Guidance

RSR permits for nuclear licensed sites: how to comply

Published 13 February 2020

This guidance is for operators with an environmental permit for radioactive substances activities on nuclear licensed sites. It explains the conditions in radioactive substances regulation (RSR) permits for:

• receiving and disposing of radioactive waste on and from nuclear sites
• tenants who keep or use unsealed radioactive sources on nuclear sites

Operators that keep or use mobile radioactive apparatus should also follow this guidance on keeping or using sealed sources, where relevant.

Purpose of this guidance

The purpose of this guidance is to help you understand:

• the requirements of each permit condition
• the reasons for imposing the permit condition
• how you should demonstrate compliance with the permit condition

This guidance does not provide detailed technical guidance on specific measures you need to use. We have published other RSR guidance which you should also read:

Radioactive substances regulation (RSR): objective and principles which applies across all RSR activities. Our staff use this guidance when making regulatory decisions. It covers areas where we regulate directly (permitting and compliance) and those where we are consultees or have influence.

RSR2: The regulation of radioactive substances activities on nuclear licensed sites which describes how we regulate the receipt and disposal of radioactive waste on nuclear sites.

Our nuclear guidance page has other RSR guidance, for example, on:

• management arrangements
• optimisation - using best available techniques (BAT)
• monitoring

We will follow our guidance when we assess:

• applications for new permits, permit variations or to transfer or surrender a permit
• compliance with permit conditions

Regulatory approach for RSR permits

The RSR environmental permit for disposing of radioactive waste is based on the following approach.

You must have suitable management arrangements, including sufficient competent persons and resources, to comply with your permit (condition 1.1.1).

You must develop and maintain a waste management plan (WMP) and a site-wide environmental safety case (SWESC) (condition 1.1.3). These must show how you will:

• manage radioactive waste over the whole lifetime of the site
• bring the site to a condition where it can be released from regulation

You must use BAT to minimise the amount of radioactive waste you generate and dispose of. This is so you reduce the impact on the public to a level that is ‘as low as reasonably achievable’ (ALARA) and you protect the environment.

BAT is mainly covered by permit conditions 2.3.1, 2.3.2 and 2.3.3, although there are other conditions which address specific aspects of BAT.

You must also:

• only dispose of radioactive waste in the manner and amounts specified in your permit (conditions 3.1.1, 3.1.2 and 3.1.3)
• carry out the monitoring (using BAT) needed to demonstrate you are complying with your permit (condition 3.5.1)
• make and keep records demonstrating compliance and provide information to us as requested (covered by several conditions)

The permit is structured as follows:

• Part 1: management
• Part 2: operations
• Part 3: disposals of radioactive waste and monitoring
• Part 4: information
• Schedules (which set out limits and other detailed issues)

Some permit conditions allow us to specify further requirements, approvals or agreements. We will do this in writing and this will be separate to the permit. We only do this to provide more detail about these requirements, which will be clearly linked to the original permit condition. We call these ‘Environment Agency requirements’ (EARs) and for the permit as a whole the ‘Compilation of Environment Agency requirements’ (CEAR). We will place these requirements on the public register taking into account any confidentiality and national security issues.

Management conditions

The management conditions are conditions 1.1.1, 1.1.2, 1.1.3, 1.1.4 and 1.1.5.

Condition 1.1.1

“1.1.1 The operator shall manage and operate the activities:

(a) in accordance with a written management system that is sufficient to ensure compliance with the conditions of this permit; and

(b) using sufficient competent persons and resources.”

This condition means that you must put in place and use appropriate management arrangements to make sure that you comply with your permit conditions. Management arrangements include systems and procedures, people and other resources, leadership and culture. We have provided the following guidance which we will use to assess your management arrangements:

• Management and leadership for the environment: generic developed principles
• our guidance Management arrangements at nuclear sites
• the section on radioactive waste management arrangements in RSR2: The regulation of radioactive substances activities on nuclear licensed sites

Also see the requirements of condition 1.1.3.

We have published joint guidance with the Office for Nuclear Regulation (ONR) on how you can meet our management arrangement expectations through a single integrated management prospectus. This more co-ordinated approach to regulating nuclear sites means that you can demonstrate your compliance in a more efficient and effective way. You may also carry out other Environmental permitting regulation (EPR) activities on your site. Where you do, you should apply:

• the guidance in this section to all the RSR activities you operate
• any additional requirements from the relevant guidance to your non-RSR activities

This is to make sure that you have a management system which fully addresses the range of activities you operate. It must do this in a consistent way, meeting all regulatory requirements.

Condition 1.1.2

“1.1.2 The operator shall maintain records demonstrating compliance with condition 1.1.1.”

You must make and keep records showing how you have applied your management arrangements to meet part (a) and part (b) of condition 1.1.1. These records are an essential part of your management system.

Section 4 of the permit tells you how to keep the records. Records include notes and receipts referred to in conditions 2.6.1 and 3.1.6. You may hold records in an electronic form.

Our joint regulatory guidance with ONR, The management of higher activity radioactive waste on nuclear licensed sites includes guidance on managing information and records. Although this covers higher activity wastes, you can use the general principles on record keeping for other forms of radioactive waste. You should apply them appropriately and proportionately.

Condition 1.1.3

“1.1.3 The operator shall maintain a waste management plan and a site-wide environmental safety case, which together demonstrate throughout the lifecycle of the regulated facility, how the:

(a) production and disposal of radioactive waste is managed to protect the environment and to optimise the protection of people;

(b) disposability of radioactive waste that will require disposal on or from the premises is assured;

(c) public and the environment are protected from the non-radiological hazards of disposals of radioactive waste; and

(d) premises will be brought to a condition at which it can be released from regulation under this permit.”

This condition reflects our expectations for managing radioactive waste at nuclear sites over the whole lifetime of the site.

Our Guidance on the requirements for release (GRR) provides more detail to help you comply with this permit condition.

The condition requires you to have a WMP and a SWESC in place. Together, the WMP and SWESC must demonstrate that you manage and dispose of radioactive waste in a way that:

• reduces the radiological impact on people to a level that is ALARA
• protects the environment from the harmful effects of radioactivity
• protects people and the environment from non-radiological hazards in the radioactive waste during regulation and afterwards

Your WMP and SWESC must show how you will plan for decommissioning and clean-up of the site and the eventual permit surrender.

Your WMP and SWESC are an essential part of your radioactive waste management arrangements, as described in RSR2: The regulation of radioactive substances activities on nuclear licensed sites.

WMP

Your WMP is a plan that specifies the actions needed to achieve your site’s environmental safety case.

The WMP should cover all aspects of your operations that generate radioactive waste requiring disposal. This should include (as far as is reasonably practicable) current and future activities over the lifetime of the facility – through to surrendering the permit. For example:

• operating plant (including maintenance)
• waste handling and treatment (including higher activity wastes in interim storage)
• decommissioning
• site restoration, including remediating contaminated land or groundwater

The WMP should include gaseous, liquid and solid radioactive wastes.

You should maintain your WMP as a live plan and regularly update it throughout the lifetime of your permit. It should hold up to date information on all radioactive wastes that have been (or will be) generated and that will require disposal.

The level of detail you include about individual wastes will vary over the lifetime of the site. It should be proportionate to the scale and complexity of your radioactive waste management operations. An archive of records showing the history of disposals should also be part of the WMP to support the description of the wastes that remain on site.

If you do not yet know about the future generation and disposal of wastes (for example, from dealing with contaminated land) your WMP should set out how you intend to address these issues, giving plans and timescales.

Your WMP should also:

• include optimisation studies showing how you have determined that waste production, existing and future waste management activities, and discharges and disposals are optimal
• demonstrate the disposability of non-standard wastes and higher activity wastes you intend to dispose of in a geological disposal facility
• demonstrate how you will manage non-standard waste and higher activity wastes in the interim so you do not prejudice their ultimate disposal
• consider the non-radiological properties of radioactive waste and, where relevant, the management of non-radioactive (Directive) waste in an integrated way (see condition 2.3.7

We expect that operators will have a range of existing information, data, studies and other resources they can use to compile their WMP. For example:

• radioactive waste inventories
• integrated waste strategies
• radioactive waste management cases (RWMCs) for higher activity wastes (HAW)

You can find detailed guidance on the management of HAW in our joint guidance with ONR, The management of higher activity radioactive waste on nuclear licensed sites.

The WMP should also include the data and documentation needed to quantify and characterise any:

• wastes that will remain on site at the completion of all planned work with radioactive substances
• radioactive contamination that will not be removed

You can find further details on the purpose, scope and contents of the WMP in the Guidance on the requirements for release (GRR).

SWESC

Your SWESC shows how implementing your WMP will achieve the relevant radiological protection standards before and after your site is released from regulation.

It should address both the:

• operational and decommissioning phases whilst you have your permit - including any periods of ‘care and maintenance’
• period of unrestricted use after you have surrendered your permit

The SWESC does not need to be a stand-alone document and it can refer to other studies. However, it must be detailed enough to provide confidence in its environmental safety claims. The effort you put into developing the SWESC should be proportionate to the scale of the hazards that:

• the WMP is intended to reduce or remove
• will remain on site

The SWESC must include the environmental safety case (ESC) for any on-site engineered disposal facility. You can find detailed guidance on the scope and content of ESCs for individual on-site disposal facilities in the Guidance on requirements for authorisation and for SWESCs in the Guidance on the requirements for release (GRR).

To demonstrate the environmental safety of the site we expect a SWESC to contain the following elements (this is not an exhaustive list):

• a full conceptual site model to show you have a clear understanding of all aspects of the site that affect environmental safety
• quantitative environmental safety assessments for the period of regulation (including dose assessments for discharges) and after the site’s release from regulation
• further qualitative and quantitative arguments, assessment and reasoning to show you are following the principles and requirements set out in the Guidance on the requirements for release (GRR)
• a clear methodology for treating uncertainties
• a description of the condition of the site and the level of environmental safety that you will achieve at the planned surrender of your permit (we call this the site reference state)

Condition 1.1.4

“1.1.4 Any person having duties that are or may be affected by the matters set out in this permit shall have convenient access to a copy of it kept at or near the place where those duties are carried out.”

You must make sure that the people who work on your premises (staff and contractors), and whose duties may be affected by the permit conditions, can easily read the permit. For example, by storing it on a corporate intranet. They should also have ready access to any other information they need to make sure they comply with the permit. This could be access to:

• the CEAR
• this guidance
• other instructions more targeted to their responsibilities

Condition 1.1.5

“1.1.5 The operator shall manage and operate the activities in consultation with a suitable Radioactive Waste Adviser for the purpose of advising the operator as to compliance with this permit.”

Under article 82 of the 2013 Basic Safety Standards Directive (BSSD) operators must get advice from a radiation protection expert on a range of matters. This includes arrangements for radioactive waste management.

In the UK we call the radiation protection expert for radioactive waste management and environmental radiation protection a ‘Radioactive waste adviser’ (RWA). The UK environment agencies have set up a scheme defining the knowledge, experience and competencies required to be a RWA. You can find details of the scheme, including the appointment of RWAs and their syllabus, on the Scottish Environment Protection Agency’s website.

To comply with the BSSD, condition 1.1.5 requires you to appoint suitable RWA(s) and to consult them as needed, as set out in the scheme.

An RWA may be an individual, or the duties may be shared amongst a group of people (a Corporate RWA). The process of approving individual RWAs or corporate RWAs is set out in the scheme.

You will need to be able to show that your RWAs (or corporate RWAs) are ‘suitable’ to give relevant advice on your business and how you have appointed them.

We expect you to keep records that show when you consulted a RWA and how you acted upon that advice. Significant changes to your RWA arrangements may mean you need to notify us under permit condition 4.3.5.

Operations conditions

Here are the conditions about controlling operations at your site and an explanation of their requirements.

Condition 2.1.1

This condition covers permitted activities.

“2.1.1 The operator is only authorised to carry out the activities specified in schedule 1 table S1.1 (the ‘activities’).”

You are only allowed to carry out the radioactive substances activities listed in your permit. For nuclear sites, these are:

• receiving radioactive waste for the purpose of disposal
• disposing of radioactive waste on or from the premises
• if you are a tenant, keeping or using radioactive material on the premises

However, you may carry out other activities on the site provided that they:

• do not need a permit under any legislation
• are exempt from needing a permit, for example, activities covered by a radioactive waste exemption as set out in Guidance on the scope of and exemptions from the radioactive substances legislation in the UK
• you have a separate permit issued by the Environment Agency or by another regulator such as the local authority

‘Limit of specified activity’ in Table S1.1 is the justified practice or work activity as specified in Part A of the application form. See the information on GOV.UK about Justification of Practices.

You must only carry out the permitted activity (for example disposal of radioactive waste) in relation to the justified practice(s) or work specified in table S1.1.

You will need to apply for a variation if you wish to change the specified activity, justified practice(s) or work listed in Table S1.1.

Conditions 2.1.2 and 2.1.3

These conditions will only be included in permits for tenants who use open (unsealed) sources.

“2.1.2 Only radioactive material in the form of open sources comprising the radionuclides specified in table S2.1 in schedule 2, together with any associated decay products present in amounts not exceeding those which could be present through radioactive decay of the specified radionuclides, shall be kept or used on the premises.”

“2.1.3 The activity of each radionuclide kept or used on the premises shall not exceed the relevant maximum activity specified in table S2.1 in schedule 2.”

If you use open sources you must keep the amounts you hold on the premises to within the limits specified in table S2.1 in schedule 2.

The activity limit applies to the parent radionuclide – you do not need to take account of the radioactivity of any decay products, as provided for in condition 2.1.2.

Condition 2.2.1

This condition defines the extent of the site.

“2.2.1 The activities shall not extend beyond the site, being the land shown edged in green on the site plan at schedule 7 to this permit.”

You can only carry out your permitted activities within the area of land shown on the site plan in schedule 7. Read RSR2: The regulation of radioactive substances activities on nuclear licensed sites for guidance on how you define the area of the site.

If you wish to expand the area of the site where you carry out your RSR activities, you need to apply for a variation to your permit. If you wish to reduce the area, you need to apply for a partial surrender for the area that you are no longer using.

Conditions 2.3.1, 2.3.2, 2.3.3

These conditions cover operating techniques.

“2.3.1 The operator shall use the best available techniques to minimise the activity of radioactive waste produced on the premises that will require to be disposed of on or from the premises.”

“2.3.2 The operator shall use the best available techniques in respect of the disposal of radioactive waste pursuant to this permit to:

(a) minimise the activity of gaseous and aqueous radioactive waste disposed of by discharge to the environment;

(b) minimise the volume of radioactive waste disposed of by transfer to other premises;

(c) dispose of radioactive waste at times, in a form, and in a manner so as to minimise the radiological effects on the environment and members of the public.”

“2.3.3 The operator shall use the best available techniques to:

(a) exclude all entrained solids, gases and non-aqueous liquids from radioactive aqueous waste prior to discharge to the environment;

(b) characterise, sort and segregate solid and non-aqueous liquid radioactive wastes, to facilitate their disposal by optimised disposal routes;

(c) remove suspended solids from radioactive waste oil prior to incineration.”

Conditions 2.3.1 and 2.3.2 address the requirements of the 2013 BSSD and Part 4 1(a) of schedule 23 of the Environmental Permitting Regulations. They follow Government guidance on RSR and the Statutory guidance concerning the regulation of radioactive discharges into the environment.

The purpose of conditions 2.3.1 and 2.3.2 is to make sure that “all exposures to ionising radiation of any member of the public and of the population as a whole resulting from the disposal of radioactive waste are kept as low as reasonably achievable, taking into account economic and social factors” (para 1(a) of Part 4 of Schedule 23). This is the optimisation requirement, and using BAT is how you achieve optimisation. The document RSR: Principles of optimisation describes the principles we expect you to apply in identifying and assessing the techniques that represent BAT.

Condition 2.3.1 requires you to use BAT to minimise the activity of any radioactive waste produced. This means that (where possible) you should prevent the production of radioactive waste. Where that is not possible, you should minimise the amount of radioactive waste you produce and the radioactivity in it. This requirement does not apply if you are only disposing of radioactive waste created by another permit holder.

Condition 2.3.2 requires you to use BAT to minimise the activity of any radioactive waste that you discharge to the environment as a gas or aqueous liquid. An example of BAT could be using appropriate abatement equipment.

Condition 2.3.2(b) means that you must also minimise the volume of radioactive waste you transfer to other premises for disposal, for example by using practices such as compaction or incineration.

This is the ‘concentrate and contain principle’ in the Statutory guidance concerning the regulation of radioactive discharges into the environment and the UK Strategy for radioactive discharges.

Finally, if you must dispose of radioactive waste to the environment, condition 2.3.2(c) requires you to dispose of it in a way which minimises radiological effects. For example, by discharging gaseous radioactive waste in a way which enables optimum dispersion.

Conditions 2.3.1 and 2.3.2 apply to all aspects of the nuclear site processes that affect the production and disposal of radioactive waste. See RSR2: The regulation of radioactive substances activities on nuclear licensed sites for examples.

For BAT, the definition of ‘techniques’ includes “both the technology used and the way in which the installation is designed, built, maintained, operated and dismantled”. The definition of BAT used in radioactive substances regulation is the one adopted by the Convention for the Protection of the Marine Environment of the North-East Atlantic. See Appendix 1 of the OSPAR convention text. The Environment Agency considers the OSPAR definition to be essentially the same as the definition of BAT in the 1996 EC Directive on Integrated Pollution Prevention and Control (IPPC).

Therefore, conditions 2.3.1, 2.3.2 and 2.3.3 apply to the design, construction, operation, maintenance and decommissioning of facilities and plant. They have a wide interpretation and also include matters such as operator competence and control of contractors. Some other permit conditions cover specific aspects of BAT for clarity and to make sure operators comply with specific requirements in regulations.

In addition to RSR: Principles of optimisation, there is guidance available from other organisations that may help you assess BAT, including a nuclear industry code of practice on BAT and Waste practitioner support and guidance.

For higher activity wastes we follow the Basic principles of radioactive waste management and The management of higher activity radioactive waste on nuclear licensed sites guidance. We carry out this work through RWMCs and will not duplicate it through applying BAT conditions.

Conditions 2.3.1 and 2.3.2 focus on achieving an outcome. We use condition 2.3.3 to clearly describe and emphasise any specific matters where operators must use BAT to deliver the outcomes in conditions 2.3.1 and 2.3.2. Generally these relate to things that have caused problems historically.

Condition 2.3.3(a) is about ensuring adequate dispersal in the aquatic environment.

Condition 2.3.3(b) is about making sure that your radioactive waste is properly characterised so that you can use the waste hierarchy and make best use of available disposal routes (see also condition 3.1.3).

Condition 2.3.3(c) is about achieving good combustion conditions in oil burners where waste is incinerated on-site.

Alternative condition 2.3.1

This condition is for tenants with open sources.

“2.3.1 The operator shall use the best available techniques to:

(a) minimise the activity of radioactive material kept or used on the premises;

(b) minimise the activity of radioactive waste produced on the premises that will require to be disposed of on or from the premises;

(c) prevent:

(i) the loss of any radioactive material or radioactive waste;

(ii) access to any radioactive material or radioactive waste by any person not authorised by the operator.”

See the relevant sections of How to comply with your EPR RSR environmental permit – open sources and receipt, accumulation and disposal of radioactive waste on non-nuclear sites.

Conditions 2.3.4, 2.3.5 and 2.3.6

“2.3.4 The operator shall maintain in good repair the systems and equipment provided:

(a) to meet the requirements of conditions 2.3.1, 2.3.2 and 2.3.3;

(b) to carry out any monitoring and measurements necessary to determine compliance with the conditions of this permit;

(c) to measure and assess the exposure of members of the public and radioactive contamination of the environment.”

“2.3.5 The operator shall check, at an appropriate frequency, the effectiveness and maintenance of systems, equipment and procedures provided to meet the requirements of conditions 2.3.1, 2.3.2 and 2.3.3.”

“2.3.6 The operator shall have and comply with appropriate criteria for the acceptance into service of adequate systems, equipment and procedures for:

(a) carrying out any monitoring and measurements necessary to determine compliance with the conditions of this permit;

(b) measuring and assessing exposure of members of the public and radioactive contamination of the environment.”

Condition 2.3.4 requires you to maintain all systems and equipment which:

• produce radioactive waste requiring disposal
• minimise, monitor and measure radioactive waste discharged to the environment
• minimise, measure and assess the radiological impact of waste discharged to the environment

We require you to maintain relevant equipment and systems so that they are reliable and can perform their intended environmental protection function.

We have used the word ‘provided’ rather than ‘used’ to make sure that operators maintain back-up systems as well as those in use. Poor maintenance of plant, instrumentation or infrastructure can result in the production of additional radioactive waste.

We expect you to keep a schedule (or some other system) specifying the ‘systems and equipment’ you will maintain under this condition, and the frequency of maintenance. You should also record:

• when maintenance is carried out
• who carried it out
• the methods used or processes followed
• the results of the maintenance activity
• any associated actions, such as fault trending

Condition 2.3.5 addresses the requirements of paragraph (c) of Article 68 of BSSD, to check the effectiveness of technical devices for protecting the environment and the population. It means that you must regularly check that your techniques are continuing to achieve what they were designed or expected to achieve.

Condition 2.3.6 addresses the requirements of paragraph (b) of Article 68 of BSSD, related to monitoring and measuring instruments and other assessment techniques associated with radioactive waste disposals, including software.

Before designing, selecting, installing or commissioning new equipment or procedures, you must define criteria that make sure:

• you are using BAT
• performance of the equipment or procedures is adequate

Similarly, you must have appropriate criteria in place following maintenance or repair to demonstrate that performance is satisfactory and in compliance with the permit. Appropriate criteria for acceptance into service will be particularly important if you are relying on contractors or other specialist supply chain providers.

Condition 2.3.7

“2.3.7 Subject to condition 2.3.2, the operator shall carry on the activities in a manner so as to minimise the risk of pollution from any non-radioactive substances in, or any non-radiological properties of, the radioactive waste, except to the extent the risk is addressed in a separate environmental permit.”

Condition 2.3.7 reflects our regulatory duty to consider the non-radioactive hazards associated with radioactive waste – as given to us in the Government guidance on RSR.

This condition focuses on the operating techniques used in the day-to-day management of processes that generate radioactive waste. Whereas condition 1.1.3(c) focuses on making sure that operators consider fully the non-radiological properties of radioactive waste in their waste management planning.

Condition 2.3.7 only applies to radioactive waste that would be controlled under other legislation if it were not radioactive. Its aim is to achieve broadly the same level of environmental protection expected from controlling non-radioactive pollutants through other regulation.

Operators that would normally need another environmental permit to carry out a non-radioactive substances activity should assess the environmental impact of the non-radioactive properties of the radioactive waste disposal. See Risk assessments for your environmental permit for guidance on doing these assessments.

If you can screen out the environmental impacts as ‘insignificant’ using the Environment Agency’s risk assessment procedures this will be enough to show that you are complying with the condition.

If you cannot screen out impacts as insignificant you should focus on the non-radiological properties of the radioactive waste when demonstrating you are complying with the condition. This could include:

• evaluating the BAT specified in relevant sector guidance and comparing it with the design and operation of your activity
• providing evidence that you have not exceeded environmental standards
• making the case that a further reduction in releases would compromise radiological optimisation

Condition 2.3.8

This condition will only apply to tenants who use open (unsealed) sources.

“2.3.8 The operator shall maintain records of open radioactive sources showing:

(a) the radionuclide present, the date on which it was received and the activity on that date;

(b) so far as is reasonably practicable its location on the premises;

(c) if it has been removed from the premises, the date of removal, the activity on that date and the name and address of the person to whom it was transferred; and

(d) the activity present on the premises at the end of each calendar month.”

As set out in condition 2.3.8, you must keep records of the:

• receipt and disposal of unsealed radioactive sources
• activity of the sources when received and disposed of
• location of the sources on the premises

You must also keep the details specified in 2.3.8 (c) about when and how you disposed of the sources. You must also keep a record of the total activity in all unsealed sources on the premises at the end of each month.

Conditions 2.4.1 and 2.4.2

These conditions are about improvement and information requirements.

“2.4.1 The operator shall complete the requirements specified in schedule 1 table S1.2 by the dates specified in that table unless otherwise agreed in writing by the Environment Agency.”

“2.4.2 Except in the case of a requirement which consists only of a submission to the Environment Agency, the operator shall notify the Environment Agency within 14 days of completion of each requirement.”

You may continue your activities whilst you meet an improvement programme requirement. We will review your progress and completion of the requirements during our compliance inspections.

Conditions 2.5.1 and 2.5.2

These condition are pre-operational conditions.

“2.5.1 The activities shall not be brought into operation until the measures specified in schedule 1 table S1.3A have been completed.”

“2.5.2 The specific disposals and receipts of radioactive waste identified in schedule 1 table S1.3B shall not commence until the relevant measures specified in that table have been completed.”

In condition 2.5.1, ‘activities’ means any activity listed in schedule 1, table S1.1. You cannot start any of the activities listed in schedule 1 table S1.1 until you have completed all the measures specified in schedule 1 table S1.3A.

This means we can require you to do something before you start receiving radioactive waste on site, or making disposals. For example, you may need to provide reports, such as commissioning reports, or to confirm information supplied in an application.

Condition 2.5.1 only applies before you first carry out activities, that is before you start to receive (any) radioactive waste on site or first dispose of it.

Condition 2.5.2 means we can prevent any new receipts or disposals of particular radioactive wastes until you have completed the measures in schedule 1 table 1.3B. So, we can require you to do something before you receive a particular consignment of waste or make a particular disposal.

We use Table S1.3B in situations where you do not need to change disposals limits or outlets and so do not need approval under the variation process. We can apply this condition at any time after you start your permitted activities and before you start any new form of receipt or disposal.

If we have not specified any measures under these conditions, you can start activities and change the nature of receipts and disposals as authorised by your permit.

Conditions 2.6.1 and 2.6.2

These conditions cover the receipt of radioactive waste.

“2.6.1 The operator shall:

(a) for each type of radioactive waste that it is prepared to receive, produce a written specification of the information required to:

(i) enable the disposal of that type of radioactive waste in compliance with this permit; or

(ii) where disposal of that type of radioactive waste is not currently permitted, sufficiently characterise that waste to, as far as reasonably practicable, enable its future disposal;

(b) provide that written specification to any person from whom the operator is prepared to receive radioactive waste of that type;

(c) only accept a consignment of radioactive waste that is accompanied by a legible note providing the information specified in 2.6.1(a);

(d) keep a copy of any such note received;

(e) provide a receipt to the consignor in respect of each consignment of radioactive waste that the Operator accepts.”

“2.6.2 The operator shall ensure that any radioactive waste which does not comply with the specifications produced pursuant to condition to 2.6.1 is returned to the consignor as soon as reasonably practicable, unless otherwise agreed in writing with the Environment Agency.”

These conditions complement 3.1.6 to 3.1.8. They cover transferring radioactive waste between waste consignors and consignees in a way that makes sure:

• there is an adequate exchange of information
• you dispose of the waste according to your permit conditions
• you keep records of transfers of radioactive waste

You should prepare a written specification for each type of radioactive waste you could receive. This should cover, for example:

• radioactivity content
• chemical composition
• packaging

This is to make sure you only receive radioactive waste which you are allowed to dispose of under your permit conditions. If you do not currently have a permitted disposal route, you should make sure that (as far as is reasonably practicable) the wastes you receive are characterised in a way that enables their future disposal.

You should make these written specifications available to prospective consignors. You should only accept waste that has a consignment note with all the information needed to confirm that the radioactive waste received meets the relevant specifications. You must keep the consignment notes that you receive.

Conditions 2.6.1 and 2.6.2 do not apply to wastes received as a result of participation in the National arrangements for incidents involving radioactivity (NAIR) scheme or the Radsafe scheme, as a result of condition 2.6.5.

They also do not apply to the small scale return of radioactive waste which originated on your site. For example samples sent to another site for analysis or testing and which are then returned to you.

Conditions 2.6.3 and 2.6.4

You will only have these conditions in your permit if you receive radioactive waste for final disposal on, or from, your premises. For example, if you operate an incinerator or carry out the on-site burial of radioactive waste. This includes waste arising from your premises and subject to internal consignment for final disposal on your premises.

“2.6.3 Before the operator first receives radioactive waste from a consignor for the purpose of final disposal of that waste from or on the premises, the operator shall, at the earliest opportunity, inform the local authority, in whose area of responsibility the premises is situated, of the origin and nature of the radioactive waste.”

“2.6.4 The provisions of 2.6.3 do not apply:

(a) where the waste consignor is exempt from the requirement to hold an environmental permit for the disposal of radioactive waste;

(b) to the extent that it would require the disclosure of information relating to sealed radioactive sources.”

If you carry out these activities you will need to inform the local authority in whose area your premises is located. In non-unitary areas, you should also inform the relevant county council. You must do this before you first receive radioactive waste from a consignor.

You must provide:

• your name and address
• the name and address of the consignor
• a description of the type of radioactive waste to be received using the recognised waste classifications - for example, low level waste (LLW)
• the date on which you are expecting to receive that radioactive waste for the first time

You must inform the local authority in writing as soon as you can. We expect you to do this once you have made arrangements for the first transfer of waste. In any event, you must inform the local authority before you receive the radioactive waste on site.

You need only tell the local authority about the first consignment of waste. You do not need to tell them about any subsequent transfers.

You do not need to inform the local authority if the transfer is made under a radioactive waste exemption. This recognises that you may not be aware of, or have details about, radioactive waste being disposed of under the exemption provisions.

You must not inform or provide the local authority with any information about a consignor sending you sealed radioactive sources for final disposal, including the fact that this transfer will take place.

Condition 2.6.5

“2.6.5 The provisions of paragraph 2.6.1 to 2.6.x do not apply to any radioactive waste collected as a result of the operator’s participation in the National Arrangements for Incidents involving Radioactivity or in the Radsafe scheme.”

Condition 2.6.5 means that conditions 2.6.1 and 2.6.2, and, where used, conditions 2.6.3 and 2.6.4 do not apply to radioactive waste received as a result of participating in NAIR or Radsafe. We recognise that these conditions are not practicable for wastes received in this way.

Disposal conditions

These are the conditions for disposals of radioactive waste.

Conditions 3.1.1, 3.1.2 and 3.1.3

“3.1.1 Subject to condition [3.1.5], there shall be no disposals of radioactive waste except of the types of radioactive waste and by the disposal routes specified in schedule 3 or otherwise agreed in writing by the Environment Agency.”

“3.1.2 The limits on disposals given in schedule 3 shall not be exceeded.”

“3.1.3 The operator shall ensure the use of an optimised disposal route when disposing of any radioactive waste in accordance with Table S3.4 [or S3.5].”

These conditions together with the tables in schedule 3 will specify:

• the types of radioactive waste you may dispose of
• how you may dispose of it, for example, by discharge to air, or transfer to another person
• limits on what you may dispose of

You can only dispose of the types of radioactive waste from the outlets and disposal routes specified and limited in schedule 3, unless we have agreed otherwise in writing.

Condition 3.1.1 does not prevent you from using the radioactive waste exemptions. It applies only to the wastes requiring a permit and not to exempt wastes.

The permit will specify all those outlets that have, either individually or collectively, significant discharges.

We may choose to approve minor disposal outlets (as ‘approved outlets’) in the CEAR, rather than specify these in the tables to the permit. The total amount of radioactivity disposed of using approved outlets will not be more than 5% of the discharge limits for the whole site. Or, we may set a specific limit in the permit for approved outlets.

We recognise that some discharges take place through ill-defined routes and we may need entries in the schedule 3 tables such as ‘reactor leakage routes’.

We will include in Table S3.1 relevant incinerator stacks to formally authorise the discharge outlet, but we normally control emissions from incinerators by setting limits on the inputs of radioactivity to incinerators in a separate table in schedule 3.

You must not dispose of radioactive waste in a way that could result in a direct or indirect discharge to groundwater unless you are specifically allowed to do so under your RSR permit. RSR delivers the requirements of Schedule 22 to the Environmental Permitting Regulations 2016 for discharges of radioactive waste.

Your permit will normally contain standard entries in schedule 3 for the transfer of solid LLW and liquid waste of activity equivalent to LLW.

The permit will also contain a standard entry for transfer of Very low level waste (VLLW) if you cannot meet the conditions of the exemption for this type of waste. The exemption for VLLW is explained in paragraphs 3.77 to 3.95 of Guidance on the scope of and exemptions from the radioactive substances legislation in the UK. If you are using the exemption you must make sure that the activity concentration in the waste meets the specific definition in the exemption (as activity per unit volume). This is different from the VLLW definition in the nuclear permit (as activity per unit mass).

If the maximum quantity of VLLW you will dispose of each year exceeds the limitations in the exemption then you must:

• transfer the waste to a RSR permit holder
• have all of the waste in the VLLW category included in your permit

You cannot use both the exemption and the permit for this waste.

We do not normally set limits on transfers of radioactive waste. We regard the disposal option you choose is part of using BAT under condition 2.3.2. But for clarity, condition 3.1.3 explicitly requires that the disposal route you choose for solid and non-aqueous wastes is the best overall option (optimised). The RSR: Principles of optimisation guidance has more information on this topic.

The wording in schedule 3 about transfers of VLLW, LLW and liquid wastes gives you flexibility in choosing disposal options and the operators or sites that receive the waste - subject to the requirements of conditions 2.3.1, 2.3.2 and 3.1.3. This reflects the 2007 government policy for the long-term management of solid low level radioactive waste in the United Kingdom.

The definition of ‘holder of an environmental permit’ in the schedule 3 table about waste transfers includes an operator authorised under the Environmental Authorisation (Scotland) Regulations 2018 or the Radioactive Substances Act 1993 in Northern Ireland. Therefore you may transfer waste there if appropriate. However, we may restrict transfers to specified sites and set limits or other conditions on disposal to meet statutory or policy requirements. For example, the requirements of the proximity principle and the waste hierarchy.

You can apply to transfer other waste forms, and to other destinations, than those set out in the standard entries in the permit.

The requirement to use BAT under conditions 2.3.1, 2.3.2, and where relevant under 2.3.3, applies to all disposals and at all times. Just complying with your disposal limits will not be sufficient. If you can achieve lower disposals through using BAT then you must do so.

Condition 3.1.4

If you apply for a variation to make a disposal of solid radioactive waste on site as part of decommissioning and preparations for surrender, we will insert a new condition 3.1.4 into your permit to authorise the disposal. We will also provide you with further guidance as to how to comply with the new condition. See Guidance on the requirements for release (GRR) for guidance about our requirements for permitting radioactive waste from decommissioning at nuclear sites.

However, most current permits do not include conditions for disposing of radioactive waste on-site. Instead, condition 3.1.4 in most permits covers the disposal of radioactive waste collected under the NAIR or Radsafe schemes.

“3.1.4 The operator may dispose of radioactive waste, not being radioactive waste otherwise authorised to be disposed of, which is collected as a result of the operator’s participation in the National Arrangements for Incidents involving Radioactivity or in the Radsafe scheme provided that the operator:

(a) transfers the radioactive waste to a person whom the Environment Agency has agreed in writing may receive that radioactive waste;

(b) as soon as practicable provides available details in writing to the Environment Agency of the nature of the radioactive waste, the radionuclides present, their activities and the manner and date of disposal.”

This paragraph allows you to dispose of radioactive waste as part of your involvement in NAIR and the Radsafe scheme. You can dispose of this waste using one of the disposal routes in your permit. If you do this, the disposal will count towards any limits in your permit for such disposals. If you are not able to dispose of the waste within your permitted routes, we will agree with you how you can transfer or otherwise dispose of the waste.

Conditions 3.1.5, 3.1.6, and 3.17

These conditions cover transfers of radioactive waste. If your permit allows you to dispose of radioactive waste by transfer to another person, it will contain the following conditions.

“3.1.5 The operator shall ensure that the transfer of radioactive waste is in accordance with the directions of the person to whom the radioactive waste is transferred that are necessary to enable that person to comply with all relevant regulatory requirements.”

“3.1.6 The operator shall:

(a) ensure that the person to whom radioactive waste is transferred receives at the time of transfer of each consignment a clear and legible note signed on the operator’s behalf

(i) stating the total activity in the consignment of each relevant radionuclide or group of radionuclides listed in the relevant table in schedule 3; or

(ii) stating, when no relevant radionuclide or group of radionuclides is specified in schedule 3, the total activity in the consignment of each radionuclide or group of radionuclides as listed in the written specification of the person to whom the radioactive waste is transferred.

(b) obtain a note signed on behalf of the person to whom radioactive waste is transferred, at the time of transfer, stating that the transfer has taken place;

(c) keep a copy of any note issued under 3.1.6(a) and any note received under 3.1.6(b).”

“3.1.7 If required by the Environment Agency, the operator shall ensure that any consignment or part of any consignment of radioactive waste found, following transfer, not to be in accordance with the conditions of this permit:

(a) is packaged in accordance with the appropriate transport regulations;

(b) is returned as soon as is reasonably practicable to the operator’s site.”

Conditions 3.1.5, 3.1.6 and 3.1.7 cover how you transfer radioactive waste to other people. These conditions complement conditions 2.6.1 and 2.6.2 for the receipt of radioactive waste.

When you transfer radioactive waste to another person (operator) you must follow the instructions they provide. This is so they can comply with their own regulatory requirements (condition 3.1.5).

When you send the consignment of waste, you must give the person receiving the waste a written, signed note containing the information set out in condition 3.1.6. This should also include any information they have specifically asked for. See condition 2.6.1 about the written specification for a waste receipt provided by the waste consignee.

You should obtain a written, signed, confirmation of the transfer when the transfer takes place. You must keep a record of these consignment notes.

Under condition 3.1.7, we may tell you to take back waste if we find that the transfer does not comply with the conditions of your permit. In this case you will be responsible for any (re)packaging of the waste that is needed so it can be transferred back to you.

Condition 3.1.8

“3.1.8 The operator shall, not later than 14 days after the end of each month or within such longer period as the Environment Agency may approve in writing, record all disposals of radioactive waste made during that month.”

You must record all disposals of radioactive waste within 14 days after the end of each month, unless we approve a longer period using an EAR. Unless we agree otherwise, your records should show clearly and legibly the:

• type of waste and the disposal route
• name of each radionuclide or group of radionuclides, specified in the schedule, which is present in the waste
• activity of each radionuclide or group of radionuclides per cubic metre of the waste
• activity of each radionuclide or group of radionuclides per tonne of the waste - for LLW waste
• total activity of each radionuclide or group of radionuclides
• total volume in cubic metres
• total mass in tonnes
• date and time on which, or the period during which, the disposal took place

Monitoring conditions

The monitoring conditions are conditions 3.2.1, 3.2.2, 3.2.3, 3.2.4, 3.2.5, and 3.2.6.

Conditions 3.2.1 and 3.2.2

“3.2.1 The operator shall:

(a) take samples and conduct measurements, tests, surveys, analyses and calculations to determine compliance with the conditions of this permit;

(b) unless otherwise agreed in writing by the Environment Agency

(i) define, document and carry out an environmental monitoring programme;

(ii) use the results of that programme to carry out an annual retrospective assessment of the dose to the representative person;

(iii) inform the Environment Agency in writing in advance of any modifications affecting the extent of that programme or that have a potential to change the results obtained.

(c) use the best available techniques when taking such samples and conducting such measurements, tests, surveys, analyses and calculations, and carrying out such environmental monitoring programmes and retrospective dose assessment, unless particular techniques are specified in schedule 3 of this permit or in writing by the Agency;

(d) define and document the techniques being employed to determine the activity of radioactive waste disposals and shall inform the Environment Agency in writing in advance of any modifications to those techniques that have a potential to change the results obtained.”

“3.2.2 The operator shall maintain records of all monitoring required by this permit including records of the taking and analysis of samples, instrument measurements (periodic and continual), calibrations, examinations, tests and surveys and any assessment or evaluation made on the basis of such data.”

You must take the samples and measurements needed to show you are complying with your permit.

Condition 3.2.1(a) applies to all appropriate conditions, not just numerical limits.

Condition 3.2.1(c) requires you to use BAT when sampling and monitoring, including environmental monitoring.

Condition 3.2.1(b) requires you to define, document and carry out a programme of environmental monitoring.

You must also carry out an annual retrospective assessment of the dose to the representative person. This is to fulfil paragraphs 4.12 and 4.13 of the Government guidance for RSR. Paragraph 4.12 states “The operator should assess the likely impact of the permitted activity in terms of effective dose to members of the public. Assessments of effective dose should take account of past, present and future regulated discharges”. Paragraph 4.13 covers the monitoring needed to support the retrospective dose assessment.

Your programme should be based on Radiological monitoring technical guidance note 2: Environmental radiological monitoring. It must be extensive enough to carry out the appropriate retrospective dose assessments, either annually or at the frequency specified in the CEAR.

You may also need to carry out environmental monitoring to meet other objectives as well as assessing the impact on people. These objectives are set out in paragraph 3.1 and table 1 of Radiological monitoring technical guidance note 2: Environmental radiological monitoring.

Clauses (b)(iii) and (d) of Condition 3.2.1 require you to notify us of any changes to your monitoring that could change the results obtained. This could either be changes to your monitoring programme as a whole, or to the particular monitoring techniques.

Numerical limits and levels included in the permit are absolute and not related to a specific measurement method, except where we specify a particular method in the permit.

If we have not specified a particular method of measurement in your permit, you must use BAT when sampling, analysing and assessing radioactive waste disposals and environmental monitoring.

If we specify a particular method of measurement in your permit, you must use that method and must carry out associated activities using BAT. In these cases, we will set the limit in a way that is linked to the specified means of analysis.

You must keep records of all the sampling and monitoring you carry out and of any assessments or reports you make using that data.

Condition 3.2.3

“3.2.3 Monitoring equipment, techniques, personnel and organisations employed for the monitoring of disposals and the environment required by condition 3.2.1 or 3.2.5 shall have either MCERTS certification or MCERTS accreditation (as appropriate), where available, unless otherwise agreed in writing by the Environment Agency.”

The Environment Agency’s monitoring certification scheme MCERTS certifies:

• monitoring systems (for example, instruments, analysers and equipment)
• the competency of personnel
• the accreditation of laboratories and organisations involved in sampling

You should use MCERTS certified equipment, staff and laboratories where available, unless we agree alternative arrangements.

This condition only applies where MCERTS certification and accreditation exists for the sampling and monitoring you are carrying out. It does not apply to any other monitoring. It also does not mean that current techniques and personnel need to become MCERTS certified or accredited over time.

Condition 3.2.4

“3.2.4 Permanent means of access shall be provided to enable sampling and monitoring to be carried out in relation to the disposal outlets specified in schedule 3 unless otherwise agreed in writing by the Environment Agency.”

This condition is to make sure that Environment Agency contractors will be able to carry out sampling and monitoring on site as required.

Condition 3.2.5

“3.2.5 If required by the Environment Agency, the operator shall

(a) take such samples and conduct such measurements, tests, surveys, analyses and calculations, including environmental measurements and assessments, at such times and using such methods and equipment as the Environment Agency specifies;

(b) keep samples, provide samples, or dispatch samples for tests at a laboratory, as the Environment Agency specifies, and ensure that the samples or residues thereof are collected from the laboratory within three months of receiving written notification that testing and repackaging in accordance with the appropriate transport regulations are complete.”

We will use 3.2.5(a) if we need to specify other testing, monitoring and assessment requirements. We will usually use 3.2.5(b) to specify the samples you need to provide for the Environment Agency’s independent monitoring programme.

Condition 3.2.6

“3.2.6 The operator shall carry out:

(a) regular calibration, at an appropriate frequency, of measuring instruments and other systems and equipment provided for:

(i) carrying out any monitoring and measurements necessary to determine compliance with the conditions of this permit;

(ii) measuring and assessing exposure of members of the public and radioactive contamination of the environment.

(b) regular checking, at an appropriate frequency, that such measuring instruments and other systems and equipment are serviceable and correctly used.”

Condition 3.2.6 addresses the requirements of Article 68 of BSSD to regularly calibrate measuring instruments and check they are serviceable and correctly used. We expect you to calibrate and check this equipment following the manufacturer’s recommendations and relevant good practice.

Information conditions

These are the information conditions.

Conditions 4.1.1 and 4.1.2

These conditions apply to records.

“4.1.1 All records required to be made by this permit shall:

(a) be legible;

(b) be made as soon as reasonably practicable;

(c) if amended, be amended in such a way that the original and any subsequent amendments remain legible, or are capable of retrieval; and

(d) be retained until notified in writing by the Environment Agency that records no longer need to be retained.”

“4.1.2 The operator shall keep on site all records, plans and the management system required by this permit, unless otherwise agreed in writing by the Environment Agency.”

You must keep records indefinitely unless we specify otherwise.

You must keep records of anything that has affected the off-site environment. This includes pollution incidents that caused, or are alleged to have caused, harm or health effects.

You can hold these records electronically. You should record times using the 24-hour clock.

Condition 4.1.3

“4.1.3 The operator shall

a) retain records made in accordance with any previous relevant permit issued to the operator and related to the premises covered by this permit;

b) retain records transferred to the operator, which were made in accordance with any previous relevant permit related to the premises covered by this permit.”

This condition refers to records made either:

• under a previous permit or authorisation held by you
• by a previous operator and transferred to you when you first took over the permitted activities

This condition complements condition 4.1.1 by requiring you to keep records relating to earlier activities carried out at the site – including those by another operator – as well as keeping records about your current activities.

Conditions 4.2.1 and 4.2.2

These conditions cover reporting.

“4.2.1 The operator shall send all reports and notifications required by this permit to the Environment Agency using the contact details supplied in writing by the Environment Agency.”

“4.2.2 The operator shall supply such information in relation to the samples, tests, surveys, analysis and calculations, environmental monitoring and assessments undertaken under conditions 3.2.1 and 3.2.5 in relation to disposals of radioactive waste, in such format and within such timescales as the Environment Agency may specify.”

We use condition 4.2.2 to specify the information you need to send to us. This will normally be information about discharges, environmental monitoring and data for the Pollution Inventory. We may also specify other requirements, for example providing information about specific plant details.

Conditions 4.3.1 and 4.3.2

These conditions cover notifications.

“4.3.1 The operator shall notify the Environment Agency without delay following the detection of:

(a) any malfunction, breakdown or failure of equipment or techniques and any accident, which has caused, is causing or may cause significant pollution or may generate significant amounts of radioactive waste;

(b) the breach of a limit specified in this permit or disposal of radioactive waste other than by a relevant permitted route;

(c) any significant adverse environmental effects that could reasonably be seen to result from the operation of the facility.”

“4.3.2 Any information provided under condition 4.3.1 shall be confirmed by sending the information listed in schedule 5 within the time period specified in that schedule.”

‘Without delay’ means that you must notify us as soon as is practicable about any of the events listed in condition 4.3.1.

‘Significant adverse environmental effects’ includes harm to any sensitive receptors and significant impacts on properties.

If your monitoring shows that you have breached any of the limits in your permit, we expect you to notify us as soon as the results have passed any laboratory quality assurance checks.

When we issue your permit, we will provide you with more information on how to notify us to meet condition 4.3.1 and 4.3.2.

Condition 4.3.5

“4.3.5 Where the operator proposes to make a change in the management system or resources, which might have, or might reasonably be seen to have a significant impact on how compliance with the conditions of this permit is achieved the operator shall:

(a) notify the Environment Agency at least 28 days before making that change, or where that is not possible, without delay; and

(b) include in the notification a description of the proposed changes.”

Your change management arrangements should include provision for:

• considering the potential impact of changes on your ability to comply with your permit
• identifying when you need to notify us under condition 4.3.5

You should normally inform us and provide a description of the proposed changes at least 28 days before you make any changes.

This condition also applies to notifying us about changes which may affect your radioactive waste management arrangements (see condition 1.1.1).

There is guidance on when to notify us in chapter 6 of RSR2: The regulation of radioactive substances activities on nuclear licensed sites.

Condition 4.3.6

“4.3.6 Where the operator proposes to make a change to the waste management plan, to the site-wide environmental safety case or, where applicable, to the facility-specific environmental safety case, including a change to the waste acceptance criteria, which might have, or might reasonably be seen to have, a significant impact on the quantity or nature of radioactive wastes disposed or planned to be disposed of on the site, or result in a significant change to the nature, place or environmental impact of such disposals, the operator shall:

(a) notify the Environment Agency at least 28 days before making that change, including in the notification a description of the proposed changes; and

(b) where the Environment Agency so notifies the operator, not implement the proposed changes until the Environment Agency has given its agreement in writing.”

We expect you to update and maintain the WMP and SWESC you prepare to meet permit condition 1.1.3 throughout the lifetime of the nuclear site. You should do this in a way that is appropriate and proportionate to the lifecycle stage that the site has reached.

We are likely to examine the WMP and SWESC as part of routine regulatory work and from time to time you may need to send us some or all of the WMP and SWESC. For example, to support an application for a permit variation. Condition 4.3.6 is there to make sure that you inform us about significant changes in between these events.

You must notify us whenever you change the WMP, or any waste acceptance criteria that could result in a significant change to the on-site waste disposals that you plan to make.

You must also notify us whenever you make a substantial change to the SWESC, for example:

• including a previously unassessed exposure pathway
• making a significant change in the assessment parameters that underpin the environmental safety case

This is to make sure we know about potentially significant changes and can comment on and influence them whilst they are being developed.

If we need to evaluate and consider the change in detail, we will notify you under condition 4.3.6(b). You must not make the change until we have made a determination.

There is guidance about change management in RSR2: The regulation of radioactive substances activities on nuclear licensed sites.

Condition 4.3.7

“4.3.7 If, in any week, the activity in any radioactive waste disposed of from any outlet or group of outlets specified in schedule 3 of any radionuclide or group of radionuclides exceeds, or is likely to exceed, the relevant Weekly Advisory Level (where specified), the operator shall:

(a) without delay, inform the Environment Agency and the Food Standards Agency;

(b) as soon as reasonably practicable, advise the Environment Agency and the Food Standards Agency of the circumstances at the site leading to the release and the possible impact of any deposition of radioactivity on pasture or crops in the vicinity of the site, including any measurements made.”

We can specify weekly advisory levels. This is so that we and the Food Standards Agency know about any short-term releases which could enhance activity levels in foodstuffs and exceed dose limits or Council Food Intervention levels. For example, this could happen under particular weather conditions or at certain times of year.

The notification allows both organisations to take early action if necessary. You must have management arrangements and monitoring in place so you can inform us when disposals exceed or are likely to exceed any weekly advisory levels.

Condition 4.3.8

“4.3.8 If, in any quarter, the activity in any waste discharged from any outlet or group of outlets specified in schedule 3 of any radionuclide or group of radionuclides exceeds the relevant Quarterly Notification Level (where specified), the operator shall provide the Environment Agency with a written submission which includes:

(a) details of the occurrence;

(b) a description of the means used to minimise the activity of radioactive waste discharged;

(c) a review of those means having regard to conditions 2.3.1, 2.3.2 and 2.3.3; not later than 14 days from making the record which demonstrates such excess.”

We may set quarterly notification levels to make sure you tell us about any operational anomalies that cause discharges to increase. We do this on a rolling quarterly period (the last full 3 months).

You must have management arrangements and monitoring in place so you can inform us when disposals exceed or are likely to exceed any quarterly notification levels.

If you notify us about exceeding a limit, you must review your techniques against the requirements of conditions 2.3.1, 2.3.2 and 2.3.3 as appropriate.

Condition 4.3.9

This condition is only for tenants using open sources.

“4.3.9 If the operator believes or has reasonable grounds for believing that an open radioactive source has been lost or stolen he shall:

(a) without delay inform the Police and the Environment Agency;

(b) make all reasonable efforts to recover the source;

(c) as soon as is practicable report the circumstances in writing to the Environment Agency.”

See conditions 4.3.1 and 4.3.2 on how to notify us.