RPS Update
Best Practicable Means applied to radioactive
waste - A summary of guidance produced by BPM subgroup
to the Thames EA/RPA forum
Introduction
A recent revision in the RSA Authorisation template
is the introduction of a condition requiring the user to use Best Practicable
Means (BPM) to minimise the activity of waste that requires disposal
and to minimise the activity discharged to the environment. New RSA3
applications must now be accompanied by a summary of how the organisation
proposes to comply with BPM in the accumulation and disposal of radioactive
waste, i.e. a 'BPM statement'.
Part of the concept of BPM is that users should
consider the work procedures and the resulting radioactive waste generated
before the work starts, to ensure the minimisation of waste at all stages.
This process must be ongoing with reviews both periodically and whenever
there is a change of circumstances. The Environment Agency requires
that the BPM approach is adopted in an appropriate manner at a level
which is proportionate to the environmental risk. It is not expected
that the same level of time, money and trouble is put into identifying
BPM for the generation of waste from the use of small quantities of
activity as is required for large amounts. However, there is no de minimis
level below which BPM does not apply; proportionality is a key principle
of BPM.
Justification
The BPM statement should make reference to a justification
for the use of specified radioactive materials. This is the starting
point for BPM in that it establishes the need to use materials which
will ultimately generate the radioactive waste. The BPM statement itself
need not provide such details, but an indication of where the justification
is documented should be included. Justification may be included in a
risk assessment, an Administration of Radioactive Substances Advisory
Committee (ARSAC) document, a Local Research Ethics Committee (LREC)
document, Local Rules or management documentation. The justification
should take account of reasonably foreseeable incidents, normally also
included in a risk assessment.
Control of incoming radioactivity
Careful control of the activities of radioactive
materials procured needs to be demonstrated in the context of limiting
the amount of radioactive waste generated,. The BPM statement should
make reference to management systems for controlling the amounts of
incoming radioactivity, with an overview of ordering and receipt of
radioactive material and record keeping procedures. Reference should
be made to compliance audits and investigation procedures.
Minimising quantities used
The statement should refer to the basic principles
of embodying good laboratory practice for minimising the quantities
used and the waste generated. Examples include consideration of appropriate
pack sizes, stock sharing and scheduling work to optimise usage taking
account of reference or delivery dates. Justification for the practice
of ordering more than required should consider the balance of cost saving
weighed against the potential problems of additional storage, disposal
of unused stock and the implications for radiation dose.
Radioactive waste disposal methods
Reference should be made to the decision making
process for different disposal routes (e.g. VLLW, direct release vs.
decay storage), to risk assessments and to environmental impact assessments.
Consideration should be given to the process stage where waste is produced
and possible physical changes occur naturally, or are brought about
deliberately (such as use of activated carbon filters in fume cupboards,
absorbing liquids on to solid media, etc). Storage of waste for decay
or disposal should include procedures for segregation of the waste with
a fail-safe tracking system including identification and labeling, monitoring,
recording and auditing of the waste. The BPM statement will probably
make reference to Local Rules, contingency plans, written work instructions,
citations in experimental protocols and empirical estimates of waste,
such as excretion factors. The choice of waste disposal methods and
techniques employed should be documented and periodically reviewed.
Need help?
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