the following constraints:-
4.37 The methods and data for the radiological analysis should follow a best estimate approach with constraints similar to those used in the PSA. The earlier guidance on source terms, features of the release and atmospheric dispersion should be applied although dose determination should be subject to the following constraints:-
4.38 Where the consequences are determined to be significantly greater than 100 deaths, the assessor should seek a demonstration of correspondingly lower frequencies of occurrence. Appendix 1 presents typical values for the input parameters for a code based on the R-91 dispersion model used for the SAA off-site radiological analysis.
| Parameter | Value | Comments | ||
|---|---|---|---|---|
| DBA | PSA & SAA | Societal risk analysis | ||
Release Height |
Ground Level |
Ground Level |
Ground Level |
The use of an elevated release should be justified. |
Building Wake |
Yes |
Yes |
Yes |
|
Release Duration |
30 mins |
30 mins |
30 mins |
Other durations need to be justified. |
Dispersion Model |
R-91 |
R-91 |
R-91 |
Other equivalent models may be used. |
Weather Category |
F 1 |
D (or probabilistic range) |
D (or probabilistic range) |
1. Category B used if release is elevated. |
Wind Speed |
2 m/s |
5 m/s |
5 m/s |
Other wind speeds need to be justified. |
Dry Deposition |
Yes |
Yes |
Yes |
|
Wet Deposition |
No |
No |
No |
Although wet deposition is usually ignored, it should be considered if skin dose is liable to be a key factor or if long term effects from deposited activity may be significant. |
Location |
Location where dose is greatest 2 |
Nearest Habitation or location where occupancy is likely or 1km from the facility or > 1km if dose is higher |
UK population 3 |
2. For elevated releases the highest dose may be some distance away, in which case that location should be used. |
Age |
Age that gives Maximum Dose |
Age that gives Maximum Dose |
Population distribution |
|
Occupancy |
Continuous |
Best Estimate |
Best Estimate |
|
Inhalation Rate |
ICRP 66 4 |
ICRP 66 4 |
ICRP 66 5 |
4. Inhalation rate for maximum appropriate age group. |
Dose Coefficients |
ICRP 72 6 |
ICRP 72 6 |
ICRP 72 7 |
6. Dose coefficients for maximum dose age group. |
Exposure Pathways |
- Cloud shine |
- Cloud shine |
- Cloud shine |
8. Food bans expected to be introduced if the EU CFILS are exceeded. The Licensee should make a case for a dose cut off for this pathway. |
Protective actions |
Only if very highly likely to be implemented 9 |
Only if highly likely to be implemented |
Only if highly likely to be implemented |
9. For example, evacuation on an adjacent site where adequate arrangements are in place and routinely demonstrated. |