8.1 The majority of respondents agreed overall with the proposed policy, but others raised concerns over some aspects of the policy.
8.2 Having considered all the responses, Government has 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:
The aim of this policy statement is to set down the Government's position on the substitution of radioactive wastes at Dounreay arising from the reprocessing of overseas nuclear fuels, known as 'raffinate'.
Government policy remains that the radioactive wastes resulting from the reprocessing of overseas spent fuel at Dounreay under those reprocessing contracts signed since 1976 should be returned to the country of origin. This should be carried out as soon as practicable after the radioactive waste has been produced.
Government accepts that the circumstances at Dounreay have changed markedly since the United Kingdom Atomic Energy Authority entered into contracts with overseas customers to reprocess nuclear fuels. As a result, alternative means of satisfying contractual obligations should now be considered in order to allow these obligations to be discharged as soon as reasonably practicable.
Substitution of Prototype Fast Reactor ( PFR) and cemented Materials Test Reactor ( MTR) raffinate wastes from Dounreay with a radiologically equivalent amount of vitrified radioactive waste from Sellafield is permitted subject to contractual agreement with overseas customers and approval from the environmental regulators (the Environment Agency and the Scottish Environment Protection Agency).
Substitution of PFR raffinate waste with a radiologically equivalent amount of cemented MTR raffinate is also permitted subject to contractual agreement with overseas customers and approval from the environmental regulator.
In both cases 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.
8.3 Government expects that the environmental regulators will work with the NDA to determine a satisfactory methodology to determine radiological equivalence in line with the policy statement above.
8.4 Government will consider provisions as to how the environmental regulators ensure that the waste substitution arrangements result in environmental neutrality.
8.5 The NDA, and Government if necessary, will discuss waste substitution options with its overseas customers.