Review of RSA Exemption Orders

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Review of RSA Exemption Orders

• Chris Wilson
• Radioactive Substances Division
• Defra

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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?

3
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

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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

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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

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Exemption Orders - Virtues

• Natural Radionuclides
• Low level Artificial Radionuclides
• Efficient for Same Activity at Different
  Locations

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Exemption Orders - Vices

• Difficult to Interpret
• Out of Date Descriptions
• Materials/Products
• Establishments

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A New Opportunity

• Objective is Better Regulation
• Options are Open to
• Change
• Revoke
• Add to
• Restructure EOs
• And even to alter Schedule 1

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Success Criteria

• Proportionate, risk-informed legislation having-
• Clear language
• Legal robustness
• Flexibility
• Transparency
• Easier to use (and seen as such)

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Exemption Order Review Programme

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

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Governance

• Programme board
• Programme management
• Projects and working groups

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Overall Programme
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Phase 2 Plan
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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
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Options Assessment Process
Identify Options
Define Criteria and Attributes
Assessed by Expert Groups
Make Recommendation
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Architecture

• What has been considered

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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

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Architecture - Revocations

• Exhibitions unused?
• Precipitated Phosphates unused?
• Schools Unique need?
• Hospitals Unique need?

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Architecture - Schedule 1

• Radionuclides v. Radioelements
• Derivation of numbers
• Inclusion of anthropogenics

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Architecture - Sola

• Is a general clearance/exemption value
  sufficient?
• Should it be nuclide specific?
• Should it be material specific?
• Should it include aqueous liquids?

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Possible Architectures
Do Nothing Minor Updates Full update of existing EOs Rebrigade EOs Top level EO(s) - detail in schedules Dose based approach
Do Nothing Minor Updates Reappraisal of numerical values Reappraisal of numerical values Reappraisal of numerical values Not applicable
Do Nothing Minor Updates Reappraisal of SoLA including high volume component (clearance?) Reappraisal of SoLA including high volume component (clearance?) Reappraisal of SoLA including high volume component (clearance?) Reappraisal of SoLA including high volume component (clearance?)
Do Nothing Minor Updates Reappraisal of Schedule 1 possible change to nuclide specific values or to include artificial Reappraisal of Schedule 1 possible change to nuclide specific values or to include artificial Reappraisal of Schedule 1 possible change to nuclide specific values or to include artificial Reappraisal of Schedule 1 possible change to nuclide specific values or to include artificial
Revocation of some EOs Revocation of some EOs Revocation of some EOs Revocation of some EOs Revocation of some EOs
Guidance Guidance Guidance Guidance Guidance Guidance
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Numbers

• Exclusion
• Unconditionally Exempt
• Conditionally Exempt/Generically Authorised

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Major Dependencies

• Environmental Permitting Programme
• Revision of Euratom and IAEA BSS
• Treatment of non-radioactive hazards and waste.

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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

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Contact us at

• Programme officer Bini Shah - email comments to
  eo-review_at_defra.gsi.gov.uk