Best Available Techniques
Code of Practice
Where previous appraisals have been undertaken, or good practice established, it may be
possible to demonstrate BAT without the need for more detailed consideration of options
(Section 5.8). This requires that the precedent is fully applicable to the facility in question.
In such instances, it may be sufficient for a short report to be produced comparing the
advantages and disadvantages of any alternative technologies or management practices
with those currently in use, together with a description of any improvements that will be
implemented following the study.
Such an approach must be reasoned, logical and transparent. It must contain sufficient
information to allow an informed review to be undertaken.
The purpose of a quantitative or semi-quantitative appraisal is to inform and assist in
identifying the best practicable option (Section 5.9). Assessments:
must be carried out in a systematic, consistent manner, including analysis of options
and assessment criteria, and identification of the best option;
require data on radiological impacts to workers and the public (under accident
conditions and normal operations);
need to consider non-radiological impacts and all relevant legal and policy, societal and
need to document all relevant risks and uncertainties.
For each short-listed option, underpinning technical and economic data should be collated
to support the selection of a preferred option (or options).
Implementation and Maintenance of BAT
Once BAT has been established it needs to be reviewed at appropriate intervals (Section
7). The requirement to implement and maintain BAT embraces:
proportionality of effort;
the provision, maintenance, and operation of relevant plant, machinery or equipment;
the supervision of any relevant operation;
taking samples and conducting measurements, tests, surveys, analyses and
calculations, to demonstrate compliance with limits and conditions.
Failure to operate equipment as intended, to inspect or maintain equipment such that it
remains in good working order, to train and supervise staff, or to monitor the effectiveness
of systems may be interpreted as a failure to apply BAT (Section 7.1).
The identification of BAT is an important element within the decision making process, but
does not necessarily represent the final decision (Section 6). For instance, a study may be
inconclusive, in that more than one approach may be regarded as essentially equivalent.
In such a case, an element of judgement is required. Likewise, a decision may be
influenced by other factors, either known at the time of the initial assessment or emerging
subsequently. For instance, there may be reasons for implementing a disproportionate
response. Where this is the case, the specific drivers need to be identified to avoid setting
this as a new benchmark. This reinforces the need to document information, including
constraints and assumptions, throughout the assessment process (Sections 5.11 and 7.8).
Subject to meeting regulatory obligations at all times, there may also be a balance to be