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.
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.