Radioactive Waste Shipment (UK Brexit)

The Exit day is 12th April (the day after tomorrow) – the Exit time is 12.00 (midnight) CET

The UK Government today issued updated instructions on radioactive waste shipment – here.

Applications to import from EU countries will need to include evidence confirming that the exporter will take back the material if the shipment cannot be completed in accordance with the regulations.

Operators will need new UK documentation instead of previously used EU documentation.

Operators will now need to notify the relevant competent authority in the UK once exports to the EU are completed.

What operators need to do

1 Comply with current regulations until Exit day. These are set out in the Transfrontier Shipment of Radioactive Waste and Spent Fuel Regulations 2008.

[subscribers to Cardinal Environment EHS Legislation Registers & Checklists will not necessarily have these regulations loaded – email me if they are needed]

2 Read and understand the new Transfrontier Shipment of Radioactive Waste and Spent Fuel (EU Exit) Regulations 2019. These will apply from 13th April, or any later Exit day.

[these Regulations are found in the Brexit Law List loaded into Cardinal Environment EHS Legislation Registers & Checklists]

3 Check authorisations. Operators who already have authorisations should check if they are valid by contacting the relevant competent authority.

4 Apply for an authorisation, if needed. Operators without existing authorisation will need to apply to the relevant competent authority using the authorisation of shipments form.

5 Use documentation with each shipment. Appropriate documentation must accompany each shipment. A failure in this area is a criminal offence.

6 Notify the competent authority. Operators must notify the relevant competent authority in the UK of completion of shipments using the notification of arrival form. Failing to notify them will be a criminal offence.

[the Exit day may change, please continue to follow this Blog]

EU Exit regulatory position statements (UK Brexit)

Exit day is 12th April

Yesterday (1st April) the Environment Agency began issuing EU Exit regulatory position statements (UK RPS).

These set out (time-limited) environmental permitting and licensing situations where the Environment Agency will not take action for non-compliance due to EU Exit.

The first two relate to radioactive materials and radioactive waste – here.

I will add these to a separate category in the Brexit Law List (in subscribers’ Cardinal Environment EHS Legislation Registers & Checklists).

Waste Transport across borders will become more difficult and delayed after EU Exit. Make sure checks are carried out on amounts stored vis a vis EPR Schedule 3 exemption limits. Contact the Environment Agency if limits will be exceeded.

Scotland, Wales and Northern Ireland – contact the local regulator.

[the Exit day may change, please continue to follow this Blog]

Radioactive Waste GDF Consultation (UK)

The UK Government (DECC) today commenced its consultation on revisions to its current siting process for geological (underground) storage facilities (GDF) that will store higher activity radioactive waste.

The consultation document is here, and has the objective of changing the current process principally in the area of local community involvement, statutory planning and regulatory processes are unaffected.