1.  SEPA completed a public consultation exercise of the UKAEA's application to dispose of radioactive wastes for Dounreay, on 23 February 1998. This was the second public consultation. The first consultation was run by SEPA's predecessor body Her Majesty's Industrial Pollution Inspectorate, and ended in February 1996. SEPA also held a public meeting in Inverness at which presentations were invited on 26 February 1997. The Scottish Office has yet to decide whether or not to "call in" the application.

  2.  The import of foreign spent fuel is highly controversial in Scotland. When the people of Caithness voted in a referendum in December 1995, 65.5 per cent of voters opposed foreign reprocessing. An opinion poll commissioned by Friends of the Earth Scotland, also in December 1995, found 94 per cent of Scots opposed to reprocessing of foreign spent fuel at Dounreay.

  3.  SEPA accepts that "there should be a clear economic justification for reprocessing overseas material" (Minutes of SEPA North Regional Board Meeting 24 January 1997, SEPA Volume 1, Annexe 6, p89).

  4.  Some of the discharges for which the UKAEA requested authorisation were planned to come from the reprocessing of overseas spent nuclear fuel. Greenpeace along with two other Non-Governmental Organisations requested of SEPA, the UKAEA and the Department of Trade and Industry, economic information on the proposed overseas spent research reactor fuel reprocessing contracts, in order to appraise the economic justification. The reply from the Dti did not arrive until 16 March, after the closing date of the public consultation exercise.

  5.  Dti failed to provide answers to several crucial questions, either because it does not have the information or because of commercial confidentiality. In fact no new information was given to Greenpeace which makes it possible to appraise the economic justification given to SEPA for the discharge of radioactivity to the environment. (See Appendix 1.—Mike Sadnicki's letter and Appendix 2—Dti reply)[1].

  6.  SEPA replied to Greenpeace on 27 January 1998 indicating that "SEPA does not have the information that you requested." (See Appendix 3).2 It is worth noting that SEPA did not say, although they have the information, they are unable to release it for reasons of commercial confidentiality. There must therefore be some doubt about whether SEPA has been able to properly appraise the economic case for foreign reprocessing at Dounreay, to be able to decide whether the discharges of radioactivity which would result are justified.

  7.  Clearly the lack of an economic justification case for foreign spent fuel reprocessing at Dounreay would increase the chances that the Secretary of State for Scotland would decide to "call in" the applications, and call a public inquiry.

  8.  Dounreay told the Observer (26 April 1998—first edition only. See Appendix 41)—that it was hoping to use the consignment of waste from Georgia to persuade the Nuclear Installations Inspectorate to lift its ban on reprocessing. Managers at Dounreay said the shipment was "vital, timely support" for their case. "To fulfil the Government's aim of reprocessing it, we need to get a licence from the NII" said one official. "If you can do the Georgian stuff, you can do other overseas contracts as well".

  9.  Before any of the latest problems at Dounreay, such as the accidental damage to the power cable, the Nuclear Installations Inspectorate had announced that Dounreay should not be allowed to import and store nuclear waste for reprocessing when it has no operative reprocessing plant and no proper place to store it. ("Nuclear Worries" Herald 17 April 1998—Appendix 51. The NII had also said that there should be no importation of spent fuel to Dounreay until the NII had approved storage and reprocessing arrangements for the fuel.

  10.  The NII safety review had already raised the possibility of expensive repairs to both reprocessing plants, which would clearly have an impact on the economic justification for any future reprocessing.

  11.  SEPA had in the past expressed concern that waste dumping rather than reprocessing is the main reason overseas research reactor operators sought contracts with UKAEA. Their concern was also shared by the Radioactive Waste Management Advisory Committee, and Michael Meacher (See Appendix 6—quoted in Greenpeace submission to SEPA 23 February 1989 page 4) 2. SEPA proposed to resolve this situation by insisting that waste from reprocessing contracts be returned to the country of origin within 10 years—the current situation allows waste to remain in store at Dounreay for up to 29 years.

  12.  It is clear from the Government's 5 June announcement that Ministers have been advised that reprocessing the spent fuel currently at the Dounreay site is a "necessary part of the decommissioning process". This is not true. In fact the UKAEA carried out a study of the Prototype Fast Reactor spent fuel management options for the Dti to determine the preferred management strategy on technical and economic grounds (PFR Fuel Management Options—Issue 1—FWTF(95)P43 September 1995). Dry storage options are costed in that document at anywhere between £188 million to £241 million. On the other hand reprocessing is expected to cost anything up to £206 million. However, that was before the cost of repairing the fast reactor reprocessing plant was included in the calculation. It is quite likely, therefore, that dry storage would turn out to be cheaper. Not only that but Dounreay would be able to develop a new expertise in dry storage to add to its expertise in decommissioning to preserve jobs on the site. Of the spent fuel currently at the Dounreay site, around 15 tonnes is fast reactor spent fuel and only one tonne research reactor spent fuel. There is no reason to think that research reactor spent fuel could not be dry stored along with the fast reactor spent fuel.

13.  CONCLUSION

  By secretly ordering the import of the Georgian uranium to Dounreay the Government has undermined the efforts of the regulators to control the growing problem of radioactive discharges from Dounreay; concern about nuclear waste in storage at Dounreay; concern about the safety of the reprocessing plants.

  The Government also went against the wishes of the vast majority of people in Scotland, and undermined the democratic process including the consultation of the public on proposals for revised discharge authorisations.

  The Government announcement on 5 June implied that the Dti will now be willing to fund any modifications that have to be made to the research reactor reprocessing plant, because of the overriding pressure created by the importation of the waste from Georgia. However it is doubtful that this expenditure can be economically justified. This in turn will place pressure on SEPA to agree to the UKAEA's application for revised discharge authorisation, irrespective of the economic justification. The Nuclear Installations Inspectorate will also be under pressure to approve the safety case made by UKAEA for the research reactor reprocessing plant.

  Although there will be these pressures on the Government and its regulators to now approve the re-opening of both reprocessing plants at Dounreay, Greenpeace would strongly oppose such a course of action. It is not inevitable. The waste from Georgia could still be stored, as could the rest of the 16 tonnes of spent fuel at Dounreay, rather than reprocessed. Long-term dry storage would prevent the extraction of unused bomb-grade uranium, which if extracted would re-enter the world market place.

  Re-opening either the research reactor reprocessing plant or the fast reactor reprocessing plant, without proper economic justification might well be unlawful and open to challenge following the ruling made byMr Justice Potts during the judicial review of the Government's decision to authorise discharges from Sellafield in 1994.

  Any increase in radioactive discharges as a result of reprocessing any of the spent fuel already on the Dounreay site, including the Georgian uranium would also be against the commitments that the UK Government has signed up to under the OSPAR convention.

11 June 1998

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