Nuclear Site Licence Application Summary Forward Work Plan

Transcription

1 Nuclear Site Licence Application Summary Forward Work Plan WD S5-NL-REP-00007

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3 Contents 1 Introduction Scope of the Summary Forward Work Plan Summary Forward Work Plan Development Table of Abbreviations and Acronyms Document Structure Overview Project lifecycle phases Hold Points and Readiness Hold Points Readiness to be Granted a NSL Work Areas Organisational Capability Management Arrangements Development Safety Cases Other Obligations Status at the Point of Application Activities Organisational Capability Management Arrangement Development Licensee Obligations Management of Site Activities Design and Safety Submissions Management Long Lead Items Safety Cases Other Obligations Development Phase (up to Site Licence Grant) Organisational Capability Management Arrangement Development Licensee Obligations Construction Oversight and Site Management Arrangements Contracts Oversight Site Preparation Safety Cases Other Obligations Development Phase (after SLG and up to Construction) Organisational Capability Management Arrangement Development Safety Cases Other Obligations Construction Phase Organisational Capability Management Arrangement Development Preparation for Commissioning Page i of ii

4 7.2.2 Nuclear Matter and Nuclear Fuel on the NLS Safety Cases Other Obligations Commissioning Phase Organisational Capability Management Arrangement development Safety Cases Other Obligations Generation Phase Organisational Capability Management Arrangement Development Safety Cases Other Obligations Decommissioning Phase Organisational Capability Management Arrangement Development Safety Cases Other Obligations Management of Future Work Regulatory Commitments Maintenance of the Summary Forward Work Plan Schedule of References List of Tables Table 2.1 Abbreviations and Acronyms... 3 Table 12.1 Schedule of references List of Figures Figure 3.1 Process development model... 8 Page ii of ii

5 Introduction 1. Horizon Nuclear Power Wylfa Limited ( Horizon ) is applying for a Nuclear Site Licence (NSL) to install and operate the Wylfa Newydd Power Station (the Power Station) on Anglesey in North Wales. 2. This Summary Forward Work Plan (SFWP) identifies the key activities that Horizon will complete prior to and throughout the lifecycle of the Power Station and the Wylfa Newydd Project (the Project). These activities will ensure that the company remains compliant with the requirements of the NSL and associated Licence Conditions (LCs) and is capable of holding and maintaining a NSL. This SFWP forms part of the Site Licence Application (SLA) package. 1.1 Scope of the Summary Forward Work Plan 3. This SFWP describes key plans and strategies, which relate to the NSL, describing how Horizon will develop throughout the lifecycle of the Power Station, with greater detail given for the current and next phases of work. 4. The document is divided into lifecycle phases (as described in Section 3.1) to allow the relationship between Horizon s organisational development and the activities relating to the installation and operation of the Power Station to be described. 5. This SFWP also defines Horizon s proposed approach towards completion of a Site Licence Grant (SLG) readiness review, which is expected to inform the Office for Nuclear Regulation (ONR) decision on granting a NSL. 1.2 Summary Forward Work Plan Development 6. In common with the other documents that make up the SLA, this SFWP has been prepared in accordance with Horizon s internal processes. It has been subject to critical examination, which has included self-assessment, internal and external stakeholder review and independent assessment by Horizon s Nuclear Oversight function. Changes to the document arising from assessments and reviews have been managed in accordance with Horizon s internal processes. 7. This SFWP provides an overview only, of the activities that Horizon will undertake prior to and throughout the lifecycle of the Power Station. Full detail is provided in relevant plans and schedules of work and this SFWP summarises their intended outcomes only. Page 1 of 38

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7 2 Table of Abbreviations and Acronyms Term or Abbreviation CNC CSSP DAC DCO EPC EP-RSR FNC GDA GDA-PCSR Hitachi-GE HLW HMS IC ILW Table 2.1 Abbreviations and Acronyms Definition Civil Nuclear Constabulary Construction Site Security Plan Design Acceptance Confirmation Development Consent Order Engineering, Procurement and Construction Environmental Permit-Radioactive Substances Regulation First Nuclear Concrete Generic Design Assessment Generic Design Assessment Pre-Construction Safety Report Hitachi-GE Nuclear Energy, Ltd. High Level Waste Horizon Management System Intelligent Customer Intermediate Level Waste IRR99 Ionising Radiations Regulations 1999 JSCO LC LLI MP NB NLS NRW NSC NSL NSSP ONR Pre-NSC REPPIR SCDP Joint Safety Case Office Licence Condition Long Lead Items Management Prospectus Nuclear Baseline Nuclear Licensed Site Natural Resources Wales Nuclear Safety Committee Nuclear Site Licence Nuclear Site Security Plan Office for Nuclear Regulation Preliminary Nuclear Safety Committee Radiation (Emergency Preparedness and Public Information) Regulations 2001 Safety Case Development Plan Page 3 of 38

8 Term or Abbreviation SFWP SLA SLG SoDA UK ABWR WN-DSR WN-PCSR WN-PCmSR WN-POSR WN-SJR Definition Nuclear Site Licence - Summary Forward Work Plan Site Licence Application Site Licence Grant Statement of Design Acceptability UK Advanced Boiling Water Reactor Wylfa Newydd Decommissioning Safety Report Wylfa Newydd Pre-Construction Safety Report Wylfa Newydd Pre-Commissioning Safety Report Wylfa Newydd Pre-Operational Safety Report Wylfa Newydd Site Justification Report See the Nuclear Site Licence Application Glossary [RD1] (known as the Glossary) for full definitions of the above terms. The Glossary also contains the definitions of additional technical terms that are presented as capitalised words within this document. Page 4 of 38

9 3 Document Structure Overview 3.1 Project Lifecycle Phases 8. A series of Lifecycle Phases have been defined. Each Lifecycle Phase definition describes the activities (e.g. fuel being bought to site, or completion of Pre-Operational Testing) that will occur within that phase, and acts as a framework for developing Horizon s organisational capability (for example people and processes) and safety submissions to support commencement of these activities. These lifecycle phases (identified below) have been used to form the structure for the document, providing a means of mapping Horizon s future evolution against respective activities and lifecycle progression. Horizon s Lifecycle Phases are: Development Phase (split into Up to SLG and Up to Construction ); Construction Phase (including Construction Testing and Pre Operational Testing); Commissioning Phase (consisting of Start Up Testing); Generation Phase; and Decommissioning Phase. 9. The Lifecycle Phase is applied to the overall Power Station, with the start of each phase characterised by the most advanced activity occurring for the most developed unit on the site. 10. Horizon s intention is to build two UK Advanced Boiling Water Reactor (UK ABWRs) at the Power Station, but with different timescales. In this SFWP, where a lifecycle phase is identified, it applies to the Power Station, but uses the most advanced activity (and most developed unit) to identify the lifecycle phase i.e.: I. When a unit (and therefore site) starts commissioning activities it is expected that some construction activities may still be ongoing. As commissioning would be the most advanced activity occurring at that time, the Power Station would be designated as being in the Commissioning Phase. 3.2 Hold Points and Readiness Hold Points 11. Horizon will review its readiness to proceed with activities that are constrained by stipulated Hold Points. Hold Points are applied to activities (such as construction and commissioning activities) constraining them from proceeding until the business has demonstrably achieved readiness to do so. 12. The Hold Point is released by the appropriate releasing authority. Hold Points can occur where there is a significant change in safety risk (e.g. nuclear safety, non-nuclear safety, the environment, security etc.) or where there is foreclosure of options through carrying out an practicably irreversible activity e.g. First Nuclear Concrete 1 (FNC). 1 Defined as the pour of the structural reinforced concrete for buildings or structures with nuclear safety significance, which also represents commencement of first practicably irreversible nuclear construction. Page 5 of 38

10 13. The criteria for release of each Hold Point are documented and are primarily concerned with: plant status (material status of plant and equipment); safety justification submissions; management arrangements including procedural documentation, licence compliance, permit compliance; availability of competent persons to carry out the work; and programme maturity (progress, scheduling, commercial funding, resources etc). 14. Hold Point release will only occur when a readiness review panel is content that readiness against these expectations has been achieved. Hold Point release may also be subject to regulatory assessment and permission by the ONR may be required before Horizon can begin the specified activities. 15. Arrangements that include the principles of Hold Point control are expected to be a key part of the compliance arrangements for: LC19 Construction or installation of new plant; LC20 Modification to design of plant under construction; LC21 Commissioning; LC22 Modification or experiment on existing plant; and LC35 Decommissioning. 16. At the end of each lifecycle phase, Horizon will need to complete successfully a readiness review before starting the next phase. This is intended to provide reassurance of the suitability of Horizon to undertake the activities defined in the next phase. Successful completion of the readiness review is a prerequisite for the release of the associated Hold Point, thereby allowing transition to the next phase Readiness to be Granted a NSL 17. Horizon will apply Hold Point principles to undertake an internal review of its own readiness, in advance of the ONR s decision on granting Horizon a NSL. Horizon will inform the ONR of the outcome of the review, completion of which will be in advance of the ONR s decision to grant a NSL. Horizon will engage with the ONR to provide updates on progress with respect to completion of this process. 3.3 Work Areas 18. The activities in each lifecycle phase have been split into different work areas. This section describes the work areas and the types of activities that will be discussed Organisational Capability Governance 19. Horizon s corporate governance structure, internal management structure and governance arrangements, including those which control and manage activities which could affect safety are summarised in the Company Manual [RD2] and the Management Prospectus (MP) [RD3]. The Company Manual defines safety as nuclear safety (including radiation protection), non-nuclear health and safety, radiological environmental Page 6 of 38

11 protection, non-radiological environmental protection, security (including safeguards and export control), and quality in so far it supports the delivery of these Horizon s Organisational Structure and Capability 20. Horizon s organisational structure and capability will evolve throughout the lifecycle phases; changes will be implemented in each phase to ensure the organisation is ready to transition into the next phase. At each phase of the project lifecycle, this will include: identifying the activities, associated capabilities and attributes required across the business to enable Horizon to effectively deliver the commitments in its business plan; putting in place the right people, with the right training, supported by the right management, to develop, construct, commission, operate and maintain (and ultimately decommission) the Power Station; understanding and delivering an effective information management system that supports Horizon s current and future information and data needs; and building a fit for purpose business organisation that meets regulatory and stakeholder requirements. 21. Horizon will ensure it has the appropriate leadership and management capabilities to exercise overall control of activities that affect the safety of the Power Station. In this respect it must also meet regulatory requirements regarding sufficient independence from shareholders, partners and suppliers. 22. The following key documents describe Horizon s organisational status and are submitted as part of the SLA. I. Management Prospectus (MP) [RD3] - A MP has been produced which also forms part of the Environmental Permit-Radioactive Substances Regulation (EP-RSR) application that will be submitted to Natural Resources Wales (NRW). The MP will be kept under review and may be updated at appropriate business delivery points that are associated with major Hold Points. II. III. Nuclear Baseline (NB) - Horizon has established a NB [RD4] in support of its SLA to ensure the organisation has the correct capability in relation to nuclear safety, security, radiological environmental protection and quality in so far as it supports the delivery of these. The NB Report defines the organisation intended to be in place at SLG, based on the activities planned to be undertaken at that time. Horizon s NB will be formally updated at relevant key points to ensure that the NB requirements are fully considered, assessed and detailed and that the organisation remains competent to deliver these requirements. Company Manual (CM) [RD2] the CM outlines Horizon s corporate governance structure, internal management structure and governance arrangements, including those which control and manage activities which could affect safety. The CM will be kept under review and will be updated as required, i.e. to support appropriate significant business delivery points or when a significant policy or organisational change occurs within Horizon which requires its amendment. 23. As Horizon moves forward through the lifecycle phases, it will monitor and assess the capabilities and attributes of the organisation. Horizon will have arrangements in place to manage organisational change and monitor key performance indicators to inform decision making and organisational development. This will include vulnerability Page 7 of 38

12 assessment and resource and succession planning so as to maintain control of Organisational Capability Management Arrangements Development Management System Development 24. Horizon controls its activities through the implementation of the arrangements contained within its developing integrated management system, the Horizon Management System (HMS). The HMS is developed to support the policy framework and contains the processes, procedures and controls that Horizon requires to carry out its operations safely and efficiently. Further information on the HMS is detailed in the Management Prospectus. The HMS is designed to deliver the Plan-Do-Check-Act approach, as shown below in Figure 3.1 for the development and implementation of processes. All management arrangements are subject to periodic review to ensure continuous improvement. This includes activities such as: using competent resource to design and develop arrangements; confirming appropriate resources are in place for arrangements to be adequately managed; implementing new processes with appropriate communications and training; using trial working periods; and reviewing the effectiveness of the revised arrangements. Figure 3.1 Process development model PLAN Establish the objectives and processes necessary to deliver results in accordance with the expected output (the target or goals). DO Implement the PLAN, execute the process and generate the output. Collect data for analysis in the following CHECK and ACT steps. CHECK Study the actual results (measured and collected in the DO step) and compare against the expected results (targets or goals from the PLAN step) to ascertain any differences. Look for deviation in implementation from the plan and also look for the appropriateness and completeness of the plan to enable the execution. Convert the collected data into information. Information is required for the ACT step. Page 8 of 38

13 ACT Request corrective actions when deviations between actual and planned results are identified. Analyse the differences to determine their root causes. Determine where to apply changes that will include improvement of the process or output Licence Compliance Arrangements 25. It is anticipated that the ONR will attach 36 standard LCs to the NSL. To achieve compliance with the LC requirements, Horizon will implement arrangements that are proportionate to the Lifecycle Phase and the activities being undertaken, with additional arrangements planned that will be implemented in future phases as required. This will be achieved through the Horizon Management System (HMS), which has been developed to fulfil Horizon s business requirements including (but not limited to) LC compliance. 26. The NSL Compliance Matrix [RD5] provides a route map to Horizon s arrangements that fulfil the requirements of the current LCs. This will be maintained to ensure that there is always a current description of Horizon s arrangements for LC compliance. The Compliance Matrix will be supported by an appropriate management system build schedule describing the work required to be completed following SLA. 27. Before each Lifecycle Phase, the Compliance Matrix will be reviewed and updated to take into account the changes that have occurred. This review will also include consideration of the suitability of assigned LC owners to ensure they are appropriate for the next phase. 28. The plans described within this document are based on the current set of standard ONR LCs. Any amendment or change to these LCs will need to be reviewed to understand the impact of the change, and may result in a change in the plans described within this document Safety Cases 29. Safety Case submissions will be made to the ONR throughout the lifecycle of the Power Station. This SFWP identifies the main Safety Case submissions and key Safety Case activities required (where known) within each Lifecycle Phase as described in more detail within the Safety Case Development Plan (SCDP) [RD6] Safety Case Development Plan 30. The SCDP included in the SLA presents a high level plan for the development of the site-specific Safety Case for the Power Station. It provides a plan to develop from the Generic Design Assessment (GDA) Pre-Construction Safety Report (PCSR) (GDA-PCSR) to the full site-specific Wylfa Newydd (WN) PCSR (WN-PCSR), to support construction activities, and additional Safety Case submissions to release Hold Points which require regulatory permission for construction, commissioning and operations. 31. The purpose of the SCDP is to facilitate, enable, schedule and communicate the timely production and delivery of fit-for-purpose Safety Case documentation, safety submissions and Safety Reports to support every key stage of the project and to allow the Project to progress. 32. Furthermore, the SCDP will: identify all key Safety Cases required to support the proposed NLS as currently envisaged for the purposes of construction, commissioning and operation, with appropriate consideration of the logic and plan for production of documentation; seek to address the particular requirements presented by procurement of Long Lead Items (LLI) before completion of the WN-PCSR; Page 9 of 38

14 give visibility of the activities required to support the timely development of the proposed NLS Safety Case documentation to all key stakeholders, e.g. Horizon, Hitachi-GE Nuclear Energy, Ltd. (Hitachi-GE), the ONR, the Environment Agency and NRW; and identify the key activities and milestones linked to the development of Safety Cases Other Obligations 33. This section details other forward work that relates to ensuring NSL compliance, nuclear safety and or security. Typical topics that are considered (for which further information and background is available in the SLA package) are listed below. I. Emergency preparedness - ensuring appropriate arrangements for emergency preparedness are in place and are informed by an understanding of the hazards and risks posed by the work and the Power Station. II. III. Security arrangements - to ensure proportionate and effective measures are in place to manage all relevant aspects of security, specific to applying for and maintaining a NSL. Nuclear Safeguards - which are measures to verify that countries comply with their international obligations not to use Nuclear Material from their civil nuclear programmes for unauthorised purposes. Page 10 of 38

15 4 Status at the Point of Application 4.1 Activities 35. At the time of application Horizon is undertaking activities that may have an impact on nuclear safety. Consequently, defined organisational capabilities have been established (described in Sections 4.2 and 4.3) to adequately complete and oversee: activities at the proposed NLS, such as site characterisation (archaeological and geological investigations), site clearance, including demolition and removal of existing buildings; design control activities, such as specification of requirements, completion of design reviews, and design acceptance and the establishment of configuration control; preparation for completing the order of the first material fabrication for LLIs; development of the Wylfa Newydd Site Justification Report (WN-SJR) and the WN-PCSR; commencement of sentencing of GDA assessment findings and GDA adoption; development of arrangements for control and oversight of the EPC contractor; and development of arrangements, capabilities and attributes required to undertake the above and to accept the obligations of being a NSL organisation. 4.2 Organisational Capability 36. Horizon has made significant progress to develop the organisation and to implement plans for continued development. The MP, NB and Company Manual all provide a holistic view of the progress made, a summary of which is provided below. I. Horizon is a private limited company, registered in England and Wales. II. III. IV. Horizon has an appropriate organisational structure. A Preliminary Nuclear Safety Committee (Pre-NSC) has been set up, which precedes the establishment of the formal NSC as required by LC13. SLG NB post and role profiles are defined, with arrangements for the completion of competency assessments implemented. V. SLG NB is defined and justified, with an associated resource plan to populate posts with competent persons in advance of SLG. VI. VII. VIII. IX. Management of NB change arrangements are in place. Intelligent Customer (IC) capability arrangements have started to be put in place, and continue to be developed and implemented. Arrangements to deliver the Systematic Approach to Training are in place. A Design Authority has been established. X. A Nuclear Oversight function has been established. XI. XII. An operating partner programme is being developed, to support Horizon s growth in capability towards commercial operations. A culture strategy is being developed to take account of organisational responsibilities, obligations and duties, and to create the landscape for continuous improvement through collaboration and learning. Page 11 of 38

16 4.3 Management Arrangement Development 37. Before submission of the SLA, Horizon made significant progress to develop an integrated management system, the HMS, and to implement plans for its continual improvement. At the point of application the HMS is controlled and used by Horizon Nuclear Power Wylfa Limited and is also used across the Horizon Group. The HMS is certified to a number of International Organization for Standardization standards, as detailed in the Management Prospectus. 38. This phase has focussed on development and implementation of arrangements for compliance with those LCs where proportionate, compliant arrangements are required to be in place at, or around, the point of SLA, namely LC1, LC3, LC4, LC6, LC7, LC9, LC10, LC11, LC12, LC13, LC14, LC17, LC19 [initial arrangements], LC20 and LC The following sub-sections describe the key management arrangements implemented to oversee the activities described in Section Licensee Obligations 40. Horizon has developed and implemented the following arrangements in preparation for submission of the SLA, and in readiness for ONR assessment to ensure that Horizon has the capability to accept its Licensee obligations at the time of SLG: established policies to prescribe the required outcomes and acceptable behaviours that apply across Horizon; established initial governance processes that will develop over the period up to SLG; a Pre-NSC, operating to Pre-NSC Terms of Reference. Terms of Reference have been submitted for the NSC, which will come into force after SLG; ensuring that all property transactions are conducted so that Horizon remains in control of the NLS; a prohibition on Nuclear Matter on the NLS; ensuring that emergency arrangements are appropriate to the hazards and risk associated with activities being undertaken (which reflects no nuclear hazard on the site); and procedures for managing documents, records, authorities and certificates, although using interim electronic and physical storage arrangements. 41. Additionally Horizon has developed arrangements for meeting a priority set of LCs, that provide a framework for ensuring the control of activities that may affect safety, i.e.: arrangements to provide a methodology for conducting training and providing instruction. This structured approach provides a way in which training requirements are related directly to roles and job performance so that training delivery meets organisational and personal needs, as well as addressing potential performance deficiencies; arrangements to manage Competency, including the Competency assessment, to ensure that only competent persons perform any duties that may affect safety; the HMS, which includes arrangements for matters that may affect safety. A Management System Manual, describing the status and approach of the HMS, has been developed; Page 12 of 38

17 the NB which demonstrates adequate resource is available for the activities being undertaken; the NB from which organisational changes, that may affect safety, can be assessed and formally controlled; and ongoing development of arrangements to manage and control Hold Points Management of Site Activities 42. To safely manage/oversee activities (including consideration of non-nuclear safety hazards) at the proposed NLS, Horizon has developed and implemented arrangements for: providing warning notices where applicable and ensuring that persons authorised to be on the site receive instructions addressing risks and operational hazards, precautions and actions to be taken in the event of an accident or emergency; and notifying, recording, investigating and reporting of incidents to the ONR and NRW. This will include possible breaches in LCs and any significant adverse environmental effects Design and Safety Submissions Management 43. To support development of the WN-PCSR, Horizon have developed arrangements for: providing documented Safety Cases. These arrangements include preparation, production, review and approval; and control of all modifications to the design of the plant Long Lead Items 44. Horizon entered into a deed with the ONR in November 2014 which included an obligation to act as though it was already a Licensee with respect to procurement of LLIs in advance of being granted a NSL. The following provisions evidence Horizon s capability to achieve this. In preparation for procurement of material required for LLIs, Horizon has developed and implemented the following arrangements: maintaining an IC capability for goods, works and services delivered on its behalf by suppliers; evaluating the organisational and technical capability of suppliers; conducting effective oversight and assurance of the supply chain, including acceptance of items or services for work with nuclear safety significance; mitigating the risks of counterfeit, fraudulent and suspect items; and capturing supply chain operational experience. 45. In addition, Horizon arranged for an Independent Certification Body to complete an assessment of Horizon and its Management System, to verify that Horizon understands its Quality Assurance responsibilities, especially those regarding items or services significant to nuclear safety. This assessment culminated in the Independent Certification Body issuing Horizon with a Licensee Certificate. 4.4 Safety Cases 46. A Joint Safety Case Office (JSCO) has been established as a collaboration between Horizon and Hitachi-GE, the reactor technology provider to support GDA. The JSCO Page 13 of 38

18 supports production of the GDA-PCSR. Toward the end of GDA the JSCO arrangements may be reviewed to ensure the suitability for the production of the WN-PCSR and beyond (preserving good practices and collaborative working). 47. The UK ABWR is currently undergoing GDA, with the design and Safety Case submitted to the ONR and the Environment Agency by Hitachi-GE. As part of the GDA process, Hitachi-GE as the Requesting Party has produced a GDA-PCSR. The GDA-PCSR has been through a number of revisions linked to the phased GDA process. Hitachi-GE has now completed GDA Step 3, which was supported by GDA-PCSR Revision B. Following GDA Step 3, a Design Reference Point was established to provide a baseline position from which changes can be controlled and managed. GDA Step 4 is underway and is scheduled to be completed at the end of The JSCO is developing the specification for the chapters that will make up the WN- PCSR, which will be based on relevant parts of the GDA-PCSR with additional sitespecific information. 49. There is high level of confidence that a compelling Safety Case can be made to support the full lifecycle of a power station comprising two UK ABWRs at the proposed NLS. 50. The risks identified through a robust assessment of the Lifecycle Phases are highly likely to be demonstrated to be controlled and maintained to be As Low As Reasonably Practicable. 51. While there is much work to do, no issues have been identified that preclude the construction of a power station comprising two UK ABWRs at the proposed NLS. 4.5 Other Obligations 52. Other obligations at the point of SLA are listed below. I. Horizon s emergency arrangements at this point cover events such as a fire in the Wylfa Newydd site office, first aid emergencies and response to incidents at the adjacent power station owned by Magnox Limited (referred to as the Existing Power Station). Horizon s emergency preparedness will be reviewed and updated whenever an increase or decrease to the level of hazard or risk is identified. II. III. Horizon has an approved Construction Site Security Plan (CSSP), which will be in place until SLG when it will be superseded by the Nuclear Site Security Plan (NSSP). Horizon will implement Nuclear Safeguards arrangements before Nuclear Fuel is brought to the NLS for the Commissioning Phase, however engagement with the ONR and the European Commission has already commenced to ensure Horizon can meet the UK s obligations. Page 14 of 38

19 5 Development Phase (up to Site Licence Grant) 53. Horizon is currently in the first part of the Development Phase, which covers the period up to SLG. Horizon continues to evolve and develop to ensure it is ready to become a Licensee upon granting of the NSL. 54. Objectives during this phase are: for the organisation to mature the capability to become a Licensee and achieve SLG, which will include the completion of a period of demonstration working; the specification and engagement of Operating Partners and training service providers; development of capabilities to oversee the completion of nuclear construction activities in preparation for starting the Construction Phase; to continue design control activities, such as specification of requirements, completion of design reviews and design acceptance, and the establishment of configuration control; to complete the WN-SJR and to continue production of the WN-PCSR; to continue sentencing GDA assessment findings and preparation for GDA adoption; to progress the development of arrangements for control and oversight of the EPC contractor; to complete first material order of LLIs, in addition to commencement of first LLI fabrication; to continue to undertake activities at site, such as the continuation of site characterisation (archaeological and geological investigations) and commencement of site preparation and clearance; and to continue to develop security arrangements, including development of the NSSP. 5.1 Organisational Capability 55. As Horizon s activities progress, arrangements will be further developed between Horizon and its holding company to clarify the boundaries of control and decision making. This is to ensure that Horizon maintains the necessary control to meet its responsibilities for its changing regulated activities and is able to carry out its duties (as a Licensee and Permit Holder) with appropriate autonomy from the holding company and the ultimate owner. 56. Horizon needs to be ready to oversee nuclear construction activities in preparation for the Construction Phase. To support this, Horizon has developed plans to maintain suitable and sufficient resource (which consider capability for oversight of the EPC contractor, preparation of the NLS and development of infrastructure to support construction). 57. During this phase Horizon will continue to recruit and train staff to ensure suitable and sufficient capability is in place to be granted a NSL and subsequently begin nuclear construction. 58. During this phase, Horizon plans to: grow the organisation in accordance with the defined SLG NB and in accordance with the management of change arrangements, specifically focussing on the areas of Page 15 of 38

20 operations, construction and technical (including Design Authority) operational units, including populating the defined SLG NB with competent resource; expand its capabilities as an IC, in particular the ability to oversee and control supply chain activities in relation to the EPC, owners scope and programme development sub-programmes; continue development of supporting partnerships to provide appropriate management/governance of major sub-programmes; develop the capability for construction supervision; develop the capability for control of access to site; develop Knowledge Management capability; continue to develop and implement the roll-out a safety culture improvement training and awareness programme; continue to develop its arrangements for decision making; and continue to develop its arrangements for learning from experience. 59. Horizon currently uses a combination of: employees provided by Horizon Nuclear Power Services Limited (Horizon Services), secondees and contractors supplied either directly to Horizon or via Horizon Services. Where resources are provided by Horizon Services the arrangements are being reviewed at the point of Application to ensure that Horizon s control of those resources is adequate and appropriate to the activities being undertaken, with any necessary changes identified being implemented prior to, and in order to support, the grant of the NSL. 60. Horizon will continue to complete a vulnerability analysis of the SLG NB organisation. As part of the ongoing review and monitoring of the suitability of the NB, and its periodic review, a review of the NB will be completed to support SLG. Page 16 of 38

21 5.2 Management Arrangement Development 61. This phase will continue to see development of Horizon s management arrangements to support the development of the HMS. In particular Horizon will develop and or update (as appropriate) the arrangements described in Section 4.3, which will be reviewed in the light of Horizon s experience and feedback during the SLA assessment period. 62. As part of the development plan for the management system, and to support the evolution (including architecture) as Horizon progresses through the Project, during this phase it is planned to complete improvements to the user interface, the document hierarchy and arrangements for governance of the management system. These changes are aimed at continual improvement of the efficiency and effectiveness of the process driven management system. 63. In accordance with the phased approach to development of compliance arrangements, this phase will focus on development of, and update of existing arrangements where available, for compliance with the LC2, LC8, LC16 and in particular further development of LC19 in preparation for nuclear construction activities. 64. During this phase Horizon will undertake a period of demonstration working, devised to show Horizon is able to use, test and improve documented arrangements. Demonstration working is a period spent working to the arrangements required to be granted a NSL, which will include completing self and independent assessments of the effectiveness of such arrangements. This activity is intended to demonstrate Horizon s ability to be a capable Licensee. Furthermore sufficient time allowance will need to be provided to allow the ONR to adequately assess and scrutinise the suitability of the management system during this phase prior to SLG. 65. Before the end of this stage of the Development Phase the arrangements described in the following sub-sections will be developed and/or updated Licensee Obligations 66. In readiness for being granted a NSL, as well as further development of arrangements previously outlined, Horizon will develop and implement arrangements for: managing the receipt and processing of Licence Instruments received from the ONR; arrangements for marking the site boundary, taking account of an anticipated exclusion application from the LC2 requirement to physically mark the NLS boundary from SLG through the Construction Phase; generating and maintaining a Site Plan, which indicates buildings and plant on the NLS that may affect safety, including buildings containing radiological and non-radiological hazards. During this phase a plant and buildings schedule will be provided to the ONR. The arrangements will also include configuration control to enable changes to buildings, plant or operations on the NLS to be reflected in the Site Plan and Plant and Buildings Schedule; and creating and maintaining a register of high activity sealed sources in accordance with the Ionising Radiations Regulations 1999 (IRR99). 67. Horizon will formally apply to the ONR for the exclusion of LC2(4) (which relates to the requirement to physically mark the NLS boundary) to the NSL that is granted to Horizon. It is considered impracticable and potentially unsafe to physically mark and maintain the NLS boundary during the Development Phase and earlier part of the Construction Phase, due to the significant earthworks and deep excavations that are anticipated to occur on Page 17 of 38

22 and around the site during those times. Horizon plans to ensure the NLS boundary is physically marked by appropriate means before pouring nuclear safety-related concrete for construction of unit 2 of the Power Station (following completion of earthworks, deep excavations and creation of the unit 2 platform). Horizon therefore anticipates that the LC2(4) exclusion will only apply until that point in time Construction Oversight and Site Management Arrangements 68. The extent and significance of activities will increase during this phase. To ensure site safety, Horizon will develop or update arrangements for: providing warning notices where applicable and ensuring that persons authorised to be on the site receive instructions addressing risks and operational hazards, precautions and actions to be taken in the event of an accident or emergency. Sufficient warning notices will be located in appropriate locations to inform people of: the meaning of warning signals; location of exits in the event of an emergency; and measures to be taken in the event of fire. preventing unauthorised access (for the purposes of compliance with the Construction (Design and Management) Regulations 2015) and for identifying the location of the NLS (noting appropriate signage will be erected at site access points identifying the location of the NLS at the point of SLG); and preventing Nuclear Matter being brought onto the proposed NLS Contracts Oversight 69. Horizon intends to enter into a Engineering, Procurement and Construction contract(s) (the EPC Contract) with an EPC contractor for the design, procurement, manufacture, supply, construction, installation, commissioning, testing, handover and defect rectification of a fully equipped and fully functioning Power Station. During this part of the Development Phase, Horizon will develop its requirements to set out its business, regulatory and legislative requirements for incorporation into the EPC s bespoke processes, procedures and systems for delivering the Project. Horizon will continue to develop its own management arrangements to manage these interfaces and to ensure appropriate oversight and management arrangements of the EPC contract are in place. Further details are provided in the MP. 70. Additional resource will be provided via the supply chain and may include project management expertise and an Owner s Engineer capability. 71. Horizon has identified the need to be able to procure works and services from the EPC Contractor in advance of the formal placing of the EPC Contract. This will be managed through an Early Contractor Engagement contract with the EPC Contractor. Further details are included in the MP Site Preparation 72. To prepare the proposed NLS for provision to the EPC contractor, site investigations (including excavations) and geophysics work will be carried out during this phase. In common with many other large civil construction projects, sealed radioactive sources will be used for ground investigation work and other testing. The use of such radioactive sources will be managed in accordance with the IRR99. Page 18 of 38

23 73. As a prudent and precautionary measure, arrangements will also be in place to monitor and manage any historic radiological contamination that might be found during these excavations and investigations, although there is no evidence to suggest that this is likely. This could potentially include contaminated ground water, contaminated land or radioactive items. 74. All work with any such discovered Radioactive Wastes or Radioactive Materials will be managed in accordance with the Environmental Permitting (England and Wales) Regulations 2010 and the IRR99. Any findings of radioactive contamination will be reported to NRW and to the extent relevant, the ONR and the holder of the Magnox Limited NSL. Following SLG (see Section 6), arrangements for dealing with such matters will be in accordance with the relevant LCs and the EP-RSR. 5.3 Safety Cases 75. During this phase it is expected that the GDA of the UK ABWR will complete, culminating in the issue of a Design Acceptance Confirmation (DAC) from the ONR and a Statement of Design Acceptability (SoDA) from the Environment Agency. On GDA completion, the site-specific Design Reference Point will be updated to incorporate design changes resulting from the resolution of assessment findings provided with the issue of the DAC and SoDA. Resolution of assessment findings will be split into two stages; those that need to be resolved before FNC as part of the WN-PCSR, and those that will be addressed later in the Construction and Commissioning Phases. Details of the key sitespecific topics required to supplement the GDA-PCSR are given in the SCDP. 76. Horizon will produce a WN-SJR in sufficient time for the ONR to complete assessment prior to SLG. The contents of the WN-SJR, which will provide justification of the adequacy of the proposed NLS to support two ABWRs, are detailed in the SCDP. 77. There will be numerous safety related items that will require many months/years to procure and manufacture. To prevent delays to construction, such LLIs may need to be procured before completion of the WN-PCSR. The SCDP discusses the nuclear safety aspects relating to procurement of LLIs. 78. The claims and arguments relevant to each LLI (or group of LLIs) will be collated and presented as an interim Safety Case in the form of a LLI Safety Pack (LLISP). Each LLISP will be prepared and owned by Horizon, using information provided by Hitachi-GE. 79. Safety justifications for LLIs have started to be developed. The LLISPs are intended to be superseded by the WN-PCSR once this is issued for ONR assessment. 80. In accordance with LC20, Horizon will implement configuration management arrangements to manage and control design changes from the baseline design. These arrangements will develop and change throughout the lifecycle of the Power Station. 5.4 Other Obligations 81. Other obligations during the first part of the Development Phase (Up to SLG) are listed below. I. Arrangements for dealing with emergencies will continue be developed during this phase, taking note of interactions with the Existing Power Station. An emergency preparedness strategy has been produced, which describes the development path through the various lifecycle phases culminating in the full arrangements for an operating reactor site. Page 19 of 38

24 II. Following SLA, the NSSP will be further developed and approved by the ONR. At SLG the CSSP will be superseded by the NSSP. III. Horizon will start to develop Nuclear Safeguards arrangements to allow Nuclear Material accountancy to be carried out once Nuclear Fuel is brought on to the NLS. Further details can be found in the Overview Document [RD7]. IV. Horizon s Funded Decommissioning Programme will be submitted during this phase. This must be approved by the Secretary of State for Business, Energy and Industrial Strategy and be in place before FNC. Horizon will make an application to the Planning Inspectorate for a Development Consent Order (DCO) for the new Power Station. Further details may be found in [RD7]. V. Horizon will make an application to NRW for an EP-RSR to dispose of Radioactive Waste, including liquid and gaseous discharges. VI. The Article 37 Submission for the construction of two UK ABWRs and associated facilities including storage facilities for Spent Fuel, High Level Waste (HLW) and Intermediate Level Waste (ILW) will be presented for consideration to the Secretary of State for Business, Energy and Industrial Strategy (as the competent body representing the UK) prior to its submission to the European Commission on behalf of the Secretary of State. VII. Horizon has secure tenure over all the land within the NSL boundary. The northern half of the site is leased to Horizon by the Nuclear Decommissioning Authority for 999 years from 2011 (leasehold ownership) and the southern half is owned (freehold ownership) by Horizon. At present, however, Horizon does not have exclusive possession of this land. A number of title issues need to be addressed before Horizon can be in full control of the land. These include the use of the highway across the site by third parties and rights of third parties such as those to run cables and pipelines across the land. The restrictions are understood fully by Horizon and are actively being addressed. It is anticipated that the majority will be resolved by voluntary agreements before SLG, with the remaining restrictions being dealt with through the DCO. For example, Horizon s DCO application will request that the DCO includes provisions which will permanently close the highway that currently divides the site. It is anticipated that all restrictions will be removed from the titles approximately six months after DCO grant. Small parcels of unregistered land are currently excluded from the title. These are considered to result from historical conveyancing discrepancies and Horizon will request that these be remedied via compulsory purchase provisions to be included in the DCO. Page 20 of 38

25 6 Development Phase (after SLG and up to Construction) 82. This section describes the activities that will occur during the second part of the Development Phase, after the NSL has been granted by the ONR, but before the start of the Construction Phase. 83. A positive Final Investment Decision is anticipated during this phase. This will be followed by a corresponding increase in the rate of development, in preparation for construction. 84. Objectives during this phase are: for the organisation to continue to develop the capability to oversee the completion of nuclear construction activities in preparation for the Construction Phase; to continue to oversee procurement of material and fabrication of LLIs (which is expected to include the commencement of factory acceptance testing), and to commence preparation for acceptance, receipt and storage of the first LLI; to continue design control activities, such as specification of requirements, completion of design reviews and design acceptance, and the establishment of configuration control; to complete production of the WN-PCSR; to complete sentencing of GDA assessment findings and GDA adoption; to continue to control and oversee the EPC contractor; continued preparation of the NLS for provision to the EPC contractor; and continued development of security arrangements commensurate with the development of the NLS. 85. At the end of this phase, the Hold Point that will enable commencement of the Construction Phase is expected to be permission for FNC. This Hold Point is also expected to require regulatory permission. 6.1 Organisational Capability 86. As described in Section 5.1, Horizon will continue to develop the capability to be ready to oversee nuclear construction activities in preparation for starting the Construction Phase. 87. Horizon will continue to recruit and train staff to ensure suitable and sufficient capability is in place for the Construction Phase. This will include activities to: continue to strengthen key capabilities associated with construction, Human Resources, supply chain and procurement, safety, contract and claims management and resilience (emergency planning). 88. In preparation for the Construction Phase, Horizon s activities will include: development of Organisational Capability with respect to the oversight and control of construction activities. Page 21 of 38

26 6.2 Management Arrangement Development 89. Proportionate, compliant arrangements will continue to be reviewed, improved, developed, implemented and tested, in order to develop capability to control and oversee nuclear construction activity. Arrangements for LC19 in particular will continue to develop during this phase. 90. In accordance with the phased approach to development of compliance arrangements, this phase will include development of, and update of existing arrangements where available, for compliance with LC14 in preparation for nuclear construction activities. 91. The Management System Manual and Compliance Matrix will be reviewed and updated before starting the Construction Phase to take account of changes that occurred during this second part of the Development Phase. This review will also consider the assigned LC owners to ensure suitability for the next phase. 92. In accordance with the defined LCs above, before the end of the Development Phase Horizon will continue preparation, production, review and approval of Safety Cases. 6.3 Safety Cases 93. The Safety Case activities in the Development Phase focus on submission of the WN-PCSR in support of FNC. Construction planning, among other tasks, entails identification of hazards (non-nuclear and nuclear) and development of the most efficient construction sequence whilst maintaining safe working conditions and quality standards. During this phase therefore, the WN-PCSR will be submitted to the ONR seeking formal regulatory permission to start nuclear construction activities. 6.4 Other Obligations 94. Other obligations during the second part of the Development Phase are listed below. I. Arrangements for emergency preparedness will continue to evolve in accordance with the emergency preparedness strategy. It is anticipated that the level of hazard and risk from the Existing Power Station will reduce as Magnox Limited, the operator of the Existing Power Station, progresses decommissioning activities. II. III. IV. Following SLG, the NSSP will replace the CSSP and will be reviewed periodically, including reviews to consider its suitability for the next Lifecycle Phase. Full control of the land including security of tenure will be achieved once the issues discussed in Section 5.4 have been addressed following the granting of the DCO. The full construction site fence (in preparation for nuclear construction activities) will be installed, which will also enable full access control arrangements for the construction site to be established. Page 22 of 38

27 7 Construction Phase 95. The Construction Phase encompasses the start of nuclear safety related construction and covers the period up to the start of the Commissioning Phase. Horizon will oversee the EPC contractor which will construct the Power Station. The NLS will see significant change during this phase as the Power Station is constructed. 96. Objectives during this phase are: to oversee the EPC contractor during nuclear safety related construction activities; to deliver the Power Station up to the start of the Commissioning Phase; to oversee the completion of the first two stages of commissioning, Construction Testing and Pre Operational Testing; for the organisation to develop the Capability for the oversight and completion of commissioning activities that will be carried out in the next phase; and to make preparations to bring Nuclear Fuel to the Power Station for the first time. 97. At the end of this phase, the Hold Point that will enable transition to the Commissioning Phase is expected to be approval to bring Nuclear Fuel onto the NLS for Start Up Testing, which is also expected to require regulatory permission. 7.1 Organisational Capability 98. Horizon will continue to recruit and train staff to ensure the capability exists to oversee and manage major sub-programmes including the EPC contract. Forward planning activities will include development and training of operations staff in preparation for the Commissioning Phase. 99. During this Construction Phase, Horizon will focus on building the capabilities to successfully commission and start up the plant In preparation for the Commissioning Phase, Horizon s activities will include development/implementation of: organisational capability in line with the resource acquisition plans for the oversight and completion of commissioning activities in preparation for the Commissioning Phase and eventual Generation Phase together with the site security organisation in preparation for bringing Nuclear Fuel to the NLS; training and competence for operational Capability; IC Capability to oversee the equipment maintenance supply chain; and arrangements to manage Nuclear Fuel procurement, accounting, transport, assembly, monitoring and waste It is planned that during this phase Horizon will have a full scope simulator in order to support operator training. 7.2 Management Arrangement Development 102. Proportionate arrangements that deliver LC compliance will continue to be developed implemented and tested in order to develop capability to control, oversee and undertake commissioning activities. Page 23 of 38

28 103. In accordance with the phased and proportionate approach to development of compliance arrangements, this phase will focus on developing and where available, updating existing arrangements for compliance with LC4, LC5, LC11, LC12, LC18, LC21, LC23, LC24, LC25, LC26, LC27, LC28, LC29, LC30, LC31, LC32, LC33 and LC34 in preparation for the start of commissioning activities. However, some of these arrangements are not required until Nuclear Fuel arrives on the NLS and the timescales will reflect that, with development of such arrangements potentially starting at a later point during the Construction Phase The arrangements for compliance with these LCs will be developed and or updated and implemented in advance of Horizon commencing the Commissioning Phase In accordance with the defined LCs above, before the end of the Construction Phase the arrangements described in the following sub-sections will be developed and/or updated Preparation for Commissioning 106. A significant focus of this phase will be to develop commissioning arrangements to support development of the capability to oversee, control and undertake commissioning activities. These will include arrangements for: commissioning the plant; ensuring that full and accurate records are kept of the results of every commissioning test and operation; ensuring that all operations are carried out in accordance with written operating instructions. The arrangements will ensure that operating instructions provide clear direction and guidance for the operating staff to enable safe operation of the plant; ensuring that adequate records are made of the operation, inspection and maintenance of any plant which may affect safety. In addition ensuring records will be produced and maintained to accurately record the amount and location of all Radioactive Material (including sources, Nuclear Fuel and waste) on the NLS at any one time; develop arrangements for production of operating rules that will contain the conditions and limits supporting safe operation. Horizon will also implement arrangements to ensure all operations are carried out in compliance with these defined operating rules; ensuring that the plant is not operated, inspected, maintained or tested unless suitable and sufficient safety mechanisms, devices and circuits are properly connected and in good working order; to prepare and implement a maintenance and surveillance programme that will plan, control and carry out regular and systematic examination, inspection, maintenance and testing on all identified safety related plant; ensuring that, when necessary for the purposes of enabling examination, inspection, maintenance and testing, the plant and/or processes are shutdown in accordance with the requirements of plant maintenance schedules and technical specifications; and ensuring safe shutdown of a specified plant, operation or process if directed by the ONR Additionally existing arrangements for management of Competency will be updated, including those: Page 24 of 38

29 so that competent persons are appointed to control and supervise all operations that may affect safety; for appointing suitably qualified persons to control, witness, record and assess the results of commissioning tests. The arrangements will also require that such persons are trained and competent to provide this role; and in preparation for Duly Authorised Persons who will be in place prior to Start Up Testing The emergency arrangements for compliance with LC11 (Emergency Arrangements) will be updated before the Commissioning Phase as the hazards present on the NLS will increase in both number and potential severity during the next phase Nuclear Matter and Nuclear Fuel on the NLS 109. To prepare for receipt of Nuclear Fuel, Horizon will: implement new arrangements for the management of Nuclear Fuel to enable Horizon to bring Nuclear Fuel on to the NLS for use in Start Up Testing and on-going operation of the Power Station; update control of Nuclear Matter arrangements, to include arrangements for the receipt, handling and storage of Nuclear Matter on the NLS; ensure that activities that produce Radioactive Waste are identified and that the rate of production and total quantity accumulated is minimised by design and by operational procedures. Any Radioactive Waste produced during the Commissioning Phase will be managed in line with the NLS arrangements. This will ensure compliance with both the LCs and the EP-RSR conditions and where applicable, the DCO and the IRR99; ensure records are kept of all Nuclear Matter consigned from the NLS; and extend and update existing arrangements that allowed sealed radioactive sources to be transferred onto the NLS for Non-Destructive Testing during the Construction Phase, to allow other Nuclear Matter to be brought onto the NLS for commissioning and later operation. 7.3 Safety Cases 110. The principal Safety Case activity in the Construction Phase will be the development of the Wylfa Newydd Pre-Commissioning Safety Report (WN-PCmSR). This will cover inactive and active commissioning (termed Pre Operational Testing and Start Up Testing respectively within Horizon). Upon completion of Pre Operational Testing, the WN- PCmSR will be supplemented with commissioning reports The key topics that the commissioning reports will cover are: outcome of the Pre Operational Testing and on-going fitness for purpose of the inactively commissioned facility; demonstration that the Start Up Testing can be carried out safely, with the commissioning schedule and operating procedures defined; and demonstration that there are no aspects of safety that remain to be demonstrated The key activities to develop a credible WN-PCmSR will be to demonstrate the suitability of the as-built facility and to have sufficiently mature information to enable production of Page 25 of 38

30 the commissioning schedules and activities. Further information on the WN-PCmSR is detailed in the SCDP The Safety Case will need to consider the hazards presented to the construction of the second unit by ongoing activities on the first unit and on other nuclear facilities on the NLS. (These ongoing activities might include commissioning, power operation, or outage of the lead unit, dependent on the overall schedule for development of the Power Station). Additionally, hazards presented by construction of the second unit will need to be considered in relation to ongoing activities on the first unit and to other nuclear facilities on the NLS The clearance of Hold Points and regulatory permission for work to proceed may require additional safety submissions to support the site-specific Safety Case. This will be considered on a case by case basis. 7.4 Other Obligations 115. Other obligations during the Construction Phase are listed below. I. The strategy for emergency preparedness lays out the development path for emergency arrangements during the Construction Phase. During this period, the emphasis will be on non-nuclear emergencies as there will be no potential radiation hazard on the NLS and the Existing Power Station is planned to have removed all fissile material; therefore there can be no reasonably foreseeable radiation emergency. II. Prior to the ONR granting regulatory permission to bring Nuclear Fuel to the NLS for Start Up Testing, there will need to be adequate arrangements to deal with radiation emergencies including on-site plans under LC11 and the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) and off-site plans under REPPIR. These plans for full operational emergency arrangements will need to have been approved and demonstrated (including demonstration of suitability of facilities, equipment and resources), including formal demonstrations to the ONR involving the local authority response plan. Horizon will contribute appropriate information for the ONR s assessment, which will determine the extent of the off-site emergency planning area. Horizon will assist Isle of Anglesey County Council to produce an off-site emergency plan. Within the off-site emergency planning area, Horizon and the local authority will work together to implement arrangements for protecting the public and the environment. Arrangements will be periodically reviewed and amendments made as necessary. III. At a time agreed with the ONR, including with respect to ending the proposed LC2(4) exclusion, suitable enduring security fences will be erected around the NLS to control access and egress and mark the NLS boundary. Once construction of the Power Station is complete, the construction site compound fence will no longer be relied upon to provide security to the NLS. Horizon will demonstrate the operational adequacy of the NSSP and installed security measures as agreed with ONR Civil Nuclear Security. IV. During the installation of utilities, provision will be made for Nuclear Safeguard s surveillance equipment. Horizon will ensure the required services are present to provide power supplies and communication links. Horizon will establish organisational capability (including implementation of arrangements for Nuclear Material accountancy) to deliver Nuclear Safeguards obligations in advance of receipt of Nuclear Fuel, including reporting and materials accountancy. Page 26 of 38

31 V. In addition to Horizon s Security Officers, the Civil Nuclear Constabulary (CNC) will have a presence on NLS from a time agreed under the principles of the NSSP and as agreed with ONR Civil Nuclear Security and CNC. Page 27 of 38

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33 8 Commissioning Phase 116. This Lifecycle Phase relates to commissioning the Power Station. The phase starts with the first receipt of Nuclear Fuel onto the NLS, and includes the completion of the final stage of commissioning, which is Start Up Testing. The previous two commissioning stages (Construction Testing and Pre Operational Testing) are both undertaken during the Construction Phase and overseen by Horizon Objectives during this phase are primarily: to receive Nuclear Fuel on the NLS for the first time, to enable Start Up Testing activities; to complete Start Up Testing; completion of the Wylfa Newydd Pre-Operational Safety Report (WN-POSR); and for the organisation to develop the capability for the operation of the Power Station in preparation for the Generation Phase Horizon will need to complete successfully a readiness review before commencement of Normal Operations. This is intended to provide reassurance of the suitability of Horizon to start the Generation Phase. A further Hold Point in this phase is expected to be commencement of Start-Up Testing (which is currently planned to include the activities of fuel load and first criticality), which is also currently expected to require regulatory permission. 8.1 Organisational Capability 119. During this phase, Horizon will maintain appropriate staff levels and training to complete the management and oversight of the EPC contract and to operate the plant during commissioning. Forward planning activities will include continued development and training of operations staff in preparation for the Operating Phase The enduring organisation will largely be in place Activities during this phase will relate to: building an operational team that will be in place at the end of commissioning; developing an emergency response capability for the full scope of emergencies before first receipt of Nuclear Fuel; ensuring the workforce are suitably trained and qualified to hold their specific posts and establishing a programme of continuous training and development; assessment of competencies and closure of any gaps in preparation for the Generation Phase; preparation for handover of responsibilities from the EPC joint venture to Horizon; and developing supply chain capability for outages. 8.2 Management Arrangement development 122. Proportionate, compliant arrangements will continue to be developed, implemented and tested to develop capability to operate the Power Station. This will include review and development of existing operational arrangements in the light of commissioning experience. Page 29 of 38

34 123. In accordance with the phased approach to development of compliance arrangements, this phase will focus on development of, and update of existing arrangements, for compliance with LC22 in preparation for the Generation Phase The arrangements for LC compliance will have been developed/updated and implemented in advance of Horizon starting each part of commissioning In preparation for the Generation Phase, this phase will focus on finalising arrangements to control all modifications, experiments (or other processes) to the existing plant that may affect safety. The arrangements will include the classification of modifications to determine their safety significance. 8.3 Safety Cases 126. Following Start Up Testing, the WN-POSR will be submitted to the ONR for assessment and will demonstrate that there are no aspects of safety that remain to be demonstrated after Start Up Testing. The WN-POSR will include the results of Start Up Testing, prior to the Generation Phase. 8.4 Other Obligations 127. Other obligations during the Commissioning Phase are listed below. I. Nuclear and radiological emergency planning and response, under LC11 arrangements, will be mature, fully established and aligned with nuclear and radiological activities and hazards on the NLS, covering all foreseeable incidents. These arrangements will exist under the approved emergency plan and will be maintained and improved throughout the Commissioning and Generation Phases. II. Once Nuclear Materials are on the NLS, Horizon s nuclear materials accounting system will be used for recording and reporting in accordance with the Nuclear Safeguards arrangements, which will be subject to inspection at the NLS. Page 30 of 38

35 9 Generation Phase 128. This Lifecycle Phase commences following approval of the WN-POSR, and the release of the Hold Point for commencement of normal operations. Objectives during this phase are primarily: safe operation of the Power Station through to final shutdown; construction and operation of ILW, HLW and Spent Fuel facilities; and to prepare the organisation for the Decommissioning Phase Prior to the end of generation, Horizon will apply for decommissioning regulatory permission under the Nuclear Reactors (Environmental Impact Assessment for Decommissioning) Regulations Obtaining regulatory permission will allow the Power Station to move from the Generation Phase to the Decommissioning Phase. 9.1 Organisational Capability 130. Following commissioning of the second reactor, the Power Station will enter a broadly stable period of operation for several tens of years. The organisation will have developed the capability to manage routine outages with supply chain support. Approximately five years before the Generation Phase ends, arrangements will be developed in preparation for decommissioning Activities during this phase will relate to: changes in the NB after the second reactor unit has been commissioned; maintenance of competence and capability; and changes in the NB towards the end of generation in preparation for decommissioning. 9.2 Management Arrangement Development 132. The management arrangements for the plant at this point will be fully developed, but will be reviewed and updated as part of continuous improvement arrangements Arrangements for LC15 for Periodic Safety Review will be developed It is expected that further arrangements associated with LC35 (Decommissioning) will be implemented and tested in this phase before the start of the Decommissioning Phase. 9.3 Safety Cases 135. The Operational Safety Report will be written and approved in this phase, following which it will be reviewed periodically and updated as appropriate Other Safety Case activities in this phase will include Periodic Safety Reviews Horizon will develop the Wylfa Newydd Decommissioning Safety Report (WN-DSR) and supporting documents ready for the transition from power generation to decommissioning. Approval of the DSR and revised maintenance schedule will be key milestones before decommissioning. 9.4 Other Obligations 138. Other obligations during the Generation Phase are listed below. Page 31 of 38

36 I. The NLS will continue to be fully secured in accordance with the prevailing UK security requirements and in line with the NSSP. This is likely to include the presence of the CNC as well as Horizon s Security Officers. Some of the demonstrations of adequacy of arrangements may be combined with those of the emergency arrangements under LC11 and REPPIR. II. Horizon will continue to comply with its Nuclear Safeguards obligations. Page 32 of 38

37 10 Decommissioning Phase 139. Horizon s currently preferred decommissioning strategy is to safely decommission the Power Station promptly, and this is planned to occur in two distinct phases. The first phase will see all buildings demolished, except the Spent Fuel and Intermediate Level Waste storage facilities and the facilities that support them. All waste that can be disposed off-site will be consigned as soon as reasonably practicable to prevent accumulation; any remaining Radioactive Waste that cannot immediately be consigned off-site will remain stored within the on-site storage facilities until a disposal route is available and the waste is suitable for disposal. Due to the long timescales involved, Horizon will continue to review the decommissioning strategy to ensure the assumptions within it remain valid and adding detail as it becomes available The objective of the Decommissioning Phase is to transition the NLS from an operational site to an end state that will be agreed with the relevant authorities Organisational Capability 141. The initial decommissioning preparations team will evolve into a decommissioning programme management organisation. The site management organisation will continue to act as the Licensee: managing the remaining operations of the NLS; retaining responsibility for the plant and retaining work control functions associated with it, ensuring regulatory compliance. The decommissioning organisation will maintain the operational capability to undertake decommissioning Management Arrangement Development 142. Management system documentation will be reviewed and revised as appropriate. This will include additional arrangements for later stages of decommissioning operations and for operation of longer-term facilities to be constructed later in the phase Safety Cases 143. At the time of issuing this document, the main safety claims for decommissioning the Power Station are provided within the GDA-PCSR documentation and include a demonstration that the Power Station can be safely decommissioned using currently available tools and techniques. This will be developed within the WN-PCSR. Final decommissioning activities will be justified at the time that they are required and will be presented as a new Safety Case (the WN-DSR) which will take account of the actual plant configurations and the techniques that will be used as they may have developed since the original WN-PCSR was prepared. It is expected that where practicable, original GDA design features will be utilised to aid final decommissioning activities Other Obligations 144. Other obligations during the Decommissioning Phase are listed below. I. On-site emergency arrangements associated with LC11 will be required until the NLS is delicensed, these may cover the security arrangements required under the NSSP. Emergency exercises will continue to be carried out in line with Horizon s arrangements. Once Horizon s assessment of the hazards and risks formally conclude that there is no probability of an off-site release of radioactivity requiring immediate countermeasures, the ONR may judge that there is no requirement for an off-site emergency planning area. At this point Isle of Anglesey County Council will be advised accordingly. Page 33 of 38

38 II. Based on current understanding and practice, it is anticipated that the CNC will continue to have a presence on the NLS until such a time that all Nuclear Matter is held in the ILW, HLW and Spent Fuel facilities; at this point they will cover only the area(s) where Nuclear Matter is held. The Security Officers will secure the remainder of the NLS. It is anticipated that the NLS will then be reduced to encompass only the storage facilities once the reactors and associated facilities are removed after approximately 20 years. Once all Nuclear Matter has been removed from the NLS the CNC will no longer be required. The Security Officers will be required up until the point of Delicensing. III. Nuclear Safeguards arrangements are required until all Nuclear Material has been removed from the NLS. Horizon will continue to provide reports, although it is anticipated that the frequency of the reports will decrease as no significant changes are expected while the Spent Fuel is in storage. Once all Nuclear Material has been removed, a visit may be conducted to the NLS to verify that no Nuclear Material remains. Arrangements for ending Nuclear Safeguards arrangements will be agreed at the appropriate time. Page 34 of 38

39 11 Management of Future Work 145. This SFWP gives an overview of planned work within different areas of Horizon. The information provided outlines Horizon s current approach and plans, which are subject to change as the project develops. Such changes to Horizon s activities and plans will be in line with Horizon s project and work management arrangements, which are designed to ensure the Power Station progresses safely through the Lifecycle Phases and that Horizon continues to be a demonstrably competent organisation capable of holding a NSL Horizon s Programme Control and Services function is Joint for the development and implementation of the overall schedule management framework. This SFWP is supported by baselined Primavera schedules, which are managed and monitored in accordance with Horizon s procedures for project management and change control Regulatory Commitments 147. Throughout this SLA, there have been a number of areas where undertakings to the ONR to deliver work in future lifecycle phases have been made. These activities have been captured in the underlying schedule that supports this SFWP Where appropriate, Horizon s undertakings to the ONR are captured in a Regulatory Commitments register managed by the Nuclear Oversight and Regulatory Affairs Function. This facilitates oversight and monitoring to close-out Maintenance of the Summary Forward Work Plan 149. This SFWP will be reviewed and updated at key milestones to ensure it is accurate and consistent with Horizon s planned schedules of work. This will ensure that Horizon s obligations and the regulatory expectations continue to be met during future lifecycle phases. Page 35 of 38

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41 12 Schedule of References Table 12.1 Schedule of references Ref. No. Document Number Title Rev No. [RD1] WD S5-NL-REP Nuclear Site Licence Application - Glossary [RD2] HG-M-02-MAN Company Manual 2.0 [RD3] [RD4] [RD5] [RD6] [RD7] WD S5-NL-REP WD S5-NL-REP WD S5-NL-REP WN S3-DA-PLN WD S2-NL-REP Management Prospectus 2.0 Nuclear Site Licence Application Nuclear Baseline Report Nuclear Site Licence Application - Compliance Matrix Safety Case Development Plan Wylfa Newydd Power Station Nuclear Site Licence Application - Overview Document Page 37 of 38

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43 Horizon Nuclear Power Sunrise House 1420 Charlton Court Gloucester Business Park Gloucester GL3 4AE T +44 (0) All material in this document is, unless specified otherwise, copyright of Horizon Nuclear Power Wylfa Ltd and may not be reproduced without prior permission. Any unauthorised use or copying of the material may violate trademark, copyright and other proprietary rights and civil and criminal statutes. The material shall not be used in any manner that infringes any trademark, copyright or other proprietary rights and Horizon Nuclear Power Wylfa Ltd reserves all rights with respect to such unauthorised use. WD S5-NL-LET-00001