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Review of RSA Exemption Orders

Explore the framework, major issues, and timescales for reviewing RSA Exemption Orders in the Radioactive Substances Division of Defra. Learn about the purpose, categories, virtues, vices, and opportunities for improvement of such orders.

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Review of RSA Exemption Orders

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  1. Review of RSA Exemption Orders Chris Wilson Radioactive Substances Division Defra

  2. 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

  4. 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

  5. NORM (7) • Precipitated phosphate; • Phosphatic substances, rare earths; • Lead; • Uranium and thorium; • Prepared uranium and thorium compounds; • Geological specimens; • Natural Gas

  6. Others (11) • Electronic Valves, GTLDs, Testing Instruments, Smoke Detectors, Luminous Articles • Exhibitions, Schools, Hospitals • Waste Closed Sources, Storage in Transit • Sola

  7. Exemption Orders - Virtues • Natural Radionuclides • Low level Artificial Radionuclides • Efficient for Same Activity at Different Locations

  8. Exemption Orders - Vices • Difficult to Interpret • Out of Date Descriptions • Materials/Products • Establishments

  9. A New Opportunity • Objective is Better Regulation • Options are Open to • Change • Revoke • Add to • Restructure EOs • And even to alter Schedule 1

  10. Success Criteria • Proportionate, risk-informed legislation having:- • Clear language; • Legal robustness; • Flexibility • Transparency • Easier to use (and seen as such)

  11. Exemption Order Review Programme Sponsors: Defra, SE, WAG, EHS (NI), EA, SEPA, NDA

  12. Governance • Programme board • Programme management • Projects and working groups

  13. Overall Programme

  14. Phase 2 Plan

  15. 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

  16. Options Assessment Process Identify Options Define Criteria and Attributes Assessed by Expert Groups Make Recommendation

  17. Architecture • What has been considered

  18. 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

  19. Architecture - Revocations • Exhibitions – unused? • Precipitated Phosphates –unused? • Schools – Unique need? • Hospitals – Unique need?

  20. Architecture - Schedule 1 • Radionuclides v. Radioelements • Derivation of numbers • Inclusion of anthropogenics

  21. Architecture - Sola • Is a general clearance/exemption value sufficient? • Should it be nuclide specific? • Should it be material specific? • Should it include aqueous liquids?

  22. Possible Architectures

  23. Numbers • Exclusion • Unconditionally Exempt • Conditionally Exempt/Generically Authorised

  24. Major Dependencies • Environmental Permitting Programme • Revision of Euratom and IAEA BSS • Treatment of non-radioactive hazards and “waste”.

  25. 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

  26. Contact us at Programme officer Bini Shah - email comments to eo-review@defra.gsi.gov.uk

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