Form

Guidance for part RSR‐E3

Published 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 nuclear licensed site. It tells you how to complete form part RSR-E3 for surrender of all or part of a permit for the receipt and disposal of radioactive waste on or from a nuclear site. For tenants on nuclear sites such permits may also include keeping and use of unsealed radioactive sources.

Partial surrender includes:

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

Before you apply

Read the guidance on the management of radioactive waste on decommissioning nuclear sites (known as the GRR): decommissioning of nuclear sites and release from regulation. The GRR sets out our requirements for surrender of radioactive substances activity permits held by licensees at nuclear sites.

Once you have read the GRR and this guidance, discuss your proposals with your Environment Agency regulator before you make an application.

Tenants on nuclear sites should complete only questions 1a and 1b and section 4 and read the related guidance. To surrender permits for keeping and use of sealed radioactive sources use form part RSR-E2: surrender a sealed source permit.

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.

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 a tenant on the nuclear site?

If you are not the licensee for the site under the Nuclear Installations Act 1965 but you have your own environmental permit, we refer to you as a tenant.

If you are a tenant you only need to complete section 4.

1c. 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 all radioactive substances activities authorised by the permit
• have disposed of all radioactive wastes produced by your activities under the permit
• 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 form part RSR‐A.

Partial surrender can include stopping some radioactive substances activities while continuing to carry on others. For example, ceasing to receive radioactive waste onto your site but continuing to undertake disposal of radioactive waste produced by your own activities.

2. About the full surrender of a permit held by the licensee

2a. Describe the final stages of decommissioning of your site and how you have arrived at the end of all planned work with radioactive substances.

Provide your waste management plan (WMP) and other information as necessary to describe the work you have done to get to the end of all planned work with radioactive substances. Your WMP should show how you have optimised the management of radioactive wastes from the final stages of decommissioning (GRR requirement R1) and carried out any on-site disposals of radioactive waste in an optimised way (R13).

2b. Have all activities involving the production or receipt of radioactive waste come to an end and all disposals of radioactive waste on or from the site definitively ceased?

End of all activities

Provide information to show that all activities on-site involving the production or receipt of radioactive waste have permanently ended. This means:

• any clean up of radioactive contamination has been completed
• all deferred decommissioning has been completed and the site has reached the final end state that you have defined for it

Disposals of radioactive waste definitively ceased

Give details to show that you have disposed of all radioactive wastes from the final stages of decommissioning and that there is no longer any radioactive waste awaiting disposal on or from the site. If you have made on-site disposals of radioactive waste, for example in-situ disposal of redundant structures, these must have been previously authorised under your permit and the disposals must have been completed. You should have a complete set of records showing how all the waste streams from decommissioning your site have been disposed of.

If you have not removed all the radioactive waste

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 2d.

2c. Have you employed a period of control for the purposes of radiological protection since the end of all planned work with radioactive substances?

Explain whether it has been necessary to have a period of control for the purposes of radiological protection since you stopped your work with radioactive substances. A period of control allows radioactive decay and other attenuation processes to act on the site until it can meet the site reference state. Where applicable, give a summary of the controls used during this period. If the site has been used for other purposes during the period of control, describe the activities that have taken place on the site during this time.

2d. Describe the current condition of the site.

Give a factual description of the current condition of the site including the nature and extent of any areas of radioactive contamination of land or groundwater. You should also include any non-radiological hazards that remain on site as a result of the activities carried out under your radioactive substances activity permit. You should refer to the relevant sections of your WMP and site-wide environmental safety case (SWESC) to answer this question.

2e. Explain how the current condition of the site meets the site reference state.

Provide your SWESC and other information to show that the condition of your site meets the standards specified in the GRR for release from radioactive substances regulation without the need for further controls.

Your response should include details of the validation monitoring that you have carried out to:

• confirm that your site is evolving as anticipated in your SWESC
• show that the site reference state has been achieved

2f. Review the requirements specified in the GRR and indicate where each requirement is addressed in the documentation supporting this application.

In the table give cross-references to relevant sections of your WMP, SWESC or other supporting documentation to indicate where information can be found to show that you have met the requirements of the GRR. Where a requirement does not apply to your site (for example requirement R13 only applies where on-site disposals of radioactive waste have been made) put ‘not applicable’.

3. About the partial surrender of a permit held by the licensee

3a. Describe the final stages of decommissioning of the part of the site for which you are seeking partial surrender and how you have arrived at the end of all planned work with radioactive substances in that part of the site.

Refer to the guidance under question 2a and apply the guidance to the part of the site for which you are seeking partial surrender. 

3b. Have all activities involving the production or receipt of radioactive waste come to an end and all disposals of radioactive waste definitively ceased on or from the part of the site for which you are seeking partial surrender?

End of all activities

For the part of the site for which you are seeking partial surrender, provide information to show that all activities have permanently ended and there can be no new sources of radioactive waste. This means:

• any clean-up of radioactive contamination has been completed
• all deferred decommissioning has been completed and the part of the site has reached its final end state that you have defined for it

You must consider the work that will be required for the whole site to meet the site reference state. You should show in your SWESC that the part of the site that will continue to be regulated will be capable of meeting the standards for release from regulation without any further clean-up being required in the future in the part of the site for which you are seeking partial surrender. 

Disposal of radioactive waste on or from part of the site definitively ceased

Give details to show that there is no longer any radioactive waste awaiting disposal. If you have transferred radioactive wastes arising from the final stages of decommissioning to the part of the site that will continue to be regulated under the permit, show that such wastes are fully accounted for in your WMP. If you have made on-site disposals of radioactive waste, for example in-situ disposal of redundant structures, these must have been previously authorised under your permit and the disposals must have been completed. You should have a complete set of records showing how all the waste streams from decommissioning the part of the site have been disposed of.

If you have not removed all the radioactive waste from the part of the site

Explain why not and describe the circumstances at your site. It is unlikely that we will be able to grant the partial surrender of a permit in this situation. If there is radioactive contamination on or under any part of your site (not just the part you are seeking to surrender), describe this in your response to question 3d.

3c. In the part of the site for which you are seeking partial surrender, have you employed a period of control for the purposes of radiological protection since the end of all planned work with radioactive substances?

Refer to the guidance under question 2c and apply the guidance to the part of the site for which you are seeking partial surrender.

3d. Describe the current condition of the:

• part of the site for which you are seeking partial surrender
• remainder of the site that will continue to be regulated under the environmental permit

Give a factual description of the current condition of the whole site including the nature and extent of any areas of radioactive contamination of land or groundwater. You should also include any:

• non-radiological hazards that remain on site as a result of the activities carried out under your radioactive substances activity permit
• contamination of land or groundwater that originates from the area but has migrated to other parts of the site

See the guidance for question 3e to understand the considerations that need to be made between the area to be surrendered and the remainder of the site. You should be able to refer to the relevant sections of your WMP and SWESC to answer this question.

3e. Explain how the current condition of the part of the site for which you are seeking surrender meets the site reference state.

Provide your SWESC and other information as necessary to show that the condition of the part of your site meets the standards specified in the GRR for release from radioactive substances regulation without the need for further controls.

You should include details of the validation monitoring you have carried out to:

• confirm that your site is evolving as anticipated in your SWESC

• show that the site reference state has been achieved in the part of the site for which you are seeking partial surrender

Your response should cover the part of the site for which you are seeking partial surrender and the part of the site that will continue to be regulated. This is because the SWESC needs to present a holistic assessment of the impact of the site activities on relevant human and wildlife receptors. Radiological and non-radiological impacts on receptors need to take account of the contribution from both:

• on-site radioactive waste disposals and residual contamination in the part of the site to be surrendered (if any)
• the remaining activities on the rest of the site that will continue to be regulated under the permit

You should consider how any remaining radioactivity in the part of the site to be surrendered will affect your ability to finally surrender the permit for the remainder of the site. When you make that application for full and final surrender of the permit, we will consider the contribution from formerly regulated parts of the site to the total radiological impact on human and wildlife receptors (unless radionuclide concentrations in the formerly regulated areas of the site are below out-of-scope levels).

3f. Review the requirements specified in the GRR and indicate where each requirement is addressed in the documentation supporting this application.

In the table give cross-references to relevant sections of your WMP, SWESC or other supporting documentation to indicate where information can be found to show that you have met the requirements of the GRR for the part of the site for which you are seeking partial surrender. Where a requirement does not apply to the part of the site (for example requirement R13 only applies where on-site disposals of radioactive waste have been made), put ‘not applicable’.

3g. Tick the relevant boxes in the table 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 receiving radioactive waste for disposal but you continue to dispose of your own radioactive waste. Such changes do not necessarily result in a reduction in the overall size of your regulated facility. Use the table to indicate which radioactive substances activities are ceasing (being surrendered) and which will continue.

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

Tell us which of your current activities will be ceasing and which will remain in operation. Describe the activities in terms of the plant and operations affected by your intended changes.

3i. Describe why you want to make the changes.

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

3j. Describe the changes you consider necessary to the existing permit, and your proposals for the new permit after the partial surrender is granted.

Set out how you think your permit should be changed to reflect the changes resulting from the partial surrender you are applying for. You should use form part RSR‐B3 as a guide to structuring your document.

Tell us:

• how the work with radioactive substances will be carried out in future
• how your operating techniques for the production, discharge and disposal of radioactive waste will change after the partial surrender
• how you think the permit should be changed, including which of the currently permitted waste types, disposal outlets and disposal routes should appear on the permit and suitable limits for disposal
• how your monitoring arrangements will change
• your prospective radiological assessment for after the partial surrender

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, use form part RSR-C3.

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

4. About the surrender of a permit held by a tenant

4a. Are you applying to surrender all or part of the permit?

To surrender a permit for all or part of your site you must:

• have stopped the radioactive substances activities authorised by the permit on all or on that part of the premises
• have disposed of radioactive substances from all or from that part of the premises
• satisfy us about the condition of the whole premises or that part of the premises

If you wish 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 form part RSR‐A.

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

4b. Confirm that all unsealed sources and radioactive waste have been removed from the premises, or from the part of the premises for which you are seeking partial surrender.

Give details of what you have done with the unsealed sources and radioactive waste on the premises or part of 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 or part of the premises, explain why not and describe the circumstances at your site. It is unlikely that we will be able to grant the full or partial surrender of a permit in this situation.

4c. How have you recorded any instances of contamination from unsealed sources and radioactive waste covered by the permit or part of 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

4d. Describe the information you have provided to the nuclear site licensee about the condition of the premises covered by the permit or part of the permit to be surrendered.

After your permit or part of it is surrendered, the buildings and land that formed your premises under the permit will revert to the licensee’s radioactive substances activity permit. The licensee will be responsible for the condition of that part of the site and for showing that this is satisfactory when they come to apply for full or partial surrender of their own radioactive substances permit. You must give all relevant information about the condition of your premises to the licensee before we grant the full or partial surrender of your permit.

4e. Provide written confirmation from the licensee that they will release you from the terms of the lease or other tenancy agreement for the premises covered by the permit or part of the permit to be surrendered.

A letter should be signed on behalf of the licensee by an appropriate person confirming that they:

• are satisfied with the condition of your premises
• consider the terms of the lease or other tenancy agreement to have been fulfilled

4f. Provide the reference number of the licensee’s radioactive substances activity permit to which your premises will revert after the surrender or partial surrender is granted.

State the reference number of the relevant radioactive substances activity permit held by the licensee.

4g. Tick the relevant boxes in the table below 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. In the table indicate which activities are ceasing (being surrendered) and which will continue.

4h. Give a description of which parts of the radioactive substances activities will be surrendered and which will continue.

Tell us what will be surrendered and what will remain. This may be in terms of the premises or the radioactive substances activities. 

4i. Describe why you want to make the changes.

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

4j. Describe the changes you consider necessary to the existing permit, and your proposals for the new permit after the partial surrender is granted.

Set out how you think your permit should be changed to reflect the changes resulting from the partial surrender you are applying for. You should use form part RSR‐B3 as a guide to structuring your document.

Tell us:

• how the work with radioactive substances will be carried out in future
• how your operating techniques for the production, discharge and disposal of radioactive waste will change after the partial surrender
• how you think the permit should be changed, including which of the currently permitted waste types, disposal outlets and disposal routes should appear on the permit and suitable limits for disposal
• how your monitoring arrangements will change
• your prospective radiological assessment for after the partial surrender
• how the limits on your holdings of radioactive material should be changed

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 use form part RSR-C3.

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