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RSA 93 Exemption Order Review – a regulator’s view.

RSA 93 Exemption Order Review – a regulator’s view. Bob Russ Policy Manager Radioactive Substances Regulation. Objectives of presentation. To share some Environment Agency expectations in relation to the future exemption regime

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RSA 93 Exemption Order Review – a regulator’s view.

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  1. RSA 93 Exemption Order Review – a regulator’s view. Bob Russ Policy Manager Radioactive Substances Regulation

  2. Objectives of presentation • To share some Environment Agency expectations in relation to the future exemption regime • To raise awareness of future challenges • To provoke discussion on a replacement for SoLA • To canvass opinions

  3. Benefits of exemption for the regulators Where a practice/product: • entails negligible risk, and • is widespread, and • is justified or unavoidable then specific registrations and authorisations (“permits”) can legitimately be avoided, allowing regulatory effort to be directed to higher risk areas.

  4. Existing EOs • Products - (GTLDs, luminous articles, smoke detectors, electronic valves, etc) • Institutions - (hospitals, schools, exhibitions) • Natural radioactivity - (uranium & thorium compounds, lead, natural gas, geological specimens, precipitated phosphate, phosphatic substances, rare earths, etc) • Source related EOs - (storage in transit, waste closed sources, testing instruments) • Substances of low activity

  5. Some EA expectations of future exemption regime • Risk based • Based on sound science • No increase in overall burden on industry • No increase in burden on regulators • If it’s currently exempt it should, in general, remain so • The exemption regime should be designed to, as far as possible, accommodate new devices and practices (easy to change)

  6. ICRP concepts of exclusion, exemption and clearance. • Exclusion • Exemption • Clearance Should we make greater use of exclusion in future? Should we link exemption and clearance in the future in the way we have with SoLA?

  7. Regulatory effort v risk

  8. Hierarchy of regulation • Exclusion - Schedule 1 • Exempt practices/products • Simple permits (authorisations/registrations) • Bespoke permits

  9. Some upcoming challenges • NDA estimate 500,000 tonnes of metal from decommissioning • If the UK wants to deal with this by recycling then we need a more scientific approach than SoLA EO.

  10. EU exemption and clearance criteria • BSS Exemption Values • Radiation Protection 122 – General Clearance Levels • Radiation Protection 89 – Recycling of metals from nuclear decommissioning • Radiation Protection 113 – Clearance of buildings and rubble from nuclear decommissioning

  11. EU exemption values and clearance values (cobalt-60 example)

  12. Radionuclides with EU clearance value - 0.1 Bq/g Na-22, Sc-46, Sc-48, V-48, Mn-52, Mn-54, Fe-59, Co-56, Co-58, Co-60, Br-82, Z-95+, Nb-94, Tc-96, Ag-108m+, Ag-110m+, Sb-124, Te-132+, I-129, Cs-134, Cs-136, Ba-140, La-140, Eu-152, Eu-154, Tb-160, Ta-182, Ir-190, Ir-192, Bi-106,Bi-207, Th-228+, Th-229+, Th-230, U-232+, Np-237+, Pu-236, Pu-238, Pu-239, Pu-240, Pu-242, Pu-244+, Am-241, Am-242m+, Am-243+, Cm-243, Cm-244, Cm245, Cm246, Cm-247+, Cm-248, Cf-249, Cf-250, Cf-251, Cf-252, Cf-254, Es-254+.

  13. Radionuclides with EU clearance value – 0.01Bq/g Pb-210+, Po-210, Ra-226+, Ra-228+, Ac-227+, Th-232+, Pa-231,

  14. Some specific EA objectives from the review. • Replace radioelement and generic (SoLA type) criteria in Schedule 1 and exemptions with radionuclide-specific quantities and criteria • Base replacement for SoLA on international clearance criteria (EU or IAEA), subject to validation for the UK. • Look at how other EU Member States deal with exclusion, exemption and clearance. • Updated exemptions that are easier to use & regulate • Reviewed, and as far as possible, consistent disposal conditions

  15. Personal view. This is an opportunity to modernise our exemption regime and move it on to a scientific and risk based basis – let’s not waste it because of attachment to existing practices.

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