Scotland’s Radioactive Waste Management Policy

It is important to note is that spent fuel is not officially defined as “waste” in the UK because it supposedly contains “useful” plutonium and unused uranium. Dealing with spent fuel is not within the remit of the Scottish Government, so this is still transported by train from EDF Energy’s two nuclear plants at Hunterston and Torness to Sellafield in Cumbria in North-west England. This also means that there are various materials at Dounreay such as “breeder material”, unirradiated highly-enriched uranium; unirradiated plutonium and irradiated fuels, none of which are defined as “waste”, which will be transported, mostly by train, from the North of Scotland down to Sellafield over the next five or six years. (see Dounreay). Finally, while some other countries might classify spent fuel as High Level Waste (HLW), officially there is no HLW in Scotland. Although previous radioactive waste inventories showed the presence of HLW at Dounreay produced by fast reactor reprocessing, this waste has cooled over time and it is now classified as Intermediate Level Waste (ILW). The term Higher Activity Waste is used in Scotland to encompass ILW and certain types of Low Level Waste (LLW) which by their nature are not currently suitable for disposal in existing LLW disposal facilities such as the one at Drigg near Sellafield.

The Scottish Government does not accept that geological disposal of radioactive waste is the right way forward. Cabinet Secretary for Rural Affairs and the Environment Richard Lochhead said:

We do not accept that it is right to seek to bury nuclear waste, which will remain active for thousands of years, in a deep geological facility or to expect any community to host such a facility. This out of sight out of mind policy should not extend to Scotland.”1

The Scottish Government published its finalised Higher Activity Waste Policy on 20th January 2011.2 The Policy is that the long-term management of higher activity radioactive waste should be in near-surface facilities. Facilities should be located as near to the site where the waste is produced as possible. Developers will need to demonstrate how the facilities will be monitored and how waste packages, or waste, could be retrieved. All long-term waste management options will be subject to robust regulatory requirements.

The finalised Policy made clear that: “…Scottish Government Policy at the present time is that long-term storage is still the primary long-term management option3 (emphasis added).

However, “disposal” of Higher Activity Waste (HAW) in near surface disposal facilities is still included as an option.4 This has led some commentators to assume that all of the higher activity waste in Scotland which is suitable for near surface disposal will be disposed of in this way.

For example, CoRWM discussed the Policy at its meeting in York on 14th September 2011. The minutes record CORWM’s view that the Scottish Government has: “…produced a policy that was adequate for some waste producers but not definite enough for those waste producers with HAW not suitable for near site, near surface disposal.”5

Around 25% of Scotland’s Higher Activity Waste is considered to be unsuitable for near-surface disposal, and would need to be stored until there are further technological developments. These wastes include plutonium contaminated materials, and raffinates – both the result of reprocessing at Dounreay – and sludges.6 (N.B. Spent fuel from Scotland’s operating reactors is not considered to be a “waste” so is not covered by Scottish Policy – it is still transported to Sellafield for reprocessing.)

The Nuclear Free Local Authorities assessment of the Scottish Policy published in January 20117 said that the “proof will now be in the pudding” and it will be necessary to watch how the policy is implemented. Near-surface disposal of graphite sleeves at Hunterston was being considered for a while – despite the fact that adequate storage facilities already exist on site. However, this project was abandoned at the end of 2011 for economic reasons.8

The NDA published a Strategy Paper on Intermediate Level Waste Storage Solutions in Central and Southern Scotland in August 2012.9 The proposals in the paper were said to be consistent with the NDA’s Integrated Waste Management (IWM) Strategy which is that centralised and multi-site approaches should be considered where advantageous. The NDA consultation considered a variety of options about moving waste including within the Hunterston nuclear reactor facility and between other sites, such as Torness and Rosyth.10

The Nuclear Free Local Authorities (NFLA) response to the NDA consultation argued against the current way in which the ‘waste hierarchy’ is used by the NDA, because it leads to the dilution and dispersal of radioactivity rather than its concentration and containment, and called on the NDA to drop altogether, rather than postpone, consideration of the storage of Torness waste at Rosyth, and consideration of transporting Torness waste to the Hunterston store.11

The NDA published its Preferred Option position paper in April 2013. Its preferred option is to store the waste on reactor sites except at Hunterston B where there are benefits in storing the Hunterston B waste within the Hunterston A store.12

1. Scottish Government Press Release 25th June 2012 
2. Scotland’s Higher Activity Radioactive Waste Policy 2011, see aso “Post Adoption Strategic Environment Assessment” and Scottish Government response to submissions made to the consultation
3. Scotland’s Higher Activity Radioactive Waste Policy, 2011. (para 2.04.03)
4. Paras 2.04.26 to 2.04.36
5. CoRWM Minutes of Plenary Meeting 14th September 2011, York
6. CoRWM Document 2621. Note of meeting with Scottish Government 20th May 2009
7. Scotland’s Higher Activity Waste Policy: A Brief Assessment, NFLA, January 2011
8. Sunday Herald 5th February 2012
9. NDA 22nd August 2012
10. NFLA Press Release 17th September 2012
11. Radioactive Waste Management Policy Briefing No.35 Scottish ILW Storage Policy.
12. NDA 30th April 2013.

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Published: 14 November 2012
Last updated: 26 June 2013