1. Why We Are Consulting
This Chapter outlines:
- why a policy for radioactive waste substitution is needed for Dounreay
- why we are not undertaking a Strategic Environmental Assessment
- the current radioactive waste substitution policies in the United Kingdom
- the proposed policy
- the reasons for this proposal, including the implications of the customers' current radioactive waste facilities
1.1 Why a Policy for Radioactive Waste Substitution is Needed for Dounreay
1.1.1 The Nuclear Decommissioning Authority ( NDA) has 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, an equivalent amount of radioactive waste from another source within the NDA's estate would be sent. Further information on the NDA can be found at:
1.1.2 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,
- Prototype Fast Reactor raffinate waste at Dounreay with Cemented Materials Test Reactor raffinate waste at Dounreay
1.1.3 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.
1.1.4 Clarity about the Government's policy on radioactive waste substitution is therefore necessary to allow the NDA to complete the discussions with it's overseas customers.
1.2 Strategic Environmental Assessment
1.2.1 The proposed policy has had to be considered within the terms of the Environmental Assessment of plans and programmes Regulations 2004 ( UK Regulations) as it relates to more than just Scotland. Having considered the matter carefully, it is our view that an Strategic Environmental Assessment ( SEA) is not required, as the proposed policy falls outside the coverage of the 2004 Regulations.
1.3 The Current Radioactive Waste Substitution Policies in the United Kingdom
1.3.1 The existing policy on radioactive waste substitution, is limited to the substitution of High Level radioactive Waste ( HLW) for Low Level radioactive Waste ( LLW) and Intermediate Level radioactive Waste ( ILW) arising from overseas reprocessing contracts at Sellafield. The policy covers the radioactive waste arising from the reprocessing of around 4,500 tonnes of nuclear fuel at Sellafield. However that policy does not cover the substitution of any radioactive waste at Dounreay.
1.3.2 The first policy about radioactive waste substitution was stated in 1995 in Cm 2919: Review of Radioactive Waste Management Policy Final Conclusions. Whilst much of Cm 2919 has been superseded, the principle of radioactive waste substitution for Sellafield allowing British Nuclear Fuels Limited ( BNFL) to return additional volumes of HLW overseas in place of LLW still stands, 1 although it is now the NDA who is responsible for any reprocessing contracts signed by BNFL.
1.3.3 The policy also covered the substitution of HLW in place of ILW but this was updated and replaced by the December 2004 Intermediate Level Radioactive Waste Substitution policy statement. 2 This approved the retention and long term management in the UK of overseas ILW under existing BNFL contracts with the return of an additional, radiologically equivalent amount of HLW in its place. Again, it is now the NDA who is responsible for these contracts.
1.3.4 The principle of radioactive waste substitution is therefore already established. The proposed policy would extend this principle to the radioactive waste allocated to customers under their reprocessing contracts at Dounreay. The amount of fuel covered by these contracts is very small in comparison with Sellafield and amounts to approximately two tonnes.
1.4 The Reasons for this Proposal
1.4.1 A radioactive waste substitution policy for Dounreay would bring a number of benefits. These include:
- The ability to return radioactive wastes earlier, in a form that recipient states can accept
- Clarity for Dounreay's future radioactive waste management needs
- Simplification of transport of radioactive waste overseas
- Completion of contracts
- Avoiding the need to construct another vitrification plant
These are described in more detail below.
1.4.2 Current Government Policy is for overseas radioactive waste to be returned as soon as practicable. Allowing the NDA to offer radioactive waste substitution as an option for managing its overseas customers' radioactive wastes at Dounreay would result in radioactive waste being returned overseas sooner than if radioactive waste substitution was not an option.
1.4.3 Agreement with customers on the type of radioactive waste to be repatriated would clarify management arrangements required for decommissioning operations at Dounreay. This in turn would be expected to minimise delays in reaching the Interim End State and therefore reduce overall expenditure.
1.4.4 There is no cementation plant for PFR reprocessing radioactive waste at Dounreay nor is one likely to be available for several years (the plans for the construction of this facility are currently on hold 3). This is in contrast to the cementation plant for MTR reprocessing radioactive waste, which is expected to finish immobilising all of the MTR reprocessing radioactive waste by the end of 2013. Where the return of vitrified radioactive waste from Sellafield is not acceptable to customers, enabling a single type of cemented radioactive waste to be returned to these customers would simplify arrangements, allow radioactive waste to be returned as soon as practicable and give Dounreay greater clarity of its future radioactive waste management requirements.
1.4.5 Some of Dounreay's customers do not have facilities for handling the cemented ILW produced at Dounreay or even have plans to develop them. Without a radioactive waste substitution option available, this radioactive waste would most likely have to remain in the UK until an overseas facility was ready to receive it. On the other hand, in many countries facilities for vitrified radioactive waste or plans for them are further advanced. Given that the contracts between the NDA and these overseas customers do not allow radioactive waste to be returned prior to the customers being ready to receive it in a form that they can handle, it is likely that it will be possible to return vitrified radioactive wastes well in advance of some cemented radioactive wastes.
1.4.6 Sellafield already has arrangements in place for transporting vitrified radioactive wastes to overseas customers. Subject to appropriate commercial terms, it may be possible to incorporate the radioactive waste return obligations from Dounreay within these arrangements. Limited arrangements are in place for the return of MTR radioactive wastes from Dounreay. However, there are no arrangements in place for the return of PFR radioactive wastes from Dounreay and these could not fully be put in place until 2017 at the earliest.
1.4.7 In the event that sending vitrified radioactive waste from Sellafield was not an option but the NDA's customers were asking for vitrified radioactive waste, having to design, build, operate and eventually decommission a vitrification facility at Dounreay to satisfy these contracts would represent a significant cost to the UK taxpayer. While the exact cost of a vitrification plant for Dounreay has not been determined, it is estimated to be in the order of several hundreds of millions of pounds. It is also worth noting that this facility would itself become contaminated through the treatment of radioactive waste, thereby creating more radioactive waste when it is decommissioned. A further facility would have to be constructed at Dounreay to allow export of the vitrified radioactive waste directly to sea transport. Alternatively, all vitrified radioactive waste produced at Dounreay would have to be transported overland to the existing Residue Export Facility in West Cumbria. There is no technical necessity for any of this plant at Dounreay, it would be solely used for the treatment of this relatively small amount of overseas radioactive waste. Government does not believe such plant is justifiable for the very small quantities of radioactive waste involved, especially as a vitrification plant is already in operation at Sellafield.
1.5.1 The ability to return vitrified radioactive waste from Sellafield in place of radioactive waste from Dounreay and/or returning cemented MTR radioactive waste in the place of PFR radioactive waste makes best use of the facilities that already exist and brings several benefits, including increased certainty on the overall decommissioning program for Dounreay. Government therefore proposes extending existing radioactive waste substitution policy to cover radioactive wastes at Dounreay from overseas contracts.