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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

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  • Out of Date Descriptions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




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
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?



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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