SMR Technologies in Poland Will Have the Same Construction Requirements as Nuclear Power Plants

Poland’s new energy strategy was adopted in 2021 and revised in 2022, due to the outbreak of russia’s full-scale war against Ukraine. As part of its efforts to achieve energy safety and independence, Poland has chosen the construction of nuclear power plants as one of its key steps. This step is supported by 86% of Poles, while more than 70% of respondents would agree that such a power plant should be built near their place of residence, according to a study conducted by the Polish Ministry of Climate and Environment in November 2022.

Poland also plans to build small modular reactors (SMRs), the deployment of which will contribute to the energy autonomy of industrial regions and ensure energy safety. To deploy a fleet of small modular reactors in Poland, a company Orlen Synthos Green Energy (OSGE) was established, which will be responsible for the implementation of this project. This is a joint venture between PKN ORLEN, the largest multi-industry energy company in Central and Eastern Europe, and Synthos Green Energy, a part of the Synthos Group chemical company. According to PKN ORLEN, the development of new, low-carbon energy sources is interlinked with ORLEN’s strategy, which aims at energy transformation and diversification of energy sources.

In 2022, OSGE started the pre-licensing process for the GEH BWRX-300 design, and at the end of March 2023, Synthos Green Energy (OSGE shareholder) signed a Technical Cooperation Agreement under which the three companies (TVA, OPG, and SGE) will invest in the development of the BWRX-300 standard design and detailed design of the main components. The design, which is expected to be finalized by the end of 2024, will significantly accelerate the deployment of small modular reactors in Poland, as the technical documentation will include EU and Polish requirements and standards.

The key authority responsible for the licensing process of a nuclear power plant in Poland is the National Atomic Energy Agency (PAA). Its role is to ensure the safe and reliable use of SMR technology, in particular, the regulator’s responsibilities include: formulating requirements in the field of nuclear and radiation safety, issuing authorizations for the construction and operation of nuclear facilities, providing expertise and reviews, as well as inspections at nuclear facilities, issuing technical regulations that define detailed methods of safety assurance and imposing sanctions to enforce compliance with the relevant regulations.

The President of the National Atomic Energy Agency of Poland can issue a general conclusion on a specific technology, which is a pre-licensing process in which the regulator determines whether the planned organizational and technical solutions meet nuclear and radiation safety requirements and Polish law.

According to Polish nuclear legislation, a small modular reactor is a nuclear installation regardless of capacity. That is, the same requirements apply to SMR technologies as to high-capacity nuclear power plants. Jaroslaw Czilmon, Specialist of the Information and Communications Department of the Office for Strategic Policy and International Cooperation of the National Atomic Energy Agency of Poland, notes:

“Polish legislation is so flexible that small modular reactors can be built on the basis of existing regulations. There are no limits or obstacles for SMR construction. However, when licensing SMRs, the Polish regulator applies a graded approach to ensure the necessary scope of analysis, documentation and measures, according to the scale of radiological and non-radiological hazards, the specifics of the facility and its characteristics, as well as the stage of the facility’s life cycle.”

OSGE has been cooperating with the National Atomic Energy Agency from the very beginning, and at the end of May 2023, the company received a general conclusion stating that the BWRX-300 design solutions meet the nuclear safety requirements and Polish nuclear legislation.

According to ORLEN, when selecting the technology, several designs of small modular reactors of generations III and IV were chosen, the analysis of which considered the readiness of the technology, the power of the unit, the possibility of building a supply chain and the potential for involving Polish companies in the construction process. The advantages of the BWRX-300 include the capacity of one unit (300 MW), which is similar to most coal and lignite units operating in Poland (about 80% of units have a capacity of 200-350 MW), as well as the position of GE Hitachi as a manufacturer of small modular reactors in Poland. The company has been implementing projects in the country for more than 30 years, attracting large investments in the energy sector and cooperating with Polish companies. It was also important for the decision that the BWRX-300 technology will be initially implemented in Canada (OPG’s decision of December 2021) and will be a reference project, i.e., the construction of small modular reactors in Poland will be based on Canadian experience in the development, preparation of the investment process, licensing, construction and operation of a nuclear power plant of the same type.

In the course of the pre-licensing process, the company selected seven locations for further geological research, including the outskirts of Ostrołęka, Włocławek, Stawy Monowskie, Dombrowa Górnicza, Nowa Góra, the Tarnobrzeża Special Economic Zone in Stalowa Wola, and Warsaw. According to PKN ORLEN, dozens of potential sites for the construction of small modular reactors were analyzed. The announced locations are those where, on the one hand, there is a business case for such an investment, and on the other hand, a preliminary analysis demonstrated absence of geological, environmental, water, mining, etc. factors that would make it impossible to build a SMR-based NPP at the initial stage. This is not a final list of sites and further potential sites will be presented in the future after the relevant analysis.

After identifying the SMR sites, OSGE submitted applications to the Ministry of Climate and Environment for an in-principle decision to construct power plants based on GEH BWRX-300 small modular reactors at the identified locations. While in Ukraine, a state or private company intending to construct nuclear power units must obtain the status of an operator before obtaining a construction permit, which is determined by the Ministry of Energy, under Polish law, which was amended in early 2023, the first step is to make a decision in principle, and it is not necessary to obtain the status of an operator at the beginning of the investment process.

Polish law stipulates that the Minister of Energy must issue a decision in principle within 90 days. This decision defines the permitted parameters of the investment in the construction of a nuclear power plant and authorizes further decisions, including the decision to select a construction site.

In addition, the company held meetings with local authorities, including the mayors of the cities where SMR is planned to be deployed. An extensive media campaign is currently underway, including TV spots, billboards, etc. PKN ORLEN is responsible for this. In the near future, OSGE will launch an intensive information campaign and establish contacts with local communities in each of the represented locations on the benefits of the SMR construction. Formal public consultations, as required by law, are part of the licensing process and will be held at a later stage of the investment process.

In Poland, public opinion is considered at two construction stages of a new nuclear power unit.

1. Before making a fundamental decision

The Director General for Environmental Protection ensures public participation in the proceedings in accordance with the law and publishes information, including:

• subject matter of the decision to be made in the case;
• the authority authorized to make decisions and implement measures to secure the claim;
• the possibility of familiarizing with the necessary documentation in the case and the place where it will be available for familiarization;
• the possibility of submitting comments and petitions;
• the method and place of submission of comments and petitions and the deadline for their submission (at least 8 weeks);
• the authority empowered to consider comments and petitions;
• procedures for reviewing cases of transboundary environmental impact.

2. Later, after receiving an application for a license to construct a nuclear installation, the Head of the National Atomic Energy Agency of Poland publishes in the Public Information Bulletin on the Agency’s website the contents of the license application together with a brief safety report and information on:

• start of the procedure for issuing a permit for the construction of a nuclear installation;
• the possibility of submitting comments and remarks from the public;
• the method and place of submission of comments and observations, indicating the 21-day period for their submission;
• date and place of the administrative hearing.

In justification of the decision, the Head of the Agency provides information on public participation in the case consideration and how the comments and conclusions were taken into account. The Head of the Agency publishes the information in the press of the local community to which the permit application applies, as well as in neighboring communities.

In February 2024, the Director General of Environmental Protection issued a decision defining the scope of the environmental report for the construction of BWRX-300 at the Stavy Monovskie site. The decision is the result of the environmental permit procedure initiated in May 2023 with the submission of an application by OSGE and allows the company to start the environmental and geographical studies at the Stavy Monovski site necessary for the preparation of the Environmental Impact Assessment Report. In 2023, the environmental authorization procedure was also initiated for the Włocławek and Ostrołęka sites.

Transboundary consultations have also been initiated for the Stavy Monovske site, which include a report on the design’s environmental impact to the countries involved. The Director General of Environmental Protection is responsible for the implementation of the Espoo Convention and transboundary consultations, and he has identified the countries for consultations – the Czech Republic and Slovakia, however, Austria will also join them. This will be the first cross-border consultation in Europe on the construction of a small modular reactor.

“Transboundary environmental impact procedures are designed to allow countries whose territory may be affected by a planned design to submit their comments, including public consultations. The aim is to maintain transparency in the implementation of designs that may have a significant impact on the environment and to make conscious decisions on the conditions for the implementation of such designs, in particular those that go beyond state borders.”

Yaroslav Chilmon

The company’s next steps for the implementation of SMR technology in Poland are further environmental analysis by professional companies involved in the licensing process (cooperation with GEH and the Environmental Protection Agency) and further analysis of the next potential sites.

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