3. Permits, registrations and authorisations for radioactive substances and waste in the UK

Source: Ionactive Resources

With the devolved administrations of the UK, this can potentially be a bit of a minefield! For example, in England and Wales you will have 'permits', whereas in Scotland you will have 'authorisations', of which two categories (out of a total of four) are known as 'registration' and 'permit' (and not to be confused with 'registration' as used in Northern Ireland, or 'permit' as used in England and Wales). See what we mean.

To break this down into more manageable chucks, for the purposes of this section we will NOT consider exemption from regulation (or out of scope). Such matters will be discussed later in this guidance as the interpretations required can be quite confusing. For the time being it is assumed that regulation is required and so a permit, registration or authorisation is required. Where appropriate links to relevant forms and guidance will be given.

Some Definitions

The definitions which follow are somewhat simplified for the time being and we will return to them in a later article and expand a little.

Radioactive Material - a substance which emits ionising radiation due to radioactive decay. The radioactive substance may be naturally occurring (NORM), or artificially made in an accelerator or nuclear reactor. This is much simplified since the actual definition is subject to a set of 'tests' to determine if a specific radioactive substance, used in a specific way and / or derived from a specific practice, is radioactive for the purpose of regulation. We will look at this in a little more detail later when considering out-of-scope or exempt situations (where radioactive material is not formally regulated).

Radioactive Waste - A radioactive material which serves no further useful purpose is radioactive waste. This much simplified definition is also subject to a number of 'tests' to determine if it really is radioactive waste for the purposes of regulation. For example, all radionuclides contained in a material which are of short half-life (<100seconds) are not classed as radioactive waste.

If you want a full explanation of the two terms above now, then head over to our Part B ; radioactive substances and waste definition resource.

Open source - A radioactive substance which is not contained or encapsulated and could be spread into the environment if uncontrolled. A radioactive solution 'contained' in a closed plastic bottle is still classed as an open source.

Sealed source - A radioactive substance which is encapsulated in some way such that radioactive material will not leak / spread from the source during normal use and during reasonably foreseeable accidents (fire, mechanical damage, crushing etc). Sometimes known as a closed source.

HASS source - A sealed High Activity Sealed Source (HASS). Sealed sources where the totall activity is above the HASS threshold and requires specific and detailed control measures to ensure safety of persons nearby, and enhanced security arrangements to avoid the source being lost or stolen. HASS sources present a significant risk of radiation injury should they become uncontrolled in the environment, particularly if a member of the public was to come into contact with one unshielded.

NORM - Naturally occurring radioactive material (NORM). Examples might include uranium in granite rock, radon gas, K-40 in cement etc. As for radioactive material and radioactive waste mentioned above, how NORM is regulated will depend on the results of applied 'tests'. For example, waste material which contains NORM and does not arise from a NORM industrial activity, and which are not used for their radioactive, fertile, or fissile properties, are not classed as radioactive waste. Therefore, a NORM containing geological specimen in a museum (e.g. Monazite) is neither radioactive material whilst on display, or radioactive waste when no longer required (with respect to environmental radiation protection) Note: Other radiation safety legislation might still apply with this example (e.g. IRR17). Some mineral specimens have been shown to have contact beta / gamma dose rates of several 100 micro Sv/h (not something you want to dump in your normal trade waste bin).

Source category - this is based on IAEA Safety Standards Series No. RS-G-1.9 and then interpreted in the UK by NaCTSO and issued as a restricted Security Requirements document. This document is then issued to certain holders of sealed radioactive sources and Counter Terrorism Security Advisers (CTSA) who advise sites (and the regulators) on security. Five categories are available, category 5 sealed source need the least security arrangements, whereas category 1 sealed sources (e.g. Co-60 sources used in industrial sterilisation) the most. There is no direct relationship between source category and HASS, although not surprisingly category 5 source will definitely not be HASS, whereas category 1 source most certainly will be HASS. If you want a full explanation of this now, then head over to 6. Sealed source category and the 'D' value within Part A of this resource

This will do for now and will allow us to present the basics of permits, registrations and authorisations in the UK.

How to use the rest of the guidance in this article. Below we present the main document types for all parts of the UK with links. Later articles in this guidance series will outline a typical application process in terms of information required, A/D calculations, consultation with a RWA, BAT assessments and similar (do not worry about these terms for the moment if they are unfamiliar). At that point we will be providing guidance applicable to all of the UK, even if the forms and devolved administration procedures are different. Once you are happy with the principles you can return to this article and select the most appropriate links.

England and Wales

Although the 'branding' may differ between EA and NRW (see articles above), essentially the permitting regime is the same (i.e. in compliance with EPR2016).

This guidance assumes you do need a permit, if you are exempt or out of scope then see our guidance later in this series of articles.

There are two basic types of permit available:

  • Standard rules permit - generally for category 5 sealed sources and some very (!) low level activity work with unsealed radioactive substances. This type of permit uses a set of standard rules that cannot be changed and must be complied with. Application fees, subsistence fees and regulator input (including site visits) is less when compared to the bespoke permit (see below).
  • Bespoke permit - for higher hazard uses of radioactive materials and waste generation. Bespoke means that the regulator will assess your application and can set specific compliance conditions. Generally the application process is more complex and the bespoke permit will contain clauses in terms of accumulation and disposal limits (activity and volume).

Since this is summary guidance we will not present every permit type or rigorous detail.

For more detail consider visiting the following link: Non-nuclear RSR: environmental permits (EA)

Generally when applying for any type of permit detailed below you will also need a Part RSR A (about the premises) and Part RSR F (for charges and declarations). For England these are found at the following links (with their own guidance):

Relevant forms for applications made in Wales are as follows:

Types of permit include the following

SR2010 No 1: category 5 sealed radioactive sources - e.g. would be needed for the holding and use of a sealed Cs-137 source > 4MBq but less < 1GBq (unless the class of practice was specifically defined in the NsCTSO guidance such as Brachytherapy - unlikely given the low activity). Suitable for users of small radioactive sealed sources where exemption provisions cannot not be and where the source is not HASS.

If you start from nothing, it is very difficult to get anywhere

– Gerhard Herzberg -