Outstanding issues in Sizewell C nuclear site licence application

On 30 June 2020, NNB Generation Company (SZC) Limited applied to the ONR for a nuclear site licence to install and operate a nuclear installation at its Sizewell site.

In an update on its assessment of the Sizewell C nuclear site licence application, ONR said it had concluded that the application has met "almost all" the regulatory requirements.

"Specifically, we are satisfied that NNB Generation Company (SZC) Ltd has put in place an organisational capability and associated arrangements suitable for licence granting and no issues have been identified regarding the suitability of the site which would prevent a licence being granted," it said.

However, ONR noted there are two outstanding matters which require resolution prior to the formal granting of a licence.

Firstly, NNB Generation Company (SZC) Ltd has yet to acquire ownership of the land, known as security of land tenure. ONR expects a nuclear site licensee to have "full rights of access to and control of" the site upon which the nuclear site will operate. The applicant, it said, "does not currently have such rights to the land proposed for the Sizewell development and this will need to be resolved prior to licence grant".

The second issue relates to the current shareholder agreement which places control of key policies relating to safety and security with a holding company, NNB Holding Company (SZC) Ltd, rather than the licence applicant, NNB Generation Company (SZC) Ltd. "As the licensee should be able to exercise effective day-to-day control over all activities on the licensed site, it is essential there is clarity on how that responsibility can be exercised," ONR said.

"Engagement between ONR and the applicant has indicated that plans are in place to address both matters in due course," it added. "When those matters are resolved, we would carry out a proportionate reassessment of the application, focused on the two outstanding matters and any other relevant licensing issues that emerge during the intervening period."

ONR said that its regulatory responsibility starts at the point of granting of a nuclear site licence. "If granted, we would use the powers within the licence to require the licensee to request our permission for starting nuclear safety related construction. Similarly, the licensee will be required to seek our permission to proceed to subsequent, key construction and commissioning stages up to the start of commercial operation and beyond."

It noted that the nuclear site licence application is separate to a Development Consent Order (DCO), considered by the Planning Inspectorate, which determines if the overall proposed scheme is acceptable under national planning legislation. A government decision on the Sizewell C DCO had been due on 8 July but has now been postponed until 20 July.

NNB Generation Company (SZC) Ltd has also submitted applications for environmental permits to the Environment Agency.

The plan is for Sizewell C to feature two EPRs producing 3.2 GW of electricity, enough to power the equivalent of around six million homes. It would be a "replica" of the Hinkley Point C plant, under construction in Somerset. EDF submitted a development consent order (a planning application) for the plant in May 2020 and if all goes well, has said it expects to make a final investment decision later this year or in 2023.