Application of the best available techniques

The optimisation of processes and implementation measures to reduce industrial discharges has a long history in the UK. The use of best prac­ticable means (BPM) to abate smoke and other stack discharges can be traced back to the Alkali Act (Amendment) 1874, which required that ‘the owner of every alkali work shall use the best practicable means of preventing the discharge into the atmosphere of all other noxious gases arising from such work, or of rendering such gases harmless when dis­charged. ’ Use of BPM became a regulatory requirement in various fields and was eventually integrated within the permitting process for managing radioactive wastes.

More recently, the Royal Commission formulated the concept of the best practicable environmental option (BPEO) to minimise total environmental impact in the context of multi-media discharges (RCEP, 1976). The Royal Commission on Environmental Pollution (RCEP)’s Twelfth Report (1988), elaborated on the concept, and defined it as: ‘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 benefits or the least damage to the environment as a whole, at accept­able cost, in the long term as well as the short term. ’

Whilst the concept of optimisation has been adopted globally, the BPM/ BPEO terminology has not been used outside the UK; and within the UK has not been widely used outside the nuclear sector for some years. The recent introduction of the Environmental Permitting Regulations (EPR) in England and Wales formed part of a major initiative to simplify and reduce the costs of permitting activities. In parallel, there has been a shift in regula­tion of the nuclear sector to adopt a more uniform approach consistent with other industry sectors. As a consequence, in England and Wales the use of BPM terminology has been discontinued and replaced with use of best available techniques (BAT), although in Scotland and Northern Ireland the use of BPM as an authorising tool will continue in the context of RAW management.

Early discharge authorisations (especially for gaseous emissions) were based on use of BPM with an implied ‘dilute and disperse’ philosophy and with less emphasis on numerical discharge limits. From the late 1970s numerical limits were increasingly established throughout the industry for both liquid and gaseous wastes. Over a similar timeframe the identification as BPM, and use of, interim ‘delay and decay’ storage tanks reduced, as the philosophy shifted to one of ‘concentrate and contain’ for disposal as solid waste.

In implementing BAT approaches to RAW management, a number of other principles are taken into account. The proximity principle requires the disposal of solid waste to be as close to its source as possible to minimise the environmental consequences of transportation. Proportionality is also a central theme in the application of BAT: the cost of implementation must be in proportion to the benefit of its introduction. In fact, the Environment Agency guidance states that all reasonable steps must be taken to reduce the doses to people unless the costs are ‘grossly disproportionate’ to the benefits (Environment Agency, 2010).

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