Consultation on our Objectives and Principles for Regulating Radioactive Substances Activities

Closes 5 May 2025

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Link to our objectives and principles policy statement in html format

 

1. Introduction

The Scottish Environment Protection Agency (SEPA) is the principal body responsible for environmental protection in Scotland[1]. Our general purpose is to protect and improve the environment in ways that, as far as possible, also contribute to improving health and wellbeing and achieving sustainable economic growth [2][3].

This policy statement sets out primary objectives for our regulation of radioactive substances activities, together with a set of principles which support us in achieving those objectives. We will apply them to all our regulatory work and guide our decision-making. This includes regulation of nuclear and non-nuclear radioactive substances activities authorised under the Environmental Authorisations (Scotland) Regulations 2018 (EASR), the Radioactive Contaminated Land (Scotland) Regulations 2007 (RCLSR), radioactive substances shipments legislation and other relevant legislation administered by SEPA.

This document sits at the top of our hierarchy of radioactive substances documents, and informs all our other radioactive substances documents, which include enforcement and position statements, guidance, procedures and decision documents.

In developing our objectives and principles for regulating radioactive substances activities we have taken account of international guidance from the International Atomic Energy Agency (IAEA) and the International Commission for Radiological Protection (ICRP) as well as other relevant good practice. The IAEA is the world's central intergovernmental forum for scientific and technical co-operation in the nuclear field. The ICRP is an independent registered charity, established to advance for the public benefit the science of radiological protection, in particular by providing recommendations and guidance on all aspects of protection against ionising radiation.

These objectives and principles add to the broader principles of better regulation that apply to all of SEPA’s work, as described in Scottish Regulators’ Strategic Code of Practice [4], and which are reflected in SEPA’s Approach to Regulation [5].

2. Objectives

2.1 Objectives

Our objectives for regulating radioactive substances activities are to:

  • protect people and the environment from the harmful effects of ionising radiation, now and in the future; and
  • protect and improve the environment as a whole.

2.2 Explanation

Many radioactive substances activities have the potential to affect people and the environment for very long periods of time. In the regulatory decisions we make now, we must ensure risks from radiation in the environment are consistent with internationally established standards and kept as low as reasonably achievable (ALARA) for current and future generations.

Our objectives are consistent with SEPA’s general purpose to protect and improve the environment in ways that, as far as possible, also contribute to improving health and wellbeing and achieving sustainable economic growth [2] [3].

In our regulation under EASR, we fulfil these objectives by:

  • including and enforcing appropriate conditions and limitations within permits and registrations for the management of higher risk radioactive substances activities, and by
  • enforcing the general binding rules for lower risk radioactive substances activities.

In doing so we seek to protect public health and the environment against harmful effects of ionising radiation arising from radioactive substances activities.

Under the RCLSR we fulfil these objectives by:

  • investigating, characterising and regulating the remediation of land where radioactive contamination is causing or likely to cause significant harm or significant pollution of the water environment.

2.3 Our objectives are derived from:

  • EASR, Regulation 9 General aims:
    “SEPA must take the general aims into account when carrying out a relevant function. The general aims are that all appropriate measures are taken to prevent or, where that is not practicable, to minimise environmental harm; to prevent and to limit the consequences of accidents which could have an impact on the environment; and to use resources in a sustainable way in the carrying out, and decommissioning, of regulated activities and following cessation of the carrying on of the regulated activity”.[6]
  • IAEA Safety Objective:
    “The fundamental safety objective is to protect people and the environment from harmful effects of ionizing radiation.”[7]
  • IAEA Principle 7 – Protection of present and future generations:
    “People and the environment, present and future must be protected against radiation risks.”[7]

3. Principles

3.1 Principle 1: Justification

Radioactive substances activities must be justified before we can authorise them.

3.1.1 Explanation

A radioactive substances activity can only be considered justified if the benefits of the activity outweigh any health detriment from radiation exposure that the activity might cause.

The principle of justification applies to planned, existing and emergency exposure situations. Decisions on whether a practice involving exposure to ionising radiation is justified are made by a justifying authority, usually a UK government department in consultation with devolved administrations and regulators.

We will only grant an EASR registration or permit for a radioactive substances activity if it is justified. Our processes for determining applications include checking that the proposed activity is suitably justified in the register of justification decisions held by the UK Government on www.gov.uk. For justified activities, the disposal or discharge of radioactive waste arising from that activity and the subsequent decommissioning after the activity ceases is also considered to be justified.

In our regulation of remediation of land under the RCLSR, we require any intervention to be justified.

This principle also directs our actions in response to emergencies involving radioactive substances.

3.1.2 This principle is derived from:

  • IAEA Principle 4: Justification of facilities and activities:
    “Facilities and activities that give rise to radiation risks must yield an overall benefit.”[7]
  • IAEA Principle 10: Protective actions to reduce existing or unregulated radiation risks:
    “Protective actions to reduce existing or unregulated radiation risks must be justified and optimised.”[7]
  • ICRP Principle of justification:
    “Any decision that alters the radiation exposure situation should do more good than harm.”[8]

3.1.3 Relevant legislation and policy:

  • Justification of Practices Involving Ionising Radiation Regulations 2004 [9]
    This is a matter for UK Government, who determines whether new activities are justified.
  • EASR, Schedule 8, paragraph 19:
    “SEPA must refuse to grant an authorisation for a radioactive substances activity unless the activity has been found to be justified…”[6]
  • Radioactive Contaminated Land (Scotland) Regulations 2007 as amended, Section 78 E:
    “Where remediation includes an intervention… an intervention may only be considered reasonable where the reduction in detriment due to radiation is sufficient to justify any adverse effects and costs, including social costs, of the intervention.”[10] [11] [12]

3.2 Principle 2: Optimisation

Radiological protection of the public must be optimised.

3.2.1 Explanation

Optimisation is the principle for ensuring radiation exposures are as low as reasonably achievable (ALARA), taking account of economic and social factors. Optimisation decisions balance exposures to ionising radiation with the other benefits and detriments associated with radioactive substances activities. Optimising radiological protection means exposures should be the lowest that can reasonably be achieved; it does not mean minimising radiation exposure regardless of the consequences of doing so.

We implement the optimisation principle by the application of Best Practicable Means (BPM) [13]. We include BPM requirements within EASR registrations and permits for radioactive substances activities. These require the use of BPM to minimise the:

  • activity and volume of radioactive waste generated;
  • total activity of radioactive waste that is discharged to the environment;
  • radiological effects of radioactive discharges on the environment and members of the public.

The optimisation process undertaken to identify options which represent BPM should be proportionate to the magnitude of the risks the options are intended to manage. It should take into account the current state of technical knowledge, social and economic factors, along with other relevant aspects, such as use of natural resources, climate changing emissions and adaptations.

Optimisation is an iterative process that continues throughout the lifetime of the radioactive substances activity. We expect authorised persons to keep their activities under review to ensure they are continuing to use BPM.

To restrict radiation exposure from the planned operation of a source of radioactivity or a number of sources at a single site, we must have regard to the dose constraints specified in EASR. The dose constraints set maximum doses for optimised exposures from radioactive substances activities covered by any individual authorisation.

When we determine an EASR application for disposals of liquid or gaseous radioactive waste to the environment, or for disposals of solid radioactive waste to a land-based facility, we set limits on the disposals to ensure that the radiation doses to individual members of the public, who are representative of those most exposed, do not exceed the dose constraints. As part of our determination process, we undertake prospective dose assessments for disposals at the proposed limits to determine their impact on members of the public, during the period of authorisation [14]. For disposals to land-based facilities, we also require that exposures after the period of authorisation are consistent with the risk and dose criteria set out in Government policy [15].

By ensuring that those who are likely to be most exposed do not receive unacceptable radiation doses as a result of disposals, we also ensure the public as a whole is protected.

The unnecessary introduction of radioactive substances into the environment should be avoided, applying the Precautionary Principle in line with SEPA’s Regulatory Approach [5]. Options for the management of gaseous and liquid radioactive waste range from direct discharge into the environment (“dilute and disperse”) to the concentration of radioactivity in a solid form (“concentrate and contain”). SEPA, in line with Government policy, considers “concentrate and contain” to be the preferred option for managing radioactive waste. However, we recognise that this may not always be reasonably practicable, or in some cases even possible, and that some releases to the environment are unavoidable. In all cases, the overriding principles should be that authorised persons keep their gaseous and liquid discharges within authorised limits, which we have set in light of the relevant dose constraint, to ensure that discharges are optimised.

In our regulation of radioactive substances activities we have regard to the threshold of optimisation for radioactive waste disposals, which is a radiation dose of 0.02 mSv per year [15]. For radioactive substances activities which result in radiation doses to members of the public below this value, we will not seek further reduction in dose, providing we are satisfied that BPM is being applied.

In our regulation of the remediation of radioactive contaminated land under RCLSR we require that any intervention is optimised. The standard of remediation we require takes account of international standards of radiological protection and the dose constraints and reference levels used for optimisation of protection and safety.

3.2.2 This principle is derived from:

  • IAEA Principle 5: Optimization of protection:
    “Protection must be optimized to provide the highest level of safety that can reasonably be achieved.” [7]
  • IAEA Principle 10: Protective actions to reduce existing or unregulated radiation risks:
    “Protective actions to reduce existing or unregulated radiation risks must be justified and optimised.”[7]
  • ICRP Principle of optimisation:
    “The likelihood of incurring exposures, the number of people exposed, and the magnitude of their individual doses should all be kept as low as reasonably achievable, taking into account economic and societal factors.”[8]

3.2.3 Relevant Legislation and Policy:

  • EASR, Schedule 8, paragraph 20(c):
    “SEPA must ensure that a permit or registration for a radioactive substances activity includes such conditions as it considers appropriate to ensure the authorised person optimises the level of radiation protection for members of the public…” [6]
  • EASR, Schedule 8, paragraph 21(2)(a):
    “SEPA must for the purpose of setting conditions required by sub-paragraph (1) take into account the results of any optimisation of radiation protection…” [6]
  • EASR, Schedule 8, paragraph 26(1):
    “SEPA must exercise its relevant functions in relation to radioactive substances activities to ensure that the radiation protection of individuals subject to public exposures is optimised.” [6]
  • EASR, Schedule 8, paragraph 27(1):
    “SEPA must have regard to the following maximum doses which may result from the planned carrying on of a radioactive substances activity, for use at the planning stage in radiation protection…” [6]
  • Radioactive Contaminated Land (Scotland) Regulations 2007 (as amended), Section 78E:
    “Where remediation includes an intervention… an intervention may only be considered reasonable… where the form, scale, and duration of the intervention is optimised.” [10][11][12]
  • IAEA International Basic Safety Standards, General Safety Requirements Part 3, Paragraphs 1.22-1.28:
    “Dose constraints and reference levels…” [17]

3.3 Principle 3: Dose Limitation

Radiation doses to the public from radioactive substances activities must be kept within statutory dose limits.

3.3.1 Explanation

The principles of justification and optimisation do not in themselves guarantee protection of people, dose limits are necessary to ensure that no individual is subjected to an unacceptable risk of harm from exposures to all controlled sources.

We are required to ensure that the sum of exposures from regulated radioactive substances activities to an individual member of the public does not exceed the dose limits specified in EASR.

In conjunction with Food Standards Scotland, we undertake an annual environmental monitoring programme which involves collecting data on levels of radioactivity in food and the environment in Scotland. The results of the monitoring programme are used, along with information on public habits, to undertake dose assessments to demonstrate that the public’s exposure to radiation does not exceed legal limits. This information is published annually in the Radioactivity in Food and the Environment (RIFE) report.

In our determination of whether land is Radioactive Contaminated Land, we are required to use the following criteria, which are specified in the Radioactive Contaminated Land (Scotland) Regulations 2007 Statutory Guidance [18]:

  • Significant Harm to human beings
  • Significant Possibility of Significant Harm to human beings
  • Significant Pollution to the Water Environment
  • Significant Possibility of Significant Pollution to the Water Environment

In our regulation of the remediation of radioactive contaminated land under RCLSR the standard of remediation we require takes account of international standards of radiological protection and the dose constraints and reference levels used for optimisation of protection and safety.

3.3.2 This principle is derived from:

  • IAEA Principle 6: Limitation of risks to individuals:
    “Measures for controlling radiation risks must ensure that no individual bear an unacceptable risk harm.” [7]
  • ICRP Application of Dose Limits:
    “The total dose to any individual from regulated sources in planned exposure situations other than medical exposure of patients should not exceed the appropriate limits recommended by the Commission.”[8]

3.3.3 Relevant legislation and policy:

  • EASR, Schedule 8, paragraph 26 (2):
    “SEPA must exercise its relevant functions in relation to radioactive substances activities to ensure that the sum of doses to an individual does not exceed [the specified dose limits].”[6]
  • Radioactive Contaminated Land (Scotland) Regulations 2007 Statutory Guidance as amended Chapter A Part 3:
    ”Definition of… Significant Harm and Significant Possibility of Significant Harm…”[18]
  • Radioactive Contaminated Land (Scotland) Regulations 2007 Statutory Guidance as amended Chapter A Part 4:
    “Definition of… Significant Pollution and Significant Possibility of Significant Pollution of the Water Environment…”[18]
  • IAEA International Basic Safety Standards, General Safety Requirements Part 3, Paragraphs 1.22-1.28:
    “Dose constraints and reference levels…”[17]

3.4 Principle 4: Radiological protection of wild animals and plants

Wild animals and plants, including all forms of non-human species, in designated habitats must be protected from harmful effects of ionising radiation from radioactive substances activities.

3.4.1 Explanation

Communities of wild animals and plants and their habitats are key components of the environment, which we are required to protect and improve.[1][2][3]

Radioactive substances activities must not expose wild animals and plants, including all forms of non-human species, to levels of ionising radiation that would adversely affect designated protected habitats (Special Protected Areas, Special Areas of Conservation, Sites of Special Scientific Interest).[19][20]

When we determine an EASR permit application for disposals of radioactive waste to the environment, we assess their potential radiological impact on wildlife during the period of regulation. We model the dose rates to reference animal and plant species, selected to represent wildlife in designated areas due to the disposals. We compare the dose rates to selected reference animal and plant species with recommended reference levels. We aim to ensure the impacts on the species at the population level are negligible, but we recognise the recommended reference levels are not limits. Other types of authorisation under EASR are underpinned by generic assessments to ensure negligible impact on wild animals and plants and in designated habitats.

When determining whether land is Radioactive Contaminated Land we are required to consider harm to non-human species in relation to pollution of the water environment. This involves undertaking modelling to facilitate quantitative risk assessment and comparison of the dose rates to non-human species with the criteria specified in the Radioactive Contaminated Land (Scotland) Regulations Statutory Guidance Part 4.[18]

Our duties do not extend to domestic animals and plants. The recommended reference levels apply only to wild animals and plants, while the relevant legislation extends only to wild animals and plants insofar as they are the qualifying biological features of designated protected habitats.

3.4.2 This principle is derived from:

  • IAEA Safety Objective:
    “The fundamental safety objective is to protect people and the environment from harmful effects of ionizing radiation.”[7]
  • IAEA Principle 7: Protection of present and future generations:
    “People and the environment, present and future, must be protected against radiation risks.”[7]

3.4.3 Relevant legislation and policy:

  • Regulatory Reform (Scotland) Act 2014 (Part 3, Chapter 5):
    “General purpose of SEPA … is to carry out the functions conferred on it … for the purpose of protecting and improving the environment …”[2]
  • The Nature Conservation (Scotland) Act 2004 (Part 1):
    “It is the duty of … [SEPA] … in exercising any functions, to further the conservation of biodiversity so far as is consistent with the proper exercise of those functions.”[19]
  • Environment Act 1995, Section 34(2)b:
    “…it shall be the duty of SEPA…to promote- the conservation of flora and fauna which are dependent on an aquatic environment”[1]
  • Conservation (Natural Habitats, &c) Regulations 1994, Regulation 48:
    “A competent authority, before deciding to undertake, or give any consent, permission or other authorisation which is likely to have a significant effect on a European site…shall make an appropriate assessment of the implications for the site in view of that site’s conservation objectives.”[20]
  • Radioactive Contaminated Land (Scotland) Regulations 2007 Statutory Guidance Chapter A Part 4:
    “Definition of… Significant Pollution and Significant Possibility of Significant Pollution of the Water Environment”[18]

3.5 Principle 5: Protection from non-radiological hazards

People and the environment must be protected from the non-radiological (such as physical, chemical or biological) hazards of radioactive substances to a level that is consistent with that provided by the relevant legislation, policy and guidance for non-radioactive substances.

3.5.1 Explanation

Some radioactive substances may have non-radiological hazardous properties and the appropriate level of protection needs to be put in place to control these hazards.

In some cases, these physical, chemical or biological hazards may be greater or last longer than the radiological hazards.

When we determine an EASR permit application for disposals of radioactive waste to the environment or to a solid radioactive waste disposal facility, we consider the non-radiological hazardous properties of the radioactive waste that will be disposed of, and we include appropriate permit conditions proportionate to both the radiological and non-radiological hazards presented by the waste.

3.5.2 This principle is derived from:

  • Regulatory Reform (Scotland) Act 2014 (Part 3, Chapter 5):
    “General purpose of SEPA … is to carry out the functions conferred on it … for the purpose of protecting and improving the environment …”[2]

3.5.3 Relevant legislation and policy:

  • The Environment Act 1995

In our regulation of radioactive waste, our decisions take account of the objectives of the following non-radiological legislation:

  • The Special Waste Regulations 1996 (as amended)
  • The Water Environment (Controlled Activities) (Scotland) Regulations 2011 (as amended)
  • Pollution Prevention and Control (Scotland) Regulations 2012
  • The Waste Management Licencing (Scotland) Regulations 2011
  • The Landfill (Scotland) Regulations 2003 (as amended)

3.6 Principle 6: Safe and secure management of radioactive substances

Radioactive substances must be safely and securely managed and an adequate level of security must be in place for sealed radioactive sources.

3.6.1 Explanation

Access to radioactive substances must be restricted to only authorised users to prevent unauthorised use, loss or theft which could result in unplanned radiological exposure to a member of the public, harm to the environment or unnecessary generation of radioactive waste.

The EASR registrations and permits we grant include conditions requiring safe and secure management of radioactive substances, applying the Principle of Prevention in line with SEPA’s Regulatory Approach [5].

We regulate the security of sealed radioactive sources except when they are only managed on a nuclear site or when they are being transported; in these circumstances security is regulated by other bodies.

For sealed radioactive sources in IAEA categories 1 to 4, we will only grant a permit if we are satisfied that the applicant has made adequate arrangements for their security [21]. We consult with the police regarding the security of premises where sealed radioactive sources are, or will be, managed. We take account of their advice in determining whether to grant, vary or allow surrender of a permit. If we grant a permit, we include conditions requiring the authorised person to comply with security standards produced by the National Counter-Terrorism Security Office (NaCTSO), and to have a security plan.

IAEA category 5 sources must be managed safely and securely as required by the EASR General Binding Rules, and the Standard Conditions if these are included in a registration or permit.

Abandoned radioactive substances can result in unplanned radiological exposure to the public or harm to the environment. Within registrations and permits we include a condition requiring operators to inform SEPA if they vacate premises or cease radioactive substances activities, or if radioactive substances are lost or stolen.

3.6.2 This principle is derived from:

  • IAEA Principle 7: Protection of present and future generations:
    “People and the environment, present and future must be protected against radiation risks.”[7]
  • IAEA Principle 8: Prevention of accidents:
    “All practical efforts must be made to prevent and mitigate nuclear or radiation accidents.”[7]

3.6.3 Relevant legislation and policy:

  • EASR Schedule 8, paragraph 17:
    “SEPA must … before carrying out any of its functions.…in relation to an authorisation… consult … the police … and have regard to any advice it receives”[6]
  • EASR Schedule 8, paragraph 18:
    “SEPA must refuse to grant an application for a permit for a radioactive substances activity involving a high-activity sealed source unless it is satisfied that the applicant has made … adequate arrangements for the safe management and control of the source”[6]
  • EASR Schedule 8, paragraph 20:
    “SEPA must ensure that a permit or registration includes such conditions to … ensure that the authorised person makes arrangements for keeping control of radioactive material with regard to its location, use and, when it becomes radioactive waste, its management; … [and] … ensure that the authorised person makes adequate arrangements for the security of sealed sources.”[6]
  • EASR Schedule 8, paragraph 23:
    “SEPA must ensure that a permit for a radioactive substances activity involving a high-activity sealed source includes … conditions to … require that the authorised person … makes adequate arrangements (including financial provision) for the safe management and control of the high-activity source.”[6]
  • EASR Schedule 9, Part 2 Paragraph 3(b):
    “a radioactive substance must be managed safely and securely to minimise the risk of… unauthorised or accidental use; … loss; and … theft”[6]

3.7 Principle 7: Lifetime planning for radioactive substances activities

Radioactive substances should be managed throughout their lifetime to ensure people and the environment are protected both now and in the future.

3.7.1 Explanation

Lifetime planning means making adequate arrangements for managing radioactive substances from the earliest stage of their use through to the point where they can no longer cause harm to people or the environment. We expect that unnecessary burdens will not be left for future generations to deal with.

We will only grant an EASR registration or permit if we are satisfied the applicant will carry out the radioactive substances activity in accordance with the requirements of the registration or permit and will adequately manage any environmental liabilities when the radioactive substances activity ceases.[22]

Within registrations and permits we include a condition requiring operators to have a waste management plan to support lifetime planning of their radioactive waste arisings, including waste generated during decommissioning activities. We require authorised persons to demonstrate that people and the environment will be protected from harmful effects of the waste disposals, both when the waste is disposed of and in the future.

We will only grant an application for surrender of a permit or registration if we are satisfied that the authorised place has been returned to a satisfactory state [22][24]. When determining an application for surrender, we will consider the radiological and non-radiological impacts on people and the environment due to radioactive substances activities, both within and beyond the boundaries of the authorised place.

We will not allow an authorised person to surrender a permit or registration where there are hazards remaining which would require regulation by another regime or organisation, unless we are legally required to do so. The authorisation of radioactive substances activities through EASR means that after surrender of the EASR permit or registration the land should not give rise to future radiation exposures that would be in scope of the RCLSR.

3.7.2 This principle is derived from:

  • IAEA Safety Objective:
    “The fundamental safety objective is to protect people and the environment from harmful effects of ionizing radiation.”[7]
  • IAEA Principle 1 – Responsibility for safety:
    “The prime responsibility for safety must rest with the person or organization responsible for facilities and activities that give rise to radiation risks.”
    “Since radioactive waste management can span many human generations consideration must be given to the fulfilment of the licensee’s (and regulator’s) responsibilities in relation to present and likely future operations.”[7]
  • IAEA Principle 7 – Protection of present and future generations:
    “People and the environment, present and future, must be protected against radiation risks.”[7]

3.7.3 Relevant Legislation and Policy:

  • EASR Regulation 18(3):
    “SEPA must not grant a registration unless it is satisfied that the applicant-
    • (a) is the person who has or will have control over the regulated activity; and
    • (b) is a fit and proper person to be in control of the activity.” [6]
  • EASR Regulation 19(3):
    “SEPA must not grant an application for a variation unless it is satisfied that the authorised person-
    • (a) is the person who will have control over the regulated activities… and
    • (b) is a fit and proper person to be in control of the regulated activities….” [6]
  • EASR Regulation 23(3):
    “SEPA must not grant a permit unless it is satisfied that the applicant:
    • (a) is the person who has or will have control over the regulated activity; and
    • (b) is a fit and proper person to be in control of the activity.” [6]
  • EASR Regulation 25(5):
    “SEPA must not grant an application for a variation unless it is satisfied that the authorised person:
    • (a) is the person who will have control over the regulated activities… and
    • (b) is a fit and proper person to be in control of the regulated activities.” [6]
  • EASR Schedule 8, paragraph 18:
    “SEPA must refuse to grant an application for a permit for a radioactive substances activity involving a high-activity sealed source unless it is satisfied the applicant has made either:
    • (a) adequate arrangements for the safe management and control of the source, including arrangements for when it becomes waste; or
    • (b) adequate provision, by way of a financial provision… for the safe management of a source.” [6]
  • EASR Schedule 1, paragraph 14(1)(b):
    “In deciding whether to grant or refuse… an application for surrender of a registration or permit, SEPA must consider… whether it is satisfied that all reasonable steps have been taken by the authorised person to:
    • (i) prevent environmental harm arising as a result of the activity…;
    • (ii) prevent environmental harm arising as a result of the cessation of the activity; and
    • (iii) restore the environment affected by the activity to a satisfactory state.” [6]
  • EASR Schedule 1, paragraph 17(1), Interpretation: satisfactory state:
    “When considering whether it is satisfied that the environment affected by an activity has been restored to a satisfactory state, SEPA may have regard to:
    • (a) the state of the environment as at the date the authorisation (or other licence) was granted;
    • (b) the state of the environment as described in any report submitted to SEPA;
    • (c) the remediation of any environmental harm which SEPA considers could reasonably have been caused by the activity; and
    • (d) such other matters as SEPA thinks fit.” [6]

4. References

1. Environment Act 1995

2. Regulatory Reform (Scotland) Act 2014, 2014 asp 3

3. Scottish Government, 2015a. Statutory Guidance on the General Purpose of the Scottish Environment Protection Agency and its Contribution Towards Sustainable Development, March 2015

4. Scottish Government, 2015b. Scottish Regulators’ Strategic Code of Practice, January 2015.

5. SEPA, Our Approach to Regulation, available on SEPA’s website

6. The Environmental Authorisations (Scotland) Regulations 2018, Scottish Statutory Instruments, 2018 No. 219.

7. IAEA, 2006, Fundamental Safety Principles, IAEA Safety Standards Series No. SF-1, IAEA, Vienna (2006).

8. ICRP, 2007. The 2007 Recommendations on the International Commission on Radiological Protection. ICRP Publication 103. Ann ICRP, 37 (2-4).

9. Justification of Practices Involving Ionising Radiation Regulations 2004, UK Statutory Instruments, 2004 No. 1769.

10. Radioactive Contaminated Land (Scotland) (Amendment) Regulations 2007, Statutory Instruments, 2007 No. 3240.

11. Radioactive Contaminated Land (Scotland) (Amendment) Regulations 2009, Scottish Statutory Instruments, 2009 No. 202.

12. Radioactive Contaminated Land (Scotland) (Amendment) Regulations 2010, Statutory Instruments, 2010 No. 2153.

13. SEPA, 2019. Satisfying the optimisation requirement and the role of Best Practicable Means, RS-POL-01, version 2.0, May 2019.

14. SEPA, 2019. Principles for the assessment of prospective public doses arising from authorised discharges of radioactive waste to the environment, RS-JG-016, reviewed October 2019.

15. UK policy framework for managing radioactive substances and nuclear decommissioning May 2024.

17. IAEA 2014, Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards, IAEA Safety Standards Series No. GSR Part 3, IAEA, Vienna (2014).

18. The Scottish Government, 2007a. Environmental Protection Act 1990: Part IIA The Radioactive Contaminated Land (Scotland) Regulations 2007 Statutory Guidance, SG/2009/87, 28 May 2009.

19. Nature Conservation (Scotland) Act 2004, 2004 asp 6.

20. The Conservation (Natural Habitats, &c.), Regulations 1994, Statutory Instruments, 1994 No. 2716.

21. IAEA, 2005. Categorization of Radioactive Sources, IAEA Safety Standards Safety Guide No. RS-G-1.9, Vienna (2005).

22. SEPA, 2018. Guidance on who can hold an authorisation: ‘In Control and ‘Fit and Proper Person Tests, SEPA’s Guidance under the Environmental Authorisations (Scotland) Regulations 2018, Version 2.

23. SEPA, 2020. Guidance on decommissioning of non-nuclear facilities for radioactive substances activities, Version 3.0, December 2020.

24. SEPA, Environment Agency, Natural Resources Wales, 2018. Management of radioactive waste from decommissioning of nuclear sites: Guidance on Requirements for Release from Radioactive Substances Regulation, Version 1.0, July 2018.