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 To raise awareness of future challenges To provoke discussion on a replacement for SoLA To canvass opinions

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.

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

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)

ICRP concepts of exclusion, exemption and 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?

Regulatory effort v risk

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

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.

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

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

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+.

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

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

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.