Review of RSA Exemption Orders Chris Wilson Radioactive Substances Division Defra.
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Transcript of 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
18 RSA EXEMPTION ORDERS (including SOLA)They apply to:• specific practices/work activities• particular types of radioactive materials &
wasteMany 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
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• Out of Date Descriptions• Materials/Products• Establishments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)
Analysis of Data
Assess Options
Interdepartmental Consultation
Options to be approved by Programme Board
Ministerial Approval Sought for Public Consultation
Public Consultation on Architecture
Road Map to Consultation
Options Assessment Process
Identify Options
Define Criteria and Attributes
Assessed by Expert Groups
Make Recommendation
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
• 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 update of existing EOs
Rebrigade EOs
Top level EO(s) - detail in schedules
Dose based approach
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
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