rps-update-radioactive-wastes
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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.


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