Regulating new nuclear power stations - 16 May 2019

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ONR - Environment Agency - Natural Resources Wales

Regulating new nuclear power stations

16 May 2019

Welcome to the latest edition of this e-bulletin covering our regulation of new nuclear power stations. It provides information about the way we regulate and current news. We hope that you find it useful and we would welcome your feedback on the content.


In this issue:

Hinkley Point C

UK EPR – NNB Generation Company (NNB GenCo)


ONR continues its engagement with the project via regular inspections, site visits and meetings with NNB GenCo. Our inspections cover:

  • Design and Safety Case
  • Organisational Capability
  • Conventional Health and safety and fire safety
  • Security

These inspections are providing ONR with valuable intelligence on the progress NNB GenCo is making to continue developing its competence and capability to manage the design, procurement and construction of Hinkley Point C (HPC). In February we issued four Project Assessment Reports (PARs) following requests from NNB GenCo for the modification to the Hinkley Point C UK EPR Design.

Environment Agency

The Environment Agency has continued to provide regulation and timely advice to the company during the construction of HPC.

The company continues to apply for environmental permits, or changes to its existing permits, for its activity on site.

The Environment Agency issued a permit for a sewage treatment plant for the site on 30 January 2019.

Details of all the permits provided to ‘NNB Generation Company (HPC) Limited’ are on the public register for environmental information.

Consultation on permit to operate Hinkley Point C

EDF Energy holds three permits to operate Hinkley Point C nuclear power station, issued by the Environment Agency in 2013. EDF Energy has applied to change the permit that sets out how cooling water is taken from the Severn Estuary by Hinkley Point C. It also describes measures needed to reduce the impact on fish. EDF originally proposed three mitigating measures but it no longer believes it is necessary, or practicable, to install one of these measures, an acoustic fish deterrent. The Environment Agency consultation on EDF Energy’s application started on 15 March. You can read the documents and submit comments online.

EDF Energy has also launched a consultation on its proposed material change to its Development Consent Order for HPC.

New EA evidence report

The EA published a new report, “Evaluation of evidence base to inform permitting decisions on cooling waters for nuclear power stations“. This study reviews the evidence on three aspects of cooling water abstraction and discharge that are particularly relevant to the protection of animal and plant life:

  • information on fish deterrent systems
  • the regulatory approach taken by other countries
  • modelling methods used to assess the impact of cooling water systems on fish and other biota

Sizewell C


EDF Energy completed its third round of consultation for Sizewell C on 29 March 2019.

Staff from the Environment Agency’s new build team attended several of EDF’s public events to share information about their role as the environmental regulator on nuclear sites and how it permits new nuclear power stations. The Environment Agency’s response to EDF’s stage 3 consultation has been published on GOV.UK. It sets out the Environment Agency’s general comments about the main development site and associated development sites.

The Environment Agency is continuing its interactions with EDF in relation to the Sizewell C project. The project team continues to provide advice to the company, as it develops its proposals for the site, and secures the information that will be required as part of its applications for environmental permits and a Development Consent Order (DCO).

ONR continues to have a low level of interaction with the Sizewell C project and providing NNB GenCo (SZC) Ltd with advice, in order to assist in development of its forward plans/programme.

UK HPR1000 - General Nuclear Systems

The UK HPR1000 is now in Step 3 of its generic design assessment. Step 3 is primarily a review by the regulators of the arguments (or ‘reasoning’) supporting the Requesting Party’s (RP) claims regarding the safety and related security aspects of the proposed design.

During Step 3 we have increased our regulatory scrutiny and we are undertaking a more detailed assessment of the design focusing on the methods and approaches used by the RP to meet the safety and security claims. These are described within the (generic) Pre-construction Safety Report (PCSR), and Generic Security Report (GSR) and their references.

In Step 3, ONR covers over 19 topics in detail and the Environment Agency over 10 topics. At the end of this the Environment Agency will consult on its preliminary findings so far.

Public comments process

The UK HPR1000 comments process is open throughout the GDA until about four months before the end of the assessment.

General Nuclear System Ltd (GNS) will publish detailed design information on its website and update it as new information becomes available. Anyone can view that information and comment on it. GNS is required to respond to questions and comments about their design. We are able to see both the question and the response so that we can consider them in our assessments. Comments can also be made to the Joint Programme Office.

How we raise questions about the design with GNS

We are raising questions about the UK HPR1000 design with the Requesting Party. Our structured approach has three levels;

  • Regulatory Queries (RQs) seek clarification from the designers about their design.
  • Regulatory Observations (ROs) reflect areas where we may have some concerns about the design.
  • Regulatory Issues (RIs) represent a much greater level of concern - sufficiently important that they may, if not resolved, prevent the successful completion of GDA.

So far, five ROs have been issued by ONR and have been published on the GDA joint regulators website, along with the agreed resolution plans.


The UK HPR1000 design is proposed to be constructed at Bradwell-on-Sea, in Essex, by Bradwell Power Generation Company Ltd, adjacent to the existing Magnox power station. The project is at an early stage with current work primarily focusing on site investigations. The ONR and EA’s project teams are continuing their engagement and providing technical advice to Bradwell Power Generation Company.

In February the Environment Agency and ONR held meetings with Blackwater Against New Nuclear Group (BANNG) and representatives from local councils in Essex. The wide-ranging discussion included a review of the Step 2 assessment reports, what happens during Step 3 assessments and an overview of consultation and engagement. The meeting also focussed on safety, siting and environmental issues, climate change and the GDA process – highlighting how RQs, RIs and ROs are used. Further meetings are currently being planned for later in the year.

UK ABWR - Horizon / Hitachi GE

Following the decision by Hitachi Ltd to suspend the proposed development at Wylfa Newydd, Horizon Nuclear Power Ltd has withdrawn the three environmental permit applications for the operational phase of the project. The company has not withdrawn the application for the construction drainage and the Marine Licence application and those remain with NRW for determination. The planning application, for a Development Consent Order, remains within the determination process. The examination phase closed on the 23rd April 2019 and a decision is expected by the Secretary of State in the autumn.

ONR has largely stopped working on the Wylfa Newydd new build project following Hitachi’s announcement. We had been assessing the site licence application submitted by Hitachi’s subsidiary Horizon Nuclear Power in 2017. We’re carrying out a small amount of work to leave the project in a meaningful state, should it restart in the future, and we’ll remain in touch with Horizon. Our staff have moved to other priorities and we have amended our recruitment and support plans accordingly.

Advanced Nuclear Technologies (ANTs)

In response to BEIS’ request for regulators’ support in the Nuclear Sector Deal, we are continuing to work on ANT related activities including developing strategies and plans.

The Generic Design Assessment (GDA)[9] process is being modernised using learning from previous assessments. We are making the process more flexible to enable the assessment of ANTs.

In response to requests from industry, ONR has developed GDA Technical Guidance.  This document primarily provides guidance to ONR inspectors working on GDA, but we expect that future GDA Requesting Parties will also find it useful.

ONR continues to build its capability to regulate these new technologies. Our three-year programme of work – which involves extensive engagement with industry and international regulators – is proving successful to develop our people’s skills and knowledge.

We’re currently advising BEIS on its Advanced Modular Reactor Feasibility and Development project and participating in international regulatory forums on Advanced Nuclear Technologies at the International Atomic Energy Agency (IAEA) and the Nuclear Energy Agency (NEA). We’re also taking part in bilateral technical exchanges with the Canadian regulator (CNSC), which includes sharing training opportunities.

The Environment Agency has been engaging with potential ANT vendors and reviewing technology feasibility studies in support of the Phase 1 of BEIS’ Feasibility and Development competition.

Other joint regulatory news

  • ONR has recently published its corporate plan setting out our priorities and objectives for 2019/20.

    Maintaining the delivery of core regulatory functions and holding industry to account on behalf of the public remain at the heart of everything we do.

    ONR’s top 10 priorities include embedding a domestic safeguards regime (SSAC) to ensure the UK meets its international safeguards and nuclear non-proliferation obligations, and supporting the UK's implementation of revised regulations relating to planning for nuclear and radiological emergencies. For more information, and to read the full corporate plan, please visit the ONR website.

  • Operators of all nuclear licensed sites and disposal sites for radioactive waste are expected to consider UK Climate Projections 2018 (UKCP18) when assessing the impacts of climate change in support of safety cases.

    We (ONR, Environment Agency and NRW) recently published our position statement, “Use of Climate Change data by the GB Nuclear Industry”, which sets out our expectations.

  • The Environment Agency has been leading a conversation with people and organisations who are affected by or work to manage flooding and coastal change. The EA wants your views on the draft strategy which aims to create a nation resilient to flooding and coastal change to the year 2100. The consultation was launched on 9 May and closes on 4 July 2019.
  • The Government and the European Union have agreed to extend Article 50 until 31 October 2019. During this period, the UK will remain a member of the EU and Euratom and all arrangements currently in place will continue until the time of the UK’s departure.

    ONR is ready to deliver a UK State System of Accountancy for and Control of Nuclear Material (UK SSAC) that enables the UK to meet its international safeguards obligations when required, and will now build on the UK SSAC to deliver a domestic safeguards regime that is equivalent in effectiveness and coverage to that currently provided by Euratom. More information on ONR’s role in nuclear safeguards.

Visit the Generic Design Assessment website

Visit the Environment Agency at

Visit the Natural Resources Wales website

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