Transcript Exemption Order Review Programme

Review of RSA Exemption Orders
Chris Wilson
Radioactive Substances Division
Defra
Overview
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What are exemption orders?
What is the framework for reviewing them?
What are the major issues?
What are the timescales?
What are the major dependencies?
Exemption Orders
18 RSA EXEMPTION ORDERS (including SOLA)
They apply to:
• specific practices/work activities
• particular types of radioactive materials &
waste
Many EOs over 30 years old; some have been
updated/amended
Purpose
• RSA ensures control over radioactive waste.
• Prior Registration for Keeping and Use
• Prior authorisation to Accumulate and Dispose
of Radioactive Waste
• EOs avoid over regulation
• Focus on significant cases
NORM (7)
Precipitated phosphate;
 Phosphatic substances, rare earths;
 Lead;
 Uranium and thorium;
 Prepared uranium and thorium compounds;
 Geological specimens;
 Natural Gas
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Others (11)
• Electronic Valves, GTLDs, Testing Instruments,
Smoke Detectors, Luminous Articles
• Exhibitions, Schools, Hospitals
• Waste Closed Sources, Storage in Transit
• Sola
Exemption Orders - Virtues
• Natural Radionuclides
• Low level Artificial Radionuclides
• Efficient for Same Activity at Different
Locations
Exemption Orders - Vices
• Difficult to Interpret
• Out of Date Descriptions
• Materials/Products
• Establishments
A New Opportunity
• Objective is Better Regulation
• Options are Open to
• Change
• Revoke
• Add to
• Restructure EOs
• And even to alter Schedule 1
Success Criteria
• Proportionate, risk-informed legislation having:• Clear language;
• Legal robustness;
• Flexibility
• Transparency
• Easier to use (and seen as such)
Exemption Order Review Programme
Sponsors:
Defra, SE, WAG, EHS (NI), EA, SEPA,
NDA
Governance
• Programme board
• Programme management
• Projects and working groups
Overall Programme
Phase 2 Plan
Road Map to Consultation
Analysis of Data
Assess Options
Interdepartmental Consultation
Options to be approved by Programme Board
Ministerial Approval Sought for Public Consultation
Public Consultation on Architecture
Options Assessment Process
Identify Options
Define Criteria and Attributes
Assessed by Expert Groups
Make Recommendation
Architecture
• What has been considered
Architecture – Cross Cutting Issues
• Revocations – what is not used and what is
covered elsewhere?
• Schedule 1 and Sola – what should be
excluded and what unconditionally exempt?
• How do we treat conditional exemptions?
• Guidance will always be needed
Architecture - Revocations
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Exhibitions – unused?
Precipitated Phosphates –unused?
Schools – Unique need?
Hospitals – Unique need?
Architecture - Schedule 1
• Radionuclides v. Radioelements
• Derivation of numbers
• Inclusion of anthropogenics
Architecture - Sola
• Is a general clearance/exemption value
sufficient?
• Should it be nuclide specific?
• Should it be material specific?
• Should it include aqueous liquids?
Possible Architectures
Do
Nothing
Minor
Updates
Full
Rebrigade Top level Dose
update of EOs
EO(s) based
existing
detail in
approach
EOs
schedules
Reappraisal of numerical values
Not
applicable
Reappraisal of SoLA – including high volume
component (clearance?)
Reappraisal of Schedule 1 – possible change to
nuclide specific values or to include artificial
Revocation of some EOs
Guidance
Numbers
• Exclusion
• Unconditionally Exempt
• Conditionally Exempt/Generically
Authorised
Major Dependencies
• Environmental Permitting Programme
• Revision of Euratom and IAEA BSS
• Treatment of non-radioactive hazards and
“waste”.
Current Work
• Working group on Schedule 1
• Impact of new numbers in EOs on LLW waste
volumes
• Current and anticipated uses of EO regime
• Meaning of ‘substantially insoluble’
• Updating Web Pages
• http://www.defra.gov.uk/environment/radioactivity/
government/legislation/exemption_orders_review
.htm
Contact us at
Programme officer Bini Shah - email
comments to [email protected]