The development clock is ticking on Bradwell B

Above: Visualisation of Bradwell B. The two decommissioned Magnox units can be seen in the lower part of the picture (Photo credit: Bradwell Power Generation)

JUST BEFORE THE TURN OF the year, on 18 December, UK energy regulator Ofgem granted an electricity generation licence to Bradwell Power Generation Co Ltd. The company is planning to build a new nuclear station at Bradwell on the UK’s Essex coast, near where one of the country’s first nuclear stations is in a ‘care and maintenance’ decommissioning phase.

The licence was welcomed by Bradwell Power Generation chief executive Alan Raymant, who called it, “an important milestone on the journey to completing the Bradwell B project and demonstrates our continued progress”. But what may sound like the culmination of a process is in fact an early step, and Raymant admitted, “The generating licence is one of many licences and permits we will need in order to develop, construct and operate Bradwell B”.

Bradwell Power Generation came into being in 2016 as part of an agreement between EDF Energy and China General Nuclear (CGN) which saw the Chinese company take a one-third ownership stake in the Hinkley Point C project, now under construction. The two companies agreed to work together on follow-up plants, the first of which, Sizewell C, is now seeking development consent.

Hinkley Point C and Sizewell C will both employ EDF’s EPR reactor, but Bradwell would use CGN’s Hualong One HPR1000 design. Bradwell Power Generation will have to bear the cost and potential delay in winning generic design approval (GDA) for the Chinese design from the UK nuclear and environment regulators, who are the Office of Nuclear Regulation and Environment Agency, respectively, as well as environmental and planning approvals for deploying it at the Bradwell site.

Government backing

Support for the Bradwell project is mixed. The UK government generally acts on the assumption that nuclear will continue to supply around a fifth of electricity supply, as it has over the last two decades. But that is largely because it was thought that replacing this large tranche of zero-carbon power with renewables sources was too ambitious. The scale of the renewables roll-out has put that assumption under pressure in some quarters.

The government has now set an ambition to build 40GW of offshore wind in the next two decades – close to the winter capacity currently secured over the winter period by the UK’s Capacity Market. And although electricity demand is expected to dramatically increase as heat and transport are electrified, onshore renewables deployment continues at speed, with 545MW of new solar PV capacity rolled out in 2020 alone.

The UK’s influential National Infrastructure Commission argued that the UK should take a very cautious approach to new nuclear and should only consider investing in one reactor at a time.

The government is less cautious about more nuclear. Kwasi Kwarteng MP, who stepped up this year from being a junior minister to Secretary of State at the Department for Business, Energy and Industrial Strategy (BEIS), said recently that nuclear was “The only way we can get decarbonised firm power which isn’t intermittent ...We will need a source of power that isn’t fluctuating, that isn’t dependent on the wind blowing and the sun shining”. Meanwhile BEIS published a long-awaited Energy White Paper – the first step to legislation – that is expected to allow the government to invest directly in new nuclear and do it in a form of ‘regulated asset base’ framework that would shift risk to consumers.

Once in place, that framework is first expected initially to benefit Sizewell C. Beyond that there is Bradwell, and also, potentially, Wylfa Newydd. Backers of this site, on the opposite coast, in Anglesey, North Wales, will also be seeking government backing and financing. Horizon was pursuing the development consent process for that site until January, although it had halted work on the ABWR. It could be revived (albeit it would have to retread much of the process) with a licensed reactor and other groups are also looking at the site.

Whether Bradwell can take its place behind Sizewell C as the UK’s next nuclear plant depends on smooth progress through the licensing process and stakeholder support from the plant’s neighbours to its investors.

The best plant design?

The GDA process has been under way since January 2017 and in February 2020 it reached step four, the final step, which ONR describes as “Successful completion of the high-level technical assessment of the design”. ONR estimates that step 4 will be completed by the start of 2022.

As part of this process, in January the Environment Agency opened a consultation on its assessment of the design. The EA’s role is to regulate “specific environmental matters at nuclear sites in England by issuing environmental permits to cover site preparation, construction, operation and decommissioning”.

EA provides a statement about a design’s acceptability at the end of the GDA. During the GDA, it works by identifying concerns. So-called ‘GDA Issues’ are significant, but resolvable, and must be resolved before construction of the reactor starts and before GDA can be completed. ‘Assessment Findings’ are matters best resolved at the site- specific stage.

In a consultation now under way EA has listed six potential GDA Issues and 40 Assessment Findings.

The GDA Issues are:

• 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. The Requesting Party has not addressed a Regulatory Observation about this.
• 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.
• The Requesting Party has proposed using rectangular filters in the heating, ventilation and air conditioning system. It must demonstrate that these are equivalent or better than cylindrical types, which are considered best practice in the UK.
• ONR/EA have not yet received design requirements for the spent fuel, which define the specifications for an interim store which will be used before the fuel is disposed of in a geological disposal facility.
• The Requesting Party has yet to confirm its strategy for disposing of the in-core instrument assemblies and that this will not affect disposal of the waste in-core instrument assemblies.
• The Requesting Party has still to get advice from Radioactive Waste Management Ltd on whether the higher activity waste from the UK HPR1000 will be able to be disposed of in the latter’s planned geological disposal facility.

With regard to the Assessment Findings, some relate to issues such as record management, waste management, or future-proofing arrangements if a future site operator has multiple sites.

Three Assessment Findings refer to discharges, ten to solid waste management and four to sampling and monitoring.

There are ten Assessment Findings in connection with requirements to use ‘best available techniques’. Some refer to general good practice and others are specific, such as: keeping under review the possibility to remove secondary neutron sources or to optimise their design at the earliest occasion; selection and change strategy of demineraliser resins; optimising water chemistry regimes to reduce waste generation; minimising dissolved nitrogen in the primary coolant; and abating carbon-14.

Findings on other environmental issues relate to managing water supplies and cooling water structures, use and management of chemicals and non-radioactive waste and discharges – mentioning in particular fluorinated greenhouse gases, which must be kept under review to ensure they continue to be legally acceptable for use given new climate restrictions.

The Environment Agency consultation closes in May.

The best site?

With design approval part-way through, the company has begun work in parallel on winning development consent to build the plant at the Bradwell site.

The company opened initial contact (an ‘inception meeting’) with the Planning Inspectorate in 2019. The Inspectorate will assess any planning application – including associated development, such as necessary network assets, which had previously been decided locally and often delayed major projects – and make a report and recommendation to the Secretary of State, who has decision-making powers.

The application allows of little variation once submitted, and operates on a strict timetable. But some interaction
is allowed with the Planning Inspectorate in advance, to ensure the final application is appropriate and that the level of challenge is understood by the applicant, examining authority (ie, the Planning Inspectorate) and the decision- maker. An applicant may ask the Secretary of State to state in writing an opinion “as to the scope, and level of detail,
of the information to be provided in the environmental statement”. That request begins to fix the final form of the application because it must include:

• a plan sufficient to identify the land;
• a description of the proposed development, including its location and technical capacity;
• an explanation of the likely significant effects of the development on the environment; and
• such other information or representations as the person making the request may wish to make.

The Bradwell application will encompass two UK HPR1000 nuclear reactors totalling 2,200MW, two turbine halls, cooling infrastructure, flood defences, construction of a platform raised by 7.5m for safety critical elements, along with associated temporary storage, waste, access, offices, welfare, utilities, transmission and security infrastructure. Construction will take nine to twelve years, it says. The lifetime of the proposed development is anticipated to be 60 years, after which it will be decommissioned.

It is clear from the Planning Inspectorate’s response to the Scoping Statement there is still considerable work to be done, including defining the site and layout within the envelope put forward. The Inspectorate set out a list of areas where it would expect more justification or detail, and some areas where it does not agree with the Bradwell company’s current position – on matters as wide as arrangements for pedestrians, whether to use temporary or permanent worker housing and the effects – eg noise, as well as radiological impact – on nearby communities. But identifying areas where the scoping is inadequate is partly the aim of this phase of the process and it is up to the applicant to meet the Secretary of State’s requirements in the final application.

No date for submission of the final application to the Planning Inspectorate have been published by Bradwell Power Generation, but it is likely to be after 2022.

After receipt of the application, there will be 28 days for the Planning Inspectorate to review the application and decide whether or not to accept it for examination. The pre-examination, examination and report stages take around a year and the Secretary of State has three months to make a decision (although in some cases that has been extended). So – if all goes as planned – Bradwell may get development consent in 2024.

That is the point at which we will find out whether the government has managed to set in place sufficiently attractive funding arrangements for the company to move to a final investment decision.

Author details: Janet Wood is an Expert author on energy issues