Consultation outcome

Generic design assessment of General Nuclear System Limited’s UK Hualong pressurised (water) reactor (UK HPR1000): consultation summary document

Updated 7 February 2022

Introduction

Government is responsible for the UK’s energy policy and set out its current position in the December 2020 white paper, ‘Powering our Net Zero Future’. In the white paper government highlights the need to address climate change urgently and sets out its strategy for wider energy systems so as to achieve the UK’s target of net zero greenhouse gas emissions by 2050. New nuclear power stations are an important part of the government’s strategy to help ensure that we have secure supplies of low carbon electricity in the future.

The Environment Agency has published its own plan, ‘EA2025 creating a better place’, to guide our activities. This plan will act as our compass, enabling us and others to chart a course towards a healthier, greener and more prosperous country in 2025.

Our EA2025 plan sets out 3 main goals:

• a nation resilient to climate change
• healthy air, land and water
• green growth and a sustainable future

Our regulation of nuclear sites aligns with these goals because it helps ensure that these facilities are designed and operated in ways which minimise waste and protect the environment.

As regulators of the nuclear industry, the Environment Agency and the Office for Nuclear Regulation (ONR) are working together to make sure that any new nuclear power stations built in the UK meet high standards of safety, security, environmental protection and waste management. We are scrutinising new nuclear power station designs thoroughly, making sure people and the environment are properly protected.

Generic design assessment (GDA) is the first step in this process and the Environment Agency is asking for your views on its assessment of the UK Hualong pressurised (water) reactor (UK HPR1000) nuclear power station design.

General Nuclear System Ltd (GNSL) is a UK company that is owned jointly by China General Nuclear (CGN) and Électricité de France (EDF). Both companies are major providers of nuclear technologies, in China and France respectively. CGN has developed and is constructing new nuclear power stations in China using Hualong reactors. The UK HPR1000 power station is based on the Hualong design and has been submitted to the UK nuclear regulators for GDA. GNSL’s role is to act on behalf of the ‘Requesting Parties’, the organisations submitting their reactor designs for this GDA, working directly with the regulators.

GDA allows us to begin scrutinising new nuclear power station designs well in advance of construction starting. This means that we can identify any potential design issues at an early stage and ask the reactor design company to address them. This will help to avoid potential costly and time consuming changes when the reactor is being built.

We have previously carried out GDA on 3 different reactor designs:

• EDF-Areva’s UK EPR, completed in December 2012 and currently under construction at Hinkley Point C in Somerset and proposed for construction at Sizewell C in Suffolk
• Westinghouse’s AP1000, completed in March 2017
• Hitachi-GE’s Advanced Boiling Water reactor, completed in December 2017

We began GDA of the UK HPR1000 in September 2017.

This consultation asks for your views on our preliminary conclusions following our detailed assessment of environmental aspects of the UK HPR1000 new nuclear power station design. Our consultation does not relate to a specific site. However, the Bradwell B Power Company (BrB) is developing proposals for 2 UK HPR1000s to be constructed at the Bradwell site in Essex, adjacent to the existing Magnox power station. Successfully completing GDA would not mean that BrB can proceed to construction at the site as the company must still secure all relevant permissions for the site before this could begin.

We would emphasise that this consultation is not about the need for nuclear power, UK energy policy, policy relating to the siting of nuclear power stations, or the safety and security of the design.

Your views count

We can all help to protect and improve the environment by being actively involved. We have deliberately made the GDA process open, transparent and consultative and we would like people to understand our role, what we are doing and why it’s important.

This is a public consultation and we welcome everyone’s views. We want to hear from the public, the energy industry, academics with an interest in nuclear power, energy or the environment, non-governmental organisations and any other organisation or public body.

We would like to find out your views on the Environment Agency’s preliminary conclusions following our detailed assessment of the environmental aspects of the UK HPR1000 nuclear power station design.

The 12-week consultation begins on 11 January 2021 and will close on 4 April 2021.

You can find details of our consultation questions, detailed assessment topics and Assessment Findings in our full consultation document and assessment reports on GOV.UK and the Environment Agency’s online consultation hub.

New nuclear power stations – the government’s view

The government has set out its strategy to help the UK achieve its target of net zero greenhouse gas emissions by 2050 as part of its response to climate change. The strategy sets out the actions government is taking on wider energy systems. The strategy includes a continuing and future role for nuclear generation to provide reliable clean electricity and it sees a potential, additional role for Advanced Modular Reactors to provide high temperature process heat in the future.

Government’s position is that additional new nuclear power stations are required and it intends to bring at least one further large scale nuclear power station to a final investment decision by the end of the current parliament.

The nuclear regulators, the Environment Agency and the ONR, developed the GDA process at the request of government in 2006. It enables early assessment of safety, security and environment protection aspects of new reactor designs at a generic level, before receiving an application to consider a particular nuclear power station design at a specific location. Access to GDA is controlled by government as the selection of which reactor designs should be assessed is primarily a UK strategic or commercial consideration or both.

The government requested that the Environment Agency and ONR start a GDA of the UK HPR1000 in January 2017. See the written statement on the UK Parliament website.

Regulating nuclear power stations

The Environment Agency regulates specific environmental matters at nuclear sites in England by issuing environmental permits to cover site preparation, construction, operation and decommissioning. We also work closely with the ONR, which regulates the safety and security aspects of nuclear sites.

We have split our process for assessing and permitting new nuclear power stations into 2 parts. This is to help identify early any aspects of designs that may need changing to meet UK regulatory requirements and expectations. It also enables stations of almost the same design to be built on a number of sites (as for Hinkley Point C and proposals at Sizewell C).

In the first phase of GDA, we assess power station designs and, at the end, provide a statement about the acceptability of each design. There may be matters that cannot be initially resolved. These are identified as ‘GDA Issues’. The assessment process can then be extended while these issues are resolved.

There are also matters which are best resolved at the site-specific stage by the proposed operator. These are Assessment Findings. GDA Issues and Assessment Findings are identified in any statement issued. Our preliminary findings for this phase for the UK HPR1000 are the subject of this consultation.

A GDA Issue is an unresolved issue that is significant, but resolvable, and which requires resolution before construction of the reactor starts. The company must publish a ‘resolution plan’ setting out how it will address the issue. All GDA Issues must be resolved to the satisfaction of the regulators before GDA can be completed.

An Assessment Finding is an unresolved issue that is not considered critical to the decision to start construction – it will need to be addressed during the design, procurement, construction or commissioning phase of any new build project.

In the second phase, we receive applications for environmental permits for a specific site. We take into account all of the work we have done during GDA, so that our efforts are focused on site-specific matters, including how the operator is addressing GDA Assessment Findings. We also carry out further public consultations before deciding whether or not to issue operational permits for a specific site and, if we do issue permits, we decide what the permits’ conditions should be.

Other site-specific permissions

Before any new nuclear power station can be constructed at a site, the future operator must obtain all the relevant permissions. There are many different permissions and other regulators and organisations are involved in making decisions about these.

The Environment Agency is a consultee in certain permissions and provides advice to relevant decision makers. These permissions include planning permission (the Development Consent Order) where the Environment Agency provides significant advice to the decision maker (Department for Business, Energy and Industrial Strategy’s Secretary of State), primarily via the Planning Inspectorate that examines the site-specific proposals and provides recommendations to the Secretary of State.

Generic design assessment

GDA means that we begin assessing if the environmental aspects of a design are acceptable before an application is made to build the power station. We can get involved with designers and potential operators at the earliest stage when issues can be best addressed effectively and efficiently before construction begins.

There are a number of stages:

1. Initial assessment: we may ask the Requesting Party for further information or for design changes to be made.
2. Detailed assessment: we form our preliminary views and prepare for consultation.
3. Consultation: we ask for views following detailed assessment – this is the stage we are at now.
4. Post consultation review: we consider all responses to the consultation and complete our assessments.
5. Decision and statement: we decide whether to issue a statement of design acceptability, an interim statement of design acceptability if there are any outstanding issues to be addressed, or no statement of design acceptability.

What do we mean by generic?

GDA is based on a ‘generic’ site that is specified by the Requesting Party. We use these site characteristics when we make assessments. We encourage Requesting Parties to select characteristics for their generic sites that reflect those of potential new build sites in Great Britain.

When assessing applications for site-specific environmental permits we use the actual characteristics of the specific site where it is proposed to be built. The site-specific characteristics may be different from those of the generic site. More details of our GDA process can be found in our Process and Information Document (Environment Agency, 2016).

There are 3 possible outcomes for a GDA:

• we issue a Statement of Design Acceptability if we are satisfied with the design
• if, after we have completed our assessments, we are largely satisfied, we provide an Interim Statement of Design Acceptability that identifies the issues that must be addressed before we could consider issuing a full Statement of Design Acceptability
• if we are not satisfied, we do not issue a Statement of Design Acceptability or an Interim Statement of Design Acceptability

The UK HPR1000 design

There are various types of nuclear reactors around the world, with over 440 in operation. One of the most common types is the pressurised water reactor, of which the HPR1000 is one of the latest designs under construction. It is capable of providing around 1,180 megawatts of electricity, enough to power more than 1.5 million homes on average. The HPR1000 is currently under construction in China.

A simplified illustration of the UK HPR1000 reactor

Image copyright of China General Nuclear

How does the reactor work?

In the reactor core, ‘fissions’ or splits occur in some of the uranium atoms of its fuel. This produces energy in a continuous process called a ‘chain reaction’.

The energy created by the fissions heats water inside the reactor, which is circulated by pumps in the ‘primary circuit’ to a ‘steam generator’. In the steam generator, the very hot primary circuit water is used to heat water in the separate ‘secondary circuit’, producing steam which is fed to a turbine. This makes the turbine spin and drives a generator that produces electricity.

Both the primary and secondary circuits are at very high pressures, giving this type of reactor its name.

There is a third water circuit which is used to cool the condenser of the turbine, converting the steam of the secondary circuit back to water, which is pumped back into the secondary circuit to flow through the steam generator again. In UK nuclear power stations, sea water is usually used in the third water circuit, but this can be replaced by water from rivers or estuaries or by cooling towers.

More information is available on the UK HPR1000, Generic Design Assessment (GDA) website.

Also see how the UK HPR1000 works.

Our views so far on the UK HPR1000 design

GNSL submitted its UK HPR1000 design for GDA in November 2017. We completed our initial assessment and published our report in November 2018 (Environment Agency, 2018). Since then, we have been carrying out our detailed assessment. We have based our findings so far on information submitted up to July 2020.

We are publishing 8 preliminary assessment reports and an independent dose assessment alongside our consultation document.

The following are our environmental assessment reports.

Management systems

We check that the designer has the right management systems in place and enough resources to make sure the design will adequately protect people and the environment. We also check that all appropriate information can be transferred from the designer to a future operator.

Radioactive waste management arrangements

We consider the integrated waste strategy for a generic site to check it is in line with UK policy and good practice.

Best available techniques

We examine the claims made by the designer about minimising waste and the impact on the environment. We consider the evidence supporting these claims in relation to good practice in the UK.

Gaseous and aqueous waste

We examine the amount of liquid and gaseous waste expected to be discharged into the environment and the proposed limits under which the power station could operate. We also consider the estimated discharges in relation to other comparable power plants across the world.

Solid waste, spent fuel and disposability

We consider the amount and type of solid waste expected to be generated, looking for potential impacts on the disposability of the waste. We look to see that all opportunities have been taken to avoid or minimise the amount of waste generated. We also check that UK good practice in processing and packaging the waste has been followed so it can be disposed of in the most effective way possible.

Sampling and monitoring

We identify if the design can monitor radioactive discharges to the standard needed to comply with a future permit.

The generic site and radiological impact on people and wildlife

We review the designer’s assessment of the impact of radioactivity on members of the public, plants and animals against our own independent assessment. We compare the results to the legal limit for exposure to radioactivity.

Other environmental regulations

We consider how other environmental legislation would apply to the design at a generic site. Other environmental regulations we have considered during our assessment include those for combustion processes using diesel generators and those for storing and using hazardous chemicals.

Independent dose assessment

We commissioned an independent assessment of the impact of radioactivity on members of the public, plants and animals using the designer’s proposed discharge limits and generic UK data.

Based on our findings so far, our preliminary conclusion is that we consider many of the environmental aspects of the design would be acceptable. However, at this stage of our detailed assessment, there are 6 potential issues to be addressed before we would consider issuing a full statement of design acceptability for the UK HPR1000.

Here is a summary of these issues. More detail and context is provided in our consultation documents. Our assessments continue and it may be that these are addressed satisfactorily during the GDA period, and that we identify further issues.

Potential GDA Issues

Potential GDA Issue 1

While operational experience is used to support safety case documentation, the Environment Agency and ONR have noted that it is not used consistently across the project. We have raised a Regulatory Observation to address this. The Requesting Party has not addressed this yet, so we have listed it as a potential GDA Issue.

Potential GDA Issue 2

The Requesting Party has shown that it has considered the environmental aspects of the station design. However, it still has to demonstrate that it has adequately considered the safety aspects of the design. Where safety aspects are still under review the Requesting Party must ensure that environmental protection is given appropriate consideration.

Potential GDA Issue 3

In the UK, we consider that cylindrical filters are the best type of ‘high efficiency particulate air’ (HEPA) filter. However, the Requesting Party has proposed using rectangular filters in the UK HPR1000 heating, ventilation and air conditioning system. It must therefore demonstrate that these are equivalent or better than the cylindrical types in terms of environmental impact.

Potential GDA Issue 4

The Requesting Party has committed to demonstrating that the spent fuel will be stored in an appropriate interim storage facility before it is disposed of in a geological disposal facility. We have not yet received the design requirements for the spent fuel which define the specifications for the interim store and therefore have identified this as a potential GDA Issue.

Potential GDA Issue 5

The Requesting Party has yet to confirm its strategy for disposing of the in core instrument assemblies. The Requesting Party needs to confirm to us the strategy and that this will not impact on the disposal of the waste in core instrument assemblies.

Potential GDA Issue 6

We expect the Requesting Party to get advice from Radioactive Waste Management Ltd, the organisation responsible for providing geological disposal in the UK, on whether the higher activity waste from the UK HPR1000 will be able to be disposed of in a geological disposal facility.

Other findings and how we will progress the assessment

We have also identified 40 Assessment Findings in the consultation documents which we would expect a future power station operator to address.

We have included a draft Interim Statement of Design Acceptability with the consultation document.

We will continue with our detailed assessment, including carefully considering consultation responses. We expect that GNSL will continue to work to resolve the above potential GDA Issues during the GDA process.

Only when we are satisfied that all the issues have been addressed would we issue a full statement of design acceptability. If the issues are, for any reason not resolved by the end of the GDA process, or new issues were identified but not resolved, then we would consider only issuing an Interim Statement of Design Acceptability.

Our preliminary conclusions and supporting reasoning are available in our full consultation document and we welcome your views.

How to respond

There are a number of ways you can let us know your views.

Online

Visit our e-consultation website.

We have designed the online consultation to make it easy to submit responses to the questions. We would prefer you to comment online as this will help us to gather and summarise responses quickly and accurately. To do this, you will need to either log in or register a consultee account before providing your comments.

By email or letter

You can also submit a response by email or letter. It would help us if you would send your comments using the form provided in Appendix 7. Email to:

nuclear@environment-agency.gov.uk

By post:

For the attention of Dr Paula Atkin

Environment Agency
Ghyll Mount
Gillan Way
Penrith
CA11 9BP

Consultation and engagement plan

A programme of communications and stakeholder engagement is underway and will continue during the consultation period.

You can read our joint regulators’ engagement plan for this GDA.

You can read our consultation plan for this GDA.

Our plan includes events with stakeholders. These will be held online, by telephone or in person, unless government or Environment Agency restrictions or guidance prevents this. Events will be advertised to stakeholders at the start of the consultation.

Next steps

We expect to publish the document containing all your responses in May 2021, approximately 1 month from the close of consultation.

Our assessment of the UK HPR1000 continues, as does ONR’s, and we have not yet reached any decisions.

We will carefully consider all the responses to the consultation and complete our detailed assessment. We will then make our decision on whether or not to issue a full or Interim Statement of Design Acceptability for the UK HPR1000. We and ONR carry out GDA as a joint project and we will coordinate our decision making.

We will summarise the responses to our consultation, issues raised and our views on those issues in our decision document.

We aim to publish our final conclusions in our ‘decision document’ in early 2022.

Future opportunities to have your say

There would be further consultation on any environmental permit applications for the operation of this design on specific sites. You can read our publication participation document.

References

Environment Agency, 2016

Process and Information Document for generic assessment of candidate nuclear power plant designs. Version 3. October 2016.

Environment Agency, 2018

New nuclear power stations: initial assessment of General Nuclear System’s UK HPR1000 design.