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Dounreay's work means increased pollution

The following report details the increase in marine and atmospheric radioactive discharges proposed for Dounreay in an application for authorisation by the operators, UKAEA, and examines the reasons for the discharges. It was written by environment journalist and consultant Mike Townsley for the Nuclear Free Local Authorities in February 1996. Since this was written a decision has been reached on the application.

The Scottish Environment Protection Agency (SEPA) which has taken over HMIPI's responsibilities wants to impose stricter discharge limits, based on 100 per cent of need, rather than the 200 per cent used by HMIPI, and initially also wanted all waste from reprocessing foreign fuel returned within 10 years rather than the present 25 year limit. This was successfully opposed by Dounreay and Sellafield interests during a new, second round of public consultations due to end in February 1998 and a final decision was announced by the Scottish Government in July 1999. See SEPA's Decision for a full summary.

Introduction

1.2 Various activities at Dounreay, over the last forty years, have led to significant discharges of radioactivity to the environment, causing considerable concern both in the UK and in Europe. Those discharges are overseen and authorised by HM Industrial Pollution Inspectorate (HMIPI). In 1992 HMIPI informed the UKAEA that it intended to review the Dounreay site's authorisation for discharging radioactivity.

1.3 Subsequently, the UKAEA submitted an application for new discharge authorisations in October 1993. That process is now, finally, nearing completion. A public consultation on the application was launched at the end of last year and is scheduled to run until February 23.

1.4 This briefing is accompanied by a separate Legal Briefing (LB) for reference. Where an issue is mentioned here that points to a breach of law or policy, references to the LB are given for a fuller explanation to assist authorities in making representations.

2 The Application

2.2 In particular, the ruling made in 1994 by Mr Justice Potts during a judicial review of the Government's decision to open the Thermal Oxide Reprocessing Plant at Sellafield clarified the fact that as a matter of law radioactive discharges could not be permitted at all unless the processes involving the discharges offered benefits to society which outweigh the harm caused by its discharges. This has therefore placed the onus on the UKAEA to prove this for the first time and it is clear that the weighing of advantage and disadvantage involves a complex process that requires the review of all relevant factors, tangible and intangible. This is not limited to environmental, health and safety, and economics but includes many other factors including public attitudes.

2.3 Further, changes and developments in Dounreay's decommissioning programme and alterations to the UKAEA's planned commercial diversification programme have also led to substantial alterations being made to the original application.

2.4 The application covers discharges from:

(i) the decommissioning of redundant facilities, primarily decommissioning of the Dounreay Fast Reactor (DFR) and the Prototype Fast Reactor (PFR); (ii) the reprocessing of PFR fuel; (iii) a wide variety of supporting facilities, operated to provide waste handling support, which generate radioactive waste and; (iv) commercial work, including, reprocessing, fuel fabrication and waste treatment.

2.5 The delays and alterations have resulted in public consultation documents which are at best haphazard and at worst chaotic. Five different UKAEA documents have now been released for public comment by HMIPI, along with six of their own. Little or no effort appears to have been made to make the documents accessible to members of the public. As such, the consultation process cannot be considered satisfactory.

2.6 On these grounds alone, the Scottish Secretary, Michael Forsyth, should use his power under the Radioactive Substances Act 1993 and call in the application for a full public inquiry.

2.7 For example, in dealing with the justification for continuing to reprocess spent fuel from the now closed PFR, no substantive information is supplied within the consultation documents outlining what alternatives have been considered to reprocessing. Instead the UKAEA simply states that reprocessing is its preferred option.

2.8 On the possibility of using dry storage followed by direct disposal it simply notes that this option was "rejected for various reasons described in ref 1". Ref 1 ("PFR Fuel Management Options -- Issue 1 -- FWT(95)P43, September 1995") has not been included with the consultation documents. It is, therefore, impossible to determine whether or not the UKAEA's judgement is valid.

3.2 Following the authorisation of the THORP plant to discharge radioactivity and the controversy which surrounded the purported public consultation, the Government's advisory body, the Committee on Medical Aspects of Radiation in the Environment (COMARE), made a very clear recommendation that expected discharges levels should be provided as part of any public consultation. (Report on the public Consultation on BNFL's applications for revision of the Certificates of Authorisations, Letter from Professor B Bridges (Chair of COMARE) to MR M Mardell, HMIP, 1993)

3.3 Such is the scale of the planned increased discharges that, broadly speaking, Dounreay's discharges are set to reach levels akin to that of Sellafield, in Cumbria. For gaseous discharges some radionuclides (including Sr-90, Cs- 137, Pu-241) will be discharged at a higher level than at Sellafield.

3.4 It is also worth noting that in calculating doses to the so-called 'critical groups' -- those deemed most likely to accrue significant radiation doses from Dounreay -- HMIPI and the UKAEA appear to rely upon a habitat survey carried out in 1988 and a 1985 modelling paper by Nicholson. (The Estimation of Individual Doses from Routine Discharges of Liquid Effluent from a Fast Reactor Reprocessing Plant. SRD R328, March 1985) Neither paper has been included with the consultation documentation. When the Nicholson paper was obtained it was found to be marked "in confidence". This suggests that the methodology has not been independently verified and therefore casts serious doubt upon the critical group calculations. There are no legitimate grounds for concealing such documents in a consultation about the protection of public health and the environment, which requires as wide a peer review as possible.

3.5 The UKAEA's collective dose calculations are fundamentally flawed. The UKAEA fails to report C-14 and I-129 releases and consequently fail to report their effects, while this omission is noted by HMIPI, no action to remedy the matter has been taken. Both are long-lived radionuclides which are potent contributors to collective dose. Indeed, such is their potency, that BNFL at Sellafield has spent 10 million on a C-14 reduction plant. C-14 accounts for 85% of the Sellafield "collective dose" received by the public in 1991.

3.6 In its October 1993 document, "Information in support of an application for authorisation for the disposal of liquid radioactive wastes from AEA-Technology Dounreay" the Authority states: "Assuming the discharges are maintained at the proposed limit for five years the worth [i.e., detriment] of the discharges is about 1M (0.5 million at needs level)."

3.7 This calculation is arrived at by under reporting of the collective radiation dose and by attributing a very low value to human life. The UKAEA uses a detriment value of 20,000 per man sievert of exposure. This, in effect, places a 400,000 price on a human life. However, when carrying out cost benefit analysis during road traffic studies the Department of Transport (DoT) uses a figure of 700,000. Further, the Commission of the European Communities (CEC) uses a value of 2 million for a life. Using the DoT value of 700,000 the health detriment associated with Dounreay's application would be a minimum of 2.3 million, while the CEC figure gives a cost of 6.5 million.

3.8 In applying for new discharge authorisations, the UKAEA has stated its need to discharge. This turns out to be at most only two thirds of the discharge limits which HMIPI plan to authorise. No adequate reason is given for the large gulf between the stated need and the proposed limits, and no justification for the wide margin is provided in any of the consultation documents. Environmental and public protection requires that the tightest limits achievable should be imposed to ensure that the UKAEA meets its obligation to keep its discharges As Low As Reasonably Achievable (ALARA).

3.9 The UKAEA cites National Radiation Protection Board's protection standards for future generations which should be least equivalent to those afforded to present generations. However, this is contradictory to the principles of 'sustainability' and 'intergenerational equity' promoted at the Rio 'Earth Summit' which permit future generations to set their own levels of protection. No action should therefore be embarked upon which limits the rights of future generations.

3.10 Given the consistent downward trend in permitted dose limits since the inception of the nuclear industry, it is unrealistic to assume that this process is complete and that we now fully understand the effects and behaviour of radiation in the environment.

4 Decommissioning

4.2 However, in its original 1993 application the UKAEA comments that the limits being applied for "include allowances for decommissioning, as far as these can be foreseen at present." Such statements do not constitute an acceptable basis for blanket approval to future discharges arising from and decommissioning work.

4.3 The gap between the UKAEA's stated need to discharge and the limits which HMIPI are proposing can only be interpreted as being designed to allow Dounreay to bypass public consultation over the discharges associated with its decommissioning programme. This view is confirmed by the UKAEA's statement on potassium-40 and sodium-22 discharges from decommissioning in that "... no allowance has been made for the total beta need. It is considered that the margin between need and the proposed limit will be sufficient to accommodate these, effectively transient arisings, which, according to present plans, will be disposed of at different times."

4.4 Considerable uncertainty surrounds the issue of decommissioning at Dounreay and planning permission for aspects of this may well be required. Not only is there a large number of damaged fuel and breeder elements held within the cores of the two fast reactors but there remains a residue of highly volatile NaK (sodium potassium) coolant within the DFR and the entire Na (sodium) cooling inventory of the PFR to be neutralised, which by the UKAEA's admission is a fire risk.

4.5 Perhaps, one of the most vexing decommissioning problems facing the UKAEA at Dounreay is how to deal with its controversial Intermediate Level Waste Disposal Shaft. Yet, this is not even mentioned in the UKAEA consultation document "Social & Economic Effects of Dounreay's Projected Programme of work 1995-2005", which contains a section on waste management. The shaft is believed to be responsible for widespread radioactive contamination of the Dounreay foreshore. Indeed, such has been the severity of the outcry over the shaft -- which contains an unspecified quantity of radioactive waste and which exploded in 1977 -- that the Government's Radioactive Waste Management Advisory Committee (RWMAC) warned last year that it is not an acceptable method for disposing of radioactive waste and said that natural erosion of the nearby cliff side could cause it to be breached within the next hundred years. (Potential Health Effects and Possible Sources of Radioactive Particles found in the Vicinity of the Dounreay Nuclear establishment. RWMAC/COMARE, May 1995) The proposed authorisations for solid wastes will delete the present authorisations for the shaft. The only remaining control of the shaft will then be a requirement under the proposed new authorisations to "use the best practicable means for preventing the escape of any contaminated liquid from [the shaft]."

5.2 In its 1993 application the UKAEA stated its intention to reprocess the PFR spent fuel at a rate of 7.5te per year. This has now been down graded to 5te per year, based on operational experience since 1993.

5.3 In choosing to continue reprocessing PFR spent fuel at Dounreay, the UKAEA considered a number of alternatives, including on-site dry-storage followed by direct disposal. The dry-store option would cost between 197 million and 241 million, while reprocessing has been costed at between 165 million and 206 million.

5.4 However, in failing to make the September 1995 "PFR Fuel Management Options -- Issue I" (2.8) document available as part of the public consultation, it is impossible to scrutinise these calculations. Yet, it is worth noting that the original decision to reprocess 7.5te per year was made at the insistence of the DTI. The DTI feared that any delay in reprocessing the fuel could leave it open to expensive repair bills for the ageing fast reactor reprocessing plant. Clearly, in that instance, at least, short term economics, and not long term environmental considerations, was the driving force behind the reprocessing programme and therefore the resultant radioactive discharges.

5.5 A 5te per year throughput would require the reprocessing plant to work at 70% of its technical capacity, so considerable doubt must remain about the ability of the ageing plant to meet this target. Any breakdown or delay would significantly increase the costs of the reprocessing option and therefor make the option of dry-storage much more attractive. No indication has been given as to whether this possibility has been considered or played any part in the UKAEA decision making process.

5.6 In conclusion, the UKAEA says that while the Nuclear Installations Inspectorate felt that the alternatives to reprocessing would be technically feasible they would require special arrangements to be made. It further comments that the NII said such alternatives would "probably" result in increased worker exposure, but the reasons for this are not explained. This once more illustrates the way in which the UKAEA's application is drafted to promote 'business as usual' rather than towards meeting its ALARA commitment.

5.7 While the DFR closed in 1977 all of the fuel from its reactor core has not yet been removed. This, says the UKAEA, is to be achieved by 2003. Even if this is technically possible, the UKAEA say that no decision has yet been taken as to what to do with the fuel once it is removed, although, storage and direct disposal to the planned Nirex repository are being considered.

5.8 No explanation has been provided about why storage and direct disposal remain an option for DFR spent fuel but at the same time has been dismissed as an option for the PFR spent fuel.

6.2 In 1993, the Authority anticipated reprocessing up to 1,800 MTR fuel elements a year, however by 1995 this had fallen substantially, to just 600 a year. Surprisingly, the associated discharges have not fallen by two thirds, as would be expected. The UKAEA claim: "the elements which are now to be reprocessed are of a different kind from those envisaged previously. In particular they contain a U-235 inventory about three times that of those originally expected to be available for reprocessing."

6.4 The HEU work could be worth between 40 million and 180 million, over a ten year period, while it will produce a health detriment calculated to be 228,000. The UKAEA further suggests the work will "enhance the UK's reputation as a provider of high technology services that is complementary to that of BNFL." (Social and Economic Effects of Dounreay's Projected Programme of Work, 1995-2005, Sept 1995)

6.5 It continues, "for the customer the benefits are many and varied but in the case of MTR operators it is chiefly the ability to continue their operations within their national regulatory systems." Further, in a briefing issued in August last year, "Reprocessing at Dounreay", the UKAEA said: "The UKAEA have had discussions with European research reactor operators, many of whom are past customers, concerning possible reprocessing at Dounreay to alleviate the fuel storage problems which may otherwise cause a number of these reactors to close." This clearly indicates that the contracts are not about reprocessing but about the desperate need of some research reactor operators to off-load their spent fuel. This is not a good reason for reprocessing at Dounreay or creating subsequent waste arisings for disposal or discharge. Neither is it in accordance with UK Government policy as laid down in last summer's white paper on Radioactive Waste Management. (Review of Radioactive Waste Management Policy, Final Conclusions, CM 2919, para 145 & 146. July 1995)

6.6 Currently, Government policy only allows spent fuel to be imported "for the recovery of reusable materials, provided that is the genuine prime purpose." It further permits importation "for treatment that will make its subsequent disposal more manageable in cases: "where the processes are at a developmental stage; or which involve quantities which are too small for the processes to be practicable in the country of origin." There is also a proviso which would allow "EC member states which produce such small quantities that provision of their own specialised installations would be impractical."

6.7 That reprocessing is not the "genuine prime purpose" for the importation of spent HEU fuel to Dounreay for reprocessing is further supported by a DTI briefing on the proposed contracts issued at the end of last year. The DTI "Information Sheet -- Dounreay Reprocessing" says, "The UKAEA have had discussions with European research reactor operators, many of whom are past customers, concerning possible reprocessing at Dounreay to alleviate fuel storage problems which may otherwise cause a number of these reactors to close."

6.8 In reference to a shipment of HEU from Germany's Hahn-Meitner Institute (HMI) to Dounreay in October last year the DTI comments: "HMI are experiencing severe difficulties with a shortage of spent fuel storage capacity, they have exercised a [an] option from an earlier contract with the UKAEA to reprocess small quantity of their fuel (52 elements) sufficient to relieve their problem."

6.9 The UKAEA is also negotiating a contract with the Australian research reactor at Lucas Heights for the reprocessing of 1,000 spent HEU fuel elements. Information supplied in the Australian public consultation document further highlights the dubious nature of the contracts: "no other alternative [than reprocessing at Dounreay] meets the [Australian] government's decision that the present inventory should be reduced." (Public Environment Report: Transports of HIFAR Spent Fuel from Lucas Heights Research Establishment to the UK for Reprocessing, October 1995. ANSTO)

6.10 HEU is a weapons grade nuclear material and is widely recognised as the shortest route to the bomb for non- weapons states or terrorist organisations. According to the US nuclear weapons designer Luis Alvarez: "With modern weapons- grade ... even a high school kid could make a bomb in short order."

6.11 Neither the UKAEA nor HMIPI believes that, in offering reprocessing contracts and the refabrication of HEU fuel, a serious proliferation risk is posed, claiming that Euratom safeguards offer adequate protection. This view, however, is not shared by Dr Hans Blix, chair of the International Atomic Energy Agency (IAEA), who recently stated his opposition to the use of HEU as a reactor fuel. (Nucleonic Week, 28:7:95) These issues are highly relevant to any consideration of justification for further reprocessing at Dounreay.

6.12 Further evidence of the British Government's confused attitude towards the continued use of HEU and the proliferation concerns comes in the form of a promise made by the Prime Minister, John Major, to President Clinton that the UK's stockpile of 600-800kg would not be sold to European research reactor operators. (Nuclear Fuel, 23:5:94)

6.13 HMIPI and the UKAEA are also dismissive of any risks involved in nuclear transports. They simply comment that such transports are carried out in accordance with IAEA standards.

6.14 However, the IAEA standards, which govern the transport of HEU -- in Type B flasks -- give no confidence that a transport flask could, or would, withstand a real accident. They demand that a flask should be able to cope with being engulfed in fire burning at 800 degrees C for 30 minutes; withstand being dropped onto a hard surface from nine meters (roughly equal to an impact of 30 miles per hour); and survive immersion in water at a depth of 200m for an hour.

6.15 Real accident statistics show just how wide the gulf between the Type B flask design specifications and the conditions which could be expected in an accident is. According to the International Maritime Organisation (IMO) the average shipboard fire burns for 23 hours at sea and 20 hours in port. While temperatures reach over 1,100 degrees C. Both trains and lorries carrying spent fuel travel faster than 30mph. And just how a flask weighing several tonnes could be recovered from the sea bed, at depths up to 200m, within one hour has never been explained.

6.16 According to the UKAEA: "Contracts for commercial reprocessing include agreements that the country of origin will accept the nuclear waste (or its equivalent in radioactivity terms) generated by reprocessing."

6.17 Despite the inclusion of waste return clauses in all contracts signed with the UKAEA since 1976, no waste has ever been returned from the site. Considerable doubt must surround the foreign contractee's ability to accept back the radioactive waste generated during reprocessing.

7.2 Public anxiety surrounding activities at Dounreay should be awarded the same sympathetic treatment by the government and HMIPI. Considerable public anxiety has been demonstrated recently through the publication of a Caithness referendum and Scottish opinion poll on Dounreay's planned commercial activities. In the referendum of the entire Caithness population carried out by the Electoral Reform Form society two thirds of the respondents expressed their opposition to Dounreay embarking on a programme of reprocessing spent HEU fuel from overseas. Further, the Scottish-wide poll carried out by Market Research Scotland found that 84% of the Scottish population opposed the proposals. [On significance of public perception and confidence in the context of this paragraph and paragraphs 7.7 to 7.9 below]

7.3 Employment at Dounreay is cited as a major justification for Dounreay's proposed new discharge limits. The UKAEA is a major employer in Caithness, with about 1,200 people working at Dounreay, although this is expected to drop to around 1,000 during the next five years. In addition, Dounreay accounts for the employment of some 400 contractors, a figure which is expected to rise as decommissioning work proceeds. PFR reprocessing accounts for 200 of the total and MTR reprocessing employs about 50 people. However, no alternative job figures are given for alternative decommissioning and spent fuel management practices. The employment information supplied in the application documents is therefore meaningless for consultative purposes and not valid justification for the application.

7.4 That public perception of the environmental impact of Dounreay could have a "disbenefit" on the locality, is acknowledged by the UKAEA. It further comments that "the perception of the environmental impact of Dounreay by some people is, however, different, particularly for those distant from the county." The UKAEA continues: "This erroneous perception may be reflected in several ways, these could have a disbenefit on the locality." This is an assertion unsupported by any evidence provided for consultation.

7.5 The "low values of Critical Group and Collective Doses show that such anxiety is misplaced", says the Authority. This conclusion is arrived at by an incorrect analysis of the data. The Critical Group analysis shows that some combinations of critical pathways could give rise to a member of the public receiving a higher radiation dose than is currently permitted by Government recommendations, if they fell into several of the risk categories rather than just one as is apparently assumed by the UKAEA. Further, the UKAEA blames adverse publicity for such anxiety. Yet this publicity arises from findings of 'bona fide' inquiries e.g., last years joint report from two Government advisory bodies -- RWMAC and COMARE -- which substantially undermined the UKAEA credibility with regards to protecting public safety.

7.6 It emerged, last year, that COMARE was misinformed by the UKAEA about the consequences of the explosion at the Dounreay waste shaft. During its 1988 inquiry into the increased incidence of childhood leukaemia in the vicinity of Dounreay, COMARE had asked for details of all "planned or experimental releases which might have had off-site radiological consequences", it was not given any information about the explosion. However, around 12 highly radioactive particles have been found on the Dounreay foreshore, at Sandside beach, every year since 1984. When pressed by the Scotsman newspaper, at the end of last year, on whether or not the UKAEA had lied, the COMARE chair, Bryn Bridges replied that both the UKAEA and HMIPI had been "considerably economical with the truth." The then chair of RWMAC, Professor Sir John Knill, said: "... to say they were lying is not an unreasonable conclusion to reach. The contamination on the beach and within the site has proved to be higher than I had previously been told. I received the highest radiation dose I have ever recorded during my time with RWMAC while standing at the top of the waste disposal shaft." Dounreay's Collin Gregory later claimed in the Caithness Courier (4-10-95) that RWMAC and COMARE had apologised to the UKAEA, in a letter, for saying they had not been informed about the extent of the contamination. No such letter was ever written, and Gregory was subsequently forced to withdraw his claim. These are matters which any consideration of justification for future avoidable processes at the site must weigh.

7.7 RWMAC and COMARE identified significant contamination both inside and outside of the site. While RWMAC believes that the foreshore contamination is most likely to have come from the waste shaft it says: "There could well be other sources within the site." Such statements contrast starkly with the UKAEA's assertion in the public consultation documents that benefits arise from "safety and environmental protection." and that: "Appropriate environmental programmes are conducted to confirm that any radioactivity detected in the environment and attributable to operations conducted at Dounreay is acceptably low and consistent with the discharge history."

7.8 The UKAEA claims that "appropriate remediation is planned and in the meantime the affected areas have been barriered off." It further says: "Considerable time and effort is being devoted to ensuring that similar instances are not caused by present of future practices." In light of the UKAEA's continued attempts to mislead the public and Government advisors over the origin and the extent contamination, such programmes should be open to public consultation and not carried out behind closed doors.

7.9 In concluding its dismissal of any detriments associated with Dounreay, the UKAEA comments: "The recent siting of the ill-fated OSPREY wave-turbine generator a few yards off-shore of Dounreay also suggests that contamination of the environment around Dounreay (or any perception of risk being in the vicinity of the plant) is of no practical significance where other industrial enterprises are concerned." The UKAEA omit reference to the fact that at the time of the OSPREY going to sea, last year, HMIPI wrote saying: "When the investigation on the foreshore is ongoing and when we have not established where the contamination is coming from and how wide-spread it is, it is perhaps not the most sensible time to be putting a wave machine there." HMIPI's concerns were ignored by the UKAEA, and no such communication was made to Allan Thompson of Applied Research and Technology, the architects of the project.

7.10 No analysis of the impact of serious accidents at Dounreay is provided.

8 International Commitments

8.2 The 1974 Convention on the Prevention of Pollution from Land-Based Sources. Under Recommendation 88/5 of the Paris Commission (PARCOM) established by the Convention and adopted on 17 June 1988, the UK agreed to "apply the best available technology to minimise and, as appropriate, eliminate any pollution caused by radioactive discharges from all nuclear industries ... into the marine environment." No evidence has been provided in the consultation that the best available technology is being employed at Dounreay to respect this agreement.

8.3 The 1992 Convention for the Protection of the Marine Environment of the North East Atlantic (OSPAR Convention). Although not yet ratified by the UK, it has been signed and the Government has stated that "... its provisions are being applied to all UK waters." (Review of Radioactive Waste Management Policy, para 15. HMSO, July 1995) It requires the Government to take "all possible steps to prevent and eliminate pollution from land-based sources." To achieve this Annex 1 requires the use of : "best available techniques" and; "best environmental practice." Again, no evidence has been provided as part of the consultation package to show that these requirements have been met.

8.4 Agenda 21. This programme was agreed by the Government in Rio in 1992. It states that it is necessary to: "Not promote or allow the storage or disposal of high level, intermediate level or low-level radioactive wastes near the marine environment unless they determine that scientific evidence consistent with the applicable international agreed principles and guidelines, shows that such storage or disposal poses no unacceptable risk to people and the marine environment or does not interfere with the legitimate uses of the sea, making in the process of consideration, appropriate use of the concept of the precautionary approach." (para 21.59(c)). again, this appears to have been ignored.

The consultation process is seriously flawed:

• the documentation is badly organised and haphazard and therefor precludes genuine public consultation
• the documents give the implication that there will be a reduction in radioactive discharges from Dounreay when the reverse is true;
• two major isotopes, C-14 and I-129, are omitted from the UKAEA's collective dose and as a result the collective dose is underestimated;
• in carrying the cost benefit analysis the UKAEA has undervalued human life, quoting values at half those used by the Department of the Environment
• decommissioning plans are at a very early stage and consequently insufficient information is offered on the discharge implications;
• inadequate attention has been paid to the alternatives to reprocessing spent fuel from the PFR and key information was not contained within the consultation documents;
• dubious assertions and value judgements are being made about the justification for so-called "commercial activities";
• the UKAEA's plans to import spent MTR fuel is contrary to current Government policy; the documents do not show, as is required by law, that the disadvantages of the proposed discharges are justified; and
• the documents fails to establish, as is required by law, that the exposures that draft authorisations would permit are as low as reasonably achievable.

Given the serious and compound flaws in the public consultation process and the degree of public anxiety over activities at Dounreay, the only real way to deal with the issues adequately would be for the Secretary of State for Scotland to exercise his power under section 24(2) the Radioactive Substances Act 1993 and call a public inquiry. In the meantime HMIPI should extend the public consultation period by at least two months.

If indeed the only real detriments associated with operations at Dounreay are, as the UKAEA would have us believe, due to ill-informed public anxiety, what better way to gain informed public opinion than through an open inquiry covering all aspects of the work at Dounreay

Such an inquiry would have implications beyond the issuing of revised discharge authorisations. It would set clear standards by which future public consultations could be judged.