Response 468482507

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About You

Are you responding as an individual or an organisation?

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(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Magnox Ltd

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

22. What other alternative arrangements would you suggest for managing non-standard applications?

Comments:
We agree that a realistic determination date should be agreed at the time of the application in order that the determination period is not unlimited.

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?
See response to question 40.

40. Do you foresee any practical implications of the proposal to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?

Do you foresee any practical implications of the proposal to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?
The proposal appears to result in a different definition of radioactive material in Scotland to that used in the rest of the United Kingdom. As an operator with sites in Scotland, Wales, and England, we consider this in principle to be an undesirable outcome. It is also not clear how this proposal ‘will simplify the legislation’ as claimed in paragraph 7.3.8. However, we note that the proposal is related to the ‘keeping and use’ of radioactively contaminated materials and that it is proposed in paragraph 7.3.24 that the keeping and use of radioactive material on a nuclear licensed site would remain exempt. As such, our understanding of the proposal is that there are not intended to be any practical implications for us as operators of nuclear licensed sites.

44. Do you agree with the proposed radioactive substances regulated activities?

If not, why not?
As the accumulation of radioactive waste on a nuclear licensed site is currently exempted from control under RSA93 (as it is controlled under different legislation), and the disposal of radioactive waste is not, the introduction of a term encompassing both activities implies the introduction of duplicate regulation for accumulation. This appears to contradict the overall intent of the proposed integrated authorisation framework to deliver ‘proportionate, joined up, outcome focussed regulation that significantly simplifies the regulatory landscape and reduces regulatory burden’ as stated in paragraph 1.1.2.

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

Please select one item
Yes
Ticked No
If not, why not?
No. We consider that the proposals as stated would result in duplicate regulation of the accumulation of radioactive waste at nuclear licensed sites. We consider this to be against the claimed aims of the integrated authorisation framework related to simplification and reduced regulatory burden. While we note the statement in paragraph 7.3.25 regarding ‘no intention, or desire, to duplicate any of the functions or responsibilities of ONR or impose additional regulatory burden on nuclear operators’, we do not consider that the proposals as stated are consistent with this statement.

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 – provided there is also a mechanism in place to ensure that other landowners allow the authorisation holder to carry out such operations on their land/site as described in paragraph 7.5.7.