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10 Glossary and Definitions
For a comprehensive list of terms and definitions used in nuclear safety and radiological
protection, see: International Atomic Energy Agency (IAEA) Safety Glossary, Terminology
used in nuclear safety and radiation protection, 2007 edition, http://www-
pub.iaea.org/MTCD/publications/PDF/Pub1290_web.pdf
. Terms and acronyms used in
this report are defined below.
Activity
A generic title for the practices or operations which require to be permitted
(unless exempted from the need for a permit)
ALARA
ALARP
As Low As Reasonably Achievable (economic and social factors being taken into
account). Radiation doses comply with ALARA when they have been reduced to
a level that represents a balance between dose and other factors (including
economics). This is a statement of the optimisation principle.
The term ALARP arises in the Health and Safety at Work etc. Act 1974, which
requires "provision and maintenance of plant and systems of work that are, so
far as is reasonably practicable, safe and without risks to health". The phrase So
Far As is Reasonably Practicable (SFARP), and similar clauses, is interpreted as
leading to a requirement that risks must be reduced to a level that is As Low As
Reasonably Practicable (ALARP). For a risk to be ALARP it must be possible to
demonstrate that the cost of reducing the risk further would be grossly
disproportionate to the benefit gained.
Attribute
A quality, property, or performance measure of an option that enables different
options to be scored or ranked in relation to one another. Depending on the
attribute concerned, the scoring or ranking process may lie anywhere in the
range from entirely objective to entirely subjective. Different attributes are not
normally commensurable with one another in any direct way and hence a
subjective weighting factor must be applied to each attribute if an overall scoring
or ranking of options is to be obtained.
Authorisation
The granting of regulatory permission to undertake an activity under licence. In
this document, the more generic term ‘permit’ is used, except where
Authorisations granted under RSA93 are specifically referred to, or where
information is cited direct from a source which uses the term Authorisation.
BAT
Best Available Techniques. See text throughout this document for a fuller
meaning and application.
BPEO
Best Practicable Environmental Option. The outcome of a systematic and
consultative decision-making procedure which emphasises the protection and
conservation of the environment across land, air and water. The BPEO
procedure establishes, for a given set of objectives, the option that provides the
most benefit or least damage to the environment as a whole, at acceptable cost,
in the long term as well as in the short term.
BPM
Best Practicable Means. BPM for radioactive waste management represents
the, “
level of management and engineering control that minimises, as far as
practicable, the release of radioactivity to the environment whilst taking account
of a wider range of factors, including cost-effectiveness, technological status,
operational safety, and social and environmental factors
”. BPM requires
operators to take all reasonably practicable measures in the design, operation
and management of their facilities to minimise disposals of radioactive waste, so
as to achieve a high standard of protection for the public and the environment.
BPM applies to minimising waste creation, abating discharges, and monitoring of
plant, discharges and the environment. It takes account of the availability and
cost of measures, operator safety and the benefits to be gained. BPM continues
to be required by the SEPA in authorisations issued under the Radioactive
Substances Act. BPM and BAT are considered to be essentially equivalent.
BSSD
Basic Safety Standard Directive (96/29/EURATOM)
CBA
Cost benefit Analysis
competent
persons
In this Code of Practice, taken to include (but not be limited to) SQEP, QE,
suitable RPAs and other qualified or experienced personnel.
DECC
Department of Energy and Climate Change. The Government Department with
policy responsibility for Radioactive Substances Regulation in England.
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Defra
Department for the Environment, Food and Rural Affairs. This is the
Government Department with specific responsibilities for EPR.
Discharge
The disposal of material in liquid or gaseous form by emission to the
environment.
Disposal
The long term disposal of solid, liquid or gaseous materials either by emission to
the environment or by emplacement in such a way that no retrieval of the
material is intended. The term ‘disposal’ is used throughout this document in
place of the more restrictive term ‘discharge’ except where citing information
from other sources or where the more restrictive term is clearly appropriate.
Environment
There is no fixed definition of the ‘environment’ within national law, as it is
usually taken to represent the sum of the surroundings – and therefore it is a
dependent quantity, rather than a fixed, independent, article. The environment
may be considered to include both the living and the physical surroundings, and
their interactions.
The interactions between individual members of different species in the
environment are complex, and competitive. Any living organism is constantly
under stress from other organisms and from physical agents. The relative
numbers of individuals and species fluctuate in time. Over long periods of time,
such as may be considered with respect to geological facilities for waste
management and disposal, species may vary as a result of evolutionary
changes, themselves a product of various stressors.
EPR 2010
Environmental Permitting Regulations (2010)
Environmental
Principles
Environmental Principles aim towards desired environmental outcomes. In
practice, they are a combination of International agreements, UK Government
policy and the Environment Agencies' policy choices.
Environmental
Sustainability
Sustainability is based on meeting the needs of the present without
compromising the ability of future generations to meet their own and requires an
analysis of the environmental, social and economic impacts.
EARWG
The Environment Agencies' Requirements Working Group
FSA
Food Standards Agency.
GRA
Guidance on Requirements for Authorisation. Regulatory guidance detailing the
environmental objectives which an underground facility for the permanent
disposal of radioactive waste must achieve. There are two versions of the GRA:
one for geological disposal of higher activity radioactive waste; and one for near-
surface disposal of lower activity radioactive waste.
GW
Groundwater (specifically in relation to a groundwater activity under the
Regulations)
HSE
Health and Safety Executive. Regulator with responsibilities for, amongst
others, IRR99 and NIA65.
HPA
Health Protection Agency
ICRP
International Commission on Radiological Protection
ILW
Intermediate Level Radioactive Waste
Integrated
Waste Strategy
An integrated waste strategy is an outline plan, taking account of environmental
principles, that can be applied consistently to all relevant actual and potential
sources of waste, both radioactive and non-radioactive. The scope may extend
to the whole site or even to multiple sites.
Justification
The benefits and detriments of any practice which could result in exposure to
ionising radiation must by assessed prior to the practice being permitted. If the
benefits outweigh the detriments, the practice is justified.
Limitation
Limitation provides a mechanism of dose limits which ensure that no individual
shall be exposed to ionising radiation leading to an unacceptable risk under
normal circumstances.
LLW
Low Level Radioactive Waste
LV-VLLW
Low Volume Very Low Level Radioactive Waste
Licensee
An operator licensed under NIA65
Multi-attribute
Analysis
An analysis of different options in terms of multiple attributes they possess. In
this document, a potential means of achieving a specified objective. An
appraisal carried out by any person or organisation of a range of possible
options for achieving a specified objective.
NIA65
The Nuclear Installations Act 1965
NII
Nuclear Installations Inspectorate
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NLS
Nuclear Licensed Site. The term refers to sites that have a nuclear site licence
under the Nuclear Installations Act 1965. More broadly, the Environment
Agency include sites that have applied for, but not yet been granted, such a
licence.
Optimisation
Optimisation is the process whereby an operator selects the technical or
management option that best meets the full range of relevant health, safety,
environmental and security objectives, taking into account factors such as social
and economic impacts.
Option
A potential means of achieving a specified objective
Options
assessment
Any formal and recorded method by which the ‘best’ solution is determined from
a number of possible alternatives.
OSPAR
Oslo and Paris Convention for the protection of the marine environment in the
north-east Atlantic. The UK is a signatory to this Convention, and is committed
to reducing discharges of pollution, including radioactive substances, to the sea.
Permit
The granting of regulatory permission to undertake an activity under licence. In
this document, the term permit is used to embrace all authorised or permitted
activities except where specific reference is made to terms under RSA93 or
where material is cited direct from source.
PPC
Pollution Prevention and Control.
Precautionary
Principle
Where there are reasonable grounds for suspecting that an action or policy
presents a risk of causing harm to the public or to the environment then, even in
the absence of scientific consensus that the action or policy is harmful, the
burden of proof that it is not harmful falls on those taking the action.
Proximity
Principle
Enabling waste to be disposed of in one the nearest practicable installation by
means of the most appropriate methods and technologies in order to ensure a
high standard of protection to the environment and public health.
QA
Quality Assurance
QE
Qualified Expert
Ranking
Placing options in order from highest to lowest against a particular attribute.
Regulated
facility
A collective term for the range of activities permitted under the Environmental
Permitting Regulations
REPs
Radioactive Substances Regulation – Environmental Principles.
Environment Agency guidance which sets out, at a high level, the principles
which the Environment Agency applies to RSR.
RPA
Radiation Protection Advisor
RSA
Radioactive Substances Act
RSR
Radioactive Substances Regulation.
SAPs
Safety Assessment Principles. HSE guidance which sets out, at a high level, the
principles which the HSE applies to safety cases.
Scoring
Placing a numerical value on an option in relation to a particular attribute.
Screening
Criterion
A criterion representing basic expectations in relation to the practicability of
proposed options; used to exclude one or more proposed options from further
consideration. May be based on feasibility, legal, policy or regulatory
constraints, or manifestly inferior performance against important attributes.
SFAIRP
So far As Is Reasonably Practicable
SQEP
Suitably Qualified and Experienced Person
Stakeholder
Any person or organisation that considers it has an interest in the BAT study
concerned. Stakeholders may include the relevant nuclear site operator, the
regulators and Government departments and persons or organisations other
than these such as the local community, suppliers and other groups.
Sustainable
Development
Development which meets the needs of the present without compromising the
ability of future generations to meet their own needs. Specific to radioactive
waste, the Government’s policy is to ‘ensure that radioactive waste is managed
safely and that the present generation, which receives the benefit of nuclear
power, meets its responsibilities to future generations’.
Uncertainty
Lack of definite information on a matter relevant to a BAT study
Waste
Hierarchy
A principle of waste management which requires that (in order of preference)
wastes be: Avoided; Minimised; Reused; Recycled; and, Disposed of.
Weighting
Factor
A factor applied to each attribute so as to obtain an overall scoring or ranking for
an option. Weighting factors are essentially subjective.
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Appendix 1. Legal Framework and Context
The output of BAT assessments must be practicable and compliant with safety and
environmental requirements (legal and policy). In demonstrating BAT, reference should be
made to relevant standards, guidance and good practice. Defra, DECC and the Welsh
Assembly Government have issued guidance to accompany the EPR
1
. This guidance
includes advice on permitting requirements in relation to government policy and European
directives.
This Appendix provides an outline of the key policies and legislation relating to BAT.
Figure A.1.
Key drivers relating to BAT
A1.1 European Directives and initiatives
Much of the legislation in the UK is driven by European policy. Key European Directives
and initiatives which have an influence on BAT policy in the UK include:
♦
The OSPAR Convention
for the protection of the marine environment of the North-
East Atlantic requires signatory countries to apply BAT and BEP (Best Environmental
Practice) as a means of preventing and eliminating marine pollution. BEP is defined as
“
the application of the most appropriate combination of environmental control measures
and strategies
”
2
. Where disposals resulting from the use of BAT and BEP do not lead
to environmentally acceptable results, additional measures must be applied.
♦
The Basic Safety Standards Directive
(Council Directive 96/29/EURATOM)
established basic safety standards (BSS) for the protection of the health of workers and
the general public against the dangers arising from ionising radiation. The Directive,
which came into force in May 2000, places a duty on Member States to keep the
exposure risks faced by the general public, both individually and collectively, to a
minimum (and certainly within prescribed limits). Fundamental to the BSS are the
principles of justification, optimisation and limitation of exposures.
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♦
Integrated Pollution Prevention and Control
(Council Directive 96/61/EC) is
designed to prevent or, where that is not practicable, to reduce emissions to water, air
and land (including waste) from various industrial sources, in order to achieve a high
level of protection for the environment taken as a whole. The key principle is the
requirement for an integrated approach to the granting of permits, taking account of the
whole environmental performance and the application of BAT. The Directive also
introduced a requirement for the development of BAT reference documents (BREF’s,
see http://eippcb.jrc.es/
) to ensure consistent application of BAT across EU Member
States.
♦
The Framework Directive on Waste
(Council Directive 75/442/EEC, as amended by
91/156/EEC) requires that Member States of the EU produce a National Waste
Strategy setting out their policies on the disposal and recovery of waste. The main
themes were developed from the concept of sustainable development and require that
an integrated and adequate network of waste disposal installations be established,
taking account of BAT, with self sufficiency in waste disposal in each member state.
A1.2 National Legislation
In England and Wales, the formal basis for the control of radioactive disposals, and other
aspects of the control of radioactive materials, is the EPR 2010
3,4
. In Scotland and
Northern Ireland control continues to be exercised through the Radioactive Substances Act
1993).
♦
Environmental Permitting Regulations 2010.
The EPR were originally introduced in
2007, as a means of achieving a streamlined permitting and compliance regime within
in England and Wales. The EPR combined aspects of the Pollution Prevention and
Control (England and Wales) Regulations 2000, the system of waste management
licensing in Part II of the Environmental Protection Act 1990 and the Waste
Management Licensing Regulations 1994. The regulations were extended in 2010 to
cover waste discharge consents, groundwater permits and radioactive substances
regulations.
♦
Radioactive Substances Act 1993
. In Scotland, SEPA regulates the management
and disposal of radioactive waste under RSA93. The primary purpose of this
legislation is to provide for the protection of public health against harm from discharges
of radioactive waste. Exposures to ionising radiation of the public are kept ALARA by
the use of licence conditions requiring the operator to use BPM.
♦
Ionising Radiation Regulations 1999.
The IRR99 set down requirements for the
safety of people who work with ionising radiations, including radioactive substances,
and effectively implement the BSS Directive. The Regulations impose a duty on
employers to protect their employees and other persons against radiation arising from
work with radioactive substances. It requires doses to be ALARP, and specifies dose
limits which must not be exceeded. The regulations are enforced by the Health and
Safety Executive or, in some cases, by local authorities.
♦
Pollution Prevention and Control 2000.
The PPC Regulations transposed the IPPC
Directive into national legislation. The Regulations introduced a requirement for
industries legislated under PPC to ensure that BAT is applied to activities and
operations in order to minimise impacts on the environment as a result of discharges,
emissions and waste generation. In England and Wales, the PPC Regulations were
repealed and replaced in 2007 by the EPR.
♦
Environment Act 1995.
The Environment Act 1995 is the mechanism by which the
European Framework Directive on Waste is implemented in the UK and effectively
requires BAT to be applied in relation to waste management activities. In England and
Wales, aspects of the Environment Act relating to waste management activities were
repealed in 2007 and replaced by the EPR.
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♦
Nuclear Installations Act 1965.
Under the NIA65 36 standard licence conditions (LC)
are attached to all nuclear site licences. These detail how licensed sites should be
managed by the operator. LC 32 requires site licensees to establish and implement
adequate arrangements to minimise the rate of production and total quantity of
radioactive waste and to record such waste.
A1.3 RSR Regulation Environmental Principles
The Environment Agency has issued guidance to their inspectors on Regulation
Environmental Principles (REPs)
5
and the assessment of BAT
6
in the regulation of
radioactive substances within England and Wales. This states that, in demonstrating the
use of BAT in choosing and implementing waste management options, an operator must
show:
♦
that they have selected the option, which best protects people and the environment as
a whole in both the short and long term; and
♦
that they have optimised the environmental impact of the preferred option, through the
choice of techniques proposed for its operation, maintenance etc.
The EA REPs guidance includes discussion of a range of principles that are relevant to the
application of BAT. This includes the general advice that BAT should be identified and
applied whenever new sites or facilities are planned, or when modifications to scope or
function are proposed for existing sites or facilities, or when there are reasons to believe
that substantially better options than are currently employed might be available.
Table A.1 Key principles for applying BAT within the EA REPs
Guidance
category
REP Developed
Principle (DP)
Key principles
Radiological
Protection
(RP)
RPDP1:
Optimisation of
protection
“
all exposures to ionising radiation of any member of the public
and of the population as a whole shall be kept as low as
reasonably achievable (ALARA), economic and social factors
taken into account.”
Compliance with ALARA should be achieved
by applying BAT.
RSMDP3: Use of
BAT to minimise
waste
“
best available techniques should be used to ensure that the
production of radioactive waste is prevented and where that is not
practicable minimised with regard to activity and quantity
.”
o
Processes creating, handling, treating and storing radioactive
materials should be chosen so as to prevent or minimise the
production of waste over the complete lifecycle
of the facility.
o
Optimisation should be demonstrated through options studies
,
particularly for new or changing facilities.
o
Processes producing radioactive waste should be reviewed at
intervals
, to identify opportunities to minimise waste
production.
Radioactive
Substance
Management
(RSM)
RSMDP4:
Processes for
identifying BAT
“the best available techniques should be identified by a process
that is timely, transparent, inclusive, based on good quality data,
and properly documented
.” It should be carried out by competent
and properly informed personnel.
o
Resources to identify BAT should be proportionate to the
environmental benefits.
o
The process should be fit for purpose. Decisions should be
documented, including identification of assumptions,
boundaries and constraints, demonstration of sufficient
information and integrity of conclusions. Uncertainties should
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