DE21 7BE, Rolls-Royce Submarines Limited, EPR/NB3230DP/V005: application to change (vary) the radioactive substances permit at Nuclear Fuel Production Plant

Overview

Overview - our role

The Environment Agency is the independent environmental regulator for the nuclear industry in England. We make sure that nuclear power stations and radioactive waste disposal sites meet our high standards of environmental protection throughout the stages of design, construction, operation and decommissioning.

Operators of nuclear sites in England must have a permit for radioactive substances activities from the Environment Agency under the Environmental Permitting Regulations 2016 (EPR16). The environmental permits we issue to nuclear site operators contain strict conditions (rules) that they must follow at all times.

We set specific limits in the permit on what operators are allowed to release when carrying out certain activities, including:

• managing or disposing of radioactive waste

• making discharges to air and water

About Nuclear Fuel Production Plant

The Nuclear Fuel Production Plant is operated by Rolls-Royce Submarines Limited (RRSL).

RRSL has been involved in the UK naval programme since its inception in the 1950s and is the design authority for the Royal Navy's naval nuclear plant. RRSL operates two nuclear licensed sites, both wholly within its site at Raynesway, Derby: the Nuclear Fuel Production Plant site, and the Neptune Reactor site.

The Nuclear Fuel Production Plant site has historically been referred to as the ‘Operations Site’ and is responsible for manufacturing the fuel that powers the Nuclear Steam Raising Plants within Royal Navy submarines. Current work includes delivery of the new PWR3 reactor which will power the Dreadnought class SSBN boats, alongside initial work on reactor designs for the Astute replacement attack submarines.

Our consultation

To accommodate for future activities, RRSL have applied to add new disposal outlets for aqueous wastes to sewer, alongside the addition of new radioactive group to permitted discharges in its environmental permit EPR/NB3230DP.

Alongside this, RRSL has also applied to: change their "operating techniques to protect the environment and optimise the protection of people" document; update the site plan; amend the limit of specified activities, and; update the introductory note defined within its environmental permit EPR/NB3230DP.

We are seeking your comments on an application received from Rolls-Royce Submarines Limited (RRSL) to change (vary) its radioactive substances permit EPR/NB3230DP for

Nuclear Fuel Production Plant

Raynesway

Derby

DE21 7BE

Why your views matter

Your views count

We aim to build and maintain confidence in our decision-making processes through our public engagement and consultation. It is our responsibility to make decisions about environmental permit applications for radioactive waste disposal, but we consider that our decisions can be improved through consultation with a wide range of stakeholders. We can all help to protect and improve the environment by being actively involved. Our public participation statement shows how our process is open, transparent and consultative. Our approach to consultation is in line with the government’s published consultation principles. We would like people to understand our role in relation to radioactive waste disposal, what we are doing and why it’s important.

Our consultations are open to everyone and we invite the following groups to take part:

• the nuclear and radioactive waste disposal industry

• members of the public and communities (including local interest and action groups) near to the Raynesway site and other nuclear sites

• elected representatives, including MPs and councillors

• local councils in Derbyshire or near other nuclear sites

• academics, scientists and consultants with an interest in radioactive waste disposal, nuclear power, energy or the environment

• non-governmental organisations (NGOs), campaign groups and environmental groups

• statutory consultees

• other government agencies

• other regulators

• any other organisation or public bodies

We will carefully consider consultation responses as part of our determination of the application.

We will only vary the permit if we believe that harm to the environment, people and wildlife will be minimised. If the applicant can demonstrate that the varied permit will meet all of the legal requirements, including those for the use of Best Available Techniques (BAT), 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 practices and sensitive sites

• comments on whether the right process is being used for the activity

• the potential impact, whether the impact is acceptable and what pollution control measures or abatement may be required

• the shape and use of the land around the site in terms of its potential impact, whether that impact is acceptable and what pollution control or abatement may be required

• information that we have not been made aware of in the application.

• Any 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

• whether a site should have a formal designation under Habitats Directive or other conservation legislation

• whether the activity should be allowed or not as a matter of principle and the Justification of practices involving radiation - for example, we will not consider the justification for the UK nuclear submarine programme

• the impact of noise and odour from traffic travelling to and from the site

• comments about the Government’s nuclear site decommissioning policy

• Comments about the transport of radioactive waste

• the legally defined process we follow to determine a permit