Our interest stems from us owning a holiday property on Braystones Beach, within the current emergency planning zone of Sellafield. We spend a considerable amount of time at Braystones over the year and are gravely concerned about the future amenity and safety of the area.
Please advise me whether an assessment of the proposed new-build nuclear site referred to as "Moorside", adjacent to Sellafield's site has been made. If such an assessment or opinion has been sought I would be grateful for a copy.
An assessment has been made by the Government (see pages 165-195 of ) which concludes that the Moorside site is potentially suitable for the deployment of new nuclear power stations before the end of 2025.
The assessment above (reference ) together with references  and  provide the framework for development consent decisions by the Secretary of State (SoS) for the Department for Business, Energy & Industrial Strategy (BEIS) on applications for new nuclear power stations expected to deploy by the end of 2025. They set out the need for nuclear power, whilst also providing planning guidance for developers, for the Planning Inspectorate (PINS) and for the SoS for BEIS in their consideration of development consent applications. The developer of the Moorside site, NuGeneration Limited (NuGen), has not yet applied to the SoS for BEIS for development consent for the Moorside project.
It is important to realise that a positive development consent decision by the SoS for BEIS is only one of the independent permissions required before nuclear reactors can be installed and operated at the Moorside site. In particular, ONR would need to grant a Nuclear Site Licence (NSL) to NuGen for the Moorside site. A positive development consent decision would not fetter ONR’s licensing decision.
NuGen has not yet applied to ONR for a NSL. ONR’s “Licensing Nuclear Installations” (LNI)  provides an overview of the nuclear regulatory regime and the processes for licensing nuclear sites. In relation to this FOI request, the most relevant part of LNI is in Paragraphs 63 and 64 on “Site Selection” and Paragraphs 65 and Section 66 on “Site Suitability”. In relation to the Moorside site, matters related to Site Selection have been covered already via paragraphs 165-195 of reference . In relation to Site Suitability, Paragraph 65 of LNI notes that before granting a NSL for the Moorside site, “NuGen will need to satisfy ONR on three main aspects:
In terms of Table 1 of LNI, some work has been done by NuGen relating to licensing Step 1 “Preparing to be a licensable installation” and licensing Step 2 “Creation and collation of licence application dossier” and ONR has advised NuGen about its expectations related to Site Suitability during these two pre-NSL application steps.
ONR would expect NuGen to fully demonstrate Site Suitability prior to it applying for a NSL. To date NuGen has not provided ONR with any assessment of Site Suitability. This is reasonable since the date when NuGen expects to apply a NSL is not yet known.
I am especially interested in any potential interaction between the two sites and the justification for building a second nuclear site immediately alongside the existing one - which seems to impinge on Sellafield's published emergency planning zone. To us, a "domino" effect between the two sites would be inevitable in the event of a serious incident at either site, should NuGen's proposals ever come to fruition.
When NuGen applies for development consent for the Moorside project, ONR’s Land Use Planning and Emergency Preparedness teams will be involved and they will make a representation to PINS. Reference  is the relevant ONR web page.
As part of NuGen’s assessment of Site Suitability and as part of its development consent application it will need to consider the Moorside site as an external hazard to the existing Sellafield Limited (SL) nuclear licensed site and the existing SL nuclear licensed site as an external hazard to the Moorside site. As part of this assessment it will also need to take into account natural hazards such as a seismic event which could affect both sites at the same time.
Taking these considerations into account, Moorside will be designed to have robust defences against external hazards such as radiological hazards from the existing SL nuclear licensed site, including cases in which natural hazards such as a seismic event could affect both sites at the same time. It will also be designed to minimise the external hazard it presents to the existing SL nuclear licensed site.
How would the two sites' emergency planning zone provide against such interaction?
As noted above, nuclear facilities to be constructed on the Moorside site will be designed to have robust defences against external hazards such as radiological hazards from the existing SL nuclear licensed site. This will minimise the effect on the Moorside site of an accident or emergency originating on the existing SL nuclear licensed site.
However, an adequate off-site emergency plan will need to be in place at all times dealing with reasonably foreseeable radiation emergencies from the Moorside site and from the existing SL nuclear licensed site. Cumbria County Council has the duty under REPPIR to set up and maintain this off-site emergency plan during all phases (e.g. construction, commissioning and operation) of the Moorside site. If infrastructure improvements are required to maintain an adequate off-site emergency plan, NuGen would be expected to include these in its development consent application for the Moorside site. These would be considered by ONR’s Land Use Planning and Emergency Preparedness teams as part of its representation to PINS.
Does the proximity of the two sites to each other impinge on guidance or legislation from any other body, national or international?
From ONR’s regulatory perspective and to the best of our knowledge, the proximity of the two sites to each other does not impinge on guidance or legislation from any other body, national or international.