Form

Guidance for part RSR‐E4

Updated 9 July 2024

Applies to England

Who the guidance is for and why

This guidance is for holders of an environmental permit for radioactive substances activities on a non-nuclear site – that means a site that is not a nuclear licensed site. It tells you how to complete form part RSR-E4 for surrender of all or part of a permit for keeping or use of unsealed radioactive sources and disposal of radioactive waste.

Do not use this form if your application for surrender relates to a landfill or other radioactive waste disposal facility where radioactive waste is disposed of by burial. Speak to your Environment Agency regulator about what to do in these circumstances.

Partial surrender includes:

• reducing the size of the premises where radioactive sources are used or radioactive waste is managed
• removing a radioactive substances activity from your permit while continuing to operate others

Where you see ‘document reference’ on the form, give the document identifiers and send the documents with your completed application form.

1. About the permit

1a. What is the permit number that this application relates to?

Tell us the reference number of the permit that you want to surrender fully or in part.

1b. Are you applying to surrender all or part of the permit?

If you want to give up your permit entirely, that is full surrender. To do this you must:

• have stopped the radioactive substances activities authorised by the permit
• have disposed of all radioactive substances from the premises
• satisfy us about the condition of the site

If you want to reduce the size of the regulated facility that is a partial surrender. You will need to enclose a revised plan of the site with part RSR‐A. To surrender your permit for part of your site, you must:

• have stopped all radioactive substances activities on that part of the premises
• have disposed of all radioactive substances from that part of the premises
• satisfy us about the condition of that part of the premises

Partial surrender can also include stopping some radioactive substances activities while continuing to carry on others.

2. About the full surrender

2a. Have all unsealed sources and radioactive waste been removed from the premises?

Give details of what you have done with the unsealed sources and the radioactive waste on the premises and provide copies of documents that confirm this (for example, copies of consignment notes).

If you have not removed all unsealed sources and radioactive waste from the premises, explain why not and describe the circumstances at your site. It is unlikely that we will be able to grant the full surrender of a permit in this situation. If there is radioactive contamination on or under your site, describe this in your response to question 2b and question 2d.

Your response to question 2a should include a summary of the history of the use of radioactive substances on your premises over the lifetime of the facility. You should identify all areas where work involving unsealed radioactive sources and radioactive waste has been carried out, including disposal routes such as drain runs. In particular, you should identify areas where long-lived radionuclides were used, stored and disposed of.

2b. Describe the measures you have taken to avoid a pollution risk from unsealed sources and radioactive waste covered by the permit to be surrendered.

Tell us what you have done to prevent your sources and waste from causing pollution of the premises. For example, how you have:

• stored unsealed sources and waste while they have been on your premises
• prevented contamination during use of unsealed sources and handling of radioactive waste

Provide information and data to support your claims, for example, a history of monitoring results for relevant work areas.

2c. How have you recorded any instances of contamination from unsealed sources and radioactive waste covered by the permit to be surrendered?

Tell us about your arrangements for:

• recording contamination events such as spillages or other incidents that occurred with unsealed sources and radioactive waste
• recording actions taken to remediate the situation and the results of those actions
• maintaining those records over the lifetime of your operations under the permit

2d. Describe the measures you have taken to return the premises to a satisfactory state. You should have regard to the state of the premises before the facility was put into operation, insofar as it is affected by the unsealed sources and radioactive waste covered by the permit to be surrendered.

Tell us what decontamination measures you have taken during the time the facility was in operation, which are relevant to surrender of the permit. Tell us about spillages or other incidents that occurred with unsealed sources and radioactive waste and how these were dealt with. Describe any remediation of recent or historic contamination that you have carried out in preparation for your surrender application. Provide information and data to show that the premises is in a satisfactory state so far as levels of radioactivity from your operations are concerned. Where possible, compare this with information and data about the condition of the site before operations under the permit started. You can disregard any radioactive contamination that you can show must have occurred before the facility was put into operation or before the first authorisation of activities under the Radioactive Substances Act 1960, whichever is earlier.

The information and data you provide to show that the premises is in a satisfactory state should normally include the results of monitoring of relevant areas after the final clean-up of your premises. You should set out the methodology you have adopted for the monitoring exercise and show that the instruments or other techniques you have used are suitable for the radionuclides used and the physical situation being investigated. Where remediation has been carried out you should describe the reassurance monitoring carried out and provide results to show that the remediation has been effective.

3. About the partial surrender

3a. Have all unsealed sources and radioactive waste been removed from the part of the premises for which you are seeking partial surrender?

Refer to the guidance under question 2a and apply the guidance to the part of the premises subject to the application for partial surrender.

3b. Describe the measures you have taken to avoid a pollution risk from unsealed sources and radioactive waste covered by the part of the permit to be surrendered.

Refer to the guidance under question 2b and apply the guidance to the part of the premises subject to the application for partial surrender.

3c. How have you recorded any instances of contamination from unsealed sources and radioactive waste covered by the part of the permit to be surrendered?

Refer to the guidance under question 2c and apply the guidance to the part of the premises subject to the application for partial surrender.

3d. Describe the measures you have taken to return the part of the premises to a satisfactory state. You should have regard to the state of the part of the premises before the facility was put into operation, insofar as it is affected by the unsealed sources and radioactive waste covered by the part of the permit to be surrendered.

Refer to the guidance under question 2d and apply the guidance to the part of the premises subject to the application for partial surrender.

3e. Tick the relevant boxes to show which radioactive substances activities will be surrendered and which will continue.

Partial surrender can be used to remove a specified radioactive substances activity from your permit while you continue to carry out other radioactive substances activities under the permit. For example, if you stop disposing of unsealed radioactive waste under a permit because you can use a radioactive substances exemption, but you will continue to keep and use unsealed radioactive material above the exemption limits. Use the table to indicate which activities are ceasing (being surrendered) and which will continue.

3f. Give a description of which radioactive substances activities will be surrendered and which will continue.

Tell us what activities will be ceasing and what will remain.

3g. Describe why you want to make these changes

Explain why you are making the changes to your operations and the associated timescales.

3h. Give details of the partial surrender

Provide a document setting out the details of the proposed partial surrender. You should use form part RSR‐B4 as a guide to structuring your document. You can use the tables directly from that form part.

Tell us:

• how the work with radioactive substances will be carried out in future
• how you think the permit should be changed

Where you describe how the permit should be changed, include as appropriate:

• which of the currently permitted justified practices should appear on the permit
• suitable limits on sources and disposals
• which of the currently permitted waste types, disposal outlets and disposal routes should appear on the permit

The changes made to your permit will be limited to those directly associated with the partial surrender. If you wish to make other changes to your permit that are unrelated to the partial surrender, you should apply using form part RSR-B4.

For partial surrenders you need to enclose a revised plan of the site with form part RSR‐A of your application.