• Appeal by Scotoil against Variation of Authorisation 041/06(VN01) dated 20 November 2006 - pdf : 13kb
• Consultation Document - pdf : 193kb
• Scotoil Draft Authorisation - pdf : 70kb
  

Scotoil Services Limited Review of Authorisation Issued Under the radioactive substances Act 1993 (as amended)

(Closed 30th June 2006)

Scotoil Services Limited is authorised under The Radioactive Substances Act 1993 to dispose of radioactive waste from its premises.  The waste is in the form of naturally occurring radioactive scales produced during oil and gas production and processing and is disposed of to sea.

The existing authorisation was granted in 1996 and a review of this authorisation has been completed.  The purpose of the review was to ensure conditions of authorisation were still relevant, provided adequate environmental protection and were consistent with Government policy.

SEPA proposes to vary the authorisation and a copy of the proposed revised authorisation is enclosed with the consultation document and the existing authorisation.  Significant changes include:

• Recognition of the ALARA (As Low As Reasonably Achievable) requirement by use of conditions requiring the implementation of best practicable means to reduce the activity in the waste discharged;
  
  
• Replacement of prescriptive conditions regarding waste disposal by goal-setting requirements.  Specifically, the authorisation holder is now required to dispose of radioactive waste at times, in a form, and in a manner so as to minimise the radiological effects on the environment and members of the public;
  
  
• Amendment to discharge limits to ensure consistency with Government policy that discharges of this type will be tightly controlled and reduced wherever practicable to meet the UK’s commitments to implement the Strategy of the Oslo and Paris (OSPAR) Commission;
  
  
• A requirement to appoint and consult with a Qualified Expert;
  
  
• A requirement to undertake a programme of environmental monitoring;
  
  
• Implementation of improvement conditions that will require the company to research and use an alternative disposal route that does not result in the discharge of radioactive waste to the marine environment and to carry out modifications to the system of discharge while this alternative route is being researched.
  
  

SEPA’s predecessor body, HM Industrial Pollution Inspectorate, carried out a limited consultation exercise in 1995 following the last review and we are now seeking comments on our proposals to vary the existing authorisation.  We welcome any comments you have on the conduct and outcome of the review and would particularly welcome your comments on the following:

Will the revised authorisation adequately protect the environment and members of the public?

SEPA recognises that any unnecessary introduction of radioactivity into the environment is undesirable and is proposing improvement conditions requiring the establishment of an alternative waste disposal route.  This has to be balanced with the known and estimated effect of the company’s discharges.  Using pessimistic assumptions, doses to members of the public and to non-human species are assessed to be very low (in the case of doses to members of the public, doses to the critical group are less than 5% of the relevant radiation dose limit).  Accumulations of naturally occurring radioactive material in the vicinity of the company’s discharge point appear to be mainly due to a process that ceased operating more than 20 years ago.  SEPA believes continued use of the discharge pipeline until an alternative disposal route is established is reasonable.

Do you support the removal of quarterly and daily discharge limits?

The origin of these limits is unclear and their continued application would be a departure from SEPA’s position of requiring waste disposers to dispose of radioactive waste at times, in a form, and in a manner so as to minimise the radiological effects on the environment and members of the public.

Are the timescales for improvements realistic?

SEPA believes improvement conditions 1 and 2 can be implemented without imposing a disproportionate burden on the company.  SEPA recognises that implementation of improvement condition 3 will bring a fundamental change to the company’s operations.  A timescale of 12 months is thought appropriate as a means of measuring the company’s success in establishing an alternative disposal route.  SEPA acknowledges it may not be possible to implement this improvement in full within 12 months and may be willing to extend this period if, for example, the company is able to demonstrate substantial progress towards meeting this requirement.

I will be happy to discuss this further with you and I would be grateful if you could send me your comments by Friday 30 June 2006.  A list of organisations being consulted is given in the consultation document and a copy of the consultation can also be viewed on SEPA’s website www.sepa.org.uk.

David Orr
Specialist
Radioactive Substances Unit