Dounreay Radioactive Waste Substitution Consultation: Response Paper

Question 4: Do you agree with the proposals to ensure broad environmental neutrality for the United Kingdom?

Responses

5.1 Most of the respondents answered yes to this question.

5.2 One respondent commented that the proposals were 'pragmatic', with some commenting that the proposals would result in a likely reduction in transport and would be beneficial to the environment.

5.3 One respondent commented that UK environmental neutrality may benefit from both the technology on the management of vitrified radioactive waste in Sellafield and the experience achieved by NDA on the return to customers of the vitrified residues.

5.4 One respondent answered 'in part' to this question, adding that whilst the specific measures proposals were finite and in accordance with the principle of minimum transport of waste, the principle of broad environmental neutrality was one which they could not accept. The respondent added that unless consideration was given to the environmental neutrality of constituent countries, the principle of broad environmental neutrality for the UK could permit Dounreay to be used as the national waste store.

Government Response

5.5 Government has concluded that the primary consideration for determining broad environmental neutrality is that substituted radioactive wastes should be radiologically equivalent. It will be a matter for the NDA, to determine the precise methodology used to calculate this radiological equivalence.

5.6 However, in the case of substitution of vitrified radioactive waste from Sellafield for Dounreay PFR and MTR radioactive wastes, the environmental neutrality will also be agreed, jointly, by the Scottish Environment Protection Agency ( SEPA) and the Environment Agency. For the substitution of cemented MTR radioactive waste for PFR radioactive waste, the environmental neutrality will be agreed by SEPA.

5.7 With respect to the response described in paragraph 5.4, Government recognises that this policy might result in a very small increase in the amount of waste remaining at Dounreay. However, the scope of the policy is very limited, applying to overseas MTR and PFR wastes only, hence it is not correct to infer that this poilcy means that the site will become a national waste store.