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 & waste Many 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Exemption Orders - Vices Difficult to Interpret Out of Date Descriptions Materials/Products Establishments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)

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

Governance Programme board Programme management Projects and working groups

Overall Programme

Phase 2 Plan

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 What has been considered

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 valuesNot 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

Numbers Exclusion Unconditionally Exempt Conditionally Exempt/Generically Authorised

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 /government/legislation/exemption_orders_revie w.htm

Contact us at Programme officer Bini Shah - comments to