Dounreay Radioactive Waste Substitution Consultation: Response Paper

Additional comments and requests for further information

7.1 Two respondents commented that they were opposed to the unnecessary transport of radioactive and other hazardous wastes, and their preferred solution is to retain and manage the wastes at Dounreay.

7.2 One respondent requested further information on how risks of release of material are managed during the transportation of radioactive materials.

7.3 One respondent made the following comments:

• It would be helpful for the Scottish Government to issue a Direction or similar mandate to help SEPA ensure radiological equivalence in NDA's contracts with overseas customers.
• It is assumed there is no presumption for the policy to extend to cover substituting wastes other than vitrified waste from the Sellafield site.
• Further information is requested as to why the policy was considered to be out with the scope of Strategic Environmental Assessment Regulations.
• Further information is requested as to what role UK Government would expect when concluding these arrangements for returning wastes overseas.
• It is suggested the policy should make it clear how Government would resolve the issue where customers ask for vitrified waste to be sent from Sellafield, but this option may not be practical or there are other reasons why this cannot happen.

Government Response

7.4 With respect to the response described in paragraph 7.1, Government policy remains that the radioactive wastes resulting from overseas spent fuel at Dounreay under those reprocessing contracts signed since 1976 should be returned to the country of origin, subject only to the possibility of substitution allowed by this policy.

7.5 With respect to the response described in paragraph 7.2, up to half a million packages containing radioactive materials are transported within the UK every year. The safety of the transport of radioactive material is ensured by the design of the transport packages used. These packages are designed to protect the environment from the radioactive materials that they contain and are tested to ensure that the protection they provide is maintained even under extreme circumstances.

7.6 The transportation of radioactive material must be carried out in compliance with all the required regulatory obligations that are put in place specifically to ensure that movements of nuclear materials are both safe and secure. On this basis, Government expects risks associated with any transportation of radioactive waste to be managed effectively.

7.7 With respect to the response described in paragraph 7.3, the Scottish Government will consider the merits of the request for Scottish Ministers to issue a Direction to SEPA.

7.8 Government believes that the scope of this policy is sufficiently clear: 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.

7.9 The proposed policy is out with the scope of the Environmental Assessment of Plans and Programmes Regulations (2004) in respect of 2(c) and 5(2)(b) and therefore a Strategic Environmental Assessment was not considered to be necessary on this occasion.

7.10 Substitution of waste will entail commercial negotiations between the NDA and overseas customers which will include discussion around the practicalities of returning the various waste forms. If necessary Government would consider bilateral discussions with overseas Governments in order to facilitate repatriation of overseas waste

7.11 This policy enables the substitution of overseas wastes at Dounreay but does not require that it be done. Where the option of substituting vitrified wastes from Sellafield is not practical then Government would still expect arrangements to be made to return wastes to the country of origin.