Radiological Safety Review of Siting and Layout Aspects of the ESS Technical Design Report, ESSdoc-274, April 23, 2013 Produced under contract for the Swedish Radiation Safety Authority: SSM 2012-5686 P. Wright, Radiation Protection Adviser and Radioactive Waste Adviser: UK HSE Certificate 00000397 14-09-2013 1/12 Contents Page R1 Background 3 Introduction Scope R2 Observations on Siting 4 R3 Observations on Layout 6 R4 Qualitative Assessment of Hazards and Risks 9 R5 Conclusions and Recommendations 11 R6 References 12 2/12 R1 Background Introduction This review report's purpose is to provide support for SSM in the licensing process of ESS and will help to form the basis for authorization decisions. If a license is given it may include specific requirements as license conditions which are deemed necessary to supplement the existing legal regulations so that a resulting satisfactory radiation safety is obtained from an authority perspective. The requirements shall be based on identified deficiencies in the radiation safety assessment process. This review supports the aims of the SSM and by clearly identifying specific radiological risk areas in the layout and siting concepts. The background is that SSM has received an application for a license under the Radiation Protection Act for a unique facility. SSM and Sweden have no experience with comparable facilities. There are no current legal requirements adapted to this type of facility in Sweden. ESS will become unique worldwide as an accelerator-based neutron spallation source with such a high beam power. There are some similar but smaller facilities regarding beam power with slightly differences in designs in the world. It is important for SSM to capitalize on existing relevant experience in the licensing process of the ESS. The facility will house a large amount of radioactive material that pose a significant risk if it is released into the environment and can cause dose to humans. Several aspects relate to potential emissions during normal operation and accidents of all kinds including malicious acts. Waste management during operation and future decommissioning are also important considerations. At the initial stage, questions about the design, layout and location of the facility in the proposed region and accessibility of adequate waste repository are of primary interest. Facility design with successive barriers and defines in depth are important details to estimate the protection against unacceptable emissions and exposures. SSM's believes that strategies and requirements can in some respects be designed in accordance to what applies to nuclear facilities and power plants. The level of requirements should however be deemed to be a graded approach taking the current risk into account. Aspects that all necessary operation and maintenance work must be executable within the limits imposed by the dose to personnel also provide implications for the design, layout and location of the facility. This approach to report review has been made to enable timely feedback to the SSM and to assist with the process. Scope This review covers the siting and layout of the ESS and is primarily based on the technical design report of the ESS project. It considers the potential impacts of radiological risks to operators, members of the public and the environment. 3/12 Comments on the technical design report are given only in selected sections (TDR reference headings in black italics) relating to siting and layout with comments in blue italics. Contents headings of this report are prefixed as Rxx. R2 Observations on Siting The proximity of the ESS site to nearby occupied areas places increased importance on the analysis of the significance of potential radiological hazards to people and biota from; radiation skyshine, airborne radioactive discharges (gases and dusts), radioactive liquid effluent (cooling water and sewage) discharges, spills and flooding, activated ground water and soil erosion, contaminated storm water run-off, water run-off from fires involving radioactive contamination, theft or loss of radioactive material and transport of radioactive packages including radioactive waste or scrap. The risks to critical groups and biota from these hazards at the proposed site location should be evaluated and conform to those risk levels given in the ESS General Safety Objectives-as a minimum requirement. Although this has been done to some extent with emphasis on airborne hazards (Ene, ref.1 ) and a basic Environmental Impact Assessment (EIA) has been produced in Swedish for public information: a comprehensive environmental impact assessment covering a range of critical groups, with references collated in one document could be made that addresses all the hazards given in the preceding paragraph. For example, a critical group identified in ESS-1241368, 2012 and the TDR at Ostra Torn is at 330 m from the target station yet the dose to this group is not explicitly given in the TDR and the reasons for choosing the critical group at Vastra Odarslov in preference to those at Ostra Torn are not explained. Other considerations such as the use of a societal risk as distinct from individual risk may be helpful for comparison with standards of other countries. This may also involve the use of such concepts as qualitative risk. But an explicit evaluation of risk to large communities such as those at Lund should be made. It could also be expected that such considerations would extend to the the regional future land use plans lodged with the Brunnshog district County Administrative Board. One of these plans is for a Science Village between ESS and MAX IV. It could be expected that the above evaluations would cover; construction, commissioning, operation, maintenance, modification/extension and decommissioning of the ESS project. Security of radioactive materials has become a more prominent issue in the last decade especially with regard to high activity sealed sources (HASS) and theft of radioactive scrap metals. This aspect could also be given more attention when dealing with the analysis of radiological risks associated with siting and access. TDR, 7.2 Location and conditions at the site The distance from the nearest area of high population density, Lund, is about 2 km with smaller populations scattered around the site at much closer distances. All of these distances are not so large that proximity cannot be discounted as a major factor in the analysis of the consequences of operational or accidental release of radioactivity to the environment. Indeed, 4/12 studies have been undertaken (refs. 2, 3, 4, 5) to show that the risks are low but these rely heavily on a hypothetical release term that largely discounts the production of aerosols and releases from building locations other than the main ventilation stack. It may therefore be prudent to carry out a stress test on the accidental release scenario. If the results of any stress test on the accidental release scenario is positive it will be a good recommendation for the low radiological impact of accidental releases from the facility. However an important factor in this assessment would be the magnitude of the risks associated with the release of radioactive aerosols. Although the risk of contamination of property from accidents at the site may be shown to be very low and individual risk likewise, international experience with this scenario has shown that the consequences of loss of property or economic output is a very significant issue. Therefore it could be expected that any risk assessment would include consideration of nonqualitative aspects of this type of accident. Care should be taken when using international accident data since solid spallation contamination sources have an intrinsically lower release fraction of radio-toxic and volatile nuclides compared to nuclear reactors. Operational releases of radioactive gases could also be subject to a review. It seems unusual for this type of facility not to have significant releases of short-lived gaseous nuclides such as Ar41, N13 or C11 (TDR Section 10.4.2 and Ene, ref. 1) when compared to other much lower powered facilities. However, uncertainties concerning the ventilation systems operating modes could be a factor in this assessment. It should be noted that while other international proton spallation facilities such as SNS and ISIS have developed from sites or campuses with long histories of involvement with radiological hazards with the attendant personnel knowledge, expertise, demonstrable safety and regulatory compliance: this may not initially apply to the same extent at the ESS location. Therefore consideration of the impact of the available levels of personnel safety culture, experience, training and skills when undertaking risk assessments should be a prominent factor. In practical terms for example, a probability of failure of safety critical procedures such as 10-2 for challenges to controls of hazards could be considered. TDR, 7.2.5 Ground conditions It has been noted (TDR Section 10.5) that environmental samples such as; foodstuffs, surface pond water, groundwater, well water, soil and rock would be taken and analysed to provide background data for future environmental monitoring programmes. This would also include the installation of permanent water and soil sampling bore holes at suitable locations around the facility. The bore holes should be at a depth so as not to provide flow paths through any aquifer barriers. The number of boreholes would be of the order of at least ten and should be sited to collect water from the watershed plumes. 5/12 Measurement of the elemental concentrations of soil and water samples could be carried out to assist with activation modeling. It could also be advantageous to carry out trial activation of some samples, including shielding materials, to validate any models. The closeness of the ground water level (3-5 m) to the ESS ground level could place increased focus on activation caused by beam losses in the accelerator and below the target station monolith. The accelerator building will have a floor below ground level and the target monolith will have penetrating neutron fluences. A check on the assessment of this aspect could be indicated. It is noted that consideration of groundwater migration was carried out (TDR, 10.5.2) but the conclusion was not definitive. There is also some doubt about the calculated level of tritium migration. There appears to be no consideration of radon in the TDR. Radon levels on the soil pore air (ref.6) could be significant- up to 40 kBq/m 3 in the western part of the site. How these levels translate to exposure during construction, operationally in buildings and from ventilation discharge activities is not clear. It may also be possible that construction could change the porosity of the soils and generate elevated levels of natural radon progeny in dusts but the contribution of these to risks is not known. The relevant SSM high radon limit for soils is quoted in the reference document as 50 kBq/m3. If this reduces to a lower level in the near future, with anticipated changes to radon dose risk factors (times 2) recommended by the ICRP (ref. 7), there may be an impact on occupational exposure risks. Depending on the results of further assessment and requirements of SSM, engineered abatement of radon in ESS buildings may need to be considered. R3 Observations on Layout This section only covers broad aspects of the buildings and the layout of their systems since detailed information in the TDR is not generally available. TDR, 7.3 Logistics, earthworks and buildings The general layout of the buildings on site is good, although it is not clear in the diagram (Figure 7.13) how radioactive material generated in the facility will be transported to and from the radioactive waste store. These routes could be shown on a separate diagram and include off-site transport. The on-site routes for intermediate level waste should be separate from the main traffic flows or at least have provision for exclusive use when needed. It is not clear whether the SSM Road Transport Regulations for radioactive materials are to apply for transport on the site. If this is the case then a good level of safety will apply and flasks, vehicles and personnel may have to be licensed to move radioactive packages on site. Provisions for exemption from road transport regulations exist within the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR 2013, Subpara. 1.8.3.2(b)). Such provisions are commonly adopted by national competent authorities. 6/12 A documented Quality Management System and emergency response plan for transport accidents would also be needed. Site emergency evacuation routes for fires involving radioactive contamination could be defined to help with internal road planning. TDR,7.3.2 Earthworks Storm water and run-off drainage systems should be designed so that run-off from contaminated water used in fire extinguishment or contamination spills can be dammed and recovered before entering the drainage company systems. TDR, 7.3.3 Buildings Fresh air intakes and make up air for the working environment should be located so that direct, re-entry of radioactive airborne discharges from the facility is not possible. Operation of ventilation systems for radioactive environments within the facility should be so as to remain operational initially during a fire to remove smoke and maintain contamination containment. The removal of smoke is important so that fire fighting personnel can locate missing persons and the seat of the fire. Exceptions to this general advice could be for flammable and explosive cryogenic gases such as hydrogen or methane. TDR, 7.3.4 Accelerator buildings Concrete shielding for the accelerator and target station can become activated and present long term occupational and decommissioning radiation or contamination hazards. A study of the type of aggregate to be used in the concrete could be made to determine whether aggregate with low atomic number elements is preferable in some locations. In some areas “water proof” concrete can be coated in strippable paint or water impervious membranes used to provide a barrier to tritiated water adsorbtion or ingress of water from the accelerator mound soil. This may also be important for future decommissioning where the large bulk of contaminated material can cause difficulties with disposal and high costs. The location of the radiation office at the front end of the building could be too remote from the more active parts of the facility and thus affect response times to incidents or accidents involving radiation or contamination hazards. TDR, 7.3.5 Target building The roof of the large void space between the target monolith and the experimental halls could be a weak point for neutron leakage affecting the occupational background radiation level in the hall. The shielding design for this could be checked. Although it is expected that mechanical and civil engineering will be to a high standard, special attention could be given to the long term stability of the monolith foundations and 7/12 mechanical alignment. Experience with another facility has shown that slight tilting of massive shield structures can occur and coupled with tight clearances, motion of shield assemblies has been inhibited or beam alignment has been affected. The high levels of activation associated with these structures can involve significant doses in recovery work. TDR, 7.3.7 Central laboratory, DMSC, offices and auxiliary buildings Consideration could be given to locating the main ventilation stack at the front end of the building to gain the most advantage from the distance between more occupied buildings at on-site and off-site locations. The impact of turbulence caused by the wind energy fan on the stack discharge plume could also be considered. There does not appear to be explicit provision for storage of radioactive spare components. These items could be expected to be stored in the radioactive waste facility since they form part of the radioactive materials stream that, if not used within a time agreed with the SSM, will ultimately be declared as waste. TDR, 7.4.2 Low and extra low voltage systems Special lighting could be considered for areas with prompt radiation hazards such as the accelerator tunnel. TDR, 7.5.1 Cooling water system There does not appear to be any explicit provision in the cooling water system design for leakage water containment, collection, characterisation for radioactive contamination and processing. A typical facility would have floor drainage channels, collection sumps, bunds and possibly delay tanks in all water cooled areas where radioactive contamination is possible. TDR, 7.5.4 Cooling water interfaces The apparent lack of a second heat exchange interface between active cooling circuits such as the target and the district heating line (TDR, Figure 7.31) has been discussed in a previous report on the CDR. Primary pipe lines may need to have double containment to provide protection from leaks of radioactive water. TDR, 7.6.1 Compressed air and gas systems Provision of separate compressed breathing air supplies for personal protective equipment such as air fed suits could be considered. TDR, 7.6.2 Heating and ventilation Diagrams of the active ventilation systems for the accelerator and target could be useful. It may be difficult for the accelerator tunnel ventilation plant to provide sufficient protection against loss of negative pressure differential across the accelerator/outer atmosphere interface during periods when the plant is not on and the accelerator is operating. This has 8/12 been discussed in a previous report on the CDR. There could be strong operational pressures for continuous operation of the accelerator ventilation plant when the accelerator is running and these may force a change in use of the lower, workplace environmental conditioning fan speed mode to maintain flow. The consequences of this could be the continuous release of activated air from the stack. In some experimental beam lines activation of sample gases or beam line air may be possible and provision for active ventilation of these areas could be considered in the design. TDR, 10.5.3 Accidental release scenarios Paragraph one, penultimate sentence, the volatile release fraction is given as 0.5% but table 10.18 shows 0.05%. There is also an apparent inconsistency between tables 10.17 and 10.18 where the Xe121 dose component is zero in table 10.17 but 1.4 x 10 -7 Sv in table 10.18. They should be equal since the tritium component is equal in both tables. It is also not clear why the Xe121 dose component in the TDR for table 10.17 is zero while it is 140 µSv in both tables, 7 and 8 of the referenced report; ESS-0001898. R4 Qualitative Assessment of Hazards and Risks The observations in the preceding sections were prioritised in terms of perceived hazard and risk significance and the following two aspects have been chosen for further qualitative evaluation in this section. Aspects chosen from the observations section are: operational and accidental release scenarios. Operational Release Scenarios (TDR, 7.2 Location and conditions at the site) It seems unusual for this type of facility not to have significant releases of short-lived gaseous nuclides such as Ar41, O15, N13 or C11 (TDR Section 10.4.2 and Ene, ref. 1) when compared to other, lower powered facilities. The discharge levels for three spallation facilities shown in table 1 suggest that, rounded to one significant figure, the calculated short-lived nuclide releases for the ESS are not comparable when scaled with measured or modeled releases from other spallation sources. Such discrepancies should be carefully analysed and explained because of the impact on doses to the public and the environment. Uncertainties concerning the ventilation systems operating modes for all facilities could be a major factor in this assessment. In the case of SNS the accelerator tunnel is not ventilated during accelerator operation but for ISIS all systems are continuously ventilated to; maintain a negative pressure differential, condition the air temperature and to reduce corrosion from the buildup of moisture in some 9/12 areas. The ESS calculations assume continuous ventilation to remove moisture and heat (TDR, 10.4.2) only as a worst case example. For a hypothetical example, if the ESS release of short-lived gases is factored, by an average scaling factor of 300 derived from the table, the dose component to the critical group living at Vastra Odarslov, 660 m from the stack would be 90 μSv/y. Allowing for a reduction by a factor of two for a longer turnover rate, the dose would be 45 μSv/y. The calculated tritium releases for the ESS are also not fully comparable when scaled with SNS but do scale with ISIS. The main source of the HTO discharge in the case of SNS is the Hot off-Gas exhaust and there is a relatively small fraction from the accelerator tunnel. The difference between ESS and SNS may be due to the relatively higher release of tritium from the SNS liquid mercury target via the hot off-gas system. For the hypothetical example and excluding the SNS case because of the liquid mercury target, if the ESS release of tritium is factored, by an average scaling factor of 1.5 derived from the table, the tritium dose component to the critical group living 660 m from the stack would be low at 0.048 μSv/y. Totals of short-lived nuclides and tritium doses would thus be for the hypothetical case 45.05 μSv/y which is close to the GSO limit of 50 μSv/y total (and above the limit of 10 μSv/y from a single source) with not much margin for variations such as for example; the critical group location from the stack release point, the design stack height, plant operating conditions etc. A critical group, identified in ESS-1241368, 2012 and the TDR, at Ostra Torn is at 330 m from the target station yet this group is not included in the TDR operational dose assessment. The reasons for this could be explained. Table 1, Comparative Site Airborne Discharge Levels For Various Facilities Site Short-lived nuclides Tritium as HTO (TBq/y)+ (GBq/y) Beam power (MW) Power scale factors (Short-lived/MW, HTO/MW) SNS** 400 30000 1 400, 30000 ISIS 300 0.2 200, 2000 1 30 ESS* 7 6000 5 1, 1000 **Abated model, accelerator only, SNS 102010203-ES0001-R00, 2008 * Calculated TDR, all sources, one day turnover; Section10.5.1 1 Measured +Note: the short-lived nuclide breakdown fractions for SNS, ISIS, CERN and ESS accelerator tunnels are not all similar; as shown in table 2. The most significant difference in terms of the effect on total dose is that from Ar41 and this could, if assumed true, increase the plume dose. 10/12 Table 2, Comparative Short-Lived Nuclide Fractions For Accelerator Tunnels at Various Facilities Site/Nuclide SNS*% ISIS***% ESS**% CERN+% C11 57 7.6 38 55 N13 38 73 39 12 O15 <1 2.4 22 - Ar41 4.3 16 1 22 * Abated model ** One day turn-over model ***Model + Measured; Patterson and Thomas, Accelerator Health Physics, Academic Press, 1973 Accidental Release Scenarios (TDR, 10.5.3) Paragraph one, penultimate sentence, the volatile release fraction is given as 0.5% but table 10.18 shows 0.05%. It is not clear how the scale factors for components of dose operate for the different fractions of release given in the tables. The description of accident scenarios for the target DBA including a “defined hypothetical accident” could perhaps be given in more detail either in the TDR or elsewhere. Several documents have been reviewed but an analysis to a level such as that of the LANSCE publication; Bounding Radionuclide Inventory and Accident Consequence …. LA-UR-1110388, 2007 could not be found. In particular, it could be prudent to firmly establish the basis on which the assumptions of no aerosol releases are made. For example, loss of coolant accidents with tungsten-steam reactions producing highly radioactive tungsten oxide or tungstic acid have been considered in studies of solid target alternatives for SNS. These were assumed released by mechanical containment failures and/or pressure relief devices. The estimated doses for various fractions of accidental volatile release are only given for the critical group at Vastra Odarslov, 660 m from the stack and do not include doses to the critical group at Ostra Torn, 330 m from the target station. Estimated doses from accidents to critical groups at the ESS site, Max IV, Lund and other communities could also be made to enable members of the public and authorities (SSM) to compare and evaluate risks. R5 Conclusions The application for approval could be based on a more comprehensive, radiological environmental impact assessment (EIA). The treatments given in the TDR and elsewhere (e.g. in the Preliminary Safety Assessment Report) are in themselves good but could be up dated and presented in a more wide ranging, single document for public information that additionally includes all relevant papers. 11/12 An environmental monitoring program could be included in the EIA to show due consideration of all of the issues identified including the commitment of resources and presented in a form that can be easily understood by the public. All conservative assumptions should be transparently stated. Software based models using codes such as MCNP can be inaccurate and in some cases give levels greater than a factor of 3 higher or lower than actual measured dose results. When combined with other variables such as tunnel geometry, changes to plant operating or beam loss conditions considerable errors in dose estimation can occur. It is therefore advised that operational releases of airborne radioactivity should be subject to a comparative analysis including uncertainties to resolve apparent differences between other similar facilities and to provide an estimation of the upper level for doses to members of the public. The atmospheric discharge models and dose assessments could be peer reviewed to ensure consistency and that the omission of aerosols from the release inventory is justified. Since the discharge calculations depend very much on the ventilation system and its mode of operation this aspect should be well determined. The proposal not to discharge continuously from the accelerator tunnel should be justified since it is not easy to see how a pressure differential with respect to ambient conditions will be maintained to prevent leakage of radioactive air from the tunnel near ground level. R6 References 1 2 3 4 5 6 7 Ene,Environmental Impact Analysis, ESS-0001898 Rev 1, 14/12/2012 Health Risk Assessment ESS-003789 Rev. 1(4) Studsvik, Environmental Dose Assessment, ESS Part 2 N-13/021 Summary of Analysed Events ESS-0001878, Studsvik, Assessment of Radiological Impact of Unplanned Events at ESS, N-13/183 SWENCO FFNS, Report on Site Selection, 2002 J Vaillant et.al.,Management of radon: a review of ICRP recommendations, J. Radiol.Prot. 32 (2012) R1-R12 12/12
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