Environment Agency
February 11, 2019
·
Government concluded that a waste substitution policy for radioactive waste arising
from overseas research reactor fuel reprocessing contracts is an acceptable practice that the
NDA can adopt to deal with Dounreay contracts
·
We consider that SEPA retain an interest in this matter in so far as the arrangements
for substitution continue to meet the policy direction of broad environmental neutrality. On
that basis, they have an ongoing interest however this would only involve any direct
regulatory role should there be any proposed change in the methodology which would
undermine the position we jointly declared in May 2013.
·
Government expects broad environmental neutrality to be maintained, primarily on the
basis of radiological equivalence. Government will not specify the methodology used to
determine radiological equivalence but expects the environmental regulators to be satisfied
that the waste substitution arrangements between the NDA and its overseas customers
result in environmental neutrality.
·
Based on our findings both the Environment Agency and SEPA were content that the
Dounreay waste allocation and substitution methodologies and their underpinning
calculations will meet the policy direction of broad environmental neutrality.
·
The matter of regulating the transfer of radioactive waste from Sellafield to ANSTO is
the responsibility of the Environment Agency in accordance with the Transfrontier Shipment
of Radioactive Waste and Spent Fuel Regulations. This regulation seeks to ensure that the
intended receiving country is capable of managing the waste safely, and seeks the consent
of the authorities of the country involved (see https://www.gov.uk/guidance/radioactivewaste-spent-fuel-or-sources)
·
To-date the Environment Agency has yet to receive an application for the transfer of
this waste.
·
The response to the consultation, published in 2012, can be found at:
https://www.gov.scot/publications/dounreay-radioactive-waste-substitution-consultationresponse-paper/pages/10/