NuGen has confirmed its intention to apply for a nuclear site licence to construct and operate three AP1000 pressurised water reactors at Moorside in Cumbria. NuGen cannot commence nuclear safety related construction until it has been granted a licence by ONR and received permission to do so under a condition attached to the licence. Legal conditions placed by other governmental and regulatory bodies must also be met.
The AP1000 design re-entered the joint ONR/Environment Agency Generic Design Assessment (GDA) process in 2014. The reactor designer, Westinghouse, is now in the process of resolving outstanding issues before design acceptance can be granted.
As part of our licensing assessment, ONR will consider NuGen's plans for adapting the generic design to local conditions at the Moorside site - for example the geology and to take account of interactions with the adjacent Sellafield nuclear site. We are also focusing on NuGen's development of its organisational capability to obtain, and discharge the obligations associated with holding, a nuclear site licence. This means that we seek confidence that NuGen is putting in place appropriate governance arrangements, resources, competencies and processes to manage its activities safely and securely.
NuGen is maintaining its schedule to apply for a nuclear site licence for Moorside in 2017 with a view to the licence being granted in 2018. At this stage, our principal aim is to provide constructive advice and challenge to NuGen which enables it to understand regulatory expectations, establish the infrastructure expected of a nuclear site licence holder and prepare a well-developed site licence application pack in accordance with its project schedule. When the site licence application is received, we shall commence formal assessment of that application. This process will culminate in a recommendation to the ONR Chief Inspector as to whether a nuclear site licence should be granted to NuGen.
ONR has issued an intervention strategy covering the period leading up to NuGen's submission of its formal site licence application. The strategy sets out how we plan and manage our work and identifies a number of key areas, or “cornerstones”, that we are focusing on during this initial period. The cornerstones cover licensing and legal matters; site activities and compliance arrangements; design and safety case; security; and organisational capability. These cornerstones are sub-divided into a number of "topic-streams" to enable efficient and effective engagement between the two parties at a more detailed level. ONR’s lead for each topic-stream seeks confidence that NuGen is developing suitable strategies, resources and arrangements to progress each area in a timely manner and, where appropriate, started to implement these arrangements.
We are satisfied that an effective framework has been put in place which is working well through our early technical engagements. Throughout the first part of 2016, we have progressively activated interactions on topic streams across the different cornerstone areas. We have progressed discussions on NuGen's development of the resources, competencies and arrangements that it needs to have in order to become a nuclear site licence holder. NuGen has continued to grow its organisational cadre. We have been broadly satisfied with the strategic thinking behind NuGen’s approach to key matters such as the structure of the site licensee company and the nuclear site licence application framework. We note that NuGen does not intend to develop a site-specific pre-construction safety report until well after licensing. This is in line with ONR's licensing process, which requires for licensing that ONR is satisfied that the applicant’s choice of site is suitable, that it understands the hazards and risks of the activities that it proposes to carry out, and that it has a suitable schedule of safety submissions leading through to the site specific pre‑construction safety case. To satisfy these requirements substantive discussions in some technical areas do not need to be initiated at this point. However, we will continue to seek assurance that NuGen is developing a suitable capability and arrangements to own and deliver key activities needed for licensing. In this regard, we have raised queries over NuGen’s progress towards demonstrating that the Moorside site is suitable for construction and operation of three AP1000 reactors, in particular with regard to its proximity to the existing Sellafield site: these queries are under active and constructive discussion.
During our engagement with NuGen, we continue to focus on the projected development of NuGen’s resources, in particular its plans to grow its Design Authority capability. This means that NuGen needs to work with Westinghouse to acquire design knowledge and understanding at the right time to ensure that NuGen will be able to take ownership of, and make decisions affecting, the plant design and site-specific safety case. NuGen intends to utilise an EPC (engineer, procure, construct) contractor and Owner’s Engineer, and a key expectation for ONR is that NuGen is able to demonstrate that it has the right level of oversight and control of decisions that may affect safety.
Throughout our interactions, we have developed, and will continue to maintain, constructive, open and effective working relationships with NuGen. We remain satisfied that ONR advice is being carefully considered by NuGen as it develops its nuclear site licence submission pack. We are working closely with HSE, which has responsibility for conventional safety until the site licence is granted, and the Environment Agency to ensure that safety, security and environmental matters are addressed in a transparent and consistent manner.
ONR is committed to being an open and transparent body. We have already published ONR's intervention strategy for pre-licence application engagement and will publish on this website the following material: