Dounreay Radioactive Waste Substitution Consultation: Response Paper

1 The Consultation

Background

1.1 This report is an analysis of the responses to the Dounreay Radioactive Waste Substitution Consultation 2010. The consultation was published on 3 December 2010 and is available to view on the Scottish Government website ¹ . Consultees were asked to respond to the consultation by 11 March 2011.

1.2 In this report the use of "Government" refers collectively to the Scottish and UK Governments where policy and responsibilities are aligned. Where policies and responsibilities differ, separate references are made to either the Scottish or the UK Government.

1.3 The Nuclear Decommissioning Authority ( NDA) sought clarification from Government about using radioactive waste substitution arrangements for the return of radioactive wastes resulting from reprocessing of overseas research reactor fuel at Dounreay. That is, instead of sending customers the radioactive waste allocated to them under their reprocessing contracts, a radiologically equivalent amount of radioactive waste from another source within the NDA estate would be sent.

1.4 The countries with radioactive waste at Dounreay which is due to be returned to them are Australia, Belgium, Germany and Italy.

1.5 More specifically, approval has been requested 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.

1.6 The NDA owns the UK's legacy civil nuclear facilities and is responsible for their decommissioning and clean up. In the case of Dounreay it has also inherited the long standing contracts for reprocessing of overseas research reactor fuel and the subsequent return of radioactive wastes. Requests from these overseas customers for radioactive wastes to be returned in forms that they are able to manage, along with the need to clarify the Dounreay site radioactive waste management strategy, have led the NDA to approach Government with a request to fulfil contractual obligations with radioactive wastes that are already available within its overall estate. In other words, NDA has asked Government if it can implement radioactive waste substitution to return these wastes.

1.7 Clarity about Government's policy on radioactive waste substitution is therefore necessary to allow the NDA to complete the discussions with its overseas customers.

The Consultation Questions

1.8 The consultation document asked five questions:

• Do you agree that a waste substitution policy should be adopted for radioactive waste arising from overseas research reactor fuel reprocessing contracts at Dounreay?
• Do you agree that substituting cemented Materials Test Reactor radioactive waste for Prototype Fast Reactor radioactive waste should be an available option to finalise the overseas contracts?
• Do you agree that substituting vitrified radioactive waste from Sellafield for cemented Materials Test Reactor radioactive waste and/or Prototype Fast Reactor radioactive waste should be an available option to finalise the overseas contracts?
• Do you agree with the proposals to ensure broad environmental neutrality for the United Kingdom?
• Do you agree that all of the relevant implications of the proposed policy have been identified?

1.9 Written responses were requested on a template questionnaire which could be submitted by post or email. All of the questions asked the respondent to select either Yes, No, In Part or Not Sure as their answer, and to provide additional comments where necessary to support this.

Submissions and Respondents

1.10 Twelve responses were received. While most respondents used the form provided, three did not answer the specific questions posed, but provided general comments supporting their position.

1.11 The responses are available from the Scottish Government Library. Two respondents requested that particular details (such as name and address) be withheld, so these details have been omitted accordingly.

Analysis and Presentation of the Data

1.12 All 12 responses were included in the analysis. Overall, the analysis of the data involved the following processes:

• Input of all responses into an Excel spreadsheet
• Initial identification of key themes
• Analysis of the commonalties and differences in the issues raised
• Preparation of the report

1.13 The focus of the report is on qualitative analysis and presentation, reflecting the nature of the material received.

1.14 Detailed quantitative analysis has not been undertaken for a number of reasons:

• There was a very small number of respondents
• Respondents covered similar issues but at different points on the response form
• Not all of the respondents answered the questions specifically
• The purpose of the consultation was to determine whether there were any reasons that the proposals should not be allowed or if there was anything that Government had not taken into account rather than determining the 'weight' of opinion

1.15 None of the respondents requested that their actual responses remain confidential.

1.16 Some of the questions received very few comments, whilst some received comments very similar to those made regarding other questions by different respondents. However, the comments have been separated by question rather than theme to aid the clarity of the analysis. The conclusion notes where this has occurred and draws together the comments thematically.

1.17 The report is not intended to be an exhaustive list of all the points made, but rather a detailed overview of the main themes and issues emerging from the consultation.