Decision

GDA Step 1 of the Rolls-Royce SMR: statement of findings

Published 3 April 2023

Applies to England and Wales

GDA Step 1 of the Rolls-Royce SMR: statement of findings

This report sets out our findings following the Step 1 of a Generic Design Assessment (GDA) for the Rolls-Royce 470 MWe Small Modular Reactor (Rolls-Royce SMR) nuclear power station design.

Rolls-Royce SMR Ltd (the ‘Requesting Party’ applied to the Department for Business, Energy and Industrial Strategy for its design to enter into the Generic Design Assessment (GDA) process. The application was successful. The regulators (Environment Agency, the Office for Nuclear Regulation (ONR) and Natural Resources Wales (NRW) were asked by the Minister to begin a GDA for this design. Step 1 of the GDA formally commenced on 3 April 2022.

1. About GDA

Our GDA process is described in our GDA Guidance for Requesting Parties. GDA means that we assess if the environmental aspects of a design are acceptable, at a generic level, before site-specific applications are made. ONR has introduced an equivalent and aligned process for assessing the safety and security aspects of a design, ONR GDA Guidance to Requesting Parties. GDA allows us (the Environment Agency, NRW and ONR) as regulators to get involved with designers and potential operators at the earliest stage, where we can have most influence and where lessons can be learned that may apply to other submitted designs. This early involvement also reduces regulatory uncertainty for designers and potential operators.

Joint working with ONR

GDA is a joint project between the environment agencies and ONR. We work closely with ONR particularly on GDA project management; on the Requesting Party’s management arrangements and quality assurance for GDA and on aspects of radioactive waste management. We expect this joint working to continue for the remainder of GDA.

We have:

• asked Requesting Parties to provide information about their designs as a single, integrated submission, addressing the requirements of both regulators

• set up a Joint Programme Office (JPO) to administer the assessment process on behalf of the regulators as a ‘one-stop shop’

Our assessment

GDA is carried out in up to 3 steps.

During Step 1: Initiation, we make agreements with the Requesting Party and provide advice on the scope and development of a submission.

In Step 2: Fundamental Assessment, we examine the Requesting Party’s submission at an outline level. Our aim is to identify whether we need any further information, if there are any matters that are obviously unacceptable, or if any significant design modifications may be needed.

Step 3: Detailed Assessment, is when we examine the submission in detail to come to a preliminary view on whether or not to issue:

• a statement of design acceptability (SoDA) – we have not found any GDA Issues and we consider that the design is capable of being constructed, operated and decommissioned in a way that complies with our regulatory requirements and expectations, ensuring that people and the environment are properly protected

• an interim statement of design acceptability (iSoDA) – if we have completed our assessments and are broadly content with the environmental protection aspects, but there are still GDA Issues to be resolved and the Requesting Party has provided credible resolution plans for addressing them

We will not issue either of these if the design is unsuitable and will not provide the right levels of environmental protection, or if there are GDA Issues and no credible resolution plan.

We will only make our final decision after we have consulted the public and carefully considered the responses we receive.

There are 2 other GDA outcomes:

Step 2 – the Requesting Party may stop or pause the GDA at the end of Step 2. We will publish a GDA Step 2 statement setting out our regulatory position at this point, including our findings from Step 2.

Step 3 – the Requesting Party may end the GDA at the end of Step 3 without a SoDA. In this case, we will publish a GDA Step 3 statement, which will set out our regulatory position and findings following Step 3.

We will do this where we have agreed with the Requesting Party that the GDA can be carried out on the basis of a reduced but still meaningful scope. The Step 3 statement will include Assessment Findings where appropriate. Where a Step 3 statement is the outcome, no public consultation would be carried out.

2. Regulation of nuclear power stations

The Environment Agency regulates nuclear power stations in England and NRW regulates nuclear power stations in Wales. The Environment Agency supports NRW with the regulation of nuclear sites in Wales. NRW participates in GDA where a new nuclear power plant design is likely to be proposed for construction in Wales.

The generic design assessment carried out by the Environment Agency and NRW is guided by standards and expectations set out in several regulatory regimes. However, our assessment focuses primarily on matters relevant to the disposal of radioactive waste.

This is for 2 reasons:

• radioactive waste is generated during the operation and decommissioning of a nuclear reactor and its associated plant

• permitting the disposal and discharge of radioactive wastes has, historically, been the area of regulation with the longest lead time for our permitting of new nuclear power stations

Discharge and disposal of radioactive wastes from a nuclear site require a permit under The Environmental Permitting (England and Wales) Regulations 2016 (EPR16).

The discharge of (non-radioactive) aqueous effluents, such as turbine condenser cooling water or from dewatering during construction, also require a permit under EPR16.

Some conventional plant, for example, combustion plant used as auxiliary boilers and standby power supplies, and incinerators used to dispose of combustible waste may require a permit under EPR16. Some combustion plant may also need a permit under Greenhouse Gas Emissions Trading Scheme Regulation 2012.

The disposal of waste by depositing it on or into land, including excavation materials from construction, and other waste operations may require a permit under EPR16.

The abstraction of water, for example, for cooling or process use from inland waters or groundwater, except in some specific circumstances, requires a licence under The Water Resources Act 1991 (WRA91). Inland waters include rivers, ponds, estuaries and docks, among others.

The construction of new or enhanced flood defence structures, or modification of existing ones, requires an environmental permit under EPR16 (previously flood defence consent under WRA91).

In England, the Environment Agency and ONR together form the competent authority for The Control of Major Accident Hazards Regulations 2015 (COMAH 15). In Wales, NRW and ONR form the competent authority. On-site storage of certain substances may fall under these regulations.

3. Rolls-Royce SMR Ltd’s Small Modular Reactor

This section provides a brief outline of the reactor design and how waste will be created, processed and disposed of. Rolls-Royce SMR Ltd’s Small Modular Reactor is referred to as the Rolls-Royce SMR.

Outline of design

The Rolls-Royce SMR is a pressurised water reactor (PWR) which can generate 470 megawatts (MW) of electricity. (Rolls-Royce SMR Limited – RR SMR Preliminary Safety Report, SMR0001510, Issue 1, August 2022.)

In the reactor core, the uranium oxide fuel (enriched up to 4.95% of uranium-235) is cooled by water under high pressure, which also acts as the neutron moderator necessary for sustained nuclear fission.

The water cooling the fuel is circulated in the ‘primary circuit’ using pumps through the reactor pressure vessel and into heat exchangers called steam generators. Heat in the primary circuit is transferred to water in a secondary circuit via the steam generators.

Water in the secondary circuit boils, producing steam, which directly drives a 2-stage turbine generator (high pressure and low pressure) to produce electricity. The steam is then condensed in the turbine condenser (which itself is cooled by a third water circuit), and the condensate is returned to the secondary circuit.

In the baseline design case considered in GDA, turbine condenser cooling water will be provided by mechanical draft cooling towers. (Rolls-Royce SMR Limited – Generic Site Description (SMR0001541 Issue 1), August 2022.)

The final decision on cooling will depend on site-specific factors. The option of once-through cooling remains open for the design.

The main ancillary facilities include a:

• spent fuel storage pond

• spent fuel dry store

• water treatment systems for maintaining the chemistry of the water circuit

• radioactive waste treatment and storage facilities

• back-up systems for providing power in the event of loss of electrical supply from the grid

Rolls-Royce SMR Ltd is considering the use of and options for diesel generators for back-up power. (Rolls-Royce SMR Limited – Preliminary Environmental Report (EDNS01000962396 Issue 1) April 2021.)

The Rolls-Royce SMR is based on a 3-loop PWR that would be mostly constructed and assembled in factory-built modules, apart from the largest components such as the reactor pressure vessel. The reactor is based on a standard PWR type technology, but with different reactor water chemistry and a reduced size which will allow for modular construction.

The PWR type of reactor is widely used – there are currently around 300 PWRs operating around the world. There are a range of applications and sizes of PWRs, including power generation and marine propulsion.

The Rolls-Royce SMR is still being designed and is therefore not in operation. This GDA is the first regulatory assessment of the Rolls-Royce SMR globally.

Sources, processing and disposal of radioactive waste

Radioactive waste in the form of solids, liquids and gases arise from activities associated directly or indirectly with operating and maintaining the reactor, and ultimately, from decommissioning the plant.

The operation of a PWR generates radioactive waste in the reactor coolant water (the primary circuit). Reactor coolant water is collected and treated and reused during operations.

Liquid radioactive discharges arise mainly from effluent associated with systems for collecting and treating the reactor coolant water. Other sources of radioactive aqueous effluent may include the:

• spent fuel storage pond

• washings from plant decontamination

• drainage from change‑rooms

• effluent from laboratories

Effluent treatment facilities include:

• accumulation, hold up and monitoring tanks

• filters

• demineraliser ion exchange resin beds

• membrane separation and evaporators

Facilities to monitor effluents for radioactivity prior to release are provided.

The main source of gaseous radioactive emissions is the primary circuit. Discharges from the primary circuit are collected by the gaseous radwaste system (GRWS) and held for decay storage in a carbon bed delay system.

Gaseous activity will also be present in the main process buildings, which are serviced by the heating, ventilation and air-conditioning (HVAC) systems. Discharges from these systems to atmosphere will be from an appropriate stack. There is monitoring of these discharges after filtration through high efficiency particulate air (HEPA) filters and, where appropriate, charcoal filters for adsorption of gases.

Radioactive wastes which are not discharged directly to the environment include:

• spent ion exchange resins

• spent filter media

• reverse osmosis membranes

• evaporator concentrates

• operational wastes, such as worn-out plant components and parts, contaminated protective clothing and tools, rags and tissues, and waste oil

Facilities for managing these types of waste include:

• resin storage tanks

• treatment and packaging facilities

• storage areas for packaged low-level and intermediate-level waste

All radioactive plant components are likely to become waste when the plant is decommissioned.

Spent fuel will be stored under water for about 10 years in the spent fuel storage pond. The Rolls-Royce SMR includes space for a dry store to allow further storage prior to ultimate disposal in a geological disposal facility (GDF).

Non-radioactive waste

Non-radioactive waste is produced from constructing, operating and maintaining the ‘conventional’ side of a PWR power station. It includes:

• combustion gases discharged to air from the diesel generators

• water containing water treatment chemicals, from the turbine-condenser cooling system and other non-active cooling systems, which can be discharged to the sea, lakes or other water bodies

• oils and any other significant liquids or sludges

• worn-out plant and components and general waste materials

Non-radioactive substances will also be present in the radioactive waste and may affect how it is managed and its impact on the environment.

4. The environment agencies’ GDA process for the Rolls-Royce SMR

Process

We (the Environment Agency and NRW) and ONR are using the GDA to scrutinise Rolls-Royce SMR Ltd’s Rolls-Royce SMR and assess its acceptability for use in Great Britain. The Environment Agency is the environment regulator for England and NRW for Wales. The Environment Agency supports NRW with the regulation of nuclear sites in Wales.

The GDA process is described in Guidance for Requesting Parties published by the Environment Agency and Guidance to Requesting Parties published by ONR.

We are carrying out GDA of the Rolls-Royce SMR before it has started construction. We can identify any potential regulatory design or technical issues early so that Rolls-Royce SMR Ltd can address them.

GDA is not a legal requirement, and we are carrying out the GDA of the Rolls-Royce SMR because the UK government has asked us to consider it.

Step 1 is the preparatory part of the design assessment process when we make agreements with the Requesting Party and provide advice on the scope and development of a submission. The guideline length for Step 1 is 12 months. It includes a review and confirmation that the Requesting Party has established adequate arrangements for GDA. Step 1 of the GDA of the Rolls-Royce SMR took 12 months, from April 2022 to March 2023.

At the start of Step 1, the Environment Agency entered into an agreement with Rolls-Royce SMR Ltd (the Requesting Party), under Section 37 of the Environment Act 1995 (EA95) to carry out work and recover our costs for GDA of the Rolls-Royce SMR.

NRW entered into an agreement with Rolls-Royce SMR Ltd under the Natural Resources Body for Wales (Establishment Order) 2012. We began GDA of the Rolls-Royce SMR after signing these agreements in April 2022.

We set out, jointly with ONR, a timetable for Step 1 of the GDA process in response to Rolls-Royce SMR Ltd’s GDA programme. In addition to providing feedback and advice on the contents of the submissions, we agreed detailed working arrangements with Rolls-Royce SMR Ltd covering matters such as:

• identifying and tracking documents

• how Rolls-Royce SMR Ltd will document its environment case and submit it for assessment during the GDA process

• how Rolls-Royce SMR Ltd will address any gaps in meeting our regulatory requirements, the expectations it has identified and its plan for this work

• the arrangements Rolls-Royce SMR Ltd has put in place to carry out the GDA

• the schedule and associated programme for subsequent steps

• the arrangements for initiation of the public comments process

During Step 1, we provided advice to Rolls-Royce SMR Ltd on our expectations for the environment case in readiness for Step 2.

We carried out a regulatory readiness review which showed that we have all the necessary resources in place to begin work on Step 2. Our review also considered the readiness review and gap analysis Rolls-Royce SMR Ltd carried out. This is considered in the detail of Step 1 activities in this report.

We have completed Step 1 of the GDA process. We discuss this in more detail in section 4 (Detail of Step 1 Activities) and give our Conclusions.

Next steps

Our next step is to begin our Step 2. We expect to begin Step 2 of the Rolls-Royce SMR in April 2023.

At the end of Step 2, we will publish the findings of our assessment and decide if Rolls-Royce SMR Ltd is ready to begin the GDA Step 3 and whether it is on track to reach the agreed target end point of the GDA process for the Rolls-Royce SMR.

The scope of GDA Rolls-Royce SMR Ltd proposed should be sufficient for it to aim for a SoDA to be issued.

Once we complete our Step 3 Assessment, we will consult on our preliminary findings of the assessment. We are planning to begin this public consultation in late summer 2025.

We will carefully consider all responses to the consultation before deciding whether to issue a SoDA, iSoDA or neither. We plan to publish our decision in summer 2026.

5. Details of Step 1 activities

This section summarises the outcome of the GDA Step 1 activities.

Objectives

The objectives for Step 1 of the GDA are:

• that Rolls-Royce SMR Ltd should agree with the Environment Agency and NRW the process that will be followed in GDA

• to determine if Rolls-Royce SMR Ltd is ready to proceed to Step 2 of GDA

During Step 1, with ONR, we carried out a joint assessment of the GDA project management arrangements to give us confidence in the quality of the GDA submissions. This is part of Rolls-Royce SMR Ltd’s management for safety and quality assurance (MSQA) arrangements.

We provided feedback and advice to Rolls-Royce SMR Ltd on the GDA scope, the proposed schedule of submissions, the structure of the submissions and our expectations of the contents of the parts of the submissions relevant to the environment case.

Scope of the GDA

Our GDA guidance expects the Requesting Party to provide a scope of GDA with enough information and sufficient functional specifications for the design so that we can carry out a meaningful GDA.

The scope of the environment case should include all relevant topics and sufficient details about the nuclear power plant design. The scope should be clear about whether the GDA will be a 2 or 3 step assessment, and whether the Requesting Party is aiming for a SoDA to be issued.

Full engineering details may not be available at the GDA stage, as some may only be finalised once the site-specific requirements are known and during the procurement and construction programme.

Where there is not enough or no information on certain topics, we may agree to exclude that topic from the GDA scope. We will only agree to do this if the GDA remains meaningful and the topic can be addressed effectively at a later stage. This includes during the application for site-specific environmental permits and during detailed design and procurement stages.

Rolls-Royce SMR Ltd provided a scope document in January 2023. (Rolls-Royce SMR Limited – Generic Design Assessment Scope (SMR0002183, Issue 2) January 2023.)

The scope covers the:

• structures, systems and components (SSCs)

• reactor design and layout

• relationship with the GDA activities

Information on the engineering and systems, the structures and components and the level of design maturity is also included.

The scope includes detail for each of the environmental subtopics and topics from other relevant parts of the submissions of the environment, safety, security and safeguards case (the E3S case). This includes chemistry and radioactive waste.

The scope indicates that Rolls-Royce SMR Ltd is intending to progress to the end of GDA Step 3. We are aware that Rolls-Royce SMR Ltd is seeking a SoDA at this stage.

The scope of GDA proposed by Rolls-Royce SMR Ltd should be sufficient for it to aim to progress to the end of GDA Step 3 and for a SoDA to be issued if we consider that the design is acceptable.

Entry into Step 3 and progression to a SoDA decision is subject to Rolls-Royce SMR Ltd obtaining funding.

The scope of the GDA is appropriate and contains enough information on the design so that we can carry out a meaningful GDA. The scope should be sufficient for Rolls-Royce SMR Ltd to aim for a SoDA to be issued, subject to acceptable assessment outcomes.

The scope document is supported by scope and submission plans for Step 2 for each topic. We reviewed the scope and submission plans for the environment topics and provided feedback to Rolls-Royce SMR Ltd during November 2022. We agreed the scope and submission plans in December 2022.

The sustainability of a design is not a formal area for assessment in GDA. However, we have agreed with Rolls-Royce SMR Ltd that sustainability will be included as an ongoing engagement topic within the GDA.

It is a topic of interest to the Environment Agency and NRW through duties in the Environment Act 1995 (EA95) and the goals and principles of the Wellbeing of future generations Wales Act 2015 and Part 1 of the Environment (Wales) Act 2016 respectively.

Rolls-Royce SMR Ltd recognises the importance of sustainable development, and all parties support the inclusion of sustainability as an engagement topic in the GDA. The Environment Agency and NRW recognise Rolls-Royce SMR Ltd’s willingness to explore this topic at a time when significant positive impacts could be realised from decisions made during the design process.

GDA timetable

The GDA of the Rolls-Royce SMR is currently planned to last 53 months.

Step 1 started in April 2022 and finished in March 2023 – taking 12 months.

Step 2 is expected to start in April 2023 and finish in July 2024 – taking 16 months.

Step 3 is planned to start in August 2024 and finish in August 2026 – taking 25 months.

Project management and related arrangements for GDA

Our guidance states that during Step 1 of GDA the Requesting Party should set up project management and technical teams and set up arrangements for:

• carrying out a GDA

• preparing and submitting documents during Step 1

• Step 2 of GDA

We worked with Rolls-Royce SMR Ltd to make sure that it fully understood the requirements and processes that will be applied during GDA. We discussed its arrangements for resolving concerns and issues raised by the regulators through the regulatory questions process.

We also worked with Rolls-Royce SMR Ltd to help develop and agree a project plan and other project management arrangements to support the submission of the environment case during Step 2.

Interface arrangements

During GDA Step 1, the Requesting Party must set out and implement the interface arrangements to be used throughout GDA. This includes:

• any meeting arrangements
• making sure there is full access to any relevant commercially confidential information (including any which is the property of third parties)
• obtaining all the necessary export licences to enable the transfer of information to and from the UK to all relevant countries

The interface arrangements to be used throughout GDA were agreed and documented with Rolls-Royce SMR Ltd, ONR, the Environment Agency and NRW. (ONR, Generic Design Assessment Interface Arrangements with Rolls-Royce SMR Limited, ONR-GEN-IN-023, Issue 1, July 2022.)

These include establishing how meetings will be arranged, and how commercially confidential information will be shared. The Environment Agency and NRW have developed a separate working together document which outlines the expectations and working arrangements between our 2 organisations.

Regulatory questions

In all GDAs the regulators review and assess submissions from the Requesting Party, using an agreed approach of 3 tiers of regulatory questions.

Regulatory questions are tiered in terms of significance. The lowest tier is Regulatory Queries (RQs). These are requests by the regulators for clarification and additional information. An RQ does not necessarily indicate a perceived regulatory shortfall in the design or supporting information.

The next tier is Regulatory Observations (ROs) which are raised when the regulators identify a potential regulatory shortfall in the design or the supporting information. The Requesting Party must take action to resolve it.

The final tier is Regulatory Issues (RIs). These are raised when the regulators identify a serious regulatory shortfall in the design or the supporting information which could prevent them from issuing a SoDA or from ONR issuing a design acceptance confirmation (DAC). The Requesting Party must take action to resolve it.

The interface arrangements define the approach to regulatory questions.

Rolls-Royce SMR Ltd’s procedures for managing regulatory questions were assessed during the Step 1 assessment of its management arrangements. The procedures set out processes, responsibilities and tracking metrics. Previous GDA experience suggests that responses to regulatory questions are improved where the Requesting Party confirms with the regulators their meaning and the proposed response before formally issuing them. Rolls-Royce SMR Ltd should consider capturing this in its procedure.

Document marking and export control

ONR raised a GDA-wide RQ (RQ-RRSMR-0001) for the whole of the GDA process in August 2022, requesting information on Rolls-Royce SMR Ltd’s information marking scheme that will be used during GDA.

In response to the RQ, Rolls-Royce SMR Ltd provided its standard for business sensitive information. Its standard shows the range of business sensitive markings that are used on its documents and will be used during GDA.

At this stage of the GDA, Rolls-Royce SMR Ltd considers that export-controlled information relevant to the environment case will not be required, and so no export licences for the Environment Agency and NRW are required. This position will be kept under review as the GDA progresses.

Master document submission list

The Requesting Party must agree with us the master document submission list (MDSL) format. The MDSL is a list of all the documents the Requesting Party submits during GDA. It should be maintained throughout GDA so that it references precisely each submission the Requesting Party makes.

Rolls-Royce SMR Ltd has developed a suitable process for developing and maintaining the MDSL and it shared versions of the MDSL during Step 1. The process is described in the arrangements for regulatory correspondence. (Rolls-Royce SMR Limited – Regulatory Correspondence (SMR0000967), Issue 1, September 2022.)

Review of Rolls-Royce SMR Ltd’s arrangements for carrying out the GDA

During Step 1, we and ONR jointly assessed the management arrangements Rolls-Royce SMR Ltd will use to carry out a GDA to give confidence in the quality of the submissions. This is part of Rolls-Royce SMR Ltd’s MSQA arrangements.

We carried out a relatively detailed assessment of the management arrangements (including quality assurance) during Step 1 of the GDA to give us early confidence that:

• the design will be developed, and the submission produced, by suitably qualified and experienced people, including staff and contractors
• there will be an appropriate level of verification, review and approval of design and submission documents, including those produced by contractors, and the submission will accurately reflect the design
• the design will be developed, taking environmental requirements for all plant lifecycle stages into account
• design changes will be controlled, evaluated for their impact on the environment, recorded and reflected in the submission

Rolls-Royce SMR Ltd’s GDA arrangements are captured in an integrated management system (IMS). This is a hierarchical arrangement of management policies, manuals and processes aligned to relevant standards and guidance and is described in a manual. (Rolls-Royce SMR Limited – Integrated Management System Manual, SMR0001351, Issue 1, December 2022.)

The IMS documents were submitted to regulators for assessment during GDA Step 1.

The regulators reviewed these documents as part of our Step 1 review. We attended technical MSQA meetings with Rolls-Royce SMR Ltd where the arrangements were described. We carried out sampling evaluations of how these arrangements were implemented. We concluded that Rolls-Royce SMR Ltd’s MSQA arrangements are developing and have largely been implemented as formal GDA management arrangements for developing the Rolls-Royce SMR and for controlling the content and accuracy of the GDA submissions.

Arrangements for developing the design are detailed in an engineering management plan (EMP). (Rolls-Royce SMR Limited – Engineering Management Plan for Rolls-Royce SMR, SMR0000520, Issue 3, October 2022.)

Arrangements for producing the environment case for GDA are set out in an environment, safety, security and safeguards (E3S case) management manual. (Rolls-Royce SMR Limited – Environment, Safety, Security and Safeguards (E3S) Management Manual SMR0001328, Issue 1, August 2022.)

Design and E3S activities are subject to quality assurance in line with a GDA quality management plan.

Rolls-Royce SMR Ltd is seeking independent certification of its management arrangements to ISO9001 and has completed Stage 1 and Stage 2 audits of its arrangements by Bureau Veritas.

We noted that some organisational and management arrangements were still being implemented, and the working arrangements are still evolving, for example, in relation to:

• arrangements for managing changes to the design and E3S case
• record-keeping in relation to design development, governance and review
• a formal risk management process within the IMS
• intelligent customer capabilities for specifying and managing technical service contracts supporting GDA activities
• full implementation of competency and capacity arrangements (noting that the Requesting Party’s use of ‘skills assured’ for its competency management framework appears to us to represent good practice)

Rolls-Royce SMR Ltd plans to address these gaps during the early stages of Step 2.

Overall, based on our sampling, we consider Rolls-Royce SMR Ltd’s management arrangements to be satisfactory for this stage of the GDA process. We will use our Step 1 Assessment and review findings to develop an appropriate assessment plan for management arrangements in Step 2 of GDA. This will include assessment of Rolls-Royce SMR Ltd’s progress in addressing the areas identified as gaps.

Arrangements for design changes

In their Guidance to Requesting Parties ONR requires the Requesting Party to submit a Design Reference (DR), listing all the documents that define the design of the nuclear power plant that the GDA submissions will refer to. This will be ‘frozen’ at a specific date known as the Design Reference Point (DRP). The DR arrangements will be agreed during Step 1 and the first DRP will be agreed during Step 2.

We expect the Requesting Party to send us its initial DRP for the GDA and to update the DRP as changes are made to the design.

Rolls-Royce SMR Ltd has stated that in 2023 during Step 2 the Rolls-Royce SMR will achieve the DRP.

On 16 December 2022, ONR raised 2 RQs (RQ-RRSMR-0002 and RQ-RRSMR-0003) related to design reference and change control which apply to the whole GDA project and all assessment topics, including the environment.

RQ-RRSMR-0002 is for the requirements in GDA for the scope and contents of DR and the arrangements for handling the DR, routine updates, and the intent for the DRP. Specific questions included how the DR is captured; how the DR will evolve, and the role of the master record index (MRI) in defining the DR.

Rolls-Royce SMR Ltd provided a full response to the RQ on 27 January 2023, which is sufficient for Step 1 and will be assessed in Step 2.

RQ-RRSMR-0003 is for the expectations in GDA for change control. The RQ notes that Rolls-Royce SMR Ltd’s arrangements for change control documented in the configuration management plan and engineering change management policy appear inconsistent and insufficient to explain the approach to change control. Specific questions included the relationship between the reactor design and the GDA DRP and how the evolution of the reactor design and the DRP will be managed.

Rolls-Royce SMR Ltd provided a full response to the RQ on 13 January 2023. It has committed to develop the processes in Step 2. Our assessment of the DRP and arrangements for control of reactor design changes will continue during Step 2 of GDA. The response was adequate.

Information provided by the Requesting Party

Rolls-Royce SMR Ltd provided documentation to help with the Step 1 of GDA. It provided 3 main batches of documents during Step 1. These included:

• Preliminary Safety Report (Rolls-Royce SMR Limited – RR SMR Preliminary Safety Report, SMR0001510, Issue 1, August 2022)

• Generic Site Description (Rolls-Royce SMR Limited – Generic Site Description (SMR0001541 Issue 1), August 2022)

• Preliminary Environment Report (PER) (Rolls-Royce SMR Limited – Preliminary Environmental Report (EDNS01000962396 Issue 1) April 2021)

Rolls-Royce SMR Ltd developed additional documents during Step 1 and provided these later.

The first set of documents were provided in June 2022. These allowed the assessors to familiarise themselves with the design and included a design overview document and 8 presentations on aspects of the reactor. Rolls-Royce SMR Ltd held a question and answer session on the design with the regulators.

Rolls-Royce SMR Ltd provided the second set of documents in August 2022. There were 16 documents:

• 8 were related to activities covering the management arrangements for the environment, safety, security and safeguards (E3S case)

• 2 of the documents were part of the safety case

• 3 were part of the environment case

• 3 were related to security and safeguards

We reviewed these submissions during September 2022 and provided feedback to Rolls-Royce SMR Ltd in October 2022.

Rolls-Royce SMR Ltd provided the third set of documents in October 2022. This included:

• initial information on the proposed scope of GDA

• information on solid radioactive waste and expected discharges

• more information on management arrangements, engineering and control, and environmental aspects relevant to GDA

We reviewed the documents during November 2022 and provided advice and feedback to Rolls-Royce SMR Ltd during December 2022.

For Step 2, the documents provided in Step 1 will be updated with more detailed information and developed into the environment, safety, security and safeguards (E3S case) report for our assessment.

The environment case

Our guidance expects the Requesting Party for GDA to agree with us the scope, structure and format of its environment case submission.

Full engineering details of the reactor may not be available at the GDA stage. It is normal to finalise engineering details once the site-specific requirements are known and during the procurement and construction programme. However, the Requesting Party is expected to provide enough functional specifications for its design so that a meaningful GDA can be carried out.

A sufficiently detailed environment case needs to be developed. Our guidance expects the Requesting Party to provide:

• relevant plant and process descriptions, including engineering drawings, process flow diagrams

• other information that will help us understand the nuclear power plant design, its underpinning design philosophy and its environmental protection features

The PER provided by Rolls-Royce SMR Ltd describes the design status of the environmental aspects of the plant and identifies the systems, structures and components that can affect the environmental performance. (Rolls-Royce SMR Limited – Preliminary Environmental Report (EDNS01000962396 Issue 1) April 2021.)

The PER presents the initial environmental topic assessment findings and how the requirement for best available techniques (BAT) are being incorporated within the early development of the design. Rolls-Royce SMR Ltd also provided scope documents for each of the environment subtopics and other topics from the safety case that are relevant to the environment case.

Environment case structure

In Step 2 of GDA, Rolls-Royce SMR Ltd will arrange the environmental information in a generic environment report (GER), which will form part of the environment, safety, security and safeguards (E3S case).

The E3S case will be structured using the International Atomic Energy Agency (IAEA) SSG-61. (IAEA Safety Standards for protecting people and the environment. Format and Content of the Safety Analysis Report for Nuclear Power Plants: Specific Safety Guide; IAEA Safety Standards Series No. SSG 61 (2021)).

The IAEA Safety Series SSG61 gives good practice and experience in the use of safety analysis reports for newly built nuclear power plants. Rolls-Royce SMR Ltd has adapted the IAEA good practice to meet the GDA requirements. The E3S case will adopt a hierarchical 3-tier structure, partly using a claims, arguments and evidence format. (Rolls-Royce SMR Limited – Environment, Safety, Security and Safeguards (E3S) Management Manual SMR0001328, Issue 1, August 2022.)

The main GER Tier 1 document within the E3S document will consolidate all the information in the environment case, including relevant claims and descriptions of the environmental processes.

The E3S case will have 33 chapters. 10 chapters (Tier 1 documents) form the GER.

Three of these chapters are joint with the sections of the E3S case that cover safety, security and safeguards.

Seven of the GER chapters cover:

• detailed design

• radioactive waste management arrangements (RWMA)

• BAT

• sampling and monitoring

• discharges

• radiological impact

• other environmental regulations

Tier 2 documents (topic reports) will include any arguments and evidence that directly underpin each of the chapters of the GER.

Tier 3 reports will present evidence and will comprise detailed documents, including technical specifications, methodologies, calculation notes, spreadsheets and lower-level analyses carried out to support the production of Tier 2 documentation.

Environment case content

During Step 1, we provided advice to Rolls-Royce SMR Ltd on our expectations for the environment case in readiness for Step 2. We have not carried out a formal technical assessment of any of the documents received during Step 1 that make up the environment case. Our technical assessment will begin in Step 2.

Radioactive discharges and their impact

Our GDA guidance expects the Requesting Party to present information on the quantities and types of radioactive waste (gaseous, liquid and solid) and spent fuel that are likely to arise from the reactor design.

Rolls-Royce SMR Ltd has provided a scope and documented information on the expected discharges. (Rolls-Royce SMR Limited – Preliminary Quantification of Radioactive Effluent Discharges (SMR0001543, Issue 1) October 2022.)

However, it will need to further develop the documentation and supporting evidence. The information presented is based on other PWR designs and is not yet specific for the Rolls-Royce SMR. There is limited information on waste volumes, activities, material composition, major radionuclides and hazardous and non-hazardous materials associated with the operational wastes. The expected frequency of liquid discharges needs to be confirmed during the Step 2 and Step 3 of GDA.

During GDA, the Requesting Party must provide information on the likely impact on people and the environment of any proposed discharges of gaseous and liquid radioactive waste.

Rolls-Royce SMR Ltd provided scope and provisional information on the methods it will use to assess these aspects. (Rolls-Royce SMR Limited – Initial Radiological Assessments (SMR0001542 Issue 1) October 2022.)

They also provided an outline of the expected impact on people and the environment, taking into account the characteristics of the generic site. (Rolls-Royce SMR Limited – Generic Site Description (SMR0001541 Issue 1), August 20228.)

The generic site is a description of the type of sites where the power plant could be built. Where potential sites are known, this description should include their environmental characteristics and constraints, such as protected habitats. The assessment will be based on estimated discharges to the environment. Discharges will be derived from existing PWR data until specific information on discharges from the Rolls-Royce SMR becomes available.

We expect a description of the type of sites where the power plant could be built (the generic site). This description should include the environmental characteristics and constraints, such as protected habitats. The generic site description will be an input to the assessment of the radiological impact on people and the environment.

A generic site description has been provided which reflects the preferred site type – a coastal location with the baseline design option of cooling towers. There is also an intent that direct once-through cooling will be compatible with the design. The main characteristics of the generic site have been presented, which are representative of a coastal location.

Best available techniques (BAT)

During GDA, the Requesting Party must provide its approach for determining BAT to prevent or minimise radioactive waste and its impact during the lifecycle of the plant, including design, construction, commissioning, operation and decommissioning.

Rolls-Royce SMR Ltd provided a document on the scope and submission plan for BAT assessments and a document covering optimisation. (Rolls-Royce SMR Limited – Approach for the Demonstration of Optimisation through Application of BAT (EDNS01000902308) July 2020.)

The optimisation document defines a claims, arguments and evidence model and provides an indicative structure similar to the GDA of the European Pressurised Water Reactor (EPR). The structure does not take into account some of the specific features of the Rolls-Royce SMR and will therefore need further development during GDA. Rolls-Royce SMR Ltd recognises the areas that require development and is in the process of updating the document. This will be issued at the end of Step 1 for assessment and will be assessed in Step 2.

The documents reviewed were early versions provided mainly for familiarisation. The structure does not take into account some of the specific features of the Rolls-Royce SMR or consider optimised waste disposal routes. It will therefore need further development during GDA. It is clear from engagement that Rolls-Royce SMR Ltd understood the limitations of the documentation. The documents will be updated during Step 2 of GDA. A gap analysis against previous GDAs may help develop the BAT case.

We expect a systematic BAT methodology to be presented, showing how BAT has been applied to the Rolls-Royce SMR. The document ‘Approach for the Demonstration of Optimisation through Application of BAT’ (Rolls-Royce SMR Limited – (EDNS01000902308) July 2020) summarises both the BAT methodology and Rolls-Royce SMR Ltd’s design decision process.

This process includes considering both BAT and ALARP (as low as reasonably practicable) in optimising the design, aligning with our expectations. The principle of ALARP is part of the regulation and management of safety systems. The demonstration of both BAT and ALARP will use a common evidence base. This will also help ensure consistency in the BAT case and the ALARP case as the design evolves.

Several aspects of the design decision process were updated during Step 1 of GDA. We will assess the adequacy of these arrangements in the demonstration of BAT during Step 2 and Step 3 of the GDA.

Solid radioactive waste

During GDA, the Requesting Party must provide information on the disposability of any solid radioactive waste arisings.

During GDA Step 1, Rolls-Royce SMR Ltd provided a scope and submission plan for the Radioactive Waste Management Arrangements. (Rolls-Royce SMR Limited – GDA Scope and Submission Plan for Radioactive Waste Management Arrangements (SMR0003700 Issue 1) December 2022).

They also provided an outline of the disposability assessment (Rolls-Royce SMR Limited – Disposability Assessment Skeleton Report (TS-DD-01 Issue 4) October 2023).

Additional information was given in safety documentation provided during Step 1.

These will form part of the E3S case which will be submitted in Step 2 of GDA. Rolls-Royce SMR Ltd has stated that it will share its plans and intentions with Nuclear Waste Services (NWS) early in the GDA process. NWS is part of the UK’s Nuclear Decommissioning Authority (NDA) and brings together the leading nuclear waste management capabilities.

NWS will provide an expert view on whether the proposals for radioactive waste management are achievable with suitable further detailed development. Rolls-Royce SMR Ltd will obtain disposal advice from NWS on higher activity waste (HAW) from both operational and decommissioning wastes arisings and operational low-level waste (LLW).

We are supportive of Rolls-Royce SMR Ltd’s early engagement with NWS. We note that the complete information on radioactive waste will be in a number of parts of the E3S documents, including parts of the safety sections. Therefore, Rolls-Royce SMR Ltd will need to provide appropriate mapping to the information.

During GDA, the Requesting Party must provide information on the strategic considerations for radioactive waste management which underpin the design. It must also provide a description of all radioactive wastes and spent fuel arising throughout the nuclear power plant’s lifecycle, and the proposals for its management and disposal.

During Step 1 Rolls-Royce SMR Ltd provided an Integrated Waste Strategy (IWS) (Rolls-Royce SMR Limited – Reactor Integrated Waste Strategy (SMR0002131 Issue 1) October 2023).

This strategy identifies the expected radioactive waste and spent fuel arisings as well as proposed management and disposal strategies. This document broadly aligns with our expectations, recognising further development is required in accordance with the document’s forward action plan.

Additional documents relevant to the RWMA were also submitted in Step 1 of GDA. These included:

• the ‘Approach for the Demonstration of Optimisation through Application of BAT’ (Rolls-Royce SMR Limited – (EDNS01000902308) July 2020)

• ‘Solid Operational Waste Identification’ (Rolls-Royce SMR Limited – (SMR SMR0001122 Issue 1) July 2022)

• ‘Environment, Safety, Security and Safeguards Design Principles’ (Rolls-Royce SMR Limited – (SMR0001603 Issue 1) August 2022)

Sampling and monitoring

Requesting Parties must provide appropriate information on sampling arrangements, techniques and systems for measuring and assessing discharges and disposals of radioactive waste. These must cover in-process monitoring and the monitoring of final discharges and disposals. Information is not required until later in Step 2 and Step 3 but can be developed and provided earlier in GDA.

During Step 1, Rolls-Royce SMR Ltd provided a scope and an outline of its approach to radioactive discharge sampling and monitoring in its PER (Rolls-Royce SMR Limited – Preliminary Environmental Report (EDNS01000962396 Issue 1) April 2021).

These showed it had adequately considered what will be required for sampling and monitoring discharges, provision for in-process monitoring, and that it will consider monitoring of non-aqueous liquids and solid wastes.

Conventional aspects

In our guidance, the Requesting Party should provide information about conventional aspects of the design, including potential impacts on people and the environment of discharges from back-up diesel generators, cooling and process water discharges, other waste disposals, and information about its approach to applying BAT (where applicable).

Rolls-Royce SMR Ltd provided a scope and documents covering the requirements in the Guidance for Requesting Parties (Rolls-Royce SMR Limited – Generic Design Assessment Other Environmental Regulations (SMR0001849 Issue 1) October 2022).

During the GDA Step 1 we will provide guidance to help the Requesting Party to produce a sufficiently detailed environment case.

We reviewed documents submitted in the Initiation step of GDA and provided feedback but did not make an assessment. During the review we noted intentions to consider possible use of waste heat and reuse water which are good practices. We also noted that the options for cooling water arrangements are still open.

Standards and guidance

The Requesting Party is expected to show how it will take account of Environment Agency guidance, in particular our Radioactive substances Regulation (RSR) objective and principles and the RSR generic developed principles for regulatory assessment.

Rolls-Royce SMR Ltd provided information about how it will take account of this guidance:

• Rolls-Royce SMR Limited – Preliminary Environmental Report (EDNS01000962396 Issue 1) April 2021

• Rolls-Royce SMR Limited – Environment, Safety, Security and Safeguards (E3S) Management Manual SMR0001328, Issue 1, August 2022

• Rolls-Royce SMR Limited – Approach for the Demonstration of Optimisation through Application of BAT (EDNS01000902308) July 2020

However, the references to Environment Agency guidance are in documentation from Rolls-Royce SMR Ltd that were produced before our guidance was updated.

These refer to guidance in the Regulation Environmental Principles (REPs). (Environment Agency, 2010. Regulatory Guidance Series RSR 1: Radioactive Substances Regulation - Environmental Principles.)

The REPs were withdrawn and replaced at the end of 2021 by two guidance documents - the Radioactive Substances Regulation (RSR) objective and principles (which were revised) and the RSR generic developed principles for regulatory assessment (which have not changed).

Rolls-Royce SMR Ltd has acknowledged that some of the documents it provided had been prepared before the changes to guidance. When the documents are updated for Step 2, they will use the latest Environment Agency guidance.

The Requesting Party is expected to provide the strategies, methods, models and standards that it will use to demonstrate design acceptability. Rolls-Royce SMR Ltd has identified the information it will include. This includes engineering design information, operational experience (OPEX) from PWRs, relevant good practice (RGP) and recent permitting and licensing of new reactors. Rolls-Royce SMR Ltd indicates that it will make use of information from previous GDAs of PWRs.

Rolls-Royce SMR Ltd has begun to lay out in summary form the standards, methods, models, good practice and design and assessment principles. It has identified that important aspects of the E3S case will be demonstrating that RGP and design and assessment principles and codes and standards are met (where practicable). Important national and international standards and guidance that are applicable are summarised. Rolls-Royce SMR Ltd will need to further develop their application during Step 2 and Step 3 of GDA.

Rolls-Royce SMR Ltd’s Rolls-Royce SMR has not been licensed or permitted in another country. Therefore, design documents or approvals from regulators in other countries are not available to Rolls-Royce SMR Ltd.

Document submission

We agreed with the Requesting Party a schedule for submitting the environment case information at the end of Step 1 and during Step 2.

Rolls-Royce SMR Ltd has provided a schedule for the submission of the environment case information at the end of Step 1 and during Step 2 for Tier 1, Tier 2 and Tier 3 documents. We have discussed the proposed schedule with Rolls-Royce SMR Ltd. The submission schedule is broadly acceptable, however, we agreed with Rolls-Royce SMR Ltd adjustments to the schedule to give sufficient time for our assessment.

The format of the E3S case will be as a portable document format (PDF).

Sustainability

Sustainability of a design is not a formal area for assessment in GDA. We have agreed that it will be an ongoing engagement topic.

Rolls-Royce SMR Ltd recognises the importance of sustainable development and, in support of its own activities, has agreed to incorporate sustainability as an additional topic for discussion during the GDA.

Several initial discussions took place on sustainability, and Rolls-Royce SMR Ltd has prepared a draft scope document to support ongoing discussions. Main areas of interest include:

• understanding how sustainability has been considered in decision-making during the design process, with resulting impacts on the sustainability of the design

• benchmarking within the nuclear and other industries

• understanding how sustainability-related factors will be monitored through performance indicators or metrics

No regulatory judgements will be made on the sufficiency of the material provided and no regulatory questions will be raised on this topic. However, a commentary on important discussions and commitments will be provided during subsequent GDA steps.

Gap analysis and readiness review

Rolls-Royce SMR Ltd considered its readiness for entry into Step 2 by a gap analysis, a readiness review and an assessment of its capability. Each noted some actions needed for entry into Step 2 of GDA. Rolls-Royce SMR Ltd identified the actions it needs to undertake before going into Step 2. These have now been completed.

Gap analysis

The Requesting Party must identify any gaps or shortfalls in information that it is providing to us against our expectations of its design and environment case. We have provided advice to the Requesting Party to help it do this. The Requesting Party must provide, for our agreement, how it proposes to resolve these gaps and meet our regulatory requirements and expectations.

Rolls-Royce SMR Ltd has carried out a gap analysis and identified 4 gaps in the MSQA and project activities and has proposed resolution plans. The 4 gaps in the MSQA and project activities were in:

• the scope and content of the design reference

• the change control process for the design, the E3S case and the DRP

• documentation of its arrangements for intelligent customer

• its approach to knowledge management and OPEX

We noted that OPEX is an important part of substantiating the design. Rolls-Royce SMR Ltd proposes to address this by developing a Knowledge Management Framework. This has been noted in their Readiness Review, along with actions to implement the arrangements by the end of March 2023. Additionally, these arrangements feature in the Scope and Submission document for MSQA.

Rolls-Royce SMR Ltd has carried out a gap analysis against the requirements in the Environment Agency Guidance for Requesting Parties. No specific gaps were identified in the environment components of the E3S case, but some shortfalls were noted.

Rolls-Royce SMR Ltd noted that the Rolls-Royce SMR has continued to evolve since the PER was submitted in Step 1. (Rolls-Royce SMR Limited – Preliminary Environmental Report (EDNS01000962396 Issue 1) April 2021). Therefore, some of the documents do not contain the most up-to-date information. If the documentation is not up-to-date the assessment that can be carried out in Step 2 of GDA will be limited.

The gap analysis identified shortfalls in information on some of the main systems, including stack design, the heating, ventilation and air conditioning (HVAC) system, containment and the radioactive source term. Information in these areas is still developing and maturing. Information on environmental protection functions (EPF) is also not complete and needs to be developed for Step 2. The decision recording system does not yet capture additional guidance for environment and sustainability requirements and updates to objectives and assessment criteria, optioneering and BAT training. Information is not yet detailed enough to develop the disposability case.

For the conventional aspects considered in GDA, design maturity of back-up generators and the chemical inventory are at an earlier stage than those associated with radioactive material.

Rolls-Royce SMR Ltd will capture the shortfalls in forward action plans. This will identify which of the Tier 2 and Tier 3 documents are required to support the development of Tier 1 documents that form the chapters in the environment case.

Important links with engineering work packages have been determined to identify any potential risks to the GDA programme as Step 2 progresses. This will help ensure that the formal submissions during Step 2 of GDA are up-to-date and fully mature.

Rolls-Royce SMR Ltd has reviewed the environment case chapter development against the Guidance for Requesting Parties for Step 2 and Step 3 of GDA. This took into account the design maturity of the Rolls-Royce SMR and the timing of the production of the environment case. The review identified that the chapters covering detailed design and sampling and monitoring will not be available at the start of Step 2.

Readiness review

Rolls-Royce SMR Ltd has carried out a readiness review in preparation for Step 2. The readiness review was made against the Rolls-Royce SMR Ltd Management Expectations. The readiness report was provided on 2 February 2023 and assessed 4 main areas to determine if:

• the project is mature enough and ready to commence GDA Step 2

• the arrangements needed to carry out all work required in the GDA Step 2 are in place

• the design and associated safety, security, safeguards and environment (E3S case) is mature enough and under suitable configuration control for GDA Step 2

• organisational capacity and capability needed to carry out activities within the GDA Step 2 is understood and in place

Its review showed that the majority of activities are complete or on track. Four specific activities received close attention to ensure they are on track before Step 2 starts. These relate to meeting the GDA Step 1 requirements and expectations for:

• entry into GDA Step 2

• the maturity of the project plan for Step 2 of GDA

• control of the integration between the Rolls-Royce SMR and the E3S case at the start and end of Step 2; and

• resources (staff and supply chain) for Step 2 of GDA

This last aspect was affected by Rolls-Royce SMR Ltd’s strategic review of its engineering plans and its resources which was carried out in January 2023. These 4 activities have now developed sufficiently to allow entry into step 2.

The readiness review also notes the need to develop and agree resolution plans for the gaps and shortfalls found by the gap analysis - which can be monitored during step 2.

Organisation capability report

An organisation capability report has been provided which includes the strategy for GDA resourcing. This will allow a review of the organisational specification and acquisition of capability across the engineering and safety and regulatory aspects within Rolls-Royce SMR Ltd’s GDA activities.

A draft organisational capability report was provided on 16 February 2023 and the final version provided on 27 February. (Rolls-Royce SMR Limited – Organisational Capability (SMR0004127, Issue 1) February 2023.)

This showed the resources required for the environment area of GDA during Step 2. It shows the important roles that have been filled by permanent staff and contract staff from suppliers. Other resources will be drawn from other roles within Rolls-Royce SMR Ltd or from the supply chain according to need. This will ensure resource is available to meet the needs of Step 2 - which will vary with time. Further actions will be taken during Step 2 to ensure Rolls-Royce SMR Ltd remains resilient.

Our readiness for Step 2

Our Guidance for Requesting Parties requires that we should be ready to enter Step 2.

To meet this requirement, we undertook a review of our readiness to progress Step 2. As part of our engagement in Step 1, we have reviewed the submission schedules provided by Rolls-Royce SMR Ltd for the relevant parts of the E3S case. We have agreed that there will be sufficient time after the submissions in Step 2 for our assessment. We developed an assessment schedule for Step 2 that will match the submission schedules provided by Rolls-Royce SMR.

We have agreed that there will be sufficient content in the submissions for us to assess during Step 2. We have sufficient resources for our assessment during Step 2 and suitable internal technical guides to support the assessment process.

We have joint regulator GDA webpages, hosted by ONR. The environment agencies also publish reports and GDA information on their own websites. The webpages are one of several communication channels used by the regulators to share information with the public. Stakeholder engagement will also be carried out during step 2.

We reviewed the progress of Rolls-Royce SMR Ltd in Step 1 against the requirements in our guidance – which we consider were met.

Our readiness to proceed into Step 2 was agreed by our New Reactors Programme Board.

Public comments and communication

The Requesting Party must put processes in place that allow the public to interact with it throughout Steps 2 and 3 of the GDA process.

The Requesting Party should provide information on a public website about the proposed design and how it will meet standards for environmental protection, safety, security and safeguards. The website should enable the public to see the information the Requesting Party has provided to the regulators as part of the GDA, make comments and ask questions.

The Requesting Party must agree with the regulators the information that it will publish on its website. It will be expected to update this public information whenever it makes any significant changes to the information it submits to the regulators. The Requesting Party must also agree with the regulators the process and timescales it will use to respond to comments from the public. It must provide the comments and questions raised by the public to the regulators, as well as its responses.

Rolls-Royce SMR Ltd has developed a website and identified materials to be published at the start of Step 2. This will include a process for managing and responding to public comments. The website and the comments process are on track to go live at the start of Step 2 of GDA.

Outstanding issues

At the end of Step 1, all areas in this step of GDA had been reviewed or assessed. All the issues had been identified and all the necessary forward action plans required have been provided by Rolls-Royce SMR Ltd.

6. Conclusions from Step 1 of GDA

The scope indicates that Rolls-Royce SMR Ltd is intending to progress to the end of GDA Step 3 seeking a SoDA. The scope of the GDA is appropriate and contains enough information on the design so that we can carry out a meaningful GDA. The scope should be sufficient for Rolls-Royce SMR Ltd to aim for a SoDA to be issued, subject to acceptable assessment outcomes.

An interface agreement is in place which sets out how Rolls-Royce SMR Ltd will submit information and how we will track it. Also in place are arrangements for correspondence and meetings, and how regulatory questions (RQs, ROs, and RIs) will be raised and tracked.

We have agreed with Rolls-Royce SMR Ltd how it will make the relevant GDA information available to the public and stakeholders via its website and how it will manage comments on this information. Rolls-Royce SMR Ltd currently plans to issue and publish the GDA submissions relevant to the environment in the first 3 months of Step 2 of GDA.

With ONR, we jointly carried out an assessment of Rolls-Royce SMR Ltd’s management arrangements for the GDA. Overall, based on our sampling, we consider that Rolls-Royce SMR Ltd’s management arrangements are satisfactory for this stage of the GDA process. We will use our Step 1 assessment and review our findings to develop an appropriate assessment plan for management arrangements in Step 2 of GDA. This will include assessment of Rolls-Royce SMR Ltd’s progress in addressing the areas identified as gaps.

We have reviewed some of the documentation that will form the environment case during Step 1 of GDA. The documents provided were for familiarisation and for initial feedback. The documents were precursors of the submissions that are planned for Step 2 of GDA and were therefore not fully mature. In the review of feedback, Rolls-Royce SMR acknowledged that some documents had not been recently updated, but that it would revise them before submission for Step 2 of GDA.

Rolls-Royce SMR Ltd considered its readiness for entry into Step 2 by a gap analysis, a readiness review and an assessment of its capability. Each noted some actions needed for entry into Step 2 of GDA. Rolls-Royce SMR Ltd identified to the regulators the actions it needs to undertake before going into Step 2. These have now been completed.

The environment agencies have carried out a review of Rolls-Royce SMR Ltd’s progress in Step 1 and of its readiness reviews. We have determined that the arrangements and resources Rolls-Royce SMR Ltd has put in place to carry out the GDA are adequate to progress to Step 2.

We have agreed a schedule for submitting the environment case information during Step 2. We have also agreed how any outstanding information from Step 1 will be dealt with in Step 2 of GDA.

Rolls-Royce SMR Ltd has provided sufficient information to meet our requirements for Step 1 of GDA as set out in our Guidance for Requesting Parties.

We have concluded that we can progress to Step 2 of GDA.

Our next steps will be to finalise our schedule of work and plans for Step 2, and then begin to review and assess the submissions that will be provided by Rolls-Royce SMR Ltd during Step 2.

Contact us

To contact the Environment Agency, email nuclear@environment-agency.gov.uk.

To contact NRW, contact our Customer Care Centre which handles everything from general enquiries to more complex questions about registering for various permits.

Call 0300 065 3000 (Monday to Friday, 9am to 5pm)

emailenquiries@naturalresourcewales.gov.uk

By post

Natural Resources Wales
c/o Customer Care Centre
Ty Cambria
29 Newport Road
Cardiff
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