Dounreay Radioactive Waste Substitution Consultation: Response Paper

Executive Summary

The consultation was published jointly by the Scottish Government and the Department of Energy and Climate Change ( DECC) in December 2010 and proposed a means to deal with overseas reprocessing contracts through waste substitution.

More specifically, it is proposed that approval be given for the substitution of:

• Prototype Fast Reactor ( PFR) and cemented Materials Test Reactor ( MTR) raffinate wastes from Dounreay with vitrified radioactive wastes from Sellafield; and
• PFR raffinate waste at Dounreay with cemented MTR raffinate waste at Dounreay.

We said that these proposals would, if adopted, allow the existing overseas contracts to be honoured at the earliest opportunity and that it would also give greater certainty to the overall decommissioning schedule at Dounreay.

The majority of those who responded agreed overall with the proposed policy although others raised concerns over some aspects of the policy.

Having considered all the responses and taken all the comments into consideration Government has concluded that a waste substitution policy for radioactive waste arising from overseas research reactor fuel reprocessing contracts is an acceptable practice that the Nuclear Decommissioning Authority ( NDA) can adopt to deal with historic Dounreay contracts.

More specifically:

Substitution of Prototype Fast Reactor ( PFR) and cemented Materials Test Reactor ( MTR) raffinate wastes from Dounreay with a radiologically equivalent amount of vitrified radioactive waste from Sellafield is permitted subject to contractual agreement with overseas customers and approval from the environmental regulators (the Environment Agency and the Scottish Environment Protection Agency).

Substitution of PFR raffinate waste with a radiologically equivalent amount of cemented MTR raffinate is also permitted subject to contractual agreement with overseas customers and approval from the environmental regulator.

In both cases Government expects broad environmental neutrality to be maintained, primarily on the basis of radiological equivalence. Government will not specify the methodology used to determine radiological equivalence but expects the environmental regulators to be satisfied that the waste substitution arrangements between the NDA and its overseas customers result in environmental neutrality.