O R D E R OF THE HEAD OF THE STATE NUCLEAR POWER SAFETY INSPECTORATE

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1 O R D E R OF THE HEAD OF THE STATE NUCLEAR POWER SAFETY INSPECTORATE ON THE APPROVAL OF NUCLEAR SAFETY REQUIREMENTS BSR STANDARDS OF RELEASE OF RADIONUCLIDES FROM NUCLEAR INSTALLATIONS AND REQUIREMENTS FOR THE PLAN ON RELEASE OF RADIONUCLIDES 27 September 2011 No Vilnius Following subparagraph 8 of paragraph 1 of Article 22 of the Law on Nuclear Energy of the Republic of Lithuania ; 2011, No ) and paragraph 13 of the Article 32 of the Law on Nuclear Safety of the Republic of Lithuania (Official Gazette, 2011, No ) A p p r o v e Nuclear Safety Requirements BSR Standards of Release of Radionuclides from Nuclear Installations and Requirements for the Plan on Release of Radionuclides (attached hereto); E s t a b l i s h that the Law shall come into effect as of 1 October DIRECTOR OF THE RADIATION SAFETY DEPARTMENT ACTING AS THE HEAD VIDAS PAULIKAS NUCLEAR SAFETY REQUIREMENTS BSR APPROVED BY Order No of the Head of the State Nuclear Power Safety Inspectorate 27 September 2011 STANDARDS OF RELEASE OF RADIONUCLIDES FROM NUCLEAR INSTALLATIONS AND REQUIREMENTS FOR THE PLAN ON RELEASE OF RADIONUCLIDES I. GENERAL PROVISIONS 1. Nuclear safety requirements BSR Standards of Release of Radionuclides from Nuclear Installations and Requirements for the Plan on Release of Radionuclides (hereinafter Requirements ) regulates the limitation of the release of radionuclides from nuclear installations (hereinafter NI ) into the environment, establishes standards of the release of radionuclides from NI and the requirements for the plan on the release of the radionuclides and the control of the release of the radionuclides. 2. The provisions of the requirements are not applicable in cases of the nuclear and radiological accidents. II. DEFINITIONS 3. The concepts used herein: Dose factor the ratio of the maximum possible annual effective dose for a member of a critical public group to the annual activity of release of radionuclides (Sv/Bq). Normalized release the ratio of the annual activity of radionuclides released to air or water to their activity limits. If the released several radionuclides and there are several sources of pollution, the normalized release N shall be defined as follows:

2 Q N n ; A a i j i j where: a Q Annual activity of radionuclide j released to air or water per year (Bq/year), A Activity limit of radionuclide j released to air or water (Bq/year), i pollution source. Activity limits of the released radionuclides (hereinafter Activity limits ) established permitted activity of the radionuclides released to air and water from NI per year, conditioning the dose of critical group members shall be less than dose constraint value. Pollution monitoring a systematic and continual measurement and assessment of the activity of the radionuclides released from NI performed by an economic entity. Economic entity (hereinafter the Entity ) a legal entity, intending to perform or already performing activities in the field of nuclear energy that require licenses and permits (hereinafter licenses and permits ) established in subparagraphs 2 and 4 of paragraph 1 of Article 22 and in subparagraphs 2 and 3 of paragraph 2 of Article 22 of the Law on Nuclear Safety of the Republic of Lithuania (Official Gazette, 2011, No ) The other concepts used in the Requirements shall be interpreted as they are defined in the Law on Nuclear Energy of the Republic of Lithuania (Official Gazette, ; 2011, No ), in the Law on Nuclear Safety of the Republic of Lithuania, in the Law on Radiation Protection of the Republic of Lithuania (Official Gazette, 1999, No ), in the Law on Environmental Protection (Official Gazette, 1992, No. 5-75) and in other legal acts regulating radiation protection. III. LIMITATION OF RELEASE OF RADIONUCLIDES FROM NI 4. Aiming to protect the general population from the negative impact of ionizing radiation, the activity of the radionuclides released from NI including controlled temporary increases of pollution shall be restricted insomuch that the annual effective dose of a member of a critical public group would not exceed a dose constraint. 5. Annual effective dose constraint of general public applicable while designing, operating (during normal operation and anticipated operational events) and decommissioning of NI is 0.2 msv. If the public exposure resulted from the operation of more than one NI, a total annual effective dose, caused by operations of all NI, shall not exceed the established annual effective dose constraint. 6. Annual effective dose constraint for members of the public, established in paragraph 5 herein, is applicable for the inhabitants residing and performing economic activities outside of the sanitary protection zone of NI and not working in the sanitary protection zone of NI, but still having an occasion to pass into the sanitary protection zone of NI at times (considering statistical data related to lifestyle and nutrition peculiarities and habits of local inhabitants), as well as NI visitors. 7. Annual effective dose constraint for members of the public, established in paragraph 5 herein is not applicable for individuals who permanently or on provisional basis work at NI or other installations related to operation and maintenance of NI that are situated in sanitary protection zone of NI and those who are not ascribed to either category A or B of employees. A dose limit for members of the public is applicable for them. 8. The estimation of different ways of release of radionuclides (to air or water) and of doses in case of several radionuclides may be performed for the members of different critical public groups. If, following the provisions of paragraph 6 of the Requirements, there is no members of the critical

3 public group in the defined territory, a hypothetical critical group, members of which could live within this area, shall be considered for estimation of the radiological impact of NI. 9. In the case of the release of radionuclides from several NI and in different ways (to air and water), and the impact is incurred to the same or different critical public groups, a dose constraint shall be distributed for each NI and each release of radionuclides insomuch that dose constraint would not be exceeded for the critical public groups exposed by several NI situated in the same territory. 10. Establishing limits of the releases of the radionuclides all constituent parts of ionising radiation that determine annual effective dose for the member of critical public group shall be considered, i.e. both internal and external exposures. Total (as concerns the release of radionuclides and direct external ionising radiation) annual effective dose for the member of critical group shall not exceed dose constraint. IV. STANDARDS OF RELEASE OF RADIONUCLIDES FROM NI 11. The entity shall ensure that in the course of operation or decommissioning of NI, including controlled temporary pollution increases, the dose constraint for the member of critical public group is not exceed. 12. Prior to the start of the operation or decommissioning of NI, the Entity shall evaluate activity limits of the radionuclides released to air and water. Activity limits shall be determined separately for each significant radionuclide or their groups (e.g., noble radioactive gas). In the course of grouping of the radionuclides parameters of the most radiologically dangerous radionuclide shall be applied. 13. If following the decision of the Government of the Republic of Lithuania, it is intended to start designing a new NI nearby the operating NI, which impacts the same critical public group, the Entity in the environmental impact assessment report, prepared under the provisions of the Law on Environmental Impact Assessment of the Proposed Economic Activity (Official Gazette, 1996, No ) shall prove that the dose constraint will not be exceeded by the dose from all NI. 14. Activity limits of the radionuclides are calculated taking into account internal (caused by inhaled and ingested radionuclides) and external (caused by airborne and deposited radionuclides) exposure and the fact that radionuclides released to air and water. 15. Mathematical models of radionuclide migration are applied to estimate the doses of exposure. In the assessment of the dose to the critical group members, all relevant radionuclides discharged from the NI through all possible pathways shall be taken into account. 16. In the assessment of the dose, the most conservative model which does not take into account radionuclide dispersion in the environment shall be applied at first. Should the doses estimated in this way exceed the dose constraint, generic models shall be used with generally accepted parameters of radionuclide dispersion, lifestyles and nutrition of general population. If the calculated dose still exceeds dose constraint then site-specific models are applied considering realistic dispersion of radionuclides and the circumstances of the exposure, as well as specific peculiarities of the lifestyle and nutrition of the members of the critical group, and site specific parameters of dispersion of radionuclides in the atmosphere, hydrosphere and lithosphere. 17. Activity limit of each of the radionuclides, or the group of them, released in the course of operation shall be calculated applying the formula: where: A L D F A ; (1) A - the activity limit of radionuclide j released to air or water (Bq/year); i the pathway of the radionuclides (to air or water); D L dose constraint for the pathway of radionuclides i (Sv/year); F the dose factor of radionuclide j released to air or water (Sv/Bq).

4 18. When several radionuclides released through several pathways from the same NI, their total impact shall be evaluated and it shall meet the condition: where: a Q a Q N 1; (2) i j A N normalized release; the activity of radionuclide j emitted from the source i to air and water per year (Bq/year); A the activity limit of the respective radionuclide (Bq/year). This condition shall be applied to the release of the radionuclides separately to air and water. 19. An assumption, that radionuclides emitted evenly, is made to calculate dose factors and activity limits F and A of radionuclides. In the course of controlled temporary pollution increases, it shall be released not more than 1% per day, and not more than 25% per month of the annual activity limits of radionuclides: j j Q Q d m A A 0.01; (3) 0.25; (4) where: d m Q - the daily release of radionuclide j (Bq); Q - the monthly release of radionuclide j (Bq); A - the activity limits of the radionuclide j (Bq/year); i the pathway of radionuclides. 20. Peculiarities of limitation of the release of the radionuclides from Ignalina Nuclear Power Plant (hereinafter Ignalina NPP ), the dose factors of the radionuclides and the activity limits for the release of the radionuclides from Ignalina NPP are established in Annex 1 hereto. V. REQUIREMENTS FOR THE PLAN OF RELEASE OF RADIONUCLIDES INTO THE ENVIRONMENT 21. The Entity may release radionuclides from the NI exclusively after preparation and approval of the plan of release of radionuclides (hereinafter Plan ) according to the provisions of the Law on Nuclear Safety of the Republic of Lithuania. 22. The plan shall contain the following information: The amount of materials containing radionuclides intended to release per year, physical and chemical properties, activity and composition of radionuclides; The description and layout of release points, methods and pathways; The variation of release of radionuclides, probability and reasons of short-term releases that may cause the increase of activity of released radionuclides; The analysis of all significant pathways of radionuclides by which the radionuclides can reach the general population and increase their dose of exposure, on the base of background monitoring, experience gained in the course of exploitation or analogues; The description of critical public groups considered for the estimation of NI impact; Estimated annual effective dose due to intended activity for members of critical public groups and the estimation methods; Estimated activity limits and dose factors of the radionuclides intended to release to air and water;

5 23. If release of radionuclides into the environment is not expected during operation of the intended activity, the Plan shall contain information to prove it. 24. If it is intended to start operation a new NI nearby the operating NI, the impact of which would be incurred to the same critical public group, State Nuclear Power Safety Inspectorate (hereinafter VATESI ) shall inform the Entity owing the operating NI nearby which another Entity intends to start operation of the new NI as regards a revision of the Plan of existing NI. 25. If the same entity intends to start operation of a new NI nearby the operating NI that may impact the same public critical group, the entity is allowed to prepare and submit for approval a combined Plan for the operating and the new NI. VI. CONTROL OF THE RELEASE OF RADIONUCLIDES INTO THE ENVIRONMENT 26. The entity shall ensure the control of the release of the radionuclides to the environment performing pollution monitoring. 27. Pollution monitoring of the NI is executed under provisions of the procedure established by the Law on Environmental Monitoring of the Republic of Lithuania (Official Gazette, 1997, ; 2006, No ) and the monitoring of foodstuffs, raw materials and drinking water is performed under the procedure established by the Ministry of Health. 28. The entity shall collect and preserve data of pollution monitoring according to the procedure established by the Law on Documents and Archives (Official Gazette, 1995, No ; 2004, No ) and other legal acts that regulate document management. 29. The entity, in the course of operation or decommissioning of the NI, shall reduce to a minimum activity of radionuclides released to the environment. If in the course of pollution monitoring, it is identified that the activity of radionuclides released to the environment increases, then analysis shall be performed and the cause shall be eliminated by the Entity. 30. If release per day exceeds 1% of annual Activity limits of radionuclides, the Entity shall inform VATESI, the Environmental Protection Agency and the Ministry of Health within 3 days, submitting a forecast of pollution, indicating the reasons of pollution increase and actions to be taken to reduce the pollution. 31. If release per month exceeds 25% of annual Activity limits of radionuclides, the entity shall proceed with measures to reduce the release of radionuclides and, within 5 days, submit detailed information to the VATESI, the Environmental Protection Agency and the Ministry of Health, regarding reasons of the release and measures to be taken to reduce it. 32. The Entity, after identification that the activity limits of the radionuclides indicated in the Plan are exceeded, or detection of the radionuclides that are not indicated in the Plan, shall: Analyse reasons and consequences of the exceeding of the activity limits of the radionuclides indicated in the Plan, or the release of the radionuclides that were not indicated in the Plan; Take measures to eliminate the causes of the exceeding of the activity limits of the radionuclides indicated in the Plan or the release of the radionuclides that were not indicated in the Plan and to ensure that such situation will not recur thereinafter; Inform VATESI, the Environmental Protection Agency and the Ministry of Health within 5 days about the reasons of the exceeding of the activity limits of the radionuclides indicated in the Plan or the release of the radionuclides that were not indicated in the Plan and elimination of them, as well as preventive measures to be taken. 33. VATESI after receiving the information mentioned in paragraphs hereto, sets a deadline for elimination of the causes of the exceeding of the activity limits of the radionuclides indicated in the Plan or the release of the radionuclides that were not indicated in the Plan and inform the Entity, the Environmental Protection Agency and the Ministry of Health hereof. The deadline shall be specified considering the reasons of the increased pollution but not less than 14 days. 34. VATESI shall have the right to impose sanctions established by the Law on Nuclear Safety and other laws providing that the Entity did not eliminate within the set deadline the

6 exceeding of the activity limits of the radionuclides indicated in the Plan or the release of the radionuclides that were not indicated in the Plan. 35. If after performance of analysis of the release of radionuclides that were not indicated in the Plan and the reasons hereto, the Entity submits VATESI the documentation proving that the release of radionuclides that were not indicated in the Plan is not caused by NI activity, the provisions of subparagraphs 32.2, 32.3, 33 and 34 herein are not applicable. The information that the release of radionuclides that were not indicated in the Plan is not caused by NI activity and the results of the release analysis shall be submitted to the Environmental Protection Agency and the Ministry of Health by the Entity. 36. In those cases, when the Entity, after performing the analysis of the release of radionuclides that were not indicated in the Plan and the reasons hereto, submits VATESI the documentation proving that there is a possibility hereafter of the release of radionuclides that were not indicated in the Plan, the Entity, following the procedure established by the Law on Nuclear Safety, shall revise the Plan and submit for coordination the revised information, indicated in subparagraph 22 hereto. VII. SUPERVISION OF RELEASE CONTROL PREFORMED BY THE ENTITY 37. VATESI verifies the control of the release of the radionuclides performed by the Entity. 38. At the beginning of the following month, but not later than in 10 working days the Entity shall submit data to VATESI, the Environmental Protection Agency and the Ministry of Health regarding activities of the release of radionuclides per month, except 3 H and 14 C the data of which shall be submitted every three month. 39. Annual report regarding the activities of the release of the radionuclides released into the environment shall be submitted by 1 March of the following calendar year to VATESI and the Ministry of Health. 40. In the annual report, regarding the activities of the radionuclides released into the environment, it shall be indicated: The activity of radionuclides released to air and water (monthly) and total annual activity of radionuclides; Comparison of the activity of the radionuclides released to the environment and activity limits, normalized release; The tendencies and analysis of the pollution and its change; Estimated effective doses for members of critical public groups from radionuclides released per year (for each radionuclide, radionuclide pathway, groups of radionuclides and total for NI), and comparison of them with dose constraint; The reasons of the release of unplanned radionuclides into the environment, the analysis of the releases, if there are identified radionuclides that were not indicated in the Plan The reasons of the exceeding of doses for the members of critical public groups, if the exposure dose exceeds or may exceed the dose constraint for the members of the critical public groups; Other important information. VIII. FINAL PROVISIONS 41. The Entity shall be liable for the breach of these Requirements in accordance with the procedure established by Laws of the Republic of Lithuania.

7 Annex 1 to Nuclear Safety Requirements BSR Standards of Release of Radionuclides from nuclear installations and Preparation and Renewal of the Plan of Release of Radionuclides.. PECULIARITIES OF LIMITATION OF RELEASE OF RADIONUCLIDES FROM IGNALINA NPP 1. Dose factors F and limit activities A of the radionuclides released from Ignalina NPP are presented in Tables 1 and 2 hereto. Estimating these values, conservative assumptions were made and considered peculiarities of dispersion of radionuclides and population lifestyle typical for the environment of Ignalina NPP. 2. In a course of the selection of critical public groups, it was identified that the maximum impact of radionuclides emitted to air will be on farmers, and impact of radionuclides discharged to water on fishermen or gardeners (in case of transuranic nuclides). In order to keep up to the dose constraint, it was accepted that annual effective dose through each pathway (to air or water) shall not exceed 0.1 msv per year. 3. To estimate the radionuclide migration to air, semi-empirical Gauss method was applied and the average data of temperature, wind directions and speed, peculiarities of cloudiness, precipitation and ground surface. Radionuclide migration in ecosystem of water was simulated considering dilution, sedimentation, bioaccumulation and accumulation of radionuclides in the soil of a littoral zone. 4. In a course of simulation of radionuclide migration in the ecosystem of water and exposure of fishermen, external exposure dose from the lake was calculated. 5. In a course of evaluation of dose for members of critical groups, it was considered the following: 5.1. In the case of farmers external exposure from radionuclides in the air and deposited on the ground surface, and internal exposure caused by inhalable air and contaminated food; 5.2. In the case of fishermen external exposure from radionuclides in water and the soil of littoral zone, and internal exposure from consumption of fish In the case of gardeners external exposure from ground surface watered by lake water, internal exposure from consumption of foodstuff grown in the watered ground and inhaled resuspended soil particles.

8 Table 1. Dose factors and activity limits on radionuclides released to the air and water from Ignalina NPP Dose factor Dose factor Activity limit Activity limit Aj, Nuclide Fj, Nuclide Fj, Aj, Bq/year Sv/Bq Sv/Bq Bq/year 3 H I C I Na I Ar I Cr I Mn m Xe Fe m Xe Co Xe Co m Xe Zn Xe m Kr Xe Kr Xe Kr Cs Kr Cs Kr Cs Rb Cs Rb Ba Sr La Sr Ce Sr Pr Zr Eu Nb Eu Mo Eu Ru Np Ru Pu Te Pu I Note. Radionuclides from the Ignalina NPP can be released into the air through ventilation stacks (150m height) and through ventilation pipelines of the of radioactive waste treatment facilities (8-13 and 75m height), calculations are performed for three different heights: 150, 75 and 10 m. The results of calculations presented in the table are for the release of the radionuclides at the height of 150 m. In case of the release at the height of 75 m, the value F is multiplied, and the value A is divided by the coefficient 3.4. In case of emissions up to the height of 13 m, this coefficient is 37.

9 Table 2. Dose factors and activity limits on the radionuclides released to the air and water from Ignalina NPP Dose factor Dose factor Activity limit Aj, Activity limit Aj, Nuclide Fj, Nuclide Fj, Bq/year Bq/year Sv/Bq Sv/Bq 3 H I C I Na I Na Cs K Cs Cr Cs Mn Ba Mn La Fe Ce Co Ce Co Pr Zn Pm Sr Eu Sr Np Y Pu Zr Pu Nb Pu Mo Pu Ru Pu Ru Pu m Ag Am Sb Am Sb m Am Sb Cm m Te Cm Te Cm I Cm I Cm I Cm I Cm Note. Estimating the impact of the radionuclides, it was assumed that radionuclides released from Ignalina NPP with industrial water.