The Office for Nuclear Regulation (ONR), the Environment Agency and Natural Resources Wales (NRW) have published additional guidance for those undertaking a tier 3 preliminary design review (PDR) under the early engagement process for new nuclear reactors. A PDR is a technical regulatory review of aspects of the design of a proposed new nuclear power plant involved in the early engagement process.
Supporting early understanding of regulatory activity
The government’s ambition for new nuclear has led to increased demand for engagement with regulators. The early engagement process facilitates access to regulators to those wishing to deploy nuclear reactor technology so organisations can benefit from early advice and guidance.
Throughout the PDR and wider early engagement process, applicants are encouraged to use material prepared for regulatory assessments overseas.
Applicants are encouraged to explore what regulatory pathway is most suitable for their project lifecycle, timeframes, budget and the outcomes they are seeking. Regulators can explain the requirements and expectations of regulatory pathways in different phases of early engagement such as the one-day engagement or structured workshops.
Benefits of early engagement
- Applicants gain an understanding of regulatory processes and routes to deployment
- Regulators gain an understanding of technologies proposed for deployment and operation, and the status of the safety, security and environmental justifications
- Vendors gain an understanding of key regulatory expectations and requirements for such justifications
- Vendors receive regulatory advice and guidance ahead of entering formal regulatory processes, enabling them to de-risk later project stages
- Regulators gain an understanding of the maturity of potential licensees/permit holders and the readiness of applicants to progress to more formal regulatory processes, enabling effective prioritisation and management of regulatory resource.
Types of early engagement
There are three approaches, or tiers, to early engagement:
- One day engagement – a single event for regulators to set out the UK regulatory framework, explain the available pathways, and highlight key risks and opportunities. This is a pre-requisite for subsequent ‘tiers’.
- Regulatory process and technical engagements – a series of structured engagements on a range of topics to be agreed between the applicant and the regulators, building on the one-day engagement and explaining in much greater detail the specific matters of interest.
- Preliminary design review – technical review of certain aspects of a reactor design, based on regulatory submissions provided by the applicant.
Early engagement is a voluntary process which is designed to be flexible. It may be undertaken before Generic Design Assessment (GDA) or entering the nuclear site licensing and environmental permitting processes. The approaches are not mandatory, prescriptive, or fixed in scope, and they have been designed to result in more efficient progress through subsequent regulatory processes.
How does the PDR guidance support this process
Based on up to six submissions by the applicant, the PDR process aims to support regulators to identify potentially significant gaps against regulatory expectations. Following this, it provides regulatory advice and guidance on resolution of those gaps.
It also helps applicantsto achieve better understanding of the project risks on the pathways through GDA or site-specific design assessment, providing them with an early opportunity to develop credible plans for resolution of any regulatory gaps in subsequent phases of their project.
At the end of the PDR, the regulators will produce a summary report. This will set out the advice given in relation to each submission and will provide an indication of the regulators’ confidence that expectations can be met should the design be taken forward.
Diego Lisbona, Head of Regulation for Advanced Nuclear Technologies and Early Engagement said: “The early engagement process aims to maximise the value of access to regulators. By engaging early and effectively, applicants can select technical, regulatory, legal topics, or other areas that would be of most benefit to their project.
“The new guidance for those choosing a preliminary design review aims to provide further clarity and strengthen the value added by the process. It covers all areas of the process, from development of the applicant’s scope and submissions to our review, and the final summary report. Overall, preliminary design reviews are about de-risking designs and enabling efficiencies in future stages of regulation.”
Maximising international collaboration
Throughout the PDR and wider early engagement process, applicants are encouraged to use material prepared for regulatory assessments overseas, even where the regulatory regime is different to that in the UK, maximising use of assessments undertaken by regulatory bodies internationally. We have several agreements in place to facilitate such collaboration.