Dounreay Radioactive Waste Substitution Consultation: Response Paper

Question 1: Do you agree that a waste substitution policy should be adopted for radioactive waste arising from overseas research reactor fuel reprocessing contracts at Dounreay?

Responses

2.1 Most of the respondents answered 'yes' to this question.

2.2 Some respondents commented that the policy would allow early conclusion of the contracts held with Dounreay, thereby improving the ability to plan for the management of radioactive waste.

2.3 Two of the respondents also commented that the adoption of the policy would likely reduce the international transport of radioactive waste from the UK, with one commenting that the proposals should reduce hazards and the chances of an accident with population or environmental consequences.

2.4 One respondent commented that the adoption of the policy was likely to represent the best use of the UK's infrastructure for the management of radioactive waste and better value for money for the taxpayer.

2.5 Of the respondents who did not agree with the adoption of the policy, one agreed 'in part'. Two respondents provided a ' Statement of Principles' in relation to radioactive waste management at Dounreay that has guided their decision-making in relation to the decommissioning of the site. These principles precluded their agreement with the policy.

Government Response

2.6 There were no issues identified to suggest that the principle of waste substitution for Dounreay contracts was fundamentally flawed and should not proceed. Government has therefore concluded that the NDA can adopt a waste substitution policy for radioactive waste arising from overseas research reactor fuel reprocessing contracts at Dounreay. Having the option of waste substitution will help bring closure to the contracts held with Dounreay, which in turn will help with the decommissioning, clean-up and effective management of radioactive waste at the site.

2.7 Without this policy option the NDA will not be able to clarify its strategy for overseas liquid wastes at Dounreay, resulting in:

• continued storage of overseas liquid wastes with little certainty about when they might be solidified, possibly leading to long delays or a potential inability to return wastes overseas. and
• potentially increasing the risk of delay to the decommissioning and clean-up of the Dounreay site .

2.8 This policy extends the scope of the UK Government policy set out in Cm2919 ² , and subsequently amended in 2004, that allowed BNFL (as was) to substitute Intermediate-level waste ( ILW) and return a radiologically equivalent amount of High level waste ( HLW) to its overseas customers. Thus, there is policy precedent and it has been in place and used for many years.