Form

Form guidance for Part RSR‐C6: Variation to a bespoke radioactive substances activity permit on a nuclear site to add or amend disposal by case specific exemption

Published 8 October 2026

Applies to England

Read the following guidance notes carefully before you fill in form Part RSR‐C6.

In some low-risk situations, we may permit the transfer of radioactive waste to a person (a consignee) who does not hold a permit for the receipt and disposal of radioactive waste. Regulation 12 (4) and (5) of the Environmental Permitting (England and Wales) Regulations (EPR) 2016 allows this. The consignee must dispose of the waste and comply with the conditions in the waste producer’s permit that apply to the receipt and disposal of the waste concerned. We refer to this as case specific exemption.

We will only permit case specific exemption where you can show that certain criteria are met. This includes that the radiation dose to people from the disposal by the consignee is consistent with:

• the radiological protection standards that apply to the RSR exemption regime (the exemptions from the requirement to hold a permit for a radioactive substances activity given in part 6 of Schedule 23 of the EPR 2016)
• the International Atomic Energy Agency’s (IAEA) safety standards that underpin these standards (the Radiation protection and safety of radiation sources and the Application of the concept of clearance)

Complete form RSR‐C6 if you are applying to use case specific exemption to dispose of radioactive waste to a facility that does not have a permit for the receipt and disposal of radioactive waste.

You can also use form RSR‐C6 to make changes to the disposals you are currently authorised to make using case specific exemption, for example:

• adding or removing a consignee
• changing the quantities of radioactive waste that you intend to dispose to a consignee

Use form Part RSR‐C6 to tell us about proposed disposals to a single facility. If you intend to use case specific exemption to make disposals to an additional facility, you’ll need to complete another copy of the form.

Where you see the term ‘document reference’ on the form, give the document reference and send the document with the application form when you’ve completed it.

We advise you to talk to us about your proposals for case specific exemption before completing the form.

If we agree to your proposals, you will need to inform the consignee before you make the first disposal and provide them with a copy of your permit.

1. Other applications

This section asks you about any other permit applications you are making.

2. About the consignee

You need to provide information about the operator who will receive the waste, and the address of their facility – this is the consignee.

The consignee’s facility must be suitable for the non-radioactive properties or hazards of the waste. The consignee should have any environmental permits that are required for waste with these non-radioactive properties or hazards. An environmental permit means a permit issued under the EPR 2016.

We will only permit case specific exemption where the waste will be transferred to a site operated by the consignee in England.

We will not permit case specific exemption if the waste would be transferred to a site where the consignee holds their own permit for receipt of radioactive waste.

When we receive your application, we will contact the consignee and inform them.

3. About the waste

3a. Provide a description of the waste and estimates of activity

This should include:

• how the radioactive waste will be generated
• the non-radiological properties of the radioactive waste (for example, its physical and chemical properties and the non‐radiological hazards presented by the waste)
• the radiological properties of the waste, including the radionuclides that will be present in the waste and the expected activity concentrations of each radionuclide or group of radionuclides (see note 1 on using groups of radionuclides)
• if you intend to use groups of radionuclides or a ‘sum of fractions’ approach in your proposed limits in section 3b, explain your rationale and give estimates of the activities of individual radionuclides
• the amount of waste (activity and mass or volume) that you intend to dispose to the consignee – this may be the amount you expect to transfer annually, or the total quantity of radioactive waste that you intend to send to this consignee
• how you will characterise the waste for example by measurement, calculation or sampling

3b. Your proposed limits

Provide details of your proposed limits for disposal of radioactive waste to the consignee including both activity concentration and quantity (volume, mass or activity) limits, annual limits or total limits (or both).

Under ‘Radioactive waste type’ give a short description of the waste, for example, solid combustible waste.

Note 1

You can include limits for individual radionuclides or groups of radionuclides (or both). We have produced guidance on using groups of radionuclides in the form guidance for Part RSR-B3 if you are an operator on a nuclear licensed site.

Note 2

‘Total limit’ means the maximum quantity of radioactive waste that you can send to the consignee. If you are sending waste to a facility, such as a landfill, where it will remain permanently rather than a facility where it will be treated, such as an incinerator, you may need to set a total limit. This is to show that you can meet the radiation dose criteria in section 4a.

Note 3

You can use a ‘sum of fractions’ approach to combine limits for different radionuclides or of groups of radionuclides. You may not be able to use the table in question 3b in this case and should submit an amended version with your response to 3a.

4. Case specific exemption assessment

Submit an assessment report which shows how the following criteria are met. Case specific exemption is intended for use with low-risk radioactive waste so your assessment should be relatively simple and straightforward.

If you intend to submit more than one document, give the references to each document.

4a. Optimisation

Explain why case specific exemption is the optimised disposal route for the waste concerned, including consideration of the RSR exemption regime and permitted routes.

We have provided guidance on RSR: Principles of optimisation.

4b. Radiological assessment

Provide a prospective assessment of the dose to people from your proposed disposal by case specific exemption at the consignee’s site.

We will only permit the case specific exemption where you can show that, over the whole lifetime of the disposals proposed, the dose to people is consistent with the radiological protection standards that apply to the RSR exemption regime, and the international standards that underpin this.

These criteria, which apply to reasonably foreseeable exposure scenarios, are:

• for artificial radionuclides and naturally occurring radionuclides used for their fertile, fissile or radioactive properties, the effective dose to a representative member of the public is of the order of 10 microsieverts (μSv) per year or less
• for wastes arising from naturally occurring radioactive material (NORM) industrial activities, the effective dose to a representative member of the public is no greater than 300 μSv/year

Where the waste will be disposed by burial in a landfill, you should consider the radiation doses to people that could arise after the consignee’s facility has stopped operating and is no longer subject to regulatory control. When low probability scenarios are considered, such as intrusion into the landfill after closure, a different criterion of 1 millisievert (mSv) per year may be applicable. If you are considering using this criterion you should discuss this with us. 

We keep records of the permits for case specific exemption we have issued. We will only permit case specific exemption where the combined impact at a consignee’s site from any disposals using case specific exemption meets these radiological protection standards.

Your assessment should take account of the principles and guidance in Principles for the assessment of prospective public doses arising from authorised discharges of radioactive waste to the environment (August 2012).

We have developed an initial radiological assessment tool (IRAT2) which may be suitable for your assessment of the radiation dose to people. See the IRAT2 methodology and a user guide.

The initial radiological assessment tool is implemented using a spreadsheet which is available from your Regulatory Officer.

If you use our tool to support your application, you should confirm the input data you have used and the output from the tool. Providing an electronic copy of the completed spreadsheet is the most straightforward way to do that.

You will not be able to use IRAT2 where you are intending to dispose of waste by burial in a landfill. Case specific exemption is intended for use with low-risk radioactive waste so your assessment should be relatively simple and straightforward.

4c. Final disposal

We will only permit case specific exemption where your proposals mean the consignee will undertake final disposal of the radioactive waste. In this context, final disposal means that there is no further disposal of radioactive waste that would require an environmental permit.

You should provide evidence that your proposals for case specific exemption can be considered final disposal and will not result in the generation of secondary wastes at the consignee’s site that would require transfer to another person for disposal under a radioactive substances activity permit.

We expect that you will be able to demonstrate that any secondary wastes requiring transfer are out of scope of Schedule 23 of the EPR 2016. If these wastes will be suitable for disposal under an exemption rather than being out of scope, you should discuss this with us.

If the consignee’s operations include recovery of material, your assessment must also show that none of the recovered materials will be in scope radioactive material.

4d. Non-radioactive properties of the waste

You should explain why the consignee’s site is suitable for the non-radioactive properties and hazards of the waste you are proposing to dispose of by case specific exemption.  

We expect that the consignee will manage substantial quantities of similar, non-radioactive waste.

The consignee must have any environmental permits that are required for waste with these non-radioactive properties and hazards (see question 2).

4e. The consignee’s normal operating practices

We will only permit case specific exemption where no special precautions are required by the consignee to manage the radioactive waste to meet the criteria, other than their normal operating processes. We can include conditions in your permit that give the consignee simple instructions on how to manage the waste, for example, dispose of the radioactive waste with their normal, non-radioactive waste.

Your assessment should include a description of the consignee’s normal operating practices, highlighting those which are key to ensuring the criteria are met. You should tell us about any simple instructions that the consignee should follow.

If we agree to your proposals for case specific exemption, you will need to periodically check that the consignee’s operating practices have not changed in a way that could impact your assessment.