What is BAT (Best Available Techniques) as applied to UK environmental permits involving radioactive material or waste?
Published: Feb 20, 2022
Source: Ionactive Resource
When applying for a permit (or equivalent in the UK) it is important to understand the nature of the process which uses radioactive materials, and which goes on to produce radioactive wastes. Part of the application process is to determine the uses and waste arising - this being part of the BAT assessment. If releases to air or to the sewer (or other water body) are determined, then a Radiological Impact Assessment will be required. This is normally conducted by taking advice from the Radioactive Waste Adviser (RWA). The detail of any assessment will be proportional to likely exposures into the environment.
The process normally requires information collection, followed by calculation and assessment. The results of the assessment will be considered by the environment agencies (for the UK) who will also undertake their own assessment using their own models. It is usual for the RWA to use spreadsheet data and models which can be obtained from an agency regulator.
Elements of a BAT assessment
In the text that follows, "permit" is used to mean a permit in England and Wales, and an authorisation in Scotland or Northern Ireland.
BAT = "Best Available Techniques". However BAT is really more of a process than a phrase as outlined below.
Elements of a BAT assessment could include the following
Outline of BAT process and collection of information
- Definitions (Operator, Radioactive Waste Adviser, BAT, RSA2016 etc, Permits, LLW, VLLW etc)
- Management structure for environmental compliance (i.e. recognising the position and responsibility of the Operator)
- Noting qualified person are in place for consultation (e.g. Radioactive Waste Adviser)
- Justification for use of radioactive substances (i.e. consider alternative methods that might meet the same objective)
- Recognition and evaluation of a 'cradle to grave' approach (i.e. tracking radioactive substances coming in, all the way through to radioactive wastes going out - and minimising both)
- Radioactive materials and waste management (the procedures to secure compliance with permit conditions)
- Organisational structure (e.g. operator representative, Radioactive Waste Adviser, departments, users etc)
- Radioactive substances and waste policy (what you are going to go, and how you propose to do it)
Specific BAT Elements
- Justification and use of radioactive materials (work description, radionuclides and activities, alternatives and mitigations)
- Radiological assessment (method, aims and objectives, criteria - perhaps proving < 20 micro Sv/year, inputs and outputs)
- Abatement (justification if this should or should not be used)
- Training requirements (RWA, operator, users, goods in, packaging of radioactive waste etc)
- Details of how and why radioactive wastes are accumulated
- Workplace standards (details of the work area fixtures and fittings and their design to minimise radioactive waste during operations and reasonably foreseeable accidents)
- Management and supervision of the work with radioactive substances and radioactive waste
- Details of the control of the acquisition of radioactive substances - meeting permit conditions
- Details of the chosen radioactive disposal routes, and their limits and conditions
- Monitoring the workplace and radioactive waste (detecting workplace contamination and estimating / measuring / calculating radioactive waste activity)
- Record keeping (management of all the records to comply with the permit)
Some elements below are also included within the entries in the above list.
- Radionuclides involved including their activity, physical and chemical form
- How those radionuclides are manipulated ( e.g. heating, aerosols, using centrifuges, dilution etc)
- Radiological discharge assessments (e.g. to sewer, air)
- DPUR assessments for radiation exposures in the environment - using the regulator exposure models (excel spreadsheets)
- Decay calculations (e.g. where shorter lived radionuclides like P-32 are decayed to a point where they are no longer radioactive and then disposed as non-radioactive waste)
Formal Radioactive Waste Adviser (RWA) advice
The above resource may be used as a simple checklist or sanity check when undertaking a BAT assessment. It is not the full picture since this resource covers FAQ (i.e 'what is' rather than 'how to'). If you need formal advice then consider contacting the Ionactive Radioactive Waste Adviser (RWA).