Consultation on a variation to the Radioactive Substances Regulation Environmental Permit for Hinkley Point C (HPC) Nuclear Power Station, nr Bridgwater, TA5 1UD

Overview

Our Role

The Environment Agency is the independent environmental regulator for the nuclear industry in England. We make sure that nuclear companies and the sites they operate meet high standards of environmental protection.

Any company that wants to operate a nuclear power station must show that it can do the following safely and securely, whilst also protecting the environment:

• build, commission, operate and decommission the power station
• manage the radioactive waste it produces.

Our Consultation

In June 2022 NNB Generation Company (HPC) Limited applied to us to change its existing radioactive substances environmental permit for Hinkley Point C Nuclear Power Station. Pressurised water reactors at Hinkley Point C will use uranium fuel to create heat and generate electricity when operating. Once used within the reactor, nuclear fuel (radioactive waste) will be stored on-site before being sent off-site to a Geological Disposal Facility (GDF). 

We issued the original radioactive substances environmental permit in 2013. In the original design radioactive waste was to be stored on-site in ‘wet storage’ - a method of submerging and storing in water. 

The operator has now decided to change the technology by which it will store radioactive waste, from wet storage to ‘dry storage’. Dry storage will see radioactive waste stored in sealed containers within a facility before it is sent to the GDF. This means the operator now seeks to change its radioactive substances environmental permit to remove or amend specific conditions related to the previous wet storage technology that are no longer relevant.

NNB Generation Company (HPC) Limited is not seeking any changes to the site boundary, permitted activities or permit discharge limits. The operator has said altering the storage method will not change the expected radiation dose to the general public or wider environment from discharges, which remains incredibly small.  

Outline of proposed changes

The changes that are required to ensure the permit is accurate and reflects the designed operational power station, are as follows:

Removal of Disposal Outlet A3 – Interim Spent Fuel Store (ISFS) Stack. NNB Generation Company (HPC) Limited proposes that the new facility will not have any gaseous discharges and therefore does not require a stack.

Removal of Pre-Operational Measure (POM) 1 – Install HEPA filtration to ISFS Stack. NNB Generation Company (HPC) Limited proposes that the new facility does not require a stack so installation of HEPA filtration is no longer relevant.

Amendment of Information Condition (IC) 14 – 'Provide specification for operational management of wet ISFS facility'. NNB Generation Company (HPC) Limited proposes that IC14 should be amended to remove references specific to wet storage. The requirement to provide a specification for operational management of the facility will remain.

It is an ongoing requirement of the permit that Best Available Technique (BAT) must be applied to all discharges from the HPC site, including any from the spent fuel facility and associated fuel handling and processing. We will continue to assess the overall impact of spent fuel management at HPC to ensure the minimisation of discharges and the application of BAT.

Separately, NNB Generation Company (HPC) Limited will be seeking the necessary changes to its Development Consent Order (DCO) for Hinkley Point C in the autumn. 

Why your views matter

Given the high public interest in the site, we are inviting public involvement in our decision-making process. We are consulting on the application and ask members of the public to provide comment on the application by NNB Generation Company (HPC) Limited. We will take consultation responses into consideration as part of our determination of the application.  If we decide to grant the application, we will explain how we made our decision and how we have addressed the comments that were raised. 

We will only vary the permit if we believe that it is appropriate to do so. If the applicant can demonstrate that the varied permit will meet all the legal requirements, including those for the use of best available techniques, public radiation dose and wildlife radiation dose, then we are legally obliged to grant the application.

Advice about what aspects and issues we can and cannot take account of is provided below.

We can take account of:

• relevant environmental regulatory requirements and technical standards
• information on local population habits and sensitive sites
• comments on whether the right process is being used for the activity, for example whether the technology is the right one
• the potential for the land around the site to have an effect on air quality and what pollution control may be needed
• Information that we have not been made aware of in the application, or corrections to incorrect information in the application

We cannot take account of:

• issues beyond those in the relevant environmental regulations
• anything outside the scope of the Environmental Permitting Regulations, for example, the proposed location of the site, which is done by the local authority through land use planning
• whether a site should have a formal designation under the Conservation of Habitats and Species Regulations or other conservation legislation
• whether the activity should be allowed or not as a matter of principle - for example, we will not consider whether nuclear power generation is an appropriate process or whether alternative methods of generating electricity should be used instead
• land use issues or sustainability challenges, even if it is argued that changing the location of the activity would improve its environmental performance
• the impact of noise and odour from traffic travelling to and from the site
• the legally defined process we follow to determine a permit
• comments about the government's energy policy

Next steps following the consultation

After the consultation ends we'll complete our determination, including carefully considering all comments made during the consultation. We'll publish our final decision in September 2022.

Our final decision document will:

• set out our decisions about whether the permit should be issued to NNB Generation Company (HPC) Ltd
• summarise the consultation responses and issues raised
• set out our views on those issues.

What happens next

All comments which are made publicly available will exclude e-mail addresses and telephone numbers. Any comments where confidentiality has been claimed will not appear on the public register.

In accordance with the Freedom of Information Act 2000, we may be required to publish your response to this consultation, but will not include any personal information. If you have requested to keep your response confidential, we may still be required to provide a summary of it.