Response 439118452

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About You

What is your name?

Name
Scottish Councils’ Committee on Radioactive Substances (SCCORS)_

Are you responding as an individual or an organisation?

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(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Scottish Councils’ Committee on Radioactive Substances (SCCORS)_

Part 2: Policy Overview

1. Do you agree with the benefits set out here?

Please select one item
Ticked Yes
No

Part 3: Key features of the new framework for authorisation holders.

7. Do you understand the descriptions of the regulated activities in Annex 2?

Please select one item
Ticked Yes
No
Comments:
Yes. The descriptions of those activities regulated by SEPA to which the consultation relates are clear. As SCCORS concerns itself with matters relating to Radioactive Substances its response focuses mainly on those matters dealt with Part 7 of the consultation.

Part 7: Radioactive Substances

39. Do you agree that it is appropriate to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?

If not, why not?
SCCORS agrees with the proposal to extend regulation to the management of radioactive substances whilst they remain on the premises where they were contaminated.

43. Do you agree that we should continue to exclude the public from the scope of the radioactive substances regulatory regime?

Please select one item
Ticked Yes
No
If not, why not?
SCCORS is content for the authorisation provisions to remain applicable only in relation to undertakings.

45. Do you agree with the proposals for applying the new regulatory regime to nuclear licensed sites?

Please select one item
Ticked Yes
No
If not, why not?
SCCORS supports the proposal to apply the new regulatory regime to the management of radioactive waste on nuclear licensed sites. We also support the proposal to regulate MOD authorised sites in a similar manner to civilian nuclear licensed sites buy their incorporation into the integrated authorisation framework.

47. Do you agree that SEPA should have the power to impose conditions in an authorisation requiring the permit holder to carry out operations off their site?

Please select one item
Ticked Yes
No
If not, why not?
Yes, SCCORS agrees that SEPA should have the power to impose conditions to compel an authorisation holder to carry out operations off their site. It should also be noted that SCCORS would like to see those radioactive substances registrations and authorisations affected by the proposed changes transitioned to the proposed new framework at the earliest opportunity.