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A note from SULG that EA have approved for posting on the SRP website
UPDATE ON RADIOACTIVE SUBSTANCE REGULATION POLICY MATTERS
EA/SULG Meeting 11 June 2003
1. High Activity Sealed Sources Directive. The draft HASS
Directive will apply controls, additional to those required by the BSS
Directive, to high activity sealed radioactive sources. These additional
controls are intended to protect human health and the environment, and
will apply to sealed sources with activity exceeding 1% of the A1
value, for the relevant radionuclide, as defined in IAEA Regulations for
Safe Transport of Radioactive Materials (TS-R-1).
Defra have led the negotiations on the draft Directive and have advised
the Agency that the text has now been finalised, it is expected to be published
and in force during the autumn of this year. Member States will have
two years to implement the Directive and are currently considering the
optimum mechanism for implementation (Direction, amendment of primary legislation,
secondary legislation, etc).
Implementation of the Directive will entail additional obligations on
the holders of HAS sources and new duties for the relevant regulators.
One aspect under consideration is that of creating a national register
of sealed sources. Another key issue raised by the Directive that
is receiving attention, is the requirement for applicants for registration
to have satisfied the regulators that they have made adequate financial
provision for the safe management of the source when it eventually becomes
disused. The Commission have advised that this might entail; a bank
deposit (under government control), or an auditable provision, or insurance
provision.
2. Radioactive Source Security. A number of initiatives
are currently underway to improve the security of radioactive sources,
both at the international and national levels, these include:
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International Conference, Vienna 10- 13 March
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Revised IAEA Code of Conduct
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Draft IAEA TECDOC on source security
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HASS Directive
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UK source security guidance and police Counter Terrorism Security Adviser
visits
It is proposed that the source security guidance is prepared on a sector
basis (health, research & teaching, and industry), and that the guidance
is risk based and proportionate. The Agency has provided the CTSAs
with the addresses of approximately 15% of the registered premises in England
and Wales which it considers worthy of a visit.
3. Development of UK policy for radioactive waste management:
The Government has issued a progress report to the EFRA Select Committee;
key points include:
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The Government welcomes and supports the HSE/EA/SEPA proposals for better
controls on waste conditioning and storage on nuclear sites. It has asked
the regulators to work up detailed proposals, including a regulatory impact
assessment.
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Advertisements have been placed for the chair and members of the new independent
body, “Committee on Radioactive Waste Management” (CoRWM), to advise government
and in due course, decide the best option for managing radioactive waste
in the long term.
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There has been a pilot exercise in Scotland for recovering and managing
spent sealed radioactive sources. The Government is considering how
this could be taken forward in the UK more generally, with an amnesty for
unwanted sources being one possibility. Availability of facilities
at nuclear sites to receive and package the sources are key to managing
disused sources.
The setting up of CoRWM has raised the issue of the future role for RWMAC.
The chairman of RWMAC has written to Michael Meacher and to the devolved
administrations to express concern over the areas of work which would not
be covered if RWMAC were abolished. A copy of his letter can
been seen on the RWMAC web site, www.defra.gov.uk/rwmac/index.htm.
4. Nuclear Reform Bill: The proposed Nuclear Site
and Radioactive Substances Bill will set up the Nuclear Decommissioning
Authority. The Agency has commented to Defra and DTI on drafts of the Bill
clauses. They include proposed amendments to RSA 93 which will include
a requirement for regular reviews of authorisations and provide the facility
for an undertaking to apply for a variation to its authorisation, which
currently does not feature in RSA 93. It will also allow transfers
of authorisations between owners/operators of premises situated on nuclear
sites. The draft Bill is expected to be published this month. It
is expected that the Bill will be introduced into parliament in the 2003/2004
session, with a view to the Nuclear Decommissioning Authority becoming
operational from April 2005.
5. Radioactively contaminated land: The Agency is one of a number
of organisations working with Defra to develop the outline of new regulations
on radioactively contaminated land, which will effectively extend the EPA
90 Part IIA contaminated land regime to cover hazards from radioactive
substances. Defra are soon to be instructing their lawyers to draft regulations
and statutory guidance, with a view to consult on these later in the year.
It is anticipated that these will not apply to contamination on licensed
sites, as this is regulated by HSE.
6. Pollution Inventory: The Radioactive Substances subgroup of
the Pollution Inventory Advisory Group met on 1 May 2003 to discuss proposed
radioactive substances and thresholds for the mandatory pollution inventory.
The inclusion of limited reporting of transfers was also considered.
The subgroup recommended some changes to the Agency's proposals.
These proposals will be subject to a wider consultation in summer 2003.
The proposals essentially involve a minor variation to introduce the information
provision condition to those authorisations which don't already have it,
followed by issue of a requirement under that condition to provide the
PI information. Details of the latter are still to be finalised.
7. Authorisation of discharges of radioactive waste to the environment:
Principles for the assessment of prospective public doses. This document
provides guidance on the assessment of prospective public doses arising
from authorised discharges of radioactive waste to the environment. The
guidance has been jointly agreed with the Scottish Environment Protection
Agency, Department of Environment, Northern Ireland, National Radiological
Protection Board and Food Standards Agency. The guidance is intended for
use by the sponsoring organisations when undertaking prospective radiological
assessments. It will also be useful to organisations applying for a new
or a variation to an existing radioactive waste discharge authorisation.
It is anticipated that the document will enable radiological assessments
to be produced in a more consistent and transparent manner. The document
is available at the Environment Agency’s website, http://www.environment-agency.gov.uk/business/ras/452235/ [Note by SRP Webmaster: The web address quoted gave an error message on 23 June 2003. The correct address is: http://www.environment-agency.gov.uk/business/444304/444637/ras/452235/?version=1&lang=_e (accessed 23 June 2003).]
8. European Commission’s proposed ‘Nuclear Package’. The
Commission have now published their proposals, which include:
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proposals for new legislation that would bring about the development of
common safety standards in Europe covering the full nuclear sector;
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segregated funds to cover all nuclear liabilities that remain after the
operating lifetime of an installation;
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clearly defined waste programmes for radioactive waste management in each
of the Member States of the Union.
The national waste management programmes are to include a number of decision
points:
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authorisation for development of appropriate disposal site(s) to be granted
no later than 2008. In the case of geological disposal of high-level and
long-lived waste, this authorisation could be conditional upon a further
period of detailed underground study;
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in the case of short-lived low and intermediate-level waste, if this is
to be disposed of separately from high-level and long-lived waste, authorisation
for operation of the disposal facility to be granted no later than 2013;
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in the case of high-level and long-lived waste, to be disposed of in a
geological repository, authorisation for operation of the disposal facility
to be granted no later than 2018..
The ‘Nuclear Package’ will lead to, inter alia, two new directives which
the Commission refer to as the “Safety Directive” and the “Waste Directive”.a>
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