Environmental Impact of Stressors (Sustainability Assessment)
INPRO basic principle in the area of environmental impact of stressors: The expected adverse environmental
effects of an NES should be well within the performance envelope of current NESs delivering similar energy products.
Contents
- 1 Introduction
- 2 General features of an environmental assessment
- 3 Necessary INPUT for an INPRO assessment in the area of environmental impact of stressors
- 4 INPRO basic principle, user requirements and criteria in the area of environmental impact of stressors
- 4.1 INPRO basic principle: acceptability of expected adverse environmental effects
- 4.2 User requirement UR1: controllability of environmental stressors
- 4.3 User requirement UR2: reduction of total environmental impact of emitted radioactivity
- 4.4 User requirement UR3: optimization of the measures to reduce environmental impact
- 5 Appendixes
Introduction
Objective
This volume of the updated INPRO Manual provides guidance to the assessor of an NES (or a facility thereof)
that is planned to be installed, describing how to apply the INPRO methodology in the area of environmental impact
of stressors. The INPRO assessment should either confirm the fulfilment of all INPRO methodology environmental
CRs, or identify gaps (non-compliance with the INPRO methodology CRs) requiring corrective actions (including
research, development and demonstration (RD&D)) to achieve long term sustainability of the NES assessed.
The INPRO assessor (or team of assessors) is assumed to be knowledgeable in the area of environmental
impact of stressors and/or may be using the support of qualified national or international organizations
(e.g. the IAEA) with relevant experience.
Two general types of INPRO assessor can be distinguished: a nuclear technology holder (i.e. designer,
developer or supplier of nuclear technology) and a (potential) user of such technology. The role of the latter type of
assessor, i.e. a technology user, is primarily to check, in a simplified manner, whether the designer (supplier) has
appropriately taken into account the environmental aspects in the design as defined by the INPRO methodology.
A technology user is assumed to be primarily interested in proven technology to be installed in his or her country in
the near future. A designer (developer) performing an INPRO assessment can use this current publication to check
whether the (innovative) design under development, which is expected to comply with the existing IAEA safety
standards, meets the INPRO methodology environmental requirements for the assessment of sustainability of NES,
and can additionally initiate modifications during early design stages, if necessary, to improve the environmental
performance of the design.
In INPRO sustainability assessment, the term ‘technology user’ does not refer to an independent national
nuclear regulatory authority. INPRO sustainability assessment is most often part of strategic nuclear energy
planning. Typically, this planning activity is performed by national energy ministries, utilities (government or
privately held) and/or their various technical support organizations. In INPRO terminology, the ‘technology user’
is either the country (in a generic sense) or, more specifically, the owner and/or operator of the technology. The
‘technology holder or designer’ is the engineering company (government or privately held) that holds the intellectual
property rights on the technology. When discussing the specific context where trade agreements between countries
restrict or control transfers and uses of technology, the INPRO use of the term ‘technology holder’ may also refer to
the government under which the technology is ‘flagged’.
An assessor in a country embarking on a nuclear power programme has several options when using the
INPRO methodology that depend on the stage of the programme (see the introductory manual of the updated
INPRO methodology).
Every nuclear facility needs an EIA in order to be licensed and to become operational. The INPRO
environmental assessment is not intended to substitute this licensing activity, but should rather demonstrate that the
NES assessed is sustainable in the long term with regard to its environmental impact. Application of the INPRO
methodology cannot substitute fulfilment of any of the existing national requirements in this area. However, INPRO
CR determined in this publication follow the requirements of the IAEA safety standards, in particular, IAEA Safety
Standards Series No. GSR Part 3, Radiation Protection and Safety of Radiation Sources: International Basic Safety
Standards [2].
Scope
Environmental impact from NES involves two large groups of factors. One group impacting the environment
comprises the consumption of non-renewable resources including both fissile/fertile materials necessary to produce
nuclear fuel and other materials (e.g. zirconium). All these factors and consumption of electricity necessary to
construct, operate and occasionally decommission NES installations are considered in the INPRO methodology
manual on environmental impact from depletion of resources [3].
Another group comprises radiological, chemical, thermal and other stressors which NESs release into
environment. This group also includes water intake because this factor can be important for biota even when this
water is returned to the environment in a clean form (e.g. as steam from nuclear power plant cooling towers). All
these factors are considered in this INPRO methodology manual on environmental impact of stressors.
The INPRO methodology in the area of environmental impact of stressors covers only normal operation
and anticipated operational occurrences of NES facilities. Consequences of potential accidents are discussed in
the INPRO methodology manuals in the areas of safety of reactors and safety of the nuclear fuel cycle. Guidance
provided here, describing good practices, represents expert opinion but does not constitute recommendations made
on the basis of a consensus of Member States
Structure
In Section 2, general features of an environmental assessment are presented.
In Section 3, an overview of information that must be available to an INPRO assessor to perform the
environmental assessment is provided.
In Section 4, the background of the INPRO methodology BP for environmental impact of stressors, and the
corresponding URs and CRs, consisting of INs and ALs, are presented. At the CR level, guidance is provided on
how to determine the values of the INs and ALs.
Appendix I provides general information on types of stressor and separate, illustrative lists of stressors
(in the form of tables) for all facilities of an NES based on uranium and mixed oxide (MOX) fuel (as an example).
This appendix could be used by an INPRO assessor as a starting point to generate input for the BP evaluation.
Appendix II presents simplified environmental analysis methods of how to calculate the impact of radiological
stressors, i.e. the dose on humans and non-human biota (plants and animals). It also briefly discusses the calculation
of the impacts of chemical stressors on humans and non-human biota.
Appendix III illustrates the concepts for optimization of the management options for reduction of the
environmental impact of nuclear facilities.
Appendix IV provides basic information on the concept of collective dose, which is used in the INPRO
assessment method described in this publication.
Table 1 provides an overview of the BP, URs and CR in the INPRO methodology area of environmental
impact of stressors.
INPRO basic principle the area of environmental impact of stressors (acceptability of expected adverse environmental effects): The expected adverse environmental effects of an NES should be well within the performance envelope of current NESs delivering similar energy products. | ||
INPRO user requirements | Criteria | Indicator (IN) and Acceptance Limit (AL) |
---|---|---|
UR1: Controllability of environmental stressors: The environmental stressors from each facility of an NES over the complete life cycle should be controllable to levels meeting or below current standards
|
CR1.1: Radiation exposure of the public | IN1.1: Dose to the public |
AL1.1: Lower than the dose constraint | ||
CR1.2: Radiation exposure of non-human species | IN1.2: Doses to the reference biota species | |
AL1.2: Lower than international recommendations | ||
CR1.3: Impacts of chemicals and other non-radiation environmental stressors | IN1.3: Levels of chemicals and other stressors | |
AL1.3: Lower than national environmental safety standard levels | ||
UR2: Reduction of total environmental impact of emitted radioactivity:
Total radiotoxicity of radionuclides discharged by the NES assessed should be lower than that of any current NES delivering similar energy products |
CR2.1: Reduction of environmental impact of radiation | IN2.1: Total radiotoxicity of radionuclides emitted to the environment from the NES assessed (RT) |
AL2.1: RT is lower than the radiotoxicity of stressors emitted to the environment from a current NES delivering similar energy products | ||
UR3: Optimization of the measures to reduce environmental impact:
The measures applied to reduce adverse environmental impact attributable to an NES should be optimized |
CR3.1: Optimization of the measures to reduce environmental impact | IN3.1: Measures to reduce environmental impact of the NES |
AL3.1: Measures are optimized |
Concept of sustainable development and its relationship with the area of environmental impact of stressors of the INPRO methodology
The United Nations World Commission on Environment and Development Report [4] (often known as the Brundtland Report), entitled Our Common Future, defines sustainable development as: “development that meets the needs of the present without compromising the ability of future generations to meet their own needs” (see chapter 2, para. 1 [4]). This definition contains within it two key concepts:
“
- the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given; and
- the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.”
Based on this definition of sustainable development, a three part test for any approach to sustainability and
sustainable development was proposed within INPRO project: (i) current development should be fit for the purpose
of meeting current needs with minimized environmental impacts and acceptable economics; (ii) current RD&D
programmes should establish and maintain trends that lead to technological and institutional developments that
serve as a platform for future generations to meet their needs; and (iii) the approach to meeting current needs
should not compromise the ability of future generations to meet their needs.
At first reading, this definition may appear obvious, but when considering the complexities of implemented
nuclear energy technology and systems, plus their many supporting institutions, meeting the three part test is not
always straightforward because many approaches only meet one or perhaps two parts of the test in a given area,
and may fail on the others.
The Brundtland Report overview (para. 61 [4]) of the topic of nuclear energy summarized that:
“After almost four decades of immense technological effort, nuclear energy has become widely used. During this period, however, the nature of its costs, risks, and benefits have become more evident and the subject of sharp controversy. Different countries world-wide take up different positions on the use of nuclear energy. The discussion in the Commission also reflected these different views and positions. Yet all agreed that the generation of nuclear power is only justifiable if there are solid solutions to the unsolved problems to which it gives rise. The highest priority should be accorded to research and development on environmentally sound and ecologically viable alternatives, as well as on means of increasing the safety of nuclear energy.”
The Brundtland Report presented its comments on nuclear energy in chapter 7, section III [4]. In the area of
nuclear energy, the focus of sustainability and sustainable development is on solving certain well known problems
(referred to here as ‘key issues’) of institutional and technological significance. Sustainable development implies
progress and solutions in the key issue areas. Seven key issues are discussed (in this order):
(a) Proliferation risks;
(b) Economics;
(c) Health and environment risks;
(d) Nuclear accident risks;
(e) Radioactive waste disposal;
(f) Sufficiency of national and international institutions (with particular emphasis on intergenerational and
transnational responsibilities);
(g) Public acceptability.
The INPRO methodology for the self-assessment of sustainability and sustainable development of an NES is
based on the broad philosophical outlines of the Brundtland Report’s concept of sustainable development described
above. Twenty-nine years have passed since the publication of the Brundtland Report, and 15 years have passed
since the initial consultancies on development of the INPRO methodology in 2001. In the interim period of time,
significant historical events have starkly highlighted certain key issues. However, the key issues for sustainable
development of NESs have remained essentially unchanged over nearly three decades.
By far the most notable events in the period, which have a direct impact on nuclear energy sustainability, are
related to non-proliferation, nuclear security, cost escalation of new construction and, most notably, the accident at
the Fukushima Daiichi nuclear power plant in 2011. The Fukushima Daiichi accident further clarified that nuclear
safety is an issue of paramount importance for sustainability and that external hazards, associated with a particular
site, could be responsible for a dramatic common cause failure involving multiple reactor units.
In each INPRO methodology manual, a key issue of NES sustainable development is examined. The structure
of the methodology is a hierarchy of INPRO BPs, URs and CRs measuring whether the UR has been achieved.
Under each BP, the CRs include measures that take into consideration the three part test based on Brundtland
Report’s definition of sustainable development which was described above.
This INPRO Manual focuses on the key issue of environmental stressors (radioactive, chemical, heat and
others) associated with NES development and deployment. It does not consider emissions of environmental
stressors under accident conditions. The topics of radioactive and chemical emissions during accidents are covered
under the INPRO areas of safety of reactors and fuel cycle facilities and are published in separate manuals.
In the broad sense of the full related technology chain, NESs are comparatively benign with respect to many
stressor emissions when compared to available, baseload non-NESs. For example, because the waste products
of nuclear fission are contained during all but severe nuclear accidents, releases of radiological species to the
environment from operating nuclear reactors are typically extremely small — at least one and often two or more
orders of magnitude below national regulatory limits and international standards [5]. In fact, radioactive emissions
from coal fired thermal power plants are often higher than for nuclear reactors of comparable scale. This is because
the coal and the resulting fly ash waste contain uranium and thorium oxides and radioactive progenies that are not
fully captured by emission controls. Chemical stressor emissions from nuclear reactors are also very small, whereas
chemical stressors (sulphur oxides, nitrogen oxides (NOX), mercury, dioxins, volatile aromatic hydrocarbons, etc.)
can be significant fugitive components of emissions from coal fired power plants. Although far cleaner than coal,
natural gas fired plants contribute significant emissions of NOX and emissions of methane associated with fuel
leaks. If carbon emissions are considered as an environmental stressor (an increasingly common position globally),
nuclear power is benign and comparable to renewable energy power sources such as hydroelectricity.
Typically, the largest shares of radiological and chemical stressor emissions from NESs originate from
mining, milling and spent fuel reprocessing fuel cycle facilities, as opposed to from nuclear reactors.
One area where nuclear power has similar environmental stressor impacts to other fossil fuel generation
technologies is waste heat rejection. More recently, advances such as supercritical coal and combined cycle natural
gas plants have increased thermal efficiency and thereby reduced the waste heat impacts and cooling water use
per unit of electricity produced by fossil fuel generation technology. However, if evaporative cooling towers are
used, these impacts can often be mitigated in both nuclear and fossil fuel generation technologies. Next generation
nuclear reactors also promise significant increases in thermal efficiency, and certain high temperature plant designs
may allow practical air cooling.
This current INPRO Manual tests whether an NES is sustainable with respect to environmental stressors.
In the case of each NES installation, radiation exposure of the public is compared to the dose constraints. Radiation
exposure of non-human species is compared to the lowest values of international standards or national regulations
(when available). The total radiotoxicity of emissions is also evaluated as a broad metric to consider the reduction
of radiological impact on the environment. Moreover, the manual requests, in UR3, that evidence of optimization
of measures to reduce environmental impact is provided. Suggested optimization approaches include best available
techniques (BATs), best environmental practice (BEP), as low as reasonably achievable (ALARA) or as low as
reasonably practicable (ALARP), with social and economic factors taken into account.
As previously mentioned, environmental stressor impacts tend to be primarily associated with certain fuel
cycle facilities that are not broadly distributed. These facilities are often part of national economies of nuclear fuel
suppliers and service States that provide fuels and services as an export to other national economies. In certain
cases, it may be appropriate to parse available results of environmental assessments of these facilities to consider
separately the fraction of stressor emissions associated with national nuclear power generation and of exported
nuclear fuels and services. The INPRO CRs in this manual are set as total dose constraints and other types of
recommended or required thresholds. The sustainability requirements in the INPRO area of environmental impact
of stressors are fulfilled when all ALs are met, but it is also important to understand the balance of environmental
impacts accepted in exchange for domestic power generation (a broad public good) and in exchange for exported
nuclear fuel products and services (potentially a narrower or broader public good, depending upon the tax/tariff
structures associated with the industry). Understanding this balance is a central question in cost–benefit analysis
(CBA) regarding development of the national NES, which is discussed in the INPRO methodology area of
infrastructure [6].
The NES is expected to meet the three part test based on the Brundtland Report’s definition of sustainable
development if all ALs in all areas are met as outlined in the INPRO methodology.
Protection of the environment is a major consideration in the processes for approving industrial activities in
many countries. The level of societal concern for the environment internationally is clearly indicated in several
documents, in addition to the Brundtland Report [4], reflecting international consensus, notably the Rio Declaration
on sustainable development [7], i.e. the Rio Declaration on Environment and Development, Agenda 21, the Statement
on Sustainable Development of Forests, the United Nations Framework Convention on Climate Change and the
Convention on Biological Diversity. Other related documents are the United Nations resolution on institutional
arrangements for the Implementation of the Global Programme of Action for the Protection of the Marine
Environment from Land-based Activities [8], the Joint Convention on the Safety of Spent Fuel Management and
on the Safety of Radioactive Waste Management [9], the IAEA Convention on Nuclear Safety [10], the Convention
on Environmental Impact Assessment in a Transboundary Context (Espoo Convention) [11], the Convention on the
Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Convention) [12], the Convention
for the Protection of the Marine Environment of the North-East Atlantic [13] and the European Commission
recommendation on standardized information on radioactive airborne and liquid discharges into the environment
from nuclear power reactors and reprocessing plants in normal operation [14].
Legacy of the past
In some cases, the legacy of the past may still burden the civil nuclear industry (e.g. Refs [15–20]). If the
nuclear industry in general claims its sustainability, this should be achieved for all of its facilities to prevent
objective criticism that may challenge the assertion (e.g. imported uranium used in a sustainable NES should come
from a mining/milling operation that complies with environmental standards at the time that the uranium for the
NES was extracted).
General features of an environmental assessment
This section provides some general background information on environmental issues, particularly on the environmental impact of stressors caused by an NES.
Concept of sustainable development
The concept of sustainability can be considered from several related, but different, points of view:
social, economic, environmental and institutional. This publication deals with the environmental dimension of
sustainability by considering stressors providing adverse impact to the environment.
Protection of the environment is a major consideration in the processes for approving industrial activities in
many countries. The level of international societal concern for the environment is clearly indicated in publications
reflecting international consensus, notably the Brundtland Report [4], the Rio Declaration on sustainable
development [7] and the Joint Safety Convention of the IAEA [9].
The common basic idea in these publications is that the present generation should not compromise the ability
of future generations to fulfil their needs and should leave them with a healthy environment. Nuclear power should
support sustainable development by providing much needed energy with relatively low burdens on the atmosphere,
water, land and resource use. Improvement of the technology should include improvement of its environmental
aspects to a degree that is consistent with importance to society and with the potential environmental performance
of competing technologies.
Interfaces of a nuclear energy system with the environment
An example of the different components or facilities of a complete NES is presented in Fig. 1, starting with mining and processing, through to the final disposal of nuclear waste.
An NES has several interfaces with the environment and other industries. From the environment, non-renewable resources such as fissile and fertile materials, e.g. uranium and thorium (orange arrow in Fig. 1), are removed and used in the NES, together with other non-renewable materials such as zirconium (bright yellow arrow in Fig. 1). On the other hand, the NES releases some stressors, e.g. radioactive nuclides, that have an adverse impact on the environment (pale yellow arrow in Fig. 1). In addition to these environmental effects, an NES is exchanging with other industries energy and industrial materials required for the installation, operation and finally decommissioning of the nuclear facilities (blue arrow in Fig. 1).
Performance of an environmental analysis
Figure 2 provides a general overview of how to perform an environmental impact analysis in steps.
Starting from the definition of sources, i.e. the facilities of the NES, the stressors from the sources are
identified, the pathways of the stressors to the receptors analysed, leading to the end point of the environmental
analysis, i.e. the impact/effect of the stressors on the recipients. As shown in Fig. 2, Stressors of NES facilities
include radioactive and non-radioactive chemical toxic emissions, heat discharges, noise, impacts on some
non-renewable resources, and water and land use, all with potentially adverse environmental effects, which may
occur on a local, regional or even global scale.
The actual environmental effects attributable to stressors may differ significantly with geographical location
and other site specific and project specific factors of the NES facilities. However, all things being equal, the lower
the level (magnitude) of a stressor, the lower will be the resultant environmental effect. Moreover, the stressors, as
opposed to environmental pathways and receptors, are more under the control of the designers of the NES.
Comparison between nuclear and non-nuclear energy systems
The results of sustainability assessment of NESs in the area of environmental impact of stressors can be used
in comparison with other non-nuclear energy systems only when they both have been analysed to a similar depth.
For example, some environmental stressors (e.g. greenhouse gases) that may be negligible in an NES need to be
kept in the list of stressors, enabling a comparison between different sources of power generation.
Types of stressor in a nuclear energy system
Any energy system will inevitably introduce stressors to the environment, such as release of radionuclides or
non-radioactive chemicals, and depletion of resources, with potentially adverse environmental effects (or impacts)
on a local, regional or even global scale.
The environment is considered to be composed of interacting systems, which, in turn, comprise biological
elements, i.e. fauna and flora, and physical elements, i.e. atmosphere, land, water and resources (e.g. used for
energy production). Impacts are considered to be those effects that alter the existing environment, either temporarily
or permanently.
The adverse environmental impacts usually covered in an EIA as part of the site licensing process include
health effects on people and non-human species. Both radiological and non-radiological (chemical) health effects
are considered. Trade-offs and synergies among the effects from different energy system components and different
environmental stressors are also considered, if possible.
Radionuclides discharged by an NES are stressors that are specific to (but not exclusive to) nuclear power;
in many cases, the public concerns on NES safety are related to the release of radionuclides into the environment.
At the same time, there are many other stressors such as toxic chemicals (e.g. acid mine drainage from waste rock),
heat rejections from once through cooling systems, land use, etc., that, in specific cases, might have a greater
negative impact than radionuclides released into the environment.
Regulatory standards for radiological stressors
For planned exposure situations, which is the case for the environmental INPRO assessments, exposures and risks are subject to control to ensure that the specified dose limits for occupational exposure and those for public exposure are not exceeded, and optimization is applied to attain the desired level of protection and safety. Paragraph 1.22 of GSR Part 3 [2] recommends that dose constraints are to be used “for optimization of protection and safety, the intended outcome of which is that all exposures are controlled to levels that are as low as reasonably achievable, economic, societal and environmental factors being taken into account”. It is further clarified that [2]:
“Dose constraints are set separately for each source under control and they serve as boundary conditions in
defining the range of options for the purposes of optimization of protection and safety. Dose constraints are not dose limits: exceeding a dose constraint does not represent non-compliance with regulatory requirements,
but it could result in follow-up actions.”
Although the dose limits, expressed as an annual effective dose to the representative person, are generally
set at the level of 1 mSv, dose constraints are quite different in different countries (see Table 12, in Appendix II).
It should be emphasized that there are no constraints for the release of individual radionuclides. There is
also no international recommendation on the limits for concentrations of radionuclides in the environment. On the
other hand, there are so called reference (or authorized discharge limits [22]) levels for radionuclide discharges into
the environment. These reference levels are facility and site specific, and are the result of environmental analyses
with the objective to identify, with sufficient conservatism, allowable emission rates of radionuclides, so as to not
exceed dose limits.
Primarily, the effective dose to human population/non-human species can be considered as an indicator
of environmental impact of radiation release. Ambient radionuclide concentrations in terms of both individual
radionuclides and total alpha, beta or gamma activity can also be chosen to characterize radionuclides as a stressor
specific to nuclear power (see Table 2).
During normal operation of NES facilities, only small amounts of radioactive materials are released into the
environment, resulting in minor radiological impacts on the general public and the environment, i.e. the regulatory
limits are met with high margins [5].
Stressors | Parameters characterizing stressors | Units | Models |
---|---|---|---|
Radionuclides | Total alpha/beta activity in the environments of interest | Bq/m3 | Ref. [23]/National models |
Radionuclide activity concentrations in some appropriate media | Bq/m3 | Ref. [23]/National models | |
Annual effective dose to the population | mSv/a | Ref. [23]/National models | |
Doses to reference biota species | mGy/a | ERICA, RESRAD-Biota models [24] | |
Toxic chemicals | Heavy metals | kg/m3 | National models |
Organic compounds | kg/m3 | National models | |
Land commitment | Land temporally committed | m2/tU (or GW(e)) | None |
Land permanently committed | m2/tU (or GW(e)) | None | |
Particulates | Concentration of particulates released by facility into the air | g/m3 | National models |
Heat | Heat rejected by a facility per year | MW(th)/a | National models |
Solids | Concentration of solids dissolved in effluents | g/m3 | National models |
Concentration solids suspended in water | g/m3 | National models |
Regulatory standards for chemical stressors
In most countries, there are no regulatory limits (standards) for the emission of toxic chemicals into the environment. On the other hand, in most countries there are limits of toxic substances related to their ambient concentrations. Based on such considerations, environmental authorities of some countries establish reference levels for the emission rates of different chemicals, which are evaluated based on analysis of pollutant dispersion using environment models (computer codes).
Examples of stressors
Table 2 presents the NES stressors, the parameters characterizing the stressors that are limited by regulatory requirements and the available analytical models to calculate the impact of stressors.
Necessary INPUT for an INPRO assessment in the area of environmental impact of stressors
This section defines the necessary input and its sources for assessment of an NES in the INPRO methodology area of environmental impact of stressors.
Specification of the nuclear energy system
A prerequisite for INPRO assessment is the specification of the NES (see the introductory manual of the
updated INPRO methodology) to be assessed. The NES is to be defined by the INPRO assessor.
For an environmental assessment, in principle, the following aspects should be covered in the specification
of the NES:
(a) The complete NES should be considered, covering the entire front end of the fuel cycle, the energy conversion unit (reactor) and the entire back end. For all nuclear facilities, the complete lifetime should be covered, i.e. construction, operation and decommissioning.
(b) A global approach should be used, i.e. no geographical boundaries should be introduced that limit the environmental assessment.
(c) If necessary, environmental burdens may be divided into national (or regional) and those occurring outside the country (or regional) borders if such information would be required by stakeholders.
Thus, by meeting the above defined requirements, the general underlying principle of assessing the entirety
of environmental impacts would not be violated.
However, in general, cut-offs, i.e. selection of specific facilities of an NES, will be required in an INPRO
assessment. Such an approach is recommended for nuclear technology users and specifically in the case when a
State is embarking on a nuclear power programme, i.e. in such a country that the INPRO assessment in the area of
environment may consider only the first nuclear power plant and related waste management facilities, assuming
that in the later stages of the nuclear power programme, when more experience is accrued in the country, the scope
of further INPRO assessments will be expanded.
A nuclear technology developer may focus the environmental assessment (analysis) on the design of the
nuclear facility under development.
Information on environmental stressors
An INPRO assessor should have access to relevant design information, i.e. a list of all stressors together with
their levels (e.g. emission rates of radionuclides and chemical toxins, size of land use, etc.), of all NES facilities
to be assessed. This information should be available in design reports. The assessor should further have access
to information on the environmental characteristics of the sites planned for the NES facilities to be assessed.
This information should be available from the responsible government organization or utility.
An INPRO assessor should also have access to the same relevant design information of facilities of an
existing NES that are comparable to the NES facilities to be assessed. Such facilities are called comparable current
facilities in this publication. A comparable current facility means an operating facility of a given type which is
located on a site with environmental characteristics that are comparable to the NES facility assessed and licensed
according to the requirements comparable to the NES facility assessed. For such a comparable current facility,
a complete list of all its stressors and their licensed levels, e.g. emission rates of radionuclides and toxic chemicals,
should be available to the INPRO assessor from the potential supplier. The assessor should also have access to
important environmental characteristics, e.g. wind pattern, population density, etc., and the regulatory requirements
applied for such current facilities. The assessor should further have access to and knowledge of the environmental
standards of the country (or region) where the NES is (planned) to be installed. The national standards should be
available from the responsible government organization (e.g. via its web site). The same information is needed for
the comparable current facilities (if such an approach is planned to be used in the assessment).
The INPRO assessor should also have information to compare the radiotoxicity of release of all radionuclides
of the NES assessed with a current NES delivering similar energy products. For the purpose of the INPRO
assessment, the total radiotoxicity of an NES is defined through dose conversion factors for collective dose per unit
of release, as presented in Ref. [23].
Finally, the INPRO assessor should also have to consider the evidence, e.g. in the form of a written argument
to be provided by the potential supplier, to verify that an optimization procedure such as ALARP has been
performed during the design of all NES facilities to be assessed.
Other sources of INPUT
The INPRO assessor should contact the government organization responsible for environmental aspects to
receive information on the status of EIA studies related to nuclear facilities to be installed in the country as part
of the planned NES. If such studies already exist, most of the necessary input for an INPRO assessment should be
documented in them.
If a State is embarking on a nuclear power programme and using the IAEA service Integrated Nuclear
Infrastructure Review, applying the IAEA milestones approach of Ref. [25], the INPRO assessor should contact
the nuclear energy programme implementing organization responsible for this activity to exchange information and
assure coordination of this effort with the INPRO assessment.
INPRO basic principle, user requirements and criteria in the area of environmental impact of stressors
This section presents the BP, the URs and the CRs in the INPRO methodology area of environmental impact of stressors.
INPRO basic principle: acceptability of expected adverse environmental effects
INPRO basic principle in the area of environmental impact of stressors: The expected adverse environmental
effects of an NES should be well within the performance envelope of current NESs delivering similar energy
products.
Adverse environmental effects may arise from any facility and life cycle stage of an NES. Moreover, the
design and operation of one facility of an NES can have a major influence on the environmental effects of other
facilities. Therefore, in principle, the environmental performance of a proposed NES should be evaluated as an
integrated whole (see the footnote on the scope of the INPRO assessment in the area of environmental
impact of stressors).
The BP expresses an expectation that the environmental performance of the NES assessed will be better
than that of a current NES, which is an existing NES comprising facilities of the latest design that is licensed and
operating at the time that the INPRO assessment is performed. A current NES may or may not comply with the
current standards, depending on whether the current standards are different from those that were applied when the
current NES was implemented. However, as further clarified through the first user requirement, UR1,
the BP requiring that adverse environmental effects of an NES “should be well within” the performance envelope
of current NES implies, among others, that the expected adverse environmental effects of an NES assessed should
be within the current regulatory standards. Current standards are those prevailing at the time of the INPRO
assessment, and are normally met by recently licensed facilities. In some circumstances, it may be appropriate to
use an environmental standard that is expected to apply when the NES will be implemented.
Figure 3 provides some clarification of the BP. Each stressor caused either by an NES to be assessed — called
an “innovative nuclear energy system” in the figure — or by a current NES chosen for comparison, is represented
by a vector whose length is proportional to the level of the stressor, e.g. the release rate of a radioactive nuclide.
The radius of the circle passing along the vector represents the environmental standard for that stressor. In this way,
each stressor can be represented relative to its standard, and all standards will lie on the circumference (red circle
in Fig. 3). The number of stressors illustrated is arbitrary, and the relative magnitude of vectors representing
different stressors has no specific meaning.
Stressors arising from the current NES are shown as blue arrows, and their magnitudes (levels) are denoted
by LCNS-i.
The green arrows represent the stressors arising from an (innovative) NES to be assessed, and their magnitudes
(levels) are denoted by LNES-i. The BP assumes that each of the NES environmental stressors must be located inside
the red circle (i.e. must meet its standard) representing the current standards.
The level of stressors of a current NES may or may not be entirely inside this red circle, depending on
whether the current standards are different from those that were applied when the current NES was implemented,
as illustrated by LCNS-4.
As shown in the figure, some stressors arising from an (innovative) NES to be assessed may have a lower
magnitude (LNES-2, LNES-4, LNES-5) than the current NES, while some of them may be higher (LNES-1) or the same
(LNES-6, LNES-7). In the (innovative) NES to be assessed, some stressors from the current NES may be eliminated
(one is illustrated by LNES-3), while some new stressors (one is illustrated by LNES-8) may occur. Note that neither
the magnitudes of the blue or green areas nor the angles at which the vectors are drawn represent any real quantity,
they are for visualization only.
When all stressors are considered, the performance envelope of an (innovative) NES to be assessed
(green area) should be within the performance envelope of the current NES (blue area).
In case one (or more than one) of the stressors of the (innovative) NES to be assessed compares unfavourably
with the corresponding stressor of the current NES, multivariate analysis might be a possible tool to determine
the degree to which the NES to be assessed is within the current NES environmental performance envelope. An
alternative approach would be to express the level of all stressors commensurately so that they may be accumulated
into a single ‘figure of merit’. Both methods would introduce subjective judgements, but both methods would also
be useful for comparisons of one NES to be assessed to another.
When stressor levels, e.g. dose to the population or ambient concentrations of chemicals, are used as part of a comparison between different NESs, it is important to normalize the stressor levels to per unit energy values. Summarizing the statements above, the BP requires that the spectrum of environmental burdens of an (innovative) NES to be assessed remains within the performance envelope of the current NES (see Fig. 3). Thus, operating technology systems will not be substituted by others that are performing worse, but by technologies that tend to reduce environmental damages instead. The INPRO methodology has defined three user requirements UR1, UR2 and UR3 for the BP.
User requirement UR1: controllability of environmental stressors
User requirement UR1: The environmental stressors from each facility of an NES over the complete life cycle
should be controllable to levels meeting or below current standards.
As stated previously, any energy system will inevitably introduce stressors to the environment, such as
emission of radionuclides or non-radioactive (toxic) chemicals into the air and water, land use and depletion of
non-renewable resources, with potentially adverse environmental effects on a local, regional or even global scale.
UR1 asks that a designer (supplier) of an NES (or a facility thereof) provides controllability of all stressors
throughout the system. Controllability can be achieved by provision of appropriate systems (e.g. filters to reduce
emissions) and monitoring equipment (e.g. instrumentation and control equipment to measure release rates) [26, 27].
The operators of proposed nuclear facilities and processes will be responsible for controlling (and documenting)
the level of stressors during the lifetime of each facility of the NES.
All stressors of an NES facility should be controllable to levels meeting or below current regulatory standards,
i.e. those prevailing at the time the proposed NES is being assessed. In the following, guidance is provided to the
INPRO assessor on how to perform an assessment of CRs related to UR1, assuming the INPRO assessor is a
nuclear technology user planning to install, in their country, nuclear facilities supplied by a nuclear technology
holder.
If an EIA has already been performed for the NES facilities to be assessed and accepted by the authority in
the country as part of the site licensing process, CRs related to UR1 should be automatically met, i.e. no further
application of the INPRO methodology should be needed; however, the INPRO assessor should review the
corresponding reports and confirm that the EIA was performed with due consideration of international guidance
documents (e.g. Refs [28, 29]) and agreements (e.g. Refs [11–13]), and document a summary of the results of this
EIA in the assessment report.
As a guiding objective for the protection of the environment, theoretically, consideration should be given
to the widest possible spectrum of stressors. However, for practical reasons, the degree of inclusion of different
stressors in an INPRO assessment has to be limited.
The first step of determining the level of stressors of an NES facility is to produce a list of all relevant
stressors. For facilities of the front and back end stages of current NESs, an IAEA publication issued in 1996
presents an overview of major stressors, e.g. heavy metal intrusion into surface water and groundwater from mill
tailings and conversion sludge, and mitigation thereof by, for example, effluent treatment [30]. More recent results
of the studies, focused on specific details or new technologies, can be found in the proceedings of conferences or
scientific publications (see Refs [31, 32]).
In Appendix I, examples are provided to the INPRO assessor on which stressors to focus, in the form of tables
that list the important stressors of the facilities of an NES consisting of a water cooled reactor using uranium
oxide (UOX) and MOX fuel. Appendix I also presents brief descriptions of the processes in the individual nuclear
fuel cycle facilities.
Three types of stressor are covered by UR1 and defined in the tables of Appendix I, namely:
- Exposure of the public from radionuclides released to air and/or water (CR1.1);
- Radiation exposure of biota species (CR1.2);
- Other stressors such as ambient concentrations of toxic chemicals to air and/or water, land use, waste heat rejected, dust, etc. (CR1.3).
The media, i.e. water and/or air, and soil, that the stressors are impacting on are listed in the tables of Appendix I.
Use of a simplified environmental analysis
If an EIA has not yet been performed for the NES facilities to be assessed, it has not yet been accepted
by the regulatory authority or the radiation exposure data of the facility assessed are not available, the INPRO
assessor is offered an option to continue the environmental evaluation of the NES by trying to perform a simplified
(conservative) environmental analysis, as presented in Appendix II, to confirm whether the NES facilities to be
assessed will meet national regulatory standards at their planned site.
Use of a comparable current facility
In some particular situations, the simplified environmental analysis may be avoided for the purpose of INPRO
assessment, even if the EIA has not yet been completed, assuming that the INPRO assessor considers an NES
facility to be based on proven technology. Proven nuclear technology requires that a reference facility — called a
comparable current facility — exists that is licensed based on an EIA and that is in operation. The environmental
behaviour of such a comparable current facility in comparison to the NES facility to be assessed can be used in the
INPRO assessment.
UR1 is satisfied if, in all NES facilities, the levels of all important stressors (listed in Appendix I) are equal
or lower than those of comparable current facilities and, additionally, the NES facility satisfies all of the following
conditions:
- In the NES facilities assessed, no new stressors should appear.
- The environmental characteristics of the NES facility sites should be comparable to the ones of current comparable facilities.
- Comparable regulatory standards should have been (or will be) applied to both the current facilities and the NES facilities to be assessed.
To confirm the existence of a current comparable facility, the INPRO assessor should compare the
environmental characteristics of the planned site of the NES facilities with a site of current facilities. Important
environmental characteristics include, for emissions, the stack height of the plant, the hydrological conditions
(e.g. release into a river, a lake or the ocean), geology (type of soil, aquifers, etc.), meteorology (e.g. wind patterns),
human population distribution around the plant, food chains, endangered species, etc. In principle, all (potential)
sites of nuclear installations have different environmental characteristics. However, if important environmental
characteristics of different sites are comparable, the levels of stressors of facilities located at different sites can be
compared, too. A judgement on the comparability of two sites of nuclear facilities has to be performed by an expert
in the area of EIAs.
The INPRO assessor should perform (with support from an expert in environmental analyses) a comparison
of the regulatory requirements used for licensing of the current facilities and the ones applicable for the NES
facilities to be installed in the country.
If these additional conditions regarding new stressors, comparable environmental characteristics and
regulatory standards are not met, then the proposed approach of using the comparison against comparable current
facility is not applicable.
UR1 explicitly requires to be applied to each facility of the proposed NES, over its complete life cycle (with the exception of potential accidents and their consequences). The INPRO methodology has defined three CRs for UR1, as presented in Table 1.
Criterion CR1.1: Radiation exposure of the public
ᅠIndicator IN1.1: Dose to the publicᅠ
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Dose to a representative person is considered as IN1.1. Depending on the status of the assessed NES deployment, this information may be directly available from the design or licensing documents of the NES to be assessed. If these data cannot be found, a simplified environmental analysis (see Appendix II) should be performed by the assessor. Alternatively, a comparison with a current comparable facility (when applicable) can be used, as described earlier. |
ᅠAcceptance limit AL1.1 for dose to the publicᅠ
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Based on GSR Part 3 [2], regulatory authorities should define dose constraints as outlined in detail in IAEA
Safety Standards Series No. WS-G-2.3, Regulatory Control of Radioactive Discharges to the Environment [33].
A dose constraint should be set up by the regulatory authority for a single facility on a given site, taking into
account local conditions that are relevant for radiological impact on humans. More details on dose constraints are
given in Appendix II.
Use of a current comparable facility |
Criterion CR1.2: Radiation exposure of non-human species
ᅠIndicator IN1.2: Doses to the reference biota speciesᅠ
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Current international trends in radiation protection show an increasing awareness of the vulnerability of
the environment. These trends also indicate the need to be able to demonstrate (rather than to assume) that the
environment is protected against the effects of industrial pollutants, including radionuclides, in a wider range of
environmental situations, irrespective of any human connection. The system of protection and safety required by
GSR Part 3 [2] provides a basis for protection from the harmful effects of radiation of both the public and the
environment. This procedure is usually accomplished by means of an environmental assessment that identifies the
target(s), defines the appropriate criteria for protection and assesses the impacts on biota. |
ᅠAcceptance limit AL1.2 for doses to the reference biota speciesᅠ
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In the scientific annexes to the 1996 and 2008 United Nations Scientific Committee on the Effects of Atomic
Radiation (UNSCEAR) reports [38, 39], published data on the exposures and effects on non-human biota have
been evaluated. It has been found that “chronic dose rates of less than 100 μGy·h−1 (2.4 mGy·d−1) to the most
highly exposed individuals would be unlikely to have significant effects on most terrestrial communities” and “that
maximum dose rates of 400 μGy·h−1 (10 mGy·d−1) to a small proportion of the individuals in aquatic populations
of organisms would not have any detrimental effects at the population level”. These values are in agreement with
those reported elsewhere [40, 41], and reflect an international consensus on doses which could be considered as
acceptable for biota species. |
Criterion CR1.3: Impacts of chemicals and other non-radiation environmental stressors
ᅠIndicator IN1.3: Levels of chemicals and other stressorsᅠ
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Radiological impacts in a particular environment constitute only one type of impact, and, in most cases,
may not be the dominant impact of a particular facility or activity. Furthermore, the assessment of impacts on the
environment needs to be viewed in an integrated manner with other features of the protection and safety system
in order to establish the requirements applicable to a particular source. As there are complex interrelations, the
approach to the protection of people and the environment is not limited to the prevention of radiological effects on
humans and on other species. An integrated perspective has to be adopted to ensure the sustainability, now and in
the future, of agriculture, forestry, fisheries and tourism, and of the use of natural resources. |
ᅠAcceptance limit AL1.3 for levels of chemicals and other stressorsᅠ
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For toxic chemicals, the national licensing requirements should be used as AL1.3. For the other stressors
listed in Appendix I, national licensing requirements, e.g. the (normalized) amount of heat rejected to the ultimate
heat sink such as a river or ocean, should be used as AL1.3. |
Final assessment of UR1: Controllability of environmental stressors
The tables in Appendix I can be used by the INPRO assessor to check whether all important stressors of NES
facilities have been considered by the designer.
The acceptance limits AL1.1–AL1.3 of CR1.1–CR1.3 are met if, in all NES facilities, the levels of all
important stressors (listed in Appendix I) are in compliance with existing national or international standards.
User requirement UR2: reduction of total environmental impact of emitted radioactivity
User requirement UR2: Total radiotoxicity of radionuclides discharged by the NES assessed should be lower than
that of a current NES delivering similar energy products.
Radiation tends to be considered as a stressor that is specific to nuclear power, and the concerns of the
ecological safety of the nuclear industry are frequently related to the release of radionuclides into the environment.
As different radionuclides released by nuclear facilities, including waste management facilities, differ in terms
of producing detrimental health or environmental effects, the INPRO methodology suggests using the concept of
radiotoxicity to balance the effects of different radionuclides and to combine them in a single integral parameter.
In its simplest interpretation, radiotoxicity can be defined as the ability of incorporated radionuclides to cause
harmful health effects [42]. This simple definition gives a clear understanding of the basic approach; however, it
cannot be directly applied to the emitted radioactivity, as it does not consider the transport of radionuclides between
the emitter and receptors.
In order to take into account environmental pathways, the INPRO approach is based on application of
dose conversion factors for collective dose per unit activity discharged. The approach considers the discharge of
radionuclides into the atmosphere, freshwater bodies and marine water, thus covering some differences in locations
of nuclear facilities. Hence, radiotoxicity is defined in this publication as an activity of a radionuclide in a release
multiplied by a parameter reflecting a measure of hazard from a given radionuclide.
Although the dose conversion factors (or collective effective dose commitments per unit activity discharged)
are lump parameters, they are based on comprehensive calculations where many environmental transfer parameters
and reference input data for such assessments are included. In particular, the data provided in Ref. [23] are given
for both a simple generic model, which can be used to estimate collective doses for the transfer of radionuclides in
the environment originally developed by UNSCEAR [43], and more complex models, which consider some site
specific factors. To provide comparable bases for assessment of new NESs, generic global parameter values are
used with these models.
For atmospheric releases, three exposure pathways are considered: inhalation, ingestion of terrestrial foods
and external radiation from deposited material. A population density is required in this calculation of collective
dose; for the purposes of calculating screening values, a population density of 35 people per km2 is used [23]. This
represents a global average; considerably higher densities can be found in some countries, while lower densities
can be found in others. The foods considered are: grains, green vegetables and fruit, root vegetables, milk and
meat. Global average yields of particular foods are also required and are taken from the compilation of the Food
and Agriculture Organization of the United Nations (FAO). These are the collective effective dose commitment
values calculated using the effective dose coefficients given in Ref. [23]. In most cases, the values are of the same
order as, or in the range of, the collective doses obtained from the more complex models, and are also presented in
annex VII of Ref. [23].
For releases of radionuclides in liquid form, their dispersion and subsequent transfer to humans will vary
considerably depending on the characteristics of the receiving water body. Although, the general model is used,
account is also taken of the transfer of radionuclides to sediments through the use of the sediment distribution
coefficient Kd. The exposure pathways considered are the consumption of drinking water and aquatic foods.
UR2 explicitly requires to be applied to each facility of the proposed NES, over its complete life cycle, and to
consider the total environmental impact from discharged radioactivity.
The INPRO methodology has defined one CR for UR2, which is presented in Table 1.
Criterion CR2.1: Reduction of environmental impact of radiation
ᅠIndicator IN2.1: Total radiotoxicity of radionuclides emitted to the environment from the nuclear energy system assessedᅠ
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For the purposes of the INPRO assessments, the radiotoxicity Rki,j is defined as the integral activity (Ai,j, in units
of Bq) of radionuclide (i) discharged per GW∙a for each type of release (j) from a given facility (k) multiplied by
the corresponding dose conversion factor for collective dose (DCFi,j , in man Sv/Bq), as given in Ref. [23]: It must be realized that the concept and product of the radiotoxicity assessment used in UR2 (CR2.1) are
different from those required in UR1 (CR1.1). Annual effective dose is used for assessment of the compliance with
radiation safety standards for the public exposure (UR1). Dose conversion factors for the collective effective dose
commitment used for assessments of radiotoxicity are integrated to infinity, providing an IN of the total impact of
the discharge of radionuclides to the environment within UR2. where Nj is the number of radionuclides released to environment j. Then, the total radiotoxicity of the release from the proposed NES (RT) can be calculated by: where M is the number of nuclear facilities that constitute the NES. If only one new facility (e.g. a new nuclear
power plant) is added to an existing NES, the comparison of radiotoxicity should be done only between newly
introduced and former elements of the NESs, as the radiotoxicity of the remainder of the NES remains the same. |
ᅠAcceptance limit AL2.1 for total radiotoxicity of radionuclides emitted to the environment from the nuclear energy system assessedᅠ
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Total radiotoxicity is an integral parameter, and should be calculated based on the releases of all facilities
constituting the NES, i.e. environmental analysis should be performed at the whole NES level. The acceptance
limit AL2.1 of CR2.1 is met if the total radiotoxicity evaluated for the proposed NES is lower than that of any
current NES which provides the same energy products. |
User requirement UR3: optimization of the measures to reduce environmental impact
After confirming that UR1 and UR2 are fulfilled, the next step of an INPRO assessment is to check whether
the NES facility design has been adjusted by the designer (supplier) to provide optimized protection of the
environment.
GSR Part 3 [2] is based on the ten fundamental safety principles stated in IAEA Safety Standards Series
No. SF-1, Fundamental Safety Principles [44]. Fundamental Safety Principle No. 5 of SF-1 [44] requires
optimization of protection and states that “Protection must be optimized to provide the highest level of safety that
can reasonably be achieved.” More specifically, para. 3.24 of GSR Part 3 [2] requires:
“For occupational exposure and public exposure*, registrants and licensees shall ensure that all relevant
factors are taken into account in a coherent way in the optimization of protection and safety to contribute to achieving the following objectives:
(a) To determine measures for protection and safety that are optimized for the prevailing circumstances, with account taken of the available options for protection and safety as well as the nature, likelihood and magnitude of exposures;
(b) To establish criteria, on the basis of the results of the optimization, for the restriction of the likelihood and magnitudes of exposures by means of measures for preventing accidents and for mitigating the consequences of those that do occur.”
“* Requirements for the optimization of medical exposure are specified in paras 3.162–3.177.”
User requirement UR3: The measures applied to reduce adverse environmental impact attributable to an NES
should be optimized.
It is suggested that the principle of pollution prevention [45] should be applied for this purpose by the
designer, i.e. reduction of the amount and level of the stressor produced in the NES is the most favoured means of
reducing potential environmental impacts.
As stated earlier, the NES to be assessed should be held to higher environmental standards than a current NES. Therefore, UR3:
- Applies the philosophy of achieving the best environmental performance reasonably practicable for an NES facility to be assessed;
- Covers all adverse environmental effects, not only the radiological effects on humans;
- Continues to recognize that costs incurred to enhance environmental performance should not be greatly disproportionate to the achieved benefit.
The INPRO methodology has defined one CR for UR3, which is presented in Table 1.
Criterion CR3.1: Optimization of the measures to reduce environmental impact
ᅠIndicator IN3.1: Measures to reduce environmental impact of the nuclear energy systemᅠ
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There are several options available to the INPRO assessor on how to confirm whether the measures to decrease
the environmental impact of stressors of an NES facility are optimized. This INPRO Manual is not intended
to provide any specific recommendations or indicate preferences on which optimization concept and approach
should be used for such a purpose, and relies instead on regional or national expertise in this area. Possible options
demonstrating optimization of the measures decreasing environmental impact are the BATs, the BEP or the best
available technology not entailing excessive costs (BATNEEC) concepts. Other techniques such as the ALARA or
ALARP concepts can also be used by the designer of an NES facility to demonstrate that measures to provide a
reduction of the environmental impacts are optimized depending on the requirements of national regulations and
experience.
The relationship and differences between the BEP and BATNEEC concepts can be summarized as
follows [47]. BATNEEC is construed to mean the provision and proper maintenance, operation, use and supervision
of facilities which are the most suitable for the purposes. The manner in which this is to be achieved is wide
ranging, but with the overall objective that BATNEEC will be used to limit, abate or reduce an emission from an
activity. The focus is on defined activities, though also addressing areas such as treatment of waste. BEP is more
comprehensive, addressing the entire product life cycle through a combination of practices. These practices may
involve producers, importers, distributors, commercial users and the general public, as well as those engaged in
the collection, recovery or disposal of the substance when it enters the waste stream [47]. Detailed introductory
information on the BAT and BEP methods and an example of application are provided in Appendix III. |
ᅠAcceptance limit AL3.1 for optimization of the measures to reduce environmental impactᅠ
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The Aacceptance limit L3.1 of CR3.1 is met if evidence is available to the INPRO assessor that at least one of
the possible optimization approaches was duly applied by the designer of the NES facility assessed. |
Appendixes
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