Review of rsa exemption orders
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Review of RSA Exemption Orders. Chris Wilson Radioactive Substances Division Defra. Overview. 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.

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Review of RSA Exemption Orders

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Review of rsa exemption orders

Review of RSA Exemption Orders

Chris Wilson

Radioactive Substances Division

Defra


Overview

Overview

  • 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

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

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

NORM (7)

  • Precipitated phosphate;

  • Phosphatic substances, rare earths;

  • Lead;

  • Uranium and thorium;

  • Prepared uranium and thorium compounds;

  • Geological specimens;

  • Natural Gas


Others 11

Others (11)

  • Electronic Valves, GTLDs, Testing Instruments, Smoke Detectors, Luminous Articles

  • Exhibitions, Schools, Hospitals

  • Waste Closed Sources, Storage in Transit

  • Sola


Exemption orders virtues

Exemption Orders - Virtues

  • Natural Radionuclides

  • Low level Artificial Radionuclides

  • Efficient for Same Activity at Different Locations


Exemption orders vices

Exemption Orders - Vices

  • Difficult to Interpret

  • Out of Date Descriptions

    • Materials/Products

    • Establishments


A new opportunity

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

Success Criteria

  • Proportionate, risk-informed legislation having:-

    • Clear language;

    • Legal robustness;

    • Flexibility

    • Transparency

  • Easier to use (and seen as such)


Exemption order review programme

Exemption Order Review Programme

Sponsors:

Defra, SE, WAG, EHS (NI), EA, SEPA, NDA


Governance

Governance

  • Programme board

  • Programme management

  • Projects and working groups


Overall programme

Overall Programme


Phase 2 plan

Phase 2 Plan


Review of rsa exemption orders

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


Review of rsa exemption orders

Options Assessment Process

Identify Options

Define Criteria and Attributes

Assessed by Expert Groups

Make Recommendation


Architecture

Architecture

  • What has been considered


Architecture cross cutting issues

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

Architecture - Revocations

  • Exhibitions – unused?

  • Precipitated Phosphates –unused?

  • Schools – Unique need?

  • Hospitals – Unique need?


Architecture schedule 1

Architecture - Schedule 1

  • Radionuclides v. Radioelements

  • Derivation of numbers

  • Inclusion of anthropogenics


Architecture sola

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

Possible Architectures


Numbers

Numbers

  • Exclusion

  • Unconditionally Exempt

  • Conditionally Exempt/Generically Authorised


Major dependencies

Major Dependencies

  • Environmental Permitting Programme

  • Revision of Euratom and IAEA BSS

  • Treatment of non-radioactive hazards and “waste”.


Current work

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

Contact us at

Programme officer Bini Shah - email comments to [email protected]


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