SRP 50th Anniversary ALARP Conference, Oxford University

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• SRP 50th Anniversary ALARP Conference, Oxford
  University
• BATing ALARP Out of CourtWhy the future of
  radiation protection lies in technology-based
  standards
• Using nuclear BAT principles as a framework for
  aiding decisions
• Ian Jackson
• Shehnaz Jackson
• 2 April 2003

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• OECD Expert Group Study
• The application of BAT principles to nuclear
  plants discussed in this presentation has been
  published in an OECD/NEA expert group study
  report.
• Effluent Release Options from Nuclear
  Installations Technical Background and Regulatory
  Aspects.OECD/NEA. Paris. 2003.

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• Regulatory Complexity

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• Emerging Trends
• Observing a shift in emphasis of legislation
  towards BAT for optimisation of nuclear
  installations.
• BAT defined very widely in OSPAR but IPPCgives a
  clearer insight about what is required.
• Need to translate high level OSPAR and IPPC
  policy objectives into nuclear BAT principles.
• For decision-aiding not decision-making.

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• Fuzzy Boundaries
• Key ideas underpinning ALARP are still
  relevantbut need to be reinterpreted to fit new
  realities.

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• Recent Growth of BAT in Europe
• Driven by the need to harmonise ECenvironmental
  protection legislation e.g.
• 1992 OSPAR Convention
• 1996 IPPC Directive
• 2002 Draft EC Nuclear Directives Package
• Sustainable waste management objectives
  contained within theDraft Council Directive on
  the Management of Spent Nuclear Fueland
  Radioactive Waste are likely to be harmonised to
  include BAT.

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• Influenced by Macroeconomic Forces
• Corporate burden concept where the cost of BAT is
  expressed relative to company costs or profits.
• National burden concept where the cost of BAT is
  compared to improvement in the quality of the
  receiving environment, regardless of the economic
  burden imposed on the individual company.
• EC Harmonisation favours national burden concept,
  based on common EC standards and technologies.

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• Nuclear BAT Experience
• Already some early BAT adopters in the nuclear
  sector, especially Germany and Sweden.

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• Chemical BAT Experience
• Mature system with 10 years UK experience of
  BAT(NEEC) regulation of major chemical plant.

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• American BAT Experience
• US has implemented similar concepts to BAT.
• EPA Clean Air Acts 1977-1990.
• RACT - Reasonably Available Control Technology.
• BACT - Best Available Control Technologies.
• LAER - Lowest Achievable Emissions Rate.

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• BAT Mechanisms
• BAT Mechanisms are a combination of
• Decision-making processes.
• Environment outcomes.
• Minimum environmental quality criteria.

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• BAT Mechanisms
• Decision-making processes must take account of
• "economic feasibility".
• "changes in scientific knowledge and
  understanding".
• "time limits for installation in new and existing
  plant".

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• BAT Mechanisms
• Environmental outcomes are intended to achieve
• "the use of low waste technology".
• "saving resources and the consumption of raw
  materials".
• "recovery and recycling".
• "minimise the nature and volume of discharges
  and emissions".
• "avoiding the use of hazardous substances".
• "avoiding the generation of hazardous wastes".
• "prevent accidents and minimise consequences".

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• BAT Mechanisms
• Minimum environmental quality criteria
• Act as a safety net if BAT techniques do notlead
  to environmentally acceptable results.
• Set standards for maximum permittedlevels of
  pollution in the environment(usually as a
  concentration limit).

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• BAT Environmental Outcomes

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• BAT Low Solid Waste Technology
• Minimise the creation of radioactivewastes from
  the nuclear facility.
• Radioactive wastes should becreated in a
  disposable waste form.
• Minimise treatment and conditioningnecessary to
  safely store wastes.

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• BAT Efficient Use of Resources
• Improve the eco-efficiencyof the nuclear
  facility (emissions/kWh).
• Jointly optimise both radioactive
  andnon-radioactive impacts to reduce the
  environmental footprint of the facility.
• Prioritise environmental expenditure tomaximise
  the amount of radioactive pollution avoided for
  each invested.

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• BAT Reduced Emissions
• Concentrate and contain environmentallypersistent
  or bio-accumulative emissions.
• Reduce transboundary geographicdisplacement of
  environmental impacts.
• Minimise potential radioactive releasesfrom
  credible accident conditions and their
  consequences for the environment.
• Progressively reduce doses to thepublic from
  radioactive facility emissions.

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• BAT Less Hazardous Substances
• Radioactive wastes should becreated in a
  passively safe waste form.
• Condition and immobilise unstable wasteforms
  into a passively safe state.
• Wastes should be capable of interim safe storage
  prior to final disposal in a repository.
• Wastes should be capable of being stored in a
  monitorable and retrievable waste form.
• Progressively reduce worker doses from waste
  treatment and conditioning processes.

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• Theory vs Reality

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• Optimum BAT - Modern Plant

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• Least Worst BAT - Legacy Plant

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• OECD Expert Group Study
• The application of BAT principles to nuclear
  plants discussed in this presentation have been
  published in an OECD/NEA expert group study
  report.
• Effluent Release Options from Nuclear
  Installations Technical Background and Regulatory
  Aspects.OECD/NEA. Paris. 2003.