Written evidence from Nuclear Futures Institute at Bangor University (NCL0011)
Overview of the Nuclear Futures Institute at Bangor University and reasons for responding to the call for Evidence
The Nuclear Futures Institute (NFI) at Bangor University is the largest cluster of nuclear academics and researchers in Wales and one of the largest in the UK. We are submitting evidence because of our interests in supporting nuclear developments in the UK and our belief that nuclear energy has a vital role to play in both delivering the Government’s 2050 Net Zero target and enhancing the wider prosperity of the UK.
NFI has a growing reputation as a world-leading group for research in nuclear and nuclear related technologies to support the UK nuclear industry. It is demonstrating capability in support of:
Executive Summary
The delivery of a 24GW nuclear power programme in the UK present a considerable challenge given that this is twice the size of the UK’s current and previous nuclear power programmes and with a much-reduced supply chain, research and education and training base. However, with the right strategic planning, government support and industry commitment we believe the goal is achievable. A summary of the Bangor University’s Nuclear Futures Institute response to the questions are as follows.
Question 1 - Technical Challenges
The challenge for the UK to achieve its goal of 24GW of nuclear power by 2050 should not be underestimated. To achieve this goal there will need to be a mixture of large Gen III, Gen III+ nuclear power plants (NPPs), light water reactor technology based Small Modular Reactor (SMR) NPPs and NPPs based Gen IV Advanced Modular Reactors (AMRs). For the Gen III and Gen III+ NPPs we do not believe there are any new technical challenges relating to the reactor designs, however given the changing nature of the electricity grid demands arising from an increasing proportion of intermittent renewable energy supplies, consideration will need to be given to the need for these large reactors to load follow. The technical challenges are associated with the effects of load-following on reactor components and fuel assemblies. For the Generation III+ light water reactor based SMRs, the technical challenges will arise from the need to validate the safety and reliability of the new designs. For the generation IV AMRs, the technical challenges will depend upon the type of technology being used. For High Temperature Gas-cooled Reactors (HTGR’s) the main technological challenges will be the development of the nuclear fuel supply chain, the development of materials for high temperature applications (up to 1000oC under reactor relevant conditions – including radiation), the development and validation of the fuel design and the reactor cooling system. modular construction and the application of new digital and sensor technology.
Question 1 - Support or Interventions
To bring these technologies to a state where they are ready to provide reliable electricity on the necessary timescale will require action from both Government and the electricity generating industry. Significant government support and intervention will be required in a number of areas including financing, siting, research (possibly including a materials test reactor), long-term nuclear electricity generation strategies including a decision on the use of closed or open fuel cycles as this could influence the choice of reactor technology, the electricity market, education and training, UK industrial capacity, licensee availability and nuclear regulation. The submission provides detailed analysis of these areas and suggested actions.
Question 2
The development of fusion power plants (FPPs) for routine deployment in the energy sector has many scientific and engineering challenges. We believe that fusion technology will not be able to contribute significantly to the Net Zero by 2050 nuclear programme as the technology is not as mature as nuclear fission technologies. We believe that FPPs will not be a reliable source of electrical power before the 2060s / 2070s. However, fusion has the capability of being the main low-carbon energy source for power, heat and transport in the latter part of this century and beyond. We believe that it is essential for the UK to maintain its nuclear fusion research programme and we support fully the UKAEA STEP project and the other prototype demonstration programmes such as the Tokamak Energy STE1 project. Tokamak Energy has an ambitious timeline for the ST-E1 prototype project and if realised it will make a significant contribution to the UK development of FPPs, possibly a little sooner that the 2060/2070 timeframe.
Question 3 - Impact of the current AGR decommissioning Programme.
At this critical time when secure supplied of relatively low-cost electricity is needed, the closure of the Advanced Gas-cooled Reactors (AGRs) should be reviewed and the reasons behind the closure need to be explored fully and reported openly. We believe that at this time the only reason for closing and decommissioning the AGRs should be on safety grounds.
Question 3 - Magnox reactor decommissioning programme
We believe that it is unlikely that any of the existing Magnox reactor sites could be used for the reactors that will be needed to deliver the 24GW programme. However, the land adjacent to the current Magnox nuclear licensed sites will be vital for the construction of new reactors. If the NDA continues with its plans for accelerated Magnox reactor decommissioning some of this land could become unavailable which would clearly have a detrimental effect on the ability to deliver the 24 GW programme. We believe that the NDA’s Magnox reactor accelerated decommissioning strategy should be revisited in the light of the need for adjacent land to be used for the 24GW programme.
Question 3 - How can the Government ensure that the cost of decommissioning does not increase any further?
A contributor to decommissioning cost is the interim management of radioactive waste. Every effort should be made to reduce the need for interim storage and this should include a review of the GDF programme and the need for all ILW radioactive waste to consigned to a GDF. Consideration should be given to the development of an intermediate depth underground disposal facility for all ILW. The provision of an intermediate depth ILW disposal facility (IDDF) would reduce the need and hence the cost of interim storage. The GDF could then be reduced in size and focus only on vitrified High Level Waste (HLW) and if ever declared a waste, spent fuel (SNF). The adoption of the “safe store” concept would reduce the need to construct new interim storage facilities to house the radioactive waste that accelerated decommissioning would produce. This would reduce the cost of decommissioning the current Magnox and later AGR power stations. When, disposal routes become available dismantling of the Magnox and AGRs could be completed thereby reducing the cost of ongoing surveillance.
Question 3 - How can lessons learnt from decommissioning programmes be used to benefit new nuclear power programmes?
All nuclear facilities constructed in the UK since the 1980s have been designed with decommissioning in mind. However, decommissioning should not be the primary driver for nuclear power plant selection. The key factor is that when planning new nuclear power plants ease of decommissioning should be factored into the reactor and plant layout design.
Question 4
It is important that new nuclear reactors are designed to minimise radioactive waste arising from normal operations and decommissioning. All radioactive waste streams should be identified, and their consequences evaluated as part of the pre-construction safety report. As discussed above in our response to Question 3, we believe that the current policy of co-location should be revisited. Serious consideration should be given to the disposal of ILW and some long-lived LLW in intermediate level disposal facilities (ILDF) rather than as currently planned in the geological disposal facility (GDF).
Question 5
The Hinkley Point C project was an attempt to address the new build financing issue, however, the CfD financing model for the Hinkley Point C project is now regarded as not being very successful. We support the Government proposal to use the RAB approach for new nuclear power stations as it is expected to provide electricity at nearly half the price of that for Hinkley Point C at around £51/MWh. The major attraction of the RAB model is the ability of the utility to raise revenue during the construction of the plant by charging consumers a small amount on their electricity bill. Allowing nuclear site licensees to recover costs during the construction and commissioning phases of a nuclear power station makes a lot of sense.
Question 5 - How can the UK leverage further private investment in this area?
Private investors require certainty, and it is no use simply saying that the UK will decarbonise its electricity system by 2035 or the UK will need 24GW of nuclear power by 2050, investors will need to see the details of how this will be achieved. We believe there needs to be a clear roadmap to show HOW this will be delivered. There are many interconnecting factors that need to be coordinated in order to deliver the intended outcome. Given this complexity, we believe that simply leaving it to the “market” will not deliver the required power stations on the timescale required. There are a number of key actions that must be taken on order to deliver the 24GW programme. The first is that working with industry, the government should decide on the mix of reactor types that are needed. This decision should be made early in order to enable the Government and industry to decide on the number of reactors of each type that will be needed and by when.
Response to Questions
Question 1 What technical challenges do the next generation of nuclear fission power plants, including Small Modular Reactor and Advanced Modular Reactors, face?
Technical Challenges
The challenge for the UK to achieve its goal of 24GW of nuclear power by 2050 should not be underestimated. To achieve this goal there will need to be a mixture of large Gen III, Gen III+ nuclear power plants (NPPs), light water reactor technology based Small Modular Reactor (SMR) NPPs and NPPs based Gen IV Advanced Modular Reactors (AMRs).
For the Gen III and Gen III+ NPPs we do not believe there are any new technical challenges relating to the reactor designs, however given the changing nature of the electricity grid demands arising from an increasing proportion of intermittent renewable energy supplies, consideration will need to be given to the need for these large reactors to load follow. The technical challenges associated with load following on reactor components and fuel assemblies include the long-term effects arising from thermal cycling and neutron flux (power) cycling on material behaviour. Further work may need to be carried out to investigate the load following requirements for an electricity grid with a large percentage of intermittent power sources. If the load following requirements for nuclear power stations are significantly different from current load following experience, such as in France, research will need to be undertaken to investigate the long-term effects of load following on the structural integrity of reactor components. The results of such research will provide an understanding of the impact load following will have on plant lifetime and hence on plant economics. Further research on fuel behaviour may also need to be carried out to enable the impact of load following of both safety and performance. The current trend has been to increase fuel burnup and reactor dwell times to reduce the frequency of reactor shutdowns and hence improve economic performance. Load following induced cycling could impact on the behaviour of the fuel. A potential challenge is that research reactor facilities for undertaking this type of research are ageing and new research reactor facilities may be required to substantiate fuel safety and performance alongside a robust fuel performance modelling community. New reactor control systems may be required and hence the development of these systems and their validation from a nuclear safety and operability could present additional challenges.
For the Generation III+ light water reactor based SMRs, the technical challenges will arise from the need to validate the safety and reliability of the new designs, especially new fuel designs and any novel coolant flow geometries in the nuclear steam supply system as well as the planned modular construction and application of new digital and sensor technology.
For the generation IV AMRs, the technical challenges will depend upon the type of technology being used. The choice of AMR technology will be crucial and will depend upon a number of factors. These factors are, the foreseen applications of the technology, the maturity of the technology, price of uranium due to increasing global demand, security of supply of nuclear fuel and energy independence. For both electricity generation and other industrial applications, we support the Government’s intension to back high temperature gas cooled reactor technology because of the wide variety of potential industrial applications to support the decarbonisation of current carbon intensive industries. For High Temperature Gas-cooled Reactors (HTGR’s) the main technological challenges will be the development of the nuclear fuel supply chain, the development of materials for high temperature applications (up to 1000oC), the development and validation of the fuel design and the reactor cooling system. As the UK has not constructed or operated an HTGR for over 50 years, challenges to be addressed will come from modular construction and the application of new digital and sensor technology.
There is a strong case for also developing fast reactor technology, however the use of fast reactors simply to produce heat has little to offer in relation to thermal reactor technologies. Their advantage comes in uranium utilisation. The International Atomic Energy Agency (IAEA) suggested that if we build only thermal reactors the world has about 100 years supply of known uranium at economic prices. Using fast reactor technology increases the supply of fissile material to as much as 3000 years. The development of fast breeder reactors will guard against the prospect of uranium shortages arising from the increasing use of nuclear energy globally and the impact this could have on security of supply and the UK’s future energy independence. Two contenders are worthy of consideration. The lead cooled fast reactor and the sodium cooled fast reactor.
The UK has little experience of the lead cooled fast reactor, but the technology has its supporters. There are technical challenges associated with material behaviour in a high temperature molten lead environment, and also in the validation of the thermal hydraulic performance. There will also be challenges in the development of the safety case relating to the performance of the reactor under fault conditions. Facilities sited at Westinghouse, Alsaldo and Bangor University can act as the initiation sites for such work to be carried out in collaboration with other nations and companies pursuing the technology (e.g. Swede, the USA and Italy).
The UK has extensive experience of developing and operating a fully closed fuel cycle using the Prototype Fast Reactor (PFR) at Dounreay. This showed that sodium cooled fast breeder reactor technology was feasible. However, it will be a technical challenge to reconstitute this knowledge to enable the design and operation, not only of the nuclear reactors at the heart of the NPPs, but also of the complete fuel cycle including the production of the Mixed OXide (MOX) fuel for the reactor, the production of the breeder blanket assemblies, and the reprocessing.
For both the sodium cooled and lead cooled fast breeder reactors the development of the closed fuel cycle will present a technical challenge. The UK was a world leader in demonstrating the closed fuel cycle and reprocessing technologies in particular. However, with the closure of the THermal Oxide Reprocessing Plant (THORP) by the Nuclear Decommissioning Authority (NDA) reconstituting the necessary reprocessing capacity will be a challenge. To enable the UK to maintain its reprocessing capabilities and provide the foundations for the development of the next generation, more advanced reprocessing technologies, we believe the decision to close THORP should be reversed before it is too late.
The adoption of a closed fuel cycle will give the UK considerable energy security for several hundred years.
Support or Interventions
To bring these technologies to a state where they are ready to provide reliable electricity on the necessary timescale will require action from both Government and the electricity generating industry.
Government Actions
Significant government support and intervention will be required in a number of areas including financing, siting, research, long-term nuclear electricity generation strategies including a decision on the use of closed or open fuel cycles as this could influence the choice of reactor technology, the electricity market, education and training, UK industrial capacity, licensee availability and regulation.
Financing
The financing model is key to the successful delivery of nuclear power. It is clear that since the demise of the Central Electricity Generating Board (CEGB), the financing of new nuclear power plants has been left to the electricity generation utilities who have had to find funding on the open market. This has inhibited the construction of new NPPs for decades because of the high up-front construction costs and the length of time before income can be generated. The up-front financing costs coupled with borrowing interest rates that reflect project risk has resulted in financing becoming the largest proportion of the overall cost of NPPs. The high cost of financing and hence the high cost of nuclear power stations has made nuclear generated electricity unattractive to the electricity generation utilities.
The contract for difference (CfD) model that was used for the Hinkley Point C project was an attempt to address the financing issue in order to enable the restart of the much-needed nuclear power programme in the UK. The CfD financing model for the Hinkley Point C project is now regarded as being unsuccessful. This is not surprising given that the construction cost for the two reactors at Hinkley Point C is currently expected to be around £26bn and yet the CfD model has resulted in a 35-year deal with EDF which guarantees a price of £92.5 per MWh adjusted with inflation, which by 2021 had risen to £106/MWh (it is suggested that the strike price could be reduced to £89.5/MWh if the Sizewell C project goes ahead). Assuming that the reactors operate at a 95% load factor over the 35 years, the CfD deal will result in EDF receiving in the region of £100bn during the first 35 years of operation. Of the £92/MWh, 38% is to cover construction risk premium, 26% is to cover other financing costs, 19.5 % is to cover operation and maintenance cost and 11% is to cover capital cost. Under this model, it is clear that around 67% of the price of Hinkley Point C is associated with financing.
Concerns raised by industry stakeholders suggested that the CfD model used for Hinkley Point C was not fit for purpose. Concerns about the CfD model were reinforced by the National Audit Office (NAO) in its report on Hinkley Point C. Annex 4 of the NAO Report gives information on a number of alternative financing options which indicated that a 50/50 Public Private Partnership (PPP) financing approach would give an equivalent strike price of between £48 - £59 at 2016 prices, a turnkey approach would give a strike price of between £12 - £45 and a Hybrid Regulated Asset Base (RAB) approach gave a strike price of around £51 - £58.
For new nuclear projects the Government proposes to use the RAB approach. The application of the RAB for new nuclear power stations is attractive and is expected to provide electricity at nearly half the price of that for Hinkley Point C at around £51/MWh i.e. a saving of about £45bn in the cost of electricity over the same 35 year period. It is worth noting that at the end of 2020, prior to the Russian invasion of Ukraine, gas generated electricity in the UK was about £55/MWh which is comparable to the “RAB” cost of electricity generated from nuclear power. However, by the end of 2021 the cost of Combined Cycle Gas Turbine (CCGT) generated electricity had risen to £245/MWh, which suggests that not only would nuclear energy be competitive to CCGT generation, it would also protect the UK from gas price volatility in the period leading up to 2050, and provide protection from geopolitical pressures in the future.
A major attraction of the RAB model is the ability of the utility to raise revenue during the construction of the plant by charging consumers a small amount on their electricity bill. This is similar to the way the CEGB used to cover the costs of replacement power stations. Allowing nuclear site licensees to recover costs during the construction and commissioning phases of a nuclear power station makes a lot of sense. Structuring payments should lower the cost of financing by eliminating compound interest on the capital investment costs and de-risking the investment which should make the project more appealing to a wider range of investors.
The RAB approach as set out in the Nuclear Energy Finance Act 2022 provides a comprehensive, if complicated, approach to financing new nuclear power projects. The adaption of the electricity generation licence and the designation of nuclear companies provides the necessary control over financing and the ability to charge electricity consumers during all stages of the NPP project lifetime. However, the system puts considerable responsibility on the Government (BEIS) to administer the “economic” licensing process, including the designation of “nuclear companies”. Under the Nuclear Energy Financing Act, the BEIS Secretary of State (SoS) is responsible for designating an organisation that is proposing a nuclear energy generation project as a “nuclear company”. Designating an organisation as a nuclear company requires the SoS to have considerable confidence in the viability of the proposed nuclear project and the ability of the company to become a nuclear site licensee and to deliver the project. This will require BEIS not only to liaise closely with the Office for Nuclear Regulation (ONR) and the environmental regulators but also be an “intelligent customer” to be able to assess the economic and technical viability of the proposed nuclear project.
Once designated the nuclear company can receive regulated revenue relating to the design, construction, commissioning and operation of a nuclear project. However, there is a “chicken and egg” situation to be managed at the design end of the designation process. This is because the SoS needs to be assured that the proposed design is viable and likely to gain regulatory approval which indicates that the design must be sufficiently complete to give the regulators confidence in the safety case. But this means a good deal of the design, engineering substantiation and safety case work will need to be done before the designation of the “nuclear company” and hence before it can receive any regulated revenue.
Whilst the nuclear RAB approach is welcome there are potential issues with the overlap between “economic” licensing carried out by the BEIS SoS and nuclear safety licensing and environmental permitting regulated by ONR and the appropriate environmental regulator. These will need to be managed carefully as there is a strong relationship between nuclear safety and security and the financial strength of the nuclear site licensee. Also, there will need to be close cooperation between BEIS and ONR in the event of a “nuclear company” going into administration given that under UK law (Nuclear Installations Act 1965 as amended) a nuclear site licence cannot be transferred. Hence arrangements will need to be put in place to ensure a safe transition from the nuclear site licensee under administration to a new nuclear site licensee that can continue the operation of the plant.
There will also need to be close cooperation between the economic regulator, the Gas and Electricity Market Authority (GEMA) and ONR to ensure that nuclear safety, nuclear security and non-proliferation safeguards responsibilities of the “nuclear company” are maintained at all times. This is especially the case during the operation phase where GEMA is expected to carry out periodic reviews (every 5 years) of the nuclear company’s allowed revenue. Periodic safety reviews of nuclear safety are carried out every 10 years and given the potential for cost implications of any required actions under the nuclear site licensing regime, ONR and GEMA should establish a Memorandum of Understanding to ensure effective coordination of regulatory decision making.
For the effective and efficient application of the RAB model to nuclear power stations we suggest that an “economic regulatory schedule” should be set up at the beginning of the nuclear project. The economic regulatory schedule should set out the required project timeline showing the dates for main decision points and the required applicant information submission dates, taking account of assessment time to allow each of the decisions to be taken on time. It is important that this economic regulatory schedule is aligned with the project regulatory schedule that is usually established for nuclear safety, nuclear security, safeguards and environmental protection decision making.
In summary we believe the Government should take the following actions:
Siting
The current stated UK Government goal of having 24GW of nuclear power by 2050 (25% of the predicted UK power needs) presents a considerable challenge. The 24 GW of nuclear power is almost double the nuclear installed capacity the UK has achieved in the past. One of the main challenges is the availability of sites for the nuclear power stations. The use of existing nuclear power station sites is an obvious and useful starting point as these have grid connections and communities that are used to nuclear power stations. Given the current decommissioning plans for redundant nuclear power stations, and the importance of the required engineered foundations for NPPs, it is highly unlikely that existing sites would be available on the required timescale to meet our 2050 Net Zero targets. However, we know that there is available land adjacent to the existing nuclear power stations that could be used and hence secure the advantages of grid connections and local public support.
The land adjacent to suitable existing nuclear licensed sites is unlikely to be sufficient to house the number of reactors that will be needed to deliver the required 24 GW. This is because of the 14 current nuclear power station sites in Great Britain only Bradwell, Oldbury, Berkeley, Trawsfynydd, Wylfa, Heysham and possibly Hartlepool have the potential for reuse. Hinkley Point and Sizewell are already committed to providing 3.2GW and 3.2GW+1GW respectively. The site at Dungeness is no longer available and the three sites in Scotland at Chapelcross, Hunterston and Torness can be ruled out due to the current Scottish Government’s position on nuclear power. The remaining available nuclear licensed sites in England and Wales unlikely to be sufficient for the 16.7GW of nuclear capacity that will be needed. To put this into perspective this is 11 EdF European Pressurised water Reactors (EPRs) or 17 Westinghouse AP 1000s or 38 Rolls-Royce (RR) SMRs or a combination of each. It is clear that additional new nuclear licensed sites will be needed. The large reactors would suit coastal locations whilst the SMRs/AMRs could be located on suitable inland lakes and rivers. It is possible that the smaller SMR/AMR based power stations could make use of grid connections previously used by large coal fired power stations. The land adjacent to existing nuclear power stations is owned either by the NDA or private companies.
In summary we believe the Government should take the following actions:
Research
The successful delivery of safe and reliable operation of the proposed new SMR/AMR based power stations will depend upon the substantiation of the engineering design of the nuclear reactor and the fuel design under both steady state and fault conditions, and the substantiation of the claims made in the safety case. Some of the attractive AMR technologies will require further R&D to fill in the current gaps in knowledge needed to underpin this design substantiation and safety assessment. Substantiation will require extensive knowledge of materials behaviour, nuclear fuel performance, core neutronics and thermal hydraulic behaviour in the primary circuit and in the fuel assemblies. As these designs are new and in some cases novel, an extensive research and development programme in all these areas will be needed.
For obvious reasons nuclear has been a conservative industry. However, the potential for innovation through application of new techniques and technologies such as in:
will provide the industrial supply chain and research organisations with opportunities to develop and build new facilities. As is happening with the Advanced Research Projects Agency- Energy (ARPA-E) in the USA we envisage AMRs will provide many opportunities for UK Advanced Research Invention Agency (ARIA) projects.
To support the development of its nuclear power programme the UK had a very large and successful nuclear research programme that included several zero energy facilities, low energy research reactors, 3 material test reactors, prototype AGR and liquid metal fast breeder reactors including the 250MWe PFR at Dounreay. The UK also had nuclear fuel research facilities at Springfields and Windscale and a High Enriched Uranium (HEU) processing plant and prototype and fast reactor fuel reprocessing plants at Dounreay. These have all gone but understanding the behaviour of new materials in reactor conditions will be essential for the deployment of SMR/AMR based nuclear power stations.
The deployment of SMR/AMR technologies could present an opportunity for the UK to construct a new research reactor facility not only for materials testing but also to provide trainees with the opportunity to gain nuclear reactor operating experience and act as a public facing facility for education akin to the Open Pool Australian light water (OPAL) test reactor in Australia. We believe that the construction of a new research reactor in the UK would be of great benefit to supporting the delivery of the 24GW nuclear power programme.
For the NPPs it is vitally important that the UK has its own indigenous capability. Much of the required R&D should come from the reactor vendors but there is a role for government in the provision of fundamental research in some of these areas including the provision of a new research reactor and the proposed National Thermal Hydraulics Facility (NTHF). We believe that the NTHF should be capable of focussing on thermal hydraulic characteristics of light water reactors, gas cooled reactors and liquid metal (lead and sodium) cooled reactors.
It is also possible that future nuclear programmes will require the use of a closed fuel cycle to enable the increased utilisation of uranium. The Nuclear Decommissioning Authority (NDA) has just closed the Thermal Oxide Reprocessing Plant (THORP) at Sellafield and having been a world leader in fuel cycle technologies, the UK will shortly lose its reprocessing capability just at the time when it may be needed most. In the context of the closed fuel cycle, reprocessing technologies and uranium + plutonium Mixed Oxide (MOX) fuel fabrication are two of the key areas of interest. We support the continued research by NNL on advanced reprocessing that is aimed at better characterisation of the radioactive waste streams to enable more effective radioactive waste management. We also see a need for research into more effective reprocessing of MOX fuels to enable multiple reprocessing cycles. Research into MOX fuel fabrication should enable the lessons to be learned from the UK’s fuel fabrication history dating back to the MOX fabrication for the PFR fast reactor programme, the MOX Demonstration Facility (MDF) and the ill-fated Sellafield MOX Plant (SMP).
It is important for the Government to ensure there is a coordinated research and development programme, including a nuclear safety and security research programme.
In summary we believe the Government should take the following actions:
Long-term nuclear electricity generation strategies
The current energy crisis has shown that there is a pressing need for a long-term electricity generation strategy for nuclear power. In the past the UK saw the value of long-term strategic planning for nuclear power stations. After the Suez crisis the UK constructed 18 Magnox reactors at 9 nuclear power station sites between 1962 and 1971. If the Calder Hall and Chapelcross reactors are included the UK built 26 Magnox type reactors in 18 Years (5GW) The AGR programme was the second phase of the UK’s nuclear energy strategy and here 14 reactors were constructed between 1965 and 1989 at 7 power station sites (8.5GW). The initial PWR programme comprised 5 PWRs, the first to be constructed at Sizewell. This programme was intended to deliver 5.5GW but the Government cancelled the programme in the early 1990s leaving only Sizewell B to be constructed. We believe that if the UK is to deliver the 16.7GW of nuclear power following the Hinkley Point C and Sizewell C projects on the required timescale, a strategic plan will need to be developed in the next couple of years. This plan will be necessary to ensure that all the necessary components of such a programme, reactor type, sites, supply chain, licensees etc. are available on the required timescales.
The provision of nuclear energy to power the UK economy when the wind does not blow and the sun does not shine cannot be left to chance. It is difficult to see how “the market” can be expected to plan and deliver the UK’s strategic energy needs and hence to ensure that nuclear energy can play its role in the UK meeting it’s 2050 targets, there needs to be a strategic plan for nuclear to identify what is needed and when it is needed. The Government has recently created Great British Nuclear it is important that this body develops a nuclear power strategic plan to deliver the required 24GW by 2050. Government intervention in this way is not unknown in recent times the UK Government created the NDA in 2005 to manage the UK’s nuclear decommissioning liabilities. More recently the current Government has created Great British Railways to strategically manage the UK’s rail network.
In summary we believe the Government should take the following actions:
The electricity market
The current energy crisis has exposed the inadequacies in the current electricity market and the relationship between what we pay and the cost of generation. The current electricity market pricing approach whereby every generator supplying the grid receives the same price as that of the marginal supplier, which given the current electricity generation mix will always be the gas turbine generators, may need to be revised so that generator prices reflect actual generation costs. For nuclear generation in the future there needs to be a mechanism that guarantees that there will be a market for 24GW of nuclear generated electricity. Unless the Government intends to fund the nuclear power programme, failure to attract investors will present a considerable challenge to the delivery of the Governments nuclear power intentions.
In summary we believe the Government should take the following actions:
Education and training
The construction, manufacture of components, commissioning and operation of the NPPs that are needed to deliver 24GW of nuclear generated electricity by 2050 will require people. Hence it is important to have a comprehensive education and training programme in STEM subjects to ensure there are the required number of people not only in the licensee organisations to operate and maintain the NPPs, but also in the supply chain. The supply chain needs a wide variety of skills to develop and review NPP designs, carry out component manufacture, and undertake construction and commissioning activities. Over a decade ago the industry in conjunction with the National Skills Academy for Nuclear (NSAN) produced a number of reports on the skills needs for the different sectors in the nuclear industry. These are now out of date and it would be useful to repeat this initiative and develop a new analysis of the skills required to deliver the 24GW programme.
Following the development of such an analysis the Government, in conjunction with universities and colleges for further education, should develop an education and training strategy to deliver the required number of skilled people at all levels. It is recognised that the nuclear industry itself has a responsibility to train and develop its staff to ensure that all people that undertake nuclear safety related activities are suitably qualified and experienced (SQEP) and as such will have their own training and development programmes. However, the aim of the strategy should be to provide the industry with sufficient people who have the required basic education and skills.
In summary we believe the Government should take the following actions:
UK industrial capacity
In the case of the potential SMR/AMR many of the vendor organisations are new with limited track records of delivery. The lack if a delivery track record could have implications for investor confidence and hence deployment timescales. New vendors will need time to establish their nuclear credentials and develop their design teams and organisations. This will be necessary to substantiate their designs, provide the necessary safety documentation and give confidence that they are capable of delivering the power stations on time. The Dungeness B project is a good example of how a vendor did not have the competences or capability to deliver a First Of A Kind (FOAK) reactor design. Vendor capability will need to be a factor in the selection of SMR/AMR options in order to minimise both financial risk and the risk to the delivery of the UK 24GW nuclear power programme. If attractive SMR/AMR designs are provided by less well-established companies, consideration will need to be given as to how these companies can be strengthened on the timescales needed for deployment. It is the responsibility of the licensee / licence applicant to ensure that it selects an appropriate reactor vendor, however under the Nuclear Financing Act referred to above the Government has a responsibility to designate “nuclear companies” and hence the government needs to be assured that any reactor designs will be acceptable to the regulators and that reactors can be constructed on the required timescale.
SMR/AMR technologies because of their modular manufacture and construction capabilities, have the potential to develop a new high technology engineering supply chain in the UK. However, at this point in time the supply chain that will be needed to support the envisaged fleet of nuclear plants does not exist to the extent that will be required. To effectively deliver the required 24GW programme that includes SMR/AMR programme, additional industrial capacity will be needed. These additional requirements will need to be identified. There will also need to be a plan for how the necessary supply chain can be built up on the required timescale. If the preferred SMR/AMR vendor is foreign, consideration should be given to a progressive transfer of technology from the vendor country to the UK in order to enable component manufacturing capability and skills to be developed in the UK. If the vendor is UK based, it will be essential for the deployment strategy to identify clearly supply chain development requirements.
In summary we believe the Government should take the following actions:
Licensee availability
Under UK law no person can construct or operate a nuclear installation without a nuclear site licence. Licensees are an important part of the UK nuclear regulatory regime. A nuclear site licensee must be the “controlling mind” in relation to nuclear safety. This means that a licensee must have the capability to understand the technology that it is responsible for. A licensee must also be an “intelligent customer” for the goods (including the nuclear reactor) and the services that are necessary to support nuclear safety. These are exacting requirements, and they provide the UK with one of the three main “locks” that enable the safe use of nuclear energy.
Unfortunately, at present the number of nuclear licensees with experience of building and operating nuclear power plants in the UK is limited to the two EDF related companies EDF Energy Nuclear Generation Ltd that operate the AGR stations and Sizewell B, and NNB Generation (HPC) Limited that is responsible for the construction of Hinkley Point C. A third EDF related company NNB Generation Company (SZC) Ltd is currently applying for a nuclear site licence for the Sizewell C project. Magnox Limited (formerly Magnox Electric that operated the fleet of Magnox nuclear power plants) no longer has the expertise to undertake a major new nuclear power plant project and would need extensive organisational change and recruitment to be able to qualify as a nuclear power plant licensee. It would also take time to make these changes - somewhere between 2 and 4 years. In the case of the Hitachi GE ABWR nuclear power plants proposed for the Wylfa Newydd project in Anglesey a new nuclear licence applicant (Horizon Nuclear Power) was created but this has now been disbanded following the withdrawal of Hitachi from the project.
At present there are no existing nuclear site licensee organisations associated with either large NPPs other than those operated or under construction by EDF. This is equally the case for new power stations based on SMR/AMR technologies. At the moment there are no licence applicant organisations on the horizon and this could present a significant challenge.
To deliver the 24GW nuclear power programme, new nuclear site licensees will need to be identified. Existing nuclear site licensees with an interest in operating SMRs/AMRs will need to be upskilled to gain the necessary understanding of the SMR/AMR technology. The development of any new nuclear site applicants / licensees will take time. Hence it is important for any 24GW nuclear power programme delivery strategy to factor in the time needed to identify and develop new and where appropriate, existing nuclear site licensees.
In summary we believe the Government should take the following actions:
Regulation
The UK’s nuclear licensing system has proven to be both flexible and robust. The goal setting licensing approach has allowed the Office of Nuclear Regulation (ONR) and its predecessor Her Majesty’s Nuclear Installations Inspectorate/Health and Safety Executive (HMNII/HSE) to licence nuclear installations ranging from small research reactors, large nuclear power plants, nuclear fuel fabrication and reprocessing facilities, radioactive waste processing and storage facilities, nuclear weapons production and the refuelling of nuclear submarines. No other country licenses such a wide range of facilities. This gives the UK an advantage when it comes to licensing novel nuclear plant designs such as SMR/AMRs.
In the UK the regulatory challenge will not come from the nuclear licensing system but from the availability of people with the expertise to produce the necessary safety documentation (within the nuclear site licensee and their supporting vendor organisations) and to regulate the nuclear industry. Resourcing will be an issue for the regulator and any 24GW nuclear power delivery strategy will need to take into account the time it will take to build up the necessary technical expertise required to regulate new reactor designs including SMR/AMR technologies.
The UK offers two options for those wishing to construct and operate a new nuclear facility. The first option is the direct licensing route and the second is the Generic Design Assessment (GDA) + licensing route. The direct licensing route is the quickest, but it requires a number of things to happen. The key requirements are:
If all three of these are in place the licensee or licence applicant can apply to ONR for a nuclear site licence. If ONR has the resources and expertise to understand the reactor technology, it could take a couple of years to assess the PCSR and complete the licensing process.
The second option, the GDA + licensing process will take longer because the GDA process looks at a generic design and is a commercial contract between a vendor and ONR. If the ONR (and the environment regulator) accept the vendor’s generic design, a licensee or licence applicant will then need to produce a site specific PCSR and apply for a nuclear site licence. Current GDA’s based on well-established light water reactor technologies are taking up to four years to complete. Given the timescale to implement the 24GW nuclear power programme, it is questionable if the GDA is appropriate.
The ability of the regulators to proceed with either of these routes will depend upon the number of reactor designs in the 24GW deployment programme. If the regulators do not have sufficient technical, engineering and scientific resources to assess a wide range of designs, priorities will need to be made. Where new NPPs including SMR/AMR designs, are proposed to be used for cogeneration additional regulatory approaches may be needed. For process heat cogeneration the close proximity of the NPP to other industrial facilities will be a new regulatory challenge but one that should be capable of being managed within the existing regulatory framework.
Nuclear site licensees are subject to nuclear site licensing, nuclear security regulations, non-proliferation safeguards regulation and environmental permitting. The ONR is the statutory regulator for the first three activities listed but environmental permitting is regulated by the environment regulators, the Environment Agency (EA) in England, Natural Resources Wales (NRA) in Wales, and the Scottish Environment Protection Agency (SEPA) in Scotland. This arrangement gives rise to the potential for dual regulation and conflicting requirements being placed on licensees / licence applicants, not to mention the inefficiencies caused by regulatory interfaces. Given that the 24GW nuclear power programme is considerably larger than any of the previous UK nuclear power programmes, there is not the supply chain capability or capacity that there was in previous nuclear power programmes and the timescale for implementation is tight, the Government should give serious consideration to improving the coordination of nuclear site licensing and environmental permitting by developing a more effective, efficient and streamlined nuclear site regulatory process, with reduced burdens on the licensee. This could be achieved by transferring the relatively small number of people with nuclear site environmental protection responsibilities in the EA, NRA, and SEPA into a new environmental protection division in ONR.
In summary we believe the Government should take the following actions:
Question 2 When will fusion power supply electricity to the grid?
The UK has a long history in the development of fusion energy dating back to the 1950s. The Joint European Torus (JET) facility at Culham is currently the largest fusion machine in the world but it is coming to the end of its life. The UK remains a key player in the multibillion-pound International Thermonuclear Experimental Reactor (ITER) project but its long timescale and complexity have led to pursuit of alternative routes to fusion. UKAEA is developing a prototype fusion power plant based on spherical tokamak technology (Spherical Tokamak for Energy Production, STEP) and it is targeted for a completion date of 2040. Tokamak Energy, a UK private company, is also working on a spherical tokamak fusion power plant with a target for initial operation in the early 2030s. First Light is another UK based company with plans to build a prototype fusion power plant, but this is based on a different type of technology using inertial confinement rather than magnetic confinement used in the other fusion technologies. However, the development of fusion power plants (FPPs) for routine deployment in the energy sector has many scientific and engineering challenges.
Deployment timescale
We believe that fusion technology will not be able to contribute significantly to the Net Zero by 2050 nuclear programme as the technology is not as mature as nuclear fission technologies. As such we believe that FPPs will not be a reliable source of large-scale electrical power before the 2060s / 2070s. However, fusion has the capability of being the main low-carbon energy source for power, heat and transport in the latter part of this century and beyond. We believe that it is essential for the UK to maintain its nuclear fusion research programme and we support fully the UKAEA STEP project and the other prototype demonstration programmes such as the Tokamak Energy STE1 project.
Advantages and disadvantages of developing fusion technologies over other energy sources
Advantages
When nuclear fusion technology is mature and FPPs designs are ready for deployment, nuclear fusion will offer considerable advantage over nearly all other energy forms. The main advantages are:
Disadvantages
General comments
Safety
The radioactive release potential in FPPs in severe accidents is several orders of magnitude below that from a fission based NPP. However, the hazard potential, sometimes called the unmitigated risk to the public, following such a release is not trivial. Analysis has shown that unmitigated releases would trigger the offsite counter measures that protect the public from exposure to ionising radiations. To prevent such releases and hence reduce the risk to the public to acceptable levels in line with the UK legal requirement to reduce risks so far as is reasonably practicable will require robust engineered control and protection systems and robust regulation to provide the public with the necessary confidence in the FPP safety case.
The tritium inventory is a major factor in the FPP accident source term and having tritium production and storage facilities on each site adds to the potential accident source term and hence the site hazard potential.
FPP Design and operability
The understanding of the impact of high energy neutrons (much higher energy than those produced in fission reaction reactions) on materials is of vital importance not only to the behaviour of structural materials that support both operability and safety, but also to the protection of key reactor components such as the superconducting electromagnets that provide the confinement of plasma that makes fusion possible. We believe that a materials test reactor in the UK would provide valuable support to the designers of FPPs, and a feasibility study into the viability of such a reactor should be undertaken.
As discussed above, the current intent to design FPPs that can breed their own tritium not only complicates the design but also adds to the hazard potential and hence the safety of an FPP site. Being able to design FPPs that do not need to breed tritium has many engineering and safety advantages. It also can have a positive effect on FPP economic viability, through the delivery of higher load factors that are more comparable with those of fission based NPPs. The Nuclear Futures Institute at Bangor has initiated research into the viability of developing a tritium fuel production capability in the UK. If successful it could enable the UK to develop a tritium fuel industry that would supply FPPs in the UK and internationally with tritium fuel, thus decoupling tritium production from FPP operations.
In summary we believe the Government should take the following actions:
Question 3 What could be done to ensure that the UK’s electricity supply is not affected by the high proportion of reactors being decommissioned?
Impact of the current AGR decommissioning Programme.
At this critical time when secure supplied of relatively low-cost electricity is needed, the closure of the Advanced Gas-cooled Reactors (AGRs) should be reviewed and the reasons behind the closure need to be explored fully and reported openly. We believe that at this time the only reason for closing and decommissioning the AGRs should be on safety grounds. If there are no safety grounds the AGRs should continue in operation so long as it is safe to do so because the front end and back end fuel management costs represent only a small fraction of the cost to generate electricity.
We believe that until a review of the viability of the continued operation of the AGRs has been carried out defueling and preparatory decommissioning work at Hunterston B and Hinkley B should stop so as not to prejudice the prospect of restarting these reactors.
Extending the lives of the AGRs is not simply a matter of maintaining operations at the power stations, fuel supplies, spent fuel management and technical support all need to be addressed. The AGR fuel production capabilities should be revisited to ensure that the Springfields facilities remain capable of supplying AGR fuel should the AGR closure timescale be extended. If fuel manufacture constraints are identified corrective action should be put in place to ensure fuel will be available for any extended AGR lifetimes. The AGR capabilities of the spent fuel storage and management facilities at Sellafield should be revisited to ensure that there is sufficient capacity to manage any extended AGR Fuel programme. If spent fuel management constraints are identified corrective actions should be taken to ensure that the spent fuel management facilities at Sellafield are maintained for any necessary extended period. The future of the AGR technical support team at Barnwood should be reviewed and this centre must be maintained until the at least the closure of the last AGR power station.
We believe that every effort should be made to continue to operate the AGR fleet for so long as it is safe to do so. This will not only help in providing secure electricity supplies during the current energy crisis, but it will also help provide secure electricity supplies in an uncertain future. Another advantage of extending the lives of the AGRs is that it would maintain the highly trained and experienced AGR power station workforce and allow the recruitment of the next generation of nuclear workers to enable a smoother transition to the deployment of the new reactors that will be needed to deliver the Government’s 24GW nuclear power programme. It would also enable the capability of the technical staff at Barnwood to be maintained at this critical time.
Magnox reactor decommissioning programme
The Magnox reactor decommissioning programme has the potential to impact on the required new build programme. This is because of the availability of the sites for constructing new reactors, and the impact of decommissioning practices on the availability of land surrounding existing sites for new reactor construction. Given the exacting requirements for geological load bearing capacity to support nuclear reactors the time that will be required to decommission the existing Magnox reactors and return the site to a state where a new reactor(s) could be safely constructed on that site, it is unlikely that any of the existing Magnox reactor sites could be used for the reactors that will be needed to deliver the 24GW nuclear power programme.
As discussed above in our response on siting in question, the land adjacent to the current Magnox nuclear licensed sites is very valuable for the construction of new reactors. However, if the NDA continues with its plans for accelerated Magnox reactor decommissioning this land could become unavailable as it will be needed for equipment “lay down” areas to enable decommissioning and possibly for new interim radioactive waste management storage facilities to house the reactor core graphite and other intermediate level (ILW) radioactive waste. The loss of this land for new nuclear power stations would clearly have a detrimental effect on the ability to deliver the 24 GW nuclear power programme.
We believe that the NDA’s Magnox reactor accelerated decommissioning strategy should be revisited in the light of the need for adjacent land to be used for the 24GW programme. If accelerated decommissioning could impact on the availability of the land for new nuclear reactors, priority should be given to the new build programme. If this is the case, the “safe store” option would allow the existing Magnox reactors to be put in a safe and secure state until there are disposal routes for the radioactive waste that will arise from decommissioning, including the availability of the UK geological disposal facility (GDF). The availability of disposal routes will mean that land for interim ILW storage facilities will not be required. The safe store concept will also allow some of the radioactivity in the reactor components to decay sufficiently to enable decommissioning to be more easily carried out.
How can the Government ensure that the cost of decommissioning does not increase any further?
A contributor to decommissioning cost is the interim management of radioactive waste. Every effort should be made to reduce the need for interim storage and this should include a review of the GDF programme and the need for all ILW radioactive waste to consigned to a GDF. Consideration should be given to the development of an intermediate depth underground disposal facility for all ILW. Such a facility at a depth of 150 to 200m would be cheaper and quicker to construct. This would allow quicker disposal of existing cemented ILW and the reuse of the ILW stores at Sellafield and elsewhere for new ILW waste arisings arising from the decommissioning programme and waste arising from the 24GW programme. The provision of an intermediate depth ILW disposal facility (IDDF) would reduce the need and hence the cost of interim storage. The GDF could then be reduced in size and focus only on vitrified High Level Waste (HLW) and if ever declared a waste, spent fuel (SNF). The focus on HLW and SNF would enable the design and construction of the GDF to be pursued on a longer timescale because of the time needed to allow for cooling. Priority could then be given to the delivery of one and possibly two IDDFs.
As discussed above the adoption of the “safe store” concept would reduce the need to construct new interim storage facilities to house the radioactive waste that accelerated decommissioning would produce. This would reduce the cost of decommissioning the current Magnox and later AGR power stations. When, disposal routes become available dismantling of the Magnox and AGRs could be completed thereby reducing the cost of ongoing surveillance.
How can lessons learnt from decommissioning programmes be used to benefit new nuclear power programmes?
All nuclear facilities constructed in the UK since the 1980s have been designed with decommissioning in mind. Clearly, future reactor systems based on light water reactor technology will have fewer decommissioning challenges because they do not have graphite moderator materials in the core or pre-stressed concrete pressure vessels. However, decommissioning should not be the primary driver for nuclear power plant selection. The key factor is that when planning new nuclear power plants ease of decommissioning should be factored into the reactor and plant layout design.
In summary we believe the Government should take the following actions:
Question 4 What needs to be done to improve the UK’s approach to dealing with nuclear waste and to ensure that the Government can meet its aims of transferring waste to geological disposal facilities?
The law (nuclear site licence condition 32) requires that radioactive waste is minimised. Hence there is a duty on licensees to minimise the production of radioactive waste. It is important therefore that new nuclear reactors are designed to minimise radioactive waste arising from normal operations and decommissioning. Material selection and shielding design should be used to minimise the production of both decommissioning and operational radioactive waste. The aim should be to minimise the amount of material that can be activated by exposure to neutron bombardment, minimise the potential for radioactive contamination of components, optimise the fuel design and reactor fuel management to maximise the period between refuelling. All radioactive waste streams should be identified and their consequences evaluated as part of the pre-construction safety report.
By definition waste is material that is no longer required and for vast majority of radioactive waste long-term management means land-based disposal. Currently, the UK policy for radioactive waste disposal is categorised such that very low level waste (VLLW) can be sent to designated landfill sites; low level waste (LLW) can be sent to either the national low level disposal site near Drigg in Cumbria for wastes arising in England or Wales and to Dounreay for Scottish waste; ILW and HLW (and possibly SNF if it ever declared a waste) arising in England and Wales is destined to be sent to the proposed GDF. As discussed above in our response to Question 3, we believe that the current policy of co-location should be revisited. Serious consideration should be given to the disposal of ILW and some long-lived LLW in intermediate level disposal facilities (ILDF). There are many advantages to doing this:
The only potential disadvantage would be the possible need for a separate site for the disposal of HLW in a deep GDF. However, this disadvantage would be offset by providing the opportunity for more than one community to benefit from hosting a radioactive waste disposal facility.
As discussed above if the policy of co-location was abandoned, priority could be given to the disposal of ILW and hence the reduction of expensive interim storage. The vitrified fission product HLW requires a relatively small interim storage volume as does the storage of SNF in dry cask or pond interim storage. The fission product HLW requires a minimum of 50 years before it can be consigned to a GDF. Similarly, SNF requires at least 100 years, and possibly longer, in interim storage before it can be consigned to a GDG. This shows that prioritising ILW disposal in a ILDF and putting back the need for a HLW focussed GDF would not adversely affect cost or safety.
In summary we believe the Government should take the following actions:
Question 5 How can the funding methods that support the development of nuclear technologies be improved?
Since the privatisation of the nuclear industry in the mid 1990’s the construction of new nuclear power stations to replace those coming to the end of their lives and being decommissioned has proved problematic. The resultant demise of a once vibrant and innovative UK nuclear industry also limited the UK’s ability to accelerate the development of nuclear power to meet the twin challenges of climate change and security of supply for both current and future generations. We believe the root cause of this situation has been the projected cost of NPPs, especially the high up front construction costs and the length of time before income can be generated. These up-front financing costs coupled with borrowing interest rates that reflect project risk has resulted in financing becoming the largest proportion of the overall cost of nuclear power plants. Improvement in the financing arrangements for these large projects is therefore the key to the development of nuclear power.
As discussed above in our response to Question 1, the contract for difference (CfD) model that was used for the Hinkley Point C project was an attempt to address the financing issue, however, the CfD financing model for the Hinkley Point C project is now regarded as not being very successful and has resulted in financing accounting for nearly 70% of the project overall cost. The NAO has suggested alternative ways of funding future nuclear power projects which could half the funding costs associated with the Hinkley Point C project.
We support the Government proposal to use the RAB approach for new nuclear power stations as it is expected to provide electricity at nearly half the price of that for Hinkley Point C at around £51/MWh. The major attraction of the RAB model is the ability of the utility to raise revenue during the construction of the plant by charging consumers a small amount on their electricity bill. Allowing nuclear site licensees to recover costs during the construction and commissioning phases of a nuclear power station makes a lot of sense. Structuring payments should lower the cost of financing by eliminating compound interest on the capital investment costs and de-risking the investment which should make the project more appealing to a wider range of investors.
How can the UK leverage further private investment in this area?
Private investment requires certainty. Certainty in the viability of the investment and certainty in a reasonable rate of return from the investment. To date there has not been much certainty on either of these fronts. To change this, it is important for the Government to provide confidence in the future nuclear power programme for the UK. It is no use simply saying that the UK will decarbonise its electricity system by 2035 or the UK will need 24GW of nuclear power by 2050, investors will need to see the details of how this will be achieved. The announcements made earlier this year by the Government in the “British Energy Security Strategy” are welcome, as is the announcement on the creation of the “Great British Nuclear Vehicle” but these are only a start. The cost of providing 24GW of nuclear power will be hundreds of billions of pounds and to give investors confidence that investing in the delivery of the UK’s nuclear power programme is worth doing, we believe there needs to be a clear roadmap to show HOW this will be delivered.
As shown above in our response to question 1, there are many interconnecting factors that need to be coordinated in order to deliver the intended outcome. Given this complexity, we believe that simply leaving it to the “market” will not deliver the required power stations on the timescale required. There are a number of key actions that must be taken on order to deliver the 24GW nuclear power station programme. The first is that working with industry, the government should decide on the mix of reactor types that are needed. This decision should be made early in order to enable the Government and industry to decide on the number of reactors of each type that will be needed and by when. A delivery roadmap should then be developed to show how Government and industry will work together on the required timescale to:
In addition the Industry and regulators should work together to develop the required “regulatory schedules” for each project so that regulatory requirements are understood clearly.
In summary we believe the Government should take the following actions:
Question 6 What support will industry need to meet the Government’s ambitions for delivery new nuclear power plants in the next decade?
Please see our responses to questions 1, 3 4 and 5 where we have set out or views on where Government has role to play in creating the environment that will be necessary to deliver the 24GW nuclear power programme. Clearly, during the next decade Government needs to support industry in a number of key areas including:
In summary we believe that there are many important areas where the Government can play a supporting role as outlined in our above responses.
September 2022
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