MAGAZINE OF THE UK NUCLEAR INDUSTRY ASSOCIATION WINTER / 2021
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Welcome to the final Industry Link edition of 2021! And what a year it’s been. So much has happened since the 2020 winter edition when the Energy White Paper was making headlines. Fast forward a year and the industry has found itself at the centre of a flurry of significant government announcements and exciting new developments. As is mentioned in these pages, “as a nuclear industry, we have had our best few months since 2013 at least.” From a new nuclear financing bill to fresh money for large and small-scale stations, the UK Government has ramped up its financial commitment to nuclear and it’s been nothing short of momentous. This progress is summed up, and celebrated, by the NIA’s Lincoln Hill, in his Power Politics column. Real progress was also realised on the global stage, with the industry strongly represented at COP26. From high level speaking slots to flash mobs, the climate event in Glasgow showcased the best of our industry and our very own Tom Greatrex was there to witness it all and offers his take on the summit. Elsewhere, we hear from Core Power’s Mikal Bøe on nuclear’s role in decarbonising the shipping industry, Robbie Huston gives us the lowdown on what’s been a busy period or the Trade Unionists for Safe Nuclear Energy and Ieuan Williams reflects on the success of Nuclear Week in Parliament. Lastly, I offer a roundup of what has been one of the busiest periods the NIA has ever had in the media, with press coverage and broadcast interviews galore as well as a brand-new website and a shiny new Net Zero Needs Nuclear video. As 2021 draws to a close there’s a sense that the industry is hitting a purple patch, which is testament to the hard-work of our members.
Iolo James, Media & Communications Manager, Editor IN THIS ISSUE...
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Reflections on COP26 BY. TOM GREATREX / CHIEF EXECUTIVE
The pandemic delayed but much anticipated meeting of the COP26 finally took place in early November. Despite the long queues, strict Covid-19 regulations, and the missing leaders from key climate influencers such as China and Russia, a climate deal was done, albeit a watered down resolution to “phase down” coal, rather than phasing it out.
B
oris Johnson called the Glasgow Climate Pact a “gamechanging agreement” which sounds “the death knell for coal power,” and although it shows intent, there was outrage from some quarters. Developing nations will continue to rely on coal, just as modern nations did to build and shape their economies, but ensuring jobs and opportunity aren’t also phased out is the conundrum. The business of international diplomacy can be slow, frustrating and littered with get out clauses and ambiguity to keep everybody on board – but it is nevertheless a significant step forward that both reliance on fossil fuels and the need for low carbon technology mixes were the framing of the negotiations. Of course, we have a solution: nuclear power. And the global industry was out in force in Glasgow. What began with disappointment in the Summer with whispers that the sector would have a muted presence in the all-important Green Zone - the area of the summit open to the public - ended up with a strong and influential showing. Our COP26 online hub netzeroneedsnuclear.com was supported by the Energy Minister, Greg Hands, in what was a great team effort between BEIS and the industry. It was here where delegates, and anyone with an interest in fighting climate change, could visit and discover what role nuclear is and will play in cutting emissions. It would not have happened without the cooperation and support from across the industry, and the effort of the NIA team in making the idea a reality. Given the Green Zone disappointment, we were unsure of what to expect. In previous COP meetings, notably in Bonn but elsewhere too, nuclear was almost verboten, with civil society activists consigned to a lonely presence outside as organisers bowed to pressure from some groups who operate on the basis of disinformation and intimidation, being neither very green nor especially peaceful. However, thanks to the collective efforts of nuclear advocates from around the world, what we got was a brilliant week of panel
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sessions, including ones hosted by Nuclear for Climate, the IAEA and the NIA, drinks receptions, hosted by some of our members, and even a rap concert from the Young Generation Network and Generation Atomic. For me, the industry’s presence was at its most influential during an event featuring IAEA Director General, Rafael Grossi, which was chaired by the FT’s Gillian Tett. Grossi said nuclear energy was providing three-quarters of the power needed to run COP26, according to regional grid statistics highlighted by the NIA. Indeed, on the first Tuesday of the summit, Scotland’s two nuclear stations, Hunterston B and Torness, produced approximately 70% of the electricity for COP. This fact, alongside an uncomfortable conversation on Fukushima, led Gillian to publish an article in the FT titled, ‘What I got wrong on nuclear power?’, in which she admitted her previous lack of understanding on the nuances of the arguments for nuclear power. She concluded with “It seems that other voices are coming around to [being pro-nuclear]. During the COP26 meeting, a host of EU leaders threw their weight behind nuclear, because it helps keep energy costs down for ordinary households. This is something that will be crucial if we are ever going to build broadbased support for an eventual phasing out of fossil fuels.” Gillian is representative of some members of the general public, and even some politicians that we engage with. With a lack of access to information on nuclear power and ingrained assumptions on its safety—balanced with the success of renewables over the last couple of decades—many ask what is nuclear’s role is in a modern, low-carbon energy system. The interaction proves that even a short, open conversation can have a significant and positive effect on the way people view nuclear power and its role in climate change mitigation. This, of course, highlights the importance of sustained advocacy, and at the (pun intended) coalface are the volunteers of the Young Generation Network (YGN)—most of whom are passionate
“We can now say with credibility that we have kept 1.5°C alive. But, its pulse is weak and it will only survive if we keep our promises and translate commitments into rapid action.” Alok Sharma COP26 President
nuclear professionals working in the industry today from around the world—and Nuclear for Climate, whose activities focused on stimulating conversation, whether that be through a flash mob on the streets of Glasgow, a 3-metre tall inflatable gummy bear or simply approaching delegates and offering to answer questions they had, however small or simple they may have been. Our Policy Analyst Georgina Hines was part of this group and experienced first-hand the benefits of speaking to delegates one-on-one, with most of her interactions ending positively. While she had hoped to educate people on the advantages of nuclear power, she went away with a better understanding of how and why the public view our industry the way they do. On the decisions made at the end of the conference, COP26 President Alok Sharma said: “We can now say with credibility that we have kept 1.5°C alive. But, its pulse is weak and it will only survive if we keep our promises and translate commitments into rapid action. Before this conference, the world asked: do the parties here in Glasgow have the courage to rise to the scale of the challenge? We have responded. History has been made here in Glasgow.” I strongly believe a bit of history was made by our colleagues who attended and worked on nuclear’s inclusion at COP26. We are and will continue to be a key part of the conversation thanks to their hard work. It shows what can be done with positivity, strong collaboration and a never give up attitude. It bodes well for the COPs to come, which will be framed by the need to move to phase from to phase out. So the work in Egypt, and the UAE, over the next two COPs will be in countries that are developing nuclear power for the first time to help address the threats of global warming. Governments could learn a lot from what the nuclear sector has achieved this year at COP as they work together on the ambitious targets of the Paris Agreement. Whatever their chosen route, and however long it takes them to get there, we know that Net Zero needs nuclear, and now they do too.
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BY. IOLO JAMES / MEDIA & COMMUNICATIONS MANAGER
We all know we need to cut carbon dioxide emissions and phase out fossil fuels. It’s a mammoth task, but we must act now. In a brand-new video, put together by the NIA and Nuclear AMRC, we explain how that can be achieved, focusing on the vital role nuclear is, and will continue to play in combatting the climate crisis. The challenge we set ourselves was to explain why net zero needs nuclear in 90 seconds or less, and to cut through all the noise surrounding COP26 by putting the video in front of people who may not necessarily know that much about our industry, but who care about the climate. Tim Chapman from the NAMRC, co-produced the video and explained that back in the mid-noughties, he gradually came to realise that we “couldn't realistically hope to decarbonise without new nuclear.” He went onto say, “a lot of people haven't yet come to the same conclusion—particularly among younger generations who might be fully committed to decarbonisation but don't see nuclear as part of the solution.” Struck by the IMechE survey last year which found that people aged 18-24 are the least likely to understand that nuclear is a low-carbon power source, he explained how the campaign video, launched in the run-up to Cop26, was “designed to help shift that perception, and get people to check out the facts for themselves.” Indeed, the sector knows what nuclear can do, but we must go beyond that, to cast our net wider, and be bold. Head to netzeroneedsnuclear.com and watch it for yourselves. Here’s what was written to accompany the video… The UN’s Intergovernmental Panel on Climate Change (IPCC) say the evidence for humanity’s effect on the climate is unequivocal. To give us the best chance of avoiding the worst effects of unchecked global heating, we need to limit the increase in the Earth’s temperature to 1.5 degrees C. To do that, many countries, including the UK, have committed to reducing their net greenhouse gas emissions to zero by 2050. This is a huge economic, social and technological challenge.
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For the UK, it means doubling our electricity output to power transport systems, heating and industry, at the same time as phasing out the fossil fuel power stations which currently provide half our electricity, That means we need to quadruple our production of low-carbon electricity. Meeting that challenge will take a mix of technologies. Wind and solar will play a huge role, but can only produce power when the wind blows or the sun shines. Smart grid systems, large-scale batteries and other energy storage technologies can help smooth out the peaks and troughs, but significantly add to the cost of renewable power and are not available at the scale required.
Why nuclear? Nuclear is the only proven low-carbon generation technology which can provide reliable baseload power to balance the variability of wind and other renewables. In terms of greenhouse gas emissions per unit of power produced, nuclear is as clean as offshore wind—around 12g per kilowatt-hour, which is significantly better than other energy technologies. Nuclear currently makes up around a third of the UK’s low-carbon generation. But all our current nuclear power stations are set to close well before 2050—the 7.7GW AGR f leet by 2030 (Dungeness B has already ceased production), and the 1.2GW Sizewell B PWR around 2035. As a country, therefore, we urgently need to invest in new generation – wind, solar, nuclear, and any other viable technology that can help us reach net zero emissions. Nuclear makes economic as well as environmental sense. New designs of reactor can match offshore wind in cost per unit of power. That cost includes all the additional investment in waste management and eventual decommissioning, something which no other technology does. Nuclear power also provides more employment per megawatt capacity than any other generation technology, and can create high-value jobs across the UK.
MEDIA WATCH NEWS
BY. IOLO JAMES / MEDIA & COMMUNICATIONS MANAGER
COP26, the energy crisis and the government’s announcements on new nuclear has meant this has been a busy period for the NIA on the airwaves. The Glasgow climate event was the perfect backdrop for the NIA’s Chief Executive, Tom Greatrex, to react to the news that Rolls-Royce had secured match funding for their SMRs, which enables them to kickstart the next phase of the process. In appearances on BBC World News’ World Business Report and on the BBC News Channel and BBC Two in the UK, Tom expressed the significance of the news and the vital role smaller stations will play in securing a net zero future, alongside larger stations.
Check the facts Don’t just take our word for it. To find out more from reputable organisations which don’t have “nuclear” in their name, check out the links below: → The National Grid, the UK’s electricity system operator,
explains the basics of nuclear power (www.nationalgrideso. com/news/electricity-explained-nuclear-power.) → The Prospect trade union explains why new nuclear is
essential to beating the climate crisis (https://prospect. org.uk/get-involved/climate-crisis-why-new-nuclear-isessential-to-meeting-net-zero-emissions.)
→ The
Energy Systems Catapult’s Innovating to Net Zero report (https://es.catapult.org.uk/reports/innovating-to-netzero) sets out a range of possible pathways for how the UK can achieve net zero emissions by 2050—in the centralised ‘Clockwork’ pathway, nuclear provides up to half of total electricity generation.
→ The
UK’s independent Climate Change Committee also modelled pathways to decarbonisation which showed the need for new nuclear power stations—see their latest Carbon Budget for details (www.theccc.org.uk/publication/sixthcarbon-budget.)
→ This
modelling has informed the UK government’s Energy White Paper (www.gov.uk/government/publications/ energy-white-paper-powering-our-net-zero-future), which emphasises the role of nuclear in the low-carbon energy mix.
→ Internationally, the IPCC has produced a range of pathways
(www.ipcc.ch/sr15) of how the world’s economies can limit global heating to 1.5C, with different assumptions about technological and social changes. All call for more nuclear.
→ And
the International Energy Authority’s roadmap to net zero by 2050 (www.iea.org/reports/net-zero-by-2050) calls for nuclear alongside solar, wind, hydro and bioenergy. Also check out the IEA’s paper on nuclear power in a clean energy system (www.iea.org/publications/nuclear.)
Just days before the climate summit kicked off, the NIA had one of its best coverage days, with a strong, positive reaction to the announcements of a new funding model for nuclear, and the £1.7 billion of new government money to help get a new large-scale station to a Final Investment Decision. Tom Greatrex described it as a “big vote of confidence in nuclear and a historic step forward for nuclear investment.” He was quoted on BBC News Online, ITV, The Guardian, The Times, The FT, Daily Mail, Telegraph, Bloomberg and Business Green. To show the importance of nuclear in keeping the COP26 lights on, we produced a video showcasing just how vital Scotland’s two power stations were in doing just that. Nuclear power provided approximately 70% of the electricity for COP at certain times and our video explained how much Torness and Hunterston B have contributed in delivering enough clean electricity to power every home in Scotland for nearly 60 years, saving 400 million tonnes of CO2 and providing thousands of green jobs. Head to our Twitter of LinkedIn to watch! The NIA made its Sky News Daily Climate Show debut when Tom Greatrex was interviewed about the government’s Net Zero Strategy. On a visit to Sizewell B he told Sky’s Science and Technology Editor that nuclear is a long term solution for the energy crisis, which saw gas prices sky-rocket: “What we’ve seen in the last few weeks is what happens if you’re overly reliant on importing gas and at the same time a lot of your power coming from variable sources. Consumers are affected most by the price rises that nobody can control. Nuclear gives you reliable, low carbon power with a very predictable cost.” As the energy crisis sharpened the focus on the need for nuclear as a stable and sovereign source of clean energy it gave the NIA a media platform. With appearances on BBC News, GB News and Welsh language TV and radio, as well as press releases and data analysis explaining the volatility of gas markets, the NIA was busy in making the case for new nuclear in the UK across numerous platforms.
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For full versions and more details on these and other stories please visit www.world-nuclear-news.org
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Construction of CAREM-25 to restart A contract has been signed to complete the main concrete works of Argentina's CAREM-25 small reactor. Henisa Sudamericana will employ up to 250 workers in the work. First concrete was poured in February 2014, but the project was suspended on several occasions for breach of the construction contract. In November 2019, work was halted due to late payments from the government, design changes and late delivery of technical documentation. In April 2020, it was announced that construction was to resume.
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Canadian waste storage project completed A project to relocate low-level radioactive waste from historic Canadian radium and uranium refining operations to a new, above-ground long-term storage facility has been completed, with the final layers of topsoil and grass placed on the engineered mound. The capping and closure of the mound at the Port Granby Project Long-Term Waste Management Facility completes a project begun in 2016.
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The project has involved the transfer of about 1.3 million tonnes of contaminated soil and industrial waste from a legacy storage site to the new facility, where maintenance and monitoring will continue far into the future. The historic waste is from radium and uranium refining operations from the 1930s to 1988.
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of loss of active cooling. Such fuel may incorporate the use of new materials and designs for cladding and fuel pellets. Framatome, GE/GNF and Westinghouse are all developing ATF concepts for light-water reactors, with the help of funding from the DOE, and Russian fuel company TVEL is developing ATF for use in Rosatom's VVER reactors and in western PWRs.
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Framatome ATF assembly loaded in PWR
Greater independence for nuclear regulator
Framatome announced its first 100% accident tolerant fuel (ATF) assembly has been delivered to Exelon Generation's Calvert Cliffs nuclear power plant in Maryland. The assembly—described by the company as a nuclear industry "first"—was loaded into one of the plant's two pressurised water reactors during a recent refuelling outage. The first complete fuel assembly builds on previous work that included completing an 18-month fuel cycle test on an LFA in the USA and Switzerland. The assembly was fabricated at Framatome's manufacturing facility in Washington, as part of a 2019 contract with Exelon Generation. ATF designs aim to enhance performance during normal operations at nuclear plants and provide operators with more time to respond in the event
The Hungarian parliament has adopted changes to the country's Atomic Act which will give the Hungarian Atomic Energy Authority (HAEA) more control over its structure and staffing. The changes appear to be a response to missed deadlines for decision-making on the Paks II new build project. The amendments would make HAEA "more organisationally independent", following the parliamentary approval on 9 November. HAEA will "determine its own organisational structure within the framework provided by law." An application for the plant had been submitted in July 2020 and procedures allowed the HAEA 12 months to make its decision, with the possibility of extension by three months. The first extension was triggered in July this year.
Why Nuclear For Net Zero?
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A new Hub for the NIA BY. IOLO JAMES / MEDIA & COMMUNICATIONS MANAGER
Why Nuclear?
Membership
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NUCLEAR Most sustainable POWERING ' LIVES PEOPLES
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we’ve saved more carbon for the UK than anybody else – 2.3 billion tonnes
one nuclear fuel pellet the size of a thumbnail could drive an electric car 20,000 miles
our lifecycle carbon is the lowest of any source – 6g/kWh for Sizewell C
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JACOBS TO DESIGN KEY SAFETY FEATURE FOR ITER FUSION PROJECT
CAVENDISH NUCLEAR AWARDED £10 MILLION HINKLEY POINT A CONTRACT
JACOBS JOINS NUCLEAR AMRC TO DRIVE SUPPLY CHAIN INNOVATION
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Most Most e. pulled ective he industry together during COP, notpowerful only in
Most sustainable reflecting the direction in which the industry is going, which
advocating the benefits of nuclear in the fight against will make navigating the site a far better experience for those we’ve saved more carbon one nuclear fuel pellet the size our lifecycle carbon is the lowest climate change, but also in creating spaces in which who visit. After all, it’s an important online space, and for many for the UK than anybody of a thumbnail could drive an of any source – 6g/kWh for else – 2.3 tonnespractice. There was electric car 20,000 miles C call for the industry. that advocacy could bebillion put into a physical people it’s the first Sizewell point of presence, with several events on the ground in Glasgow, crissFrom journalists looking for media releases, to those in need READconference MORE > MORE > READ MORE crossing the main zones and the city atREAD large. more information about the> industry, we wanted a site that But that was not all. There was also an important virtual hub, a best tells the story of nuclear in the UK and which does so in one-stop shop for delegates, or anybody for that matter, to learn an engaging and accessible way. It was important, therefore, more about nuclear’s role in creating a greener future. Created by that the site help put the industry’s best foot forward and kept DISCOVER MORE > Why Join the NIA? industry and the Department for Business, Energy, and Industrial our messaging clear, concise, and easy to follow. Strategy, the hub rallied around our key message—Net Zero We are perhaps most excited about the creation of The Hub, The Nuclear Industry Association is a highly to e. ective advocate, Needs Nuclear—and brought together on one platform, all the a new addition the site which will be home to all the latest a dynamic and credible information explaining why that is indeed the case. industryproviding news and events. This is where member stories will voice on behalf of its membership. A real success, the site boosted nuclear’s prominent place go, along with the NIA’s press releases and key NIA events and at COP26 and we thank all our members who helped put the dates and information how to sign up to them. VIEWimportant THE HUB > site together.The Hub.Today Of course, our members are the most aspect of JOIN NOW > But that isn’t the only hub-related news we have in this the NIA, and we have a brand-new member area, with all the edition. And spoiler alert… will have functionality of the previous site, but with added panache. The source for updates you in the nuclear industrymost probably have already seen it, but we do love some fanfare here at the NIA, so If you haven’t done so yet please visit the site and let us know I’ll just get on with it. We have a shiny new website. what you think. We hope 2022 will be a big year for the industry, NIAUK.ORG has had a refresh, and we couldn’t be happier and the new NIA hub will play a vital part in communicating, with how it’s turned out. It has a fresh look and modern feel, advocating, and supporting the sector’s next steps.
2021 | WINTER — 7 NEWS / 21ST AUGUST 2021
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Using data analytics to improve project management in the nuclear industry:
Life beyond the dashboard?
BY. TOM EASTUP & JAN SKONIEZKI / PA CONSULTING
T
he nuclear industry is poised to play a significant part in the UK’s journey to net zero but is hampered by historic underperformance in delivery, and consequently has a poor reputation. As opportunities for new projects emerge, both in decommissioning and new build, building trust in the sector to deliver will be critical to securing the public and private funding required to make these projects happen. But the nuclear industry has a consistency problem when it comes to delivering projects and programs—and we don’t seem to be getting any better. One factor that could change this is that digital transformation within the engineering, construction and project management sectors is increasing the amount and quality of tools, techniques, data and delivery approaches available—and these are creating entirely new capabilities.
they are delivered becomes volatile, uncertain, complex and ambiguous (VUCA—a term coined by the US military). Complex programs typically have dense interdependencies and exhibit complex system properties. This means that when one element changes (scope for instance) this can lead to non-linear change propagating throughout the ‘system’. For program leaders, this can quickly lead to programs becoming unpredictable and extremely challenging to manage. It is therefore becoming increasingly difficult to make well informed, timely decisions and achieve successful outcomes, and this is impacting organisations’ revenue, return-on-investment and reputation.
WE’RE STRUGGLING TO GET BETTER AT DELIVERING PROJECTS AND PROGRAMS
Data analytics can have a significant impact on improving decision-making. PA Consulting’s innovative flexible modelling and analytics solutions have helped inform critical ministerial decisions, strategic program delivery and target setting for the UK vaccination program, directly driving the administration of more than 9 million vaccines in the first two months. In the nuclear industry, there is unexploited value in the data generated and held by projects, but also within the systems of interactions connecting the building blocks of major programs. Unlocking this value will enable leaders to make better decisions, and improve the performance of their projects, program and portfolios, and ultimately, maximise return on investment. Whilst we see the primary benefit of data analytics as helping nuclear project and programme leaders make better decisions, there are other potential benefits too:
While there are lots of examples of good practice and performance in project and program delivery in the nuclear sector, unfortunately some of the highest profile projects/ programs have not performed well, and some have even been abandoned—which could reflect a lack of confidence in the sector’s delivery track record. The reality is that despite the advances in project/program management methodologies (enabled by digital transformation), we don’t seem to be improving at delivering these kinds of complex major programs. In 2021 the UK Government’s Major Projects Portfolio comprised 184 projects totalling £542 billion in whole life costs. According to the UK Government’s Infrastructure & Projects Authority (IPA), nearly four fifths of these have significant issues or are unlikely to deliver successfully. Previous years’ data show similar results—indicating a lack of progress. In addition, analysis by Oxford University’s Said Business School concluded that for all nuclear power projects contained within their database, there were cost overruns in 100% of projects, while schedule overruns occurred in 90% of projects. Whilst this database isn’t UK specific, and doesn’t capture every project the industry delivers, this is still a sobering statistic.
WHAT AREN’T WE IMPROVING MORE QUICKLY? Nuclear industry projects and programs are becoming more and more challenging as the external environment in which
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IS DATA ANALYTICS THE ANSWER?
→ Free up PMO teams’ time to do other more valuable work by speeding up or automating analytical tasks → Improve morale by automating monotonous repeatable tasks → Unlock entirely new capabilities not previously available by blending different technologies and analytics techniques (e.g. monitoring construction progress intelligently and automatically using camera footage from drones) → Reduce intervention times on emerging risks or issues, reducing their cost or schedule impact by speeding up data acquisition and interpretation → Reduce waste due to re-work by predicting areas of scope where this is more likely
LIFE BEYOND THE DASHBOARD? The dashboard is now ubiquitous amongst project and program teams for visualising management information. Dashboards add value by distilling and visualising key data in a meaningful way so that it can be used by decision makers to course correct or respond to emerging issues (this is known as descriptive analytics). However, most dashboards have a key limitation in that their datasets are a view of the past, providing only hindsight. Some organisations have driven further value from data exploring interdependencies and their effects on performance in ways not previously done (yielding insight). Yet in most nuclear industry organisations, dashboards and the data processes that sit behind them currently do little to provide foresight. There will always be a need for management information, including historical data, and dashboards (or visual reports) are an excellent medium to display these—especially if they are intuitively designed. But, we must look beyond dashboards that contain solely linear historical data if we are to truly realise the potential of data analytics in the nuclear sector. Achieving this is not necessarily about gathering more sources of data (although we believe there are unexploited sources available, which we explain below), but rather extracting greater insight, or even foresight, from the sources we have (or could have) access to. For instance, historical performance data does not tell us what is happening within a project, it just tells us how the activities of the project within its environment have manifested themselves in a range of pre-defined metrics (such as Earned Value Metrics CPI and SPI).
We argue that this does little to help a decision-maker to make corrective action, because the ‘why’ is missing. Similarly, historical data shows a trend, which can be (and often is) extrapolated into the future. But historical data can be mistaken for future certainty, and as today’s world is more ‘VUCA’ than yesterday’s, we must find new ways of understanding and dealing with that uncertainty. Below we outline key data analytics and artificial intelligence techniques including—but also beyond—dashboards (descriptive analytics), and their potential use cases in projects and programs in the nuclear sector. Descriptive analytics involves collating and presenting data to enhance its meaning, often using data visualisation techniques/ software. Example use cases include project performance and progress reporting (e.g. dashboards using PowerBI), analysis of drivers and root-causes of past performance. For example, we helped the Foreign and Commonwealth Office drive prosperity and combat global poverty more effectively by building a cloud-based system called Prospero to monitor and report on the performance of programs across its £1.2 billion Prosperity Fund. Its analytics let civil servants, ministers, diplomats and other officials track exactly where money is spent and the results of spending that money. Predictive analytics involves using historical data combined with modelling to predict future performance. This can deploy machine learning, which uses models that iteratively learn from data and can find hidden insights without being told where to look. Use cases relevant to nuclear sector projects and programmes include modelling of multiple future performance scenarios to ascertain risk or uncertainty or machine learning applied to historical project data (time, cost, benefit) to forecast future performance. Prescriptive analytics involves solving to identify a preferred solution or course of activity based on a set of defined input parameters, and can include neural networks, complex event processing and machine learning. Use cases relevant to nuclear sector projects and programs include developing smart recommendation engines for advantageous purchasing of commodities (such as steel) as market prices fluctuate, or identifying optimum combinations/
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Image by Tung Nguyen from Pixabay — https://pixabay.com/users/tungnguyen0905-17946924
The idea of using data analytics to support the management of projects and programs is not new, nor is the knowledge and understanding of data science and systems thinking techniques. However, it is worth defining what we mean by data analytics when applied to project management. Data analytics is systematic analysis of data or statistics used for the discovery, interpretation, and communication of meaningful patterns or insights to aid effective decisionmaking, and is often confused with artificial intelligence. The two are different—artificial intelligence is an umbrella term for wide-ranging computer science techniques to build smart machines capable of performing tasks that typically require human intelligence.
sequencing of activities based on strategic priorities or constraints. For example, we helped a utility company think about everything at the same time when considering their asset maintenance portfolio. We built a portfolio optimisation engine that delivered multi £m annual cost savings and improved the return on investment from multi-year investment decisions by solving for optimum portfolio composition and timing, using a multivariate constraints and parameter input framework for each portfolio. Computer vision involves the automatic extraction and analysis of digital images and videos, enabling for example significant automation opportunities in complex environments. Use cases relevant to nuclear sector projects and programs include digitising legacy engineering documentation (e.g. scans of power station as-built drawings) to embed in new digital workflow and document management. For example, we helped a large engineering asset operator develop a high performing automated digitisation of thousands of paper engineering drawings, and save 26 weeks’ work of expert time each year. Natural language processing (NLP) is used to “make sense” of semi or unstructured natural language data—textual and auditory. Most NLP techniques rely on machine learning to derive meaning from human languages. Use cases relevant to nuclear sector projects and programs include automatically scanning project baseline documentation following a change control, to rapidly ascertain the impact of a contractual change. For example, we developed and delivered a proof of concept enabling automated review of nuclear safety case documentation for a UK decommissioning organisation, which reduced the time needed to review a single document from hours to seconds. Robotic process automation(RPA) is a technique that enables the automation of digital workflows using a combination of user interface technologies. Use cases relevant to nuclear sector projects and programs include automatically generating project progress reports that extract data from a variety of software. BIM, GIS and Digital Twins use geospatial, geometric or physical performance data to define or model physical assets or environments. Use cases relevant to nuclear sector projects and programs include optimising construction or logistics sequencing using digital twins of whole sites or using GIS data captured from drones or satellites to monitor progress or weather risks. For example, we built a digital twin to optimise the maintenance of a steam distribution sub-system for a nuclear operator, identifying £2 million savings per year on the subsystem alone (around 3% of the overall system).
OVERCOMING BARRIERS TO INNOVATION AND ADOPTION OF DATA ANALYTICS IN NUCLEAR PROJECTS Apart from a few leading edge organisations and technology startups, scaled adoption of these disruptive techniques is yet to happen. That slow pace of adoption indicates that this isn’t a data science problem, the technology, methods and knowledge are available, rather it is an innovation problem. It is clear that there are a number of barriers to innovation and adoption including problems with data sharing, a lack of incentives and limited knowledge and focus on what is available. Below we expand on these, and explain how these could be overcome in the nuclear sector to realise the value of data analytics to drive decision making.
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Fragmented and unexploited data—think big, start small Data is held on different platforms, often within different organisations, and the variety of project management software used creates silos that often require manual intervention when amalgamating data. With any emerging field, the number of software developers will only increase, further fragmenting the market creating a need to develop ways to work with varying data sources. Building PMO teams with skills in coding could become the norm in future to address these challenges. In addition, commercial sensitivities in current contracts make it hard to share data. Developing novel commercial constructs that unlock the sharing of data across organisational boundaries will be key. Whilst the idea of data trusts is being discussed, we are a long way from this becoming the norm in nuclear sector commercial agreements. The other side to this is data that is available but we are not currently exploiting. Projects and programs are mature in their capture and analysis of cost, schedule and risk data. There are emerging technologies that are trying to make use of real world data (e.g. drones to support decommissioning project planning), but also other sources such as public sentiment which could be harvested using techniques such as data mining and sentiment analysis. The way to overcome these barriers is to think big but start small. Leaders should create an ambitious vision, but start with a pilot or number of pilots and don’t be afraid to fail. Decrease the time to value by delivering benefits as quickly as possible to maintain momentum, these are change initiatives after all. Innovation is hard, and it’s not incentivised in a project environment—change needs to be led from the top Developing and adopting disruptive technologies is challenging (the Technology Readiness Level valley of death is a well-known phenomenon), especially in highly regulated industries such as the nuclear sector. In addition, project and program leaders are measured on their ability to drive towards certainty—of cost, schedule and benefit outcome. Innovation (trying and testing new technologies that could improve project delivery) is inherently risky, and so why would a project manager want to try something new and risk not achieving their objectives, when they are comfortable they will achieve them without the new technique? To overcome this barrier requires support from the top. Innovation is uncertain and some initiatives will fail whilst others succeed. There will be a cost to change, and leaders need to seek support from senior management to give them the freedom to experiment. Lack of understanding of (or envisioning) the art of the possible—acquire the right expertise Data science and use of advanced analytics is a relatively new field (in the context of the evolution of science and mathematics) and not a mature capability within most traditional project delivery organisations. The pace of change in technologies such as cloud storage has enabled storage and access to large volumes of data— but project and program leaders and organisations are struggling to explore the potential. This is largely due to a lack of knowledge, but also partly because organisations haven’t invested the time in creating a vision for how they will manage projects in the future. To overcome this barrier, organisations should bring in the knowledge to help them develop the art of the possible, based on their unique organisational context. This may be inorganic to begin with (e.g. experts or consultants) but eventually should shift to organically growing the capabilities of the future (e.g. coding and data science expertise within the PMO).
For further information, contact: uksales@mirion.com
Attention turning to Molten Salt Reactor technology BY. MIKAL BØE / CHAIRMAN AND CEO, CORE POWER
As world leaders met at COP26 recently to look to find new ways of reducing carbon emissions and slow down the increase in global warming, the shipping industry is under enormous pressure to eventually eliminate burning fossil fuels as a primary energy source.
The United Nations International Maritime Organisation (IMO) has set a firm deadline for shipping to achieve a 50% reduction in CO2 emissions by 2050, compared to 2008 levels. The race is now on to find the clean, green fuels and emission free propulsion to radically change shipping and build a sustainable industry for generations to come. Now with additional pressure from governments at COP 26, the IMO will likely have to reach interim emission reduction targets in 2030 and 2040. To make green fuels sustainably you need a reliable ‘energy rich’ power source to produce green hydrogen, ammonia, and methanol. Wind power and solar provide intermittent power and are good supplemental sources of energy. To produce the enormous volumes of green fuel required to power more than 100,000 ships a long term, clean energy source is required. Molten Salt Reactor (MSR) technology can revolutionise the commercial shipping industry to make the largest ships faster, cleaner, and more efficient. Initially powering floating production platforms to make hydrogen-derived green fuels for smaller vessels and once licensed and approved, eventually to provide onboard electric propulsion power for large ships.
How nuclear energy can transform commercial shipping MSR is a disruptive technology that can put a new competitive edge back into global trade, of which shipping is the backbone since 90% of all international trade is carried at sea. The shift to advanced nuclear will be as revolutionary as the sail-tosteam transition of the 1840s because the MSR technology can make ships faster and vastly more efficient. For the nuclear industry, it’s a unique opportunity to create the ultimate mass production system around a hugely positive, deep-impact narrative. If we can build MSR technology and the ecosystem for deploying it, this can provide enough durable, clean power for large boxships to do ‘30 knots for 30 years’. In addition, we believe that ships powered by advanced nuclear can easily provide 100% clean electric power to the ports they call at.
From diesel to clean sailing The big transition Diesel engines onboard large container ships burn as much as 200 tonnes of fuel per day, producing over 600 tonnes of CO2. That's both very polluting and extremely expensive.
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To save on costs and reduce emission, ships designed to sail at around 25 knots have been doing 15 knots or less. That has slowed down supply chains and more ships were built to accommodate demand. At COP 26 the reality of carbon taxes and pollution penalties, moved a step closer which will be passed on to consumers and cause inflation in the price of industrial components and durable consumer goods as the cost of commercial shipping increases.
Increasing supply chain velocity As container shipping struggles to overcome systemic issues such as port congestion, container shortages and schedule delays, having the speed that an MSR powered vessel allows, will reduce a transatlantic voyage by five days. This also provides serious competitive advantage in a cut-throat business. Having that kind of speed means shippers could avoid the Suez Canal altogether, saving themselves USD1.5 million in transit tolls and the possible delays that such chokepoints represent. MSR would keep powering these ships for 30 years without refuelling. Fuel left over from and MSR would be recycled into new generations of MSRs.
Commercial shipping meets the nuclear industry Shipping can cope with terrible weather, rough seas, wars, famine and even pirates - and to design and use durable systems, reliable standards, classification rules, insurance models and legal frameworks to create the safest mode of transport that exists today. If you can then add a fuel efficient small atomic power system, then you can have the best of both worlds, resulting in a container ship that travels twice as fast for twice as long.
MSR minimal waste With this new technology and research, we have been able to maximise the fuel efficiency of the MSR, which produces minimal end-of-life residue. The total volume of spent nuclear fuel generated by all the world’s conventional reactors since the first pile in 1942, equals the volume of toxic sludge produced every hour from burning of coal to make electricity. Advanced nuclear can change all that.
Inherently safe technology In an MSR the fuel and the coolant are the same, so you can't lose either. The fuel salt, which is the coolant is impervious to radiation damage and remains chemically stable to be used and recycled for a very long time. An MSR operates with ambient pressure only and the fuel is always liquid when critical. At regular power, the temperature of the reactor would remain at around 600 degrees Celsius, which is double the temperature you can get with a pressurised water reactor. MSR reactors will be used until the vessel is decommissioned, the MSR and fuel, can then be recycled for the next generation of reactors and next generation of ships.
New civilian platform for atomic marine sector Nuclear-powered ships have so far mostly been naval defence but advances in nuclear technology now offer the possibility for commercial applications. We believe this is a perfect civilian grade technology that neither threatens the tactical superiority of a nuclear navy, nor poses a threat to the peace and stability of port states. Those tasked with handling export controls and licensing can be fully confident that civilian nuclear propulsion is proposed for all the right reasons. Every reactor is carefully controlled, monitored, and managed by vetted, qualified personnel, and it being installed only on floating assets that are flagged in appropriate jurisdictions like the USA, the UK and France or, less obviously, Japan, which is one of the largest shipping nations.
Failsafe as standard - all eventualities
Any MSR used in a maritime application will be located deep inside the hull and at a long distance from the reactor shielding wall to the edge of the hull. Accidents at sea do happen - ships sink, ships catch fire, ships collide - but an MSR will always be well protected and in the event of a catastrophic emergency, shut itself down thanks to its passive safety characteristics. The idea is that even if there is no crew left onboard, the reactor system is passively shut down, and left to cool inside the reactor compartment, without polluting the environment. There's no gas pressure in an MSR and therefore no way for radio toxins to be expelled into the environment. The MSR fuel would simply cool until it's a solid rock, and that solid rock should be entombed inside the reactor vessel. If the ship sinks, the MSR will remain in its box. A ship may be lost at sea and may sink to 8000 metres on the ocean floor, but even then, it would not pollute the environment.
Development Timeline The reactor development team aims to have a proof-ofconcept for the MSR ready by around 2025. Core Power aims to have the new classification (design and operational) rules for maritime assets available to the market by 2023. The classification and insurance rules will come together for the 2024/2025 work stream at the IMO. That process should take about five years, with demonstration projects at sea for the MSR by the turn of the decade. We are now building meaningful relationships across a broad set of stakeholders in the maritime and nuclear sectors so that we are ready to rumble when the green light comes on.
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IN VIEW
Teaching a new dog nuclear tricks A robot dog could soon be sniffing out hazards at Europe’s most complex nuclear site. Spot the robot dog has been going through its paces at Sellafield as part of an active demonstration. Sending robots into hazardous environments is nothing new at Sellafield. A fleet of land, air, and underwater vehicles are already contributing to the site’s decommissioning and clean-up mission. Using robots for routine tasks in hazardous environments removes people from harm’s way and frees them up for more urgent tasks. But before technology can be deployed on the site it must be rigorously tested. Spot underwent three days of trials at Calder Hall, the former nuclear power station which is now being decommissioned. The demonstration was held in conjunction with US manufacturer Boston Dynamics, Cumbria-based engineering consultant Createc, and the UK Atomic Energy Authority (UKAEA.) Calder Hall’s former turbine hall provided the perfect tricky terrain to test Spot’s agility. If successful, Spot could join Sellafield’s fleet of robots, carrying out tasks like inspections and data capture across the site.
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or quite some time now the Government has been warned about how vulnerable the UK is to fluctuating international gas supplies and prices. We have also stressed how regularly importing high volumes of electricity can leave us too dependent on our neighbours. Finally, study after study has predicted that a high penetration of renewables on a system sees system costs increase because of the backup required to balance the Grid. What nobody thought was that the UK would succumb to all three of these premonitions in the same week, and that week just so happened to be during our inaugural Nuclear Week in Parliament. There’s nothing like a crisis to focus minds, especially when every MP will have been inundated with messages from constituents concerned about their energy bills. Politicians and journalists who had never before spoken about price caps or the energy market suddenly had to be experts. Secure, clean, domestically generated energy was the topic of the moment, and it was great to be able to capitalise on that during our week of events. Getting back in the swing of doing physical events in Parliament was incredibly exciting for us public affairs and policy types. While the NIA had relatively good results with online meetings, briefings and APPG sessions, there’s nothing quite like the real thing. The week itself was made up of receptions themed around net zero and the British nuclear industry, and also a showcase of the industry’s best and brightest future workforce at a Skills and Apprenticeships Fair. The aim of Nuclear Week wasn’t just to hold receptions, it was to give a platform to industry, and it was great to see so many companies hold their own complementary events on the fringes. None of this would have been possible without the support of our sponsors, including Rolls-Royce, Atkins, Westinghouse, the NDA, Jacobs, NAMRC and EDF. Nuclear Week and Rolls-Royce’s SMR programme even got a mention in PMQs, which really added a nice touch to all the work we have put in with politicians. The NIA builds up these relationships with MPs and Peers by doing the diligent bread-and-butter work of positively engaging with Parliamentarians. One of the best tools we have is our Jobs Map, but we also research what other interests might overlap, such as climate change, hydrogen or apprenticeships. What Nuclear Week also showed was the power of our membership in drumming up support from politicians. A number of attendees at our Skills and Apprenticeships Fair got in touch with their MPs to let them know they would have constituents in Westminster, and they duly turned up to hear about the great work they do in the nuclear sector. Similarly, following on from our events, several MPs have been on site visits to facilities they otherwise wouldn’t have known were in their area.
The bottom line is this, it’s as simple as sending an email, and I encourage anyone reading this who feels their local MP isn’t supportive enough of the nuclear industry to drop them a line. NIA members are always welcome to get in touch with us if you want any advice on key talking points. Hot off the heels of Nuclear Week was Party Conference season. After a fallow year, there was plenty of catching up to do. As has become the norm, the NIA held fringe events at both the Labour and Conservative Party Conferences. Labour, by its nature was dominated by events on the conference f loor, the Party is in a very different place than two years ago, with significantly fewer MPs and a resurgent centre trying to wrestle things back from the left. Adding to the drama was a Shadow Cabinet resignation from a role nobody knew existed. I’m pleased to say there was no such drama at our event, which we held in partnership with Dods. Speaking was GMB General Secretary Gary Smith, Warrington North MP Charlotte Nichols, and our own Tom Greatrex. While the Parliamentary Labour Party has struggled to work out why they have lost every seat with a generating nuclear site, support remains strong from the Trade Unions, and their efforts have ensured that the frontbench position on nuclear improved significantly in the weeks following the conference. Conservative Conference was quite a lively one, it was the first since Johnson’s General Election win of 2019, but also came off the back of his big speech to the UN, in and around which were multiple positive mentions of nuclear as the energy crisis deepened. Would the Government intervene in the market? Would they cut VAT on energy bills? This was truly a time of seeing the cost of decades of inaction by multiple governments, and the spotlight was focussed straight on the Prime Minister. Our fringe event, in partnership with The Spectator was very well attended, and not just because of the free G&Ts! The conversation centred around current energy affairs, and nuclear’s role in providing security of supply. Our Tom was joined by the Telegraph’s energy correspondent Rachel Millard, Ynys Môn MP Virginia Crosbie and Professor Jim Watson from UCL. In and around the hubbub of Nuclear Week and Party Conferences was an interesting pre-COP26 pledge: the UK would have a net zero electricity supply by 2035, an announcement which seemed to surprise many in the civil service, given how much low carbon capacity is coming offline this decade. The Government’s pledge of getting “at least one” large scale nuclear project to FID in this Parliament looks a little bit modest when put in this context. Nevertheless, there is yet to be any indication that there will be anything more than Sizewell C being considered for the time being. Which begs the question, what will be keeping our Christmas lights on in 2035?
BY. IEUAN WILLIAMS / HEAD OF POLICY & PUBLIC AFFAIRS
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IN CONVERSATION ... ROBBIE HUSTON
obbie Huston is the coordinator for Trade Unionists for Safe Nuclear Energy (TUSNE). TUSNE are a campaign group of trade unions that represent many thousands of workers in the civil nuclear sector. TUSNE aims to promote the wellbeing of the nuclear industry and its employees. Robbie joined the nuclear industry as a mechanical fitter at the Capenhurst uranium enrichment plant in 1975. He then became a shop steward before progressing to site convenor. As a mature student he studied Politics at Liverpool John Moores University, graduating in 1997. Since then, he has been a public affairs manager at BNFL and the NDA, working with stakeholders, government, parliamentarians and trade unions.
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CAN YOU TELL US ABOUT TUSNE, ITS HISTORY AND PURPOSE? TUSNE was a response to growing calls for the closure of the UK’s civil nuclear industry following the Chernobyl disaster in 1986. Trade union members working in the industry became fearful of large-scale job losses and severe economic damage to their communities. We did what trade unions do in such circumstances—we campaigned to save our livelihoods. TUSNE, which at the time predominantly consisted of national officers representing the trade unions in the industry, set out to explain the safety record of nuclear, plus its energy and economic values. As an aside, I have to mention that alongside TUSNE a grassroots campaigning group called the National Campaign for the Nuclear Industry formed from workers in the industry. They had the ever-irresistible argument that “If we thought the UK nuclear industry is unsafe do you think we’d subject our families to such a threat?” The nuclear industry, in its relatively short life, has been subject to massive public scrutiny, possibly like no other. The threat of closure for different reasons has never been far away and I suppose that’s why TUSNE has been such an enduring entity. Although I think there is a far greater acknowledgement now of nuclear’s safety record, we continue to campaign to ensure that employees in the industry and future generations can contribute to the benefits nuclear brings to their communities, the nation and the world. TUSNE nowadays a much broader organisation and has the support and involvement of lay-representatives from employers from across the UK - EDF, Sellafield, Magnox, NNL, Rolls-Royce to name just a few.
WHAT ARE TUSNE’S KEY PRIORITIES AT PRESENT? Quite simply sustaining the nuclear industry in the UK. We’ll do this by taking our case to fellow trade unionists, politicians and
“TUSNE IS DIFFERENT FROM OTHERS ADVOCATES OF NUCLEAR ENERGY. WE REPRESENT THE VIEWS OF THE WORKFORCE—THE PEOPLE WHO HAVE SUCH AN INTIMATE UNDERSTANDING OF THE INDUSTRY AND ITS VALUE”
the public. We have a great story to tell. The industry never gets the recognition it deserves for the economic and environmental benefits its brought, and can continue to bring, to this country. So whether it’s small or large scale new nuclear build, manufacturing the fuel, decommissioning the legacy or managing the waste, our members will be putting the case forward.
WHO DOES TUSNE WORK WITH TO ACHIEVE ITS GOALS? Firstly, it’s important that we work with the nuclear industry at large, of which many are our employers. We share the same goal—a safe and sustainable industry. We want well paid, good quality jobs and the development of skills for future generations. These are interests we share with employers and will work with them to achieve; as we have in the past when the industry went through some very challenging times. Second, there are politicians who can influence and shape policy. And it’s politicians from all parties! It’s good to see we have good cross-party support. We have been able to depend upon stalwarts like Ian Liddell-Grainger for support for decades and now on fresh support from the likes of Charlotte Nichols.
WHAT CAN TUSNE OFFER IN TERMS OF ADVOCACY THAT OTHERS CAN’T? TUSNE is different from others advocates of nuclear energy. We represent the views of the workforce—the people who have such an intimate understanding of the industry and its value.
The workers’ voice is like no other. Our representatives are accountable to their members who, in turn, are accountable to their families and their communities. Our unique circumstances give us a strong and independent voice.
LOOKING TO THE FUTURE, WHAT WOULD TUSNE LIKE TO SEE IN 2022? For a start, a greater recognition of the massive contribution the nuclear industry and its employees have made to mitigating climate change and providing a secure, always on, source of electricity for the UK. In terms of tangible progress, it will great if the Moorside and Wylfa Newydd projects are re-started and progress continues with Sizewell C. These, of course, will all be dependent on the Regulated Asset Base Financing Bill having a safe passage through Parliament. The situation at Springfields continues to be a worry. We have a national asset that is in danger of perishing. If we are to have new nuclear reactors, the UK may find it will have to import its fuel if Springfields is not saved. I acknowledge it won’t be easy, but I hope we can find a solution that can keep this unique plant, with its loyal and skilful workforce, manufacturing fuel for the future. Finally, it will be remiss of me not include continued progress in the Geological Disposal Facility siting process. For too long the industry has been criticised for not have a longterm solution for managing radioactive waste. I hope 2022 is a year in which we can turn the corner on all of these.
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OPINION
SMRs and regulatory imperatives BY. SIMON STUTTAFORD & ANDREW RENTON / PRINCIPALS, CASTLETOWN LAW
This is a synopsis of Part II of a two-part guidebook looking at the future of nuclear power generation with a particular focus on Small Modular Reactors (SMRs). We look at the IAEA`s milestone structure and its potential application on SMR technology and propose an alternative regulatory structure for SMRs. The IAEA`s milestone structure identifies 19 topics that need to be revisited in the context of SMR technology deployment. 1. National Readiness for SMRs should be a less restrictive and
overwhelming undertaking than for large nuclear plants.
2. Nuclear Safety: the appropriate approach to equivalence
is a balance between protection and risks. The IAEA is moving in this direction with a proposal for SMR-specific Safety Standards.
3. Management of Process of SMRs at state and regulator
level may be more strategic by addressing the modular construction on the one hand and the operation, control and maintenance on the other.
4. Funding and Finance: SMRs have comparatively lower
capital requirements and an output price that is comparable on a levelised basis with other forms of power generation.
5. Legal Framework: SMRs can have simpler controls,
allowing consents for the development and licensing of SMR technology in a more streamlined but still robust process.
6. Safeguards: the application for SMRs is reduced as the
design includes inherent safeguards, based on a lower risk.
7. Regulation for SMRs can be modified by simple legislation
considering the level of risk, the nature of the technology and the siting of the technology.
8. Radiation Protection regulations should take into account
the technology applications, failure and emission risk profiles of SMRs.
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9. Electrical Grid: for SMRs could be a question of a
connection agreement between the local grid and network operator.
10. Human Resource: there is an opportunity for transferable
skills, upgrading of education and manageable envelopes of operation.
11. Stakeholders: Recognition of the breadth of stakeholder
groups in the host country and the COO is a critical feature of the approach to deployment of a fleet of SMRs.
12. Site and Facilities of SMRs are smaller, so there is reduced
exposure to seismic changes, to terrorist and aerial attack or accidents.
13. Environmental Protection means that SMRs will also go
through an Environmental Impact Assessment (EIA), but there is an argument that they may be treated differently.
14. Emergency Planning requirements for SMRs might be
reduced, due to smaller site and workforce, meaning a plan based on passive safety features.
15. Nuclear Security: for SMRs, due to the nature of the fuel
cells, their size and modes of transportation significantly enhances the security aspects.
16. Fuel Cycle Management in SMRs will be different from
large plants, its fuel cycle can range for close to a decade to the life of the plant.
17. Waste Management: for SMRs waste fuel can be stored in
safe facilities on site for the life of the plant or repatriated to the COO.
18. Industrial Capacity for the construction of pre-manufac-
tured modular units can be attained through training and education processes in addition to the COO training.
19. Procurement for SMRs should follow the IAEA approach.
This text is a synopsis of Part 2 of a two-part paper, the full version of which will be available online at: www.castletownlaw.com/recent-papers.
Some basic premises have to be accepted to bring the current regulatory processes to a uniform and universal approach. We suggest that it does not damage the integrity of the consenting and approvals process to allow a country to adopt the approval by another country. It is appropriate in our view to de-couple technology approval for SMR designs from site licensing.
National jurisdiction requirements We envisage a process where countries will work together to facilitate nuclear power generation under bi-lateral treaties and in compliance with the IAEA`s Milestone approach. We suggest an evolutionary approach to the current regulatory approach. In essence the current international requirements for nuclear power generation will remain, but with some additionality and modification to enable adoption and reliance on a “nuclear” country’s prior determinations, in compliance with IAEA standards.
Role of vendors/developers We see certain criteria being imposed on a vendor developer in countries other than their country of domicile: → Responsibility
for the operation, maintenance, management, and security of a facility. This liability may be capped but based on the Paris/Brussels criteria, a minimum liability of €700,000,000 should apply.
→ The
provision of financial and performance bonds, which can be accommodated within the regulations. Our suggestion is that these should be at levels commensurate to the risk of exposure to loss arising from nonperformance rather than absolute default.
→ The regulations will require some essential components: the
manufacturing of the nuclear component of the power plant; the manufacture and delivery and assembly of the nonnuclear part of the power plant; the fuelling and refuelling cycles; the operation of the plant; the oversight, good governance and reporting during the operational phase; the decommissioning and deconstruction of the plant.
→ The
method and regulation of offsite modular manufacture will be for the COO but the vendor developer must have a suitable quality assurance programme.
→ Regulations
in the COO for regulatory sign off on manufacture, transportation and post transportation inspection and checking, on site capability and competence and during assembly inspection reporting and precommissioning inspection and testing.
Manufacturing → Manufacturing
facilities must meet the relevant safety and security requirements.
→ The
manufacturing facilities will require careful and specific design and specification input.
→ The
manufacturing process will be open to inspection and certification.
→ Pre-shipping
inspection and certification and arrival onsite inspection and verification will be part of the manufacturing process.
Not all designs will lend themselves to a unitised manufacturing process. Where the manufacturing and site assembly do not lend themselves to a modular manufacturing process, the regulatory framework should be f lexible enough to accommodate the approach required, within reasonable boundaries.
Site considerations Onsite assembly should be the exclusive responsibility of the vendor/developer working with compliant local jurisdiction requirements, possibly subject to oversight by the Country of Origin (COO) regulatory and independent inspection regime: → The
site selection must be compliant with the appropriate standards and subject to independent third-party verification. Once licensed the site licence holder becomes responsible for all activities taking place on the site.
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→ Licensing
of the construction and operation of site should be unified in one process. This means the site will be licensed for the construction, commissioning and operation of the technology which is approved.
→ The
vendor/developer must have control and access to the site, including the security and the delivery of the modular construction, all subject to independent verification.
→ Pre-commissioning
and commissioning process should be subject to independent verification, audit and technical and legal opinions on the process.
→ First
fuel and start up will progress on an incremental basis with the failsafe shut down mechanisms applying on the instruction of the appointed independent inspector for a minimum of 1 year post start up.
Nuclear fuel and waste As the nuclear obligations are based on sovereign undertakings and liability, this aspect of the overall regulation must adhere to the accepted approaches although we make provision for a slight change so that the transporting company takes the risk in nuclear material during transportation. → The
nature and origin of the fuel must be clear and its stability for transportation assured.
→ The
receiving nuclear site power station must be fully compliant and certified.
→ Cooperation
between COO regulators, developer`s technical team, independent inspectors and Host Country regulatory bodies will be critical.
→ Refuelling
and repatriation of spent fuel to COO will be a key obligation.
Operation All applicable standards of safety and security should apply throughout the operation period. Where aggregation of additional units on one site is achievable, subsequent modular construction should then be able to be progressed while prior units are in operation. no less than the current requirement for safety and security as directed by the IAEA.
2. Design: Subject to Defence in Depth criteria. Where a
design is approved for construction in a signatory country to the Convention on nuclear safety by an independent regulator established within the IAEA guidelines, another signatory party may adopt the approval given, subject to any conditions which may be imposed at the discretion of the approving authority.
3. Construction: The authority granting approval of the
design may require staged hold points in the construction, but the inspection of the nuclear plant will only be of those parts which have nuclear material interface.
4. Commissioning: Licence holder is responsible for the
operation of the nuclear power generation plant on site. As part of the commissioning process each functional part of the safety and security system will be tested alongside each operational function of the plant independently and jointly. Both the authority granting the approval and the IAEA may attend on site at any time during construction, commissioning or operating to verify compliance.
5. Operation: The site licence holder shall not allow
any operation of the nuclear power generation plant on the licensed site except as may be approved in a commissioning plan.
6. Transportation and Management of Nuclear Material:
Subject to usual controls. Site Licence holder to establish that the transporter has the correct level of insurance and a licence to handle the material.
7. Safety Inspection and Records: Subject to inspection by the
relevant authority. Licence holder must maintain detailed and accurate records of all aspects of the operation of the plant including all incidents of any materiality to be logged on a real time basis on a digital format.
8. Reporting of Incidents/occurrences: Training and
reporting requirements to be put in place and maintained.
9. Decommissioning and Deconstruction: A fully scoped
Decommissioning plan maintained by the licence holder.
10. Risk, Liability and Insurance: Signatory to relevant
Convention on nuclear liability, relevant insurance and/or financial security in place and a claims management process.
→ Retain
→ Enshrine
those standards in a simplified generic statement applicable in any agreement, treaty, convention, legislation or regulation which is to apply.
→ Decouple
the process of regulation from the technical compliance issues which are dealt with in implementation of the regulations.
→ Simplify
the structure, wording and regulatory approach.
→ Use
a top-down structure so all signatories at top level may adopt all the provisions below.
Key requirements For these features, an assumption is made that the Host Country will be a signatory to the international instruments on Safety, Security, Safeguards and Liability. We suggest for discussion and development a framework for the IAEA or IEA to adopt as a basis for facilitating a regulatory regime for national regulation which will cover the following aspects: 1. Siting: Approval and grant of licence shall not be dependent
on the approval of the technology to be deployed.
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In our view SMRs merit a different approach to the current regulatory process and we have suggested some key principles in the development of a new process. In our view the current cumbersome processes, interlinking design approval to licensing of each site should not apply in the future. We consider the nuclear industry can regulate safely in the same way that aircraft and shipping has done. The process is not easy and is bound by the imperative of safety for all. There is no reason why the existing system of controls underpinned by the rules, treaties and conventions cannot be applied in a more streamlined and simplified way. This can all be achieved without reducing safety requirements. Such an approach would not reduce the state liability nor the licensed operator’s liability. It would potentially reinforce the endorsement of the COO approval process. The continuing IAEA oversight and unification of processes within a relatively short time would open the world markets to this much needed solution. The challenge is there to be met if the governments and financiers, UN and IAEA can step up to support those who can help solve the crisis the world is facing. We see the next step as the governments who are sponsors of the SMR technologies, persuading the World Bank, the IMF and other funding agencies to abandon the prohibition on funding of civil nuclear power and to endorse the modern technologies of nuclear as the future of a net zero world.
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NEWS IN BRIEF
Cavendish Nuclear using innovation and technology to drive forward net-zero emissions Cavendish Nuclear is delivering a two-year contract by U-Battery for supporting the design of an Advanced Modular Reactor (AMR), a type of advanced nuclear reactor. U-Battery is an advanced modular gas-cooled reactor, capable of providing a low carbon, cost effective, locally embedded and reliable source of power and heat for energy intensive industries and remote locations. Cavendish Nuclear is involved in a number of key areas of the conceptual design, including safety systems, auxiliary systems, refuelling and modular transportation of the plant. Cavendish Nuclear’s unique capabilities in design, operation and subsequent decommissioning bring comprehensive lifecycle expertise to the conceptual design process. The Cavendish Nuclear team is conducting a conceptual design for modular manufacturing based upon best industry practices and manufacturing methods. The work draws upon a specialist team at Babcock’s Rosyth facility, which is home to one of the largest modular manufacturing facilities in the UK. The site has embarked on a new era of digitising its facilities and systems to bring advancements and efficiencies into its manufacturing, build and assembly processes. This design project complements the full-scale, first of its kind, mock-up of the main vessels of the U-Battery AMR at Cavendish
The decommissioning of Oceanic Pintail has “set the standard others must follow” after 100% of the 3,865-tonne specialist nuclear vessel was recycled. Nuclear Transport Solutions (NTS), which operated Oceanic Pintail, set Dales Marine Services the challenge of ensuring 98% of the world-class cargo vessel was reused. Applying a number of innovative techniques, the Scottish firm exceeded expectations, and recycled every part of the Nuclear Decommissioning Authority-owned (NDA) Oceanic Pintail. Reusing 100% of a nuclear vessel is a UK first, and supports both the NDA group and Government’s carbon net-zero ambitions. Boasting a perfect safety record, the Japanese-constructed Oceanic Pintail first set sail 33 years ago. Since its maiden voyage, Oceanic Pintail has served customers from across the world with bespoke solutions to all specialist nuclear transport challenges, until its final journey to Dales Marine’s Leith dock in November 2020.
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Nuclear’s Whetstone Facility in Leicestershire in September of this year. James Ewence, Cavendish Nuclear’s New Build and Advanced Nuclear Technologies Director, said: “We are delighted to be working with U-Battery Development Ltd at our site in Rosyth, where we have extensive experience of modular build. “Combining our innovation and technology skills, we look forward to creating a design solution for the manufacturing of Advanced Modular Reactors whilst contributing to the Government’s commitment to net-zero.” The Department for Business, Energy and Industrial Strategy is investing up to £44 million in the AMR feasibility and development project, with the aim to maximise the amount of off-site factory fabrication. The UK is transitioning to net-zero emissions for the benefits of the environment, its people and prosperity. The UK’s worldleading climate change legislation sets a target date for net-zero emissions of all greenhouse gases by 2045. The Government published a Climate Change Plan update in December 2020, which reflects the increased ambition of the new targets set in the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019.
100% of 3,865-tonne specialist nuclear vessel recycled – a unique UK first
Capsa Solutions awarded £500k grant Capsa Solutions has been awarded a £500,000 grant from Innovate UK, the UK’s innovation agency, for a 2.5 year program to develop a waste container designed to meet the challenges of broad front nuclear decommissioning. As the UK moves towards Net-Zero targets, nuclear energy provides reliable low carbon power. Over the next 100 years, there is a significant program of decommissioning existing and legacy nuclear sites. This includes the general (broad front) work at Sellafield, as well as final site clearance of 17 Magnox reactor sites. The current estimate of the undiscounted total cost of cleaning up the UK’s nuclear liabilities is £119 billion for the Nuclear Decommissioning Authority (NDA) estate and £19.5 billionn for EDF’s Advanced Gas Cooled Reactor fleet and Sizewell B. It is currently estimated that approximately £5 billion will be spent over the next 100 years on nuclear waste containers. Capsa Solutions was born out of an industry challenge set by Sellafield Ltd to develop a safer, more cost effective and responsible means of disposal, transportation and storage of nuclear waste. Eadon Consulting collaborated with fabrication specialists Arc Energy Resources to form the joint venture; and together they have brought a unique combination of design and manufacturing experience to the project. The Nuclear Sector Deal (NSD) recognises there is an opportunity to improve taxpayer value from this significant spend and has set a goal to achieve a 20% reduction in the cost of decommissioning by 2030.
NIA member Castletown Law release a short film
Five sites shortlisted for UK fusion energy plant The STEP programme will pave the way to commercial fusion and a virtually limitless supply of low-carbon energy. Five sites have been shortlisted as the potential future home of the UK’s prototype fusion energy plant – the Spherical Tokamak for Energy Production, or “STEP”. The sites, listed here alphabetically, are: → Ardeer (North Ayrshire) → Goole (East Riding of Yorkshire) → Moorside (Cumbria) → Ratcliffe-on-Soar (Nottinghamshire) → Severn Edge (South Gloucestershire & Gloucestershire)
Fifteen sites were long-listed following an open call for sites between December 2020 and March 2021. Today, following an initial phase of assessment, the shortlist has been published. STEP is a government-backed programme to build a prototype fusion energy plant in the UK. The STEP plant aims to generate net electricity as well as demonstrating how the plant will be maintained and how it will produce its own fuel. STEP will create thousands of highly-skilled jobs during construction and operations and attract other high-tech industries to its host region, furthering the development of science and technology capabilities locally and nationally. Fusion has the potential to provide a near-limitless source of low carbon energy by copying the processes that power the sun and stars where atoms are fused to release energy, creating nearly four million times more energy for every kilogram of fuel than burning coal, oil or gas. STEP will pave the way to the commercialisation of fusion and the potential development of a fleet of future plants around the world. The UK Atomic Energy Authority (UKAEA) is targeting first operations in the early 2040s.
Those who say that nuclear power is not required need to wake up to reality! Meeting the 2050 decarbonisation targets will require #nuclear power. Castletown Law has released a short film which explains why this energy source is essential to achieving this goal. It deals with the many misconceptions of nuclear energy head-on and highlights why nuclear is an essential contributor! You can watch the video on the Castletown YouTube channel at www.youtube.com/watch?v=SRqvpx9fByw.
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Business Group Roundup BY. STEPHANIE MCKENNA / MEMBER RELATIONS MANAGER
Supported by
The world of events has slowly opened allowing NIA members to enjoy our business groups face to face again. Since the Business group summit in July, we have held our New Build group on Anglesey which was kindly sponsored by Vulcain Engineering welcoming a range of speakers themed around our host country of Wales. This included Ynys Môn MP Virginia Crosbie and sessions on Net zero, Wales’ energy future, nuclear technology in Wales and nuclear new build opportunities for suppliers. It was great to show support to the Island and what an island it is. The following week we met in Warrington for our Decommissioning and Existing generation group which was kindly sponsored by KBR. 120 members joined together to hear from the Nuclear Decommissioning Authority, Radioactive Waste Management, Urenco, Westinghosue and others. If
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you missed this the presentations from our business groups are available on the members side of our website. Next up was the turn of the joint International and Fusion event which went back to Wales, Cardiff. The event was kindly supported by Welsh Government, Wales Nuclear Forum and Assystem and the group looked at International AMRs & SMRs, working in Japan and what is happening in the fusion sector. We continue to run niche online events and share this information to our members through the NIA events page as well as our weekly updates. We are always keen to do more so if you would like to hear anything specific do get in touch. If you have missed any visit the members section of the website to catch up. We are also planning our Quality working group where we plan to discuss and share information on common quality/ supply chain challenges, share examples
of lessons learned / good practice, establish “common views” on issues of industry wide interest and receive input from other industry sectors. If you are keen to find out more, please get in touch. As this copy hits the desk/screens we will be thinking ahead to Christmas and family time but before too long the new year will be upon us, and the NIA will be full steam ahead preparing the next lot of events and business groups. I can’t wait for our DECOM2022 event which takes place in Telford on 2 February and will be followed by the NDA supplier event. All the information on these can be found on our website. Information on future business groups is well underway and we will share this over the forthcoming months. If you would like to be involved in any of the groups, speak, sponsor or suggest a topic do get in touch, I would love to hear from you.
“The savings achieved by automating repetitive, labour intensive processes, such as the sorting and segregation of radioactive wastes, will increase productivity, reduce the risk of human error and avoid exposing operators to radiological risk” Val Drake Waste Strategy Director, Cavendish Nuclear
Cavendish Nuclear recognised as innovators in waste sorting and segregation BY. YVONNE PRESTON / INTERNAL COMMUNICATIONS MANAGER, CAVENDISH NUCLEAR
Cavendish Nuclear announced it has been recognised as an innovator in the field of nuclear decommissioning after securing funding from the Nuclear Decommissioning Authority (NDA) and Innovate UK for a radioactive waste challenge. The Cavendish Nuclear led team brings together experts from parent company Babcock International, alongside the Bristol Robotics Laboratory, Clifton Photonics Ltd, Structure Vision Ltd and Iconsys Ltd, to develop the next generation autonomous waste sorting, segregation and packaging system known as OptiSORT. The work draws on experience from a number of successful complex waste retrieval design and build projects delivered by Cavendish Nuclear to support the decommissioning and site restoration programme at the Magnox Berkeley site. This experience helped inform OptiSORT development objectives to create a fully autonomous system by combining existing sensor technology and hardware, with an innovative control system to achieve real-time autonomous operation. The system will be capable of sorting, segregating and efficiently packaging radioactive wastes, straddling the Intermediate and Low Level Waste boundaries, without continuous human intervention or direction. The OptiSORT system is also expected to make a significant contribution to UK Nuclear 2050 and cost reduction objectives through step changes in waste management approaches. The aim of this phase of development is to provide a non-radioactive demonstration of OptiSORT to an expert panel, assembled by the NDA, who will judge the ‘fitness-forpurpose’ of our solution.
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To find out about the work of NIA and benefits of membership visit www.niauk.org/about-us/ membership-benefits. You will find more information on our business group meetings, monthly updates and our exclusive online trade directory. To discuss membership options available to your company please call +44 (0)20 7766 6651 or email stephanie.mckenna@niauk.org
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Cumbria O&M Services c-oms.co.uk
K-TIG k-tig.com
COMS are a leading UK provider of Operational, Maintenance and Engineering services to regulated industries nationwide. Their expertise covers pre-operations, commissioning, start-up, asset management, maintenance, engineering support and training. They currently provide services at Sellafield and LLWR.
K-TIG are the developers and owners of an innovative Keyhole TIG welding technology which increses quality, reduced defects, reduces time and saves money in fabrication. K-TIG signed an R&D MoU with the Nuclear AMRC and will be developing 'turnkey solutions' for the manufacture of Nuclear waste stoarage containers.
CTS Logistics cts-logistics.co.uk
Mona Lifting monanuclear.wales
CTS specialises in the movement of all classes of dangerous goods, including UN Class 7 radioactive and nuclear materials for the Energy sector. Combining the benefits of the security profile of CTS with our ADR capabilities to handle your radioactive and nuclear consignments, including High Activity Sealed Sources and Type B flasks, CTS is the partner of choice to provide compliant transportation.
Since our inception in 2005, Mona has been closely associated with the nuclear industry. Our experience and expertise in bespoke lifting and materials handling equipment, and the design and installation of specialist cranes, have allowed us work with partners in the nuclear industry across the UK and Europe. We work to exacting quality and safety standards, and are able to engage directly with power station operators as well as providing expert consultancy and manufacturing to principal contractors and other stakeholders.
BakerHicks bakerhicks.com BakerHicks are a design, engineering and project delivery company specialising in complex infrastructure, process and built environments across the full project life cycle. Our disciplines range from initial architecture to civil and structural, mechanical and electrical services, specialist high voltage, EC&I and process engineering services, supported by programme/project management, and CDM consultancy, using the latest innovations in Building Information Modelling (BIM) for the most efficient and cost-effective design.
Circular1 Health circular1.com Circular1 Health is a revolutionary testing service company, born out of the COVID-19 crisis, which has responded to critical businesses which must remain operational by necessity and nature, such as the nuclear and energy sectors. Circular1 Health offers a fully managed service, providing all elements of the science, infrastructure and highly trained staff. We provide reporting and results, and certification to customers, management of data and digital applications to enable a simple and smooth process all the way through.
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Holtec Britain holtecinternational.com Holtec Britain is a nuclear supplier focused on nuclear waste management and waste containers, waste processing, irradiated fuel flasks and containers and decommissioning. As a subsidiary of Holtec International, Holtec Britain is also preparing for new build construction and commissioning as we evaluate the UK market for Holtec's SMR-160 reactor.
newcleo newcleo.com newcleo is the clean and safe nuclear technology company. Privately funded and headquartered in London, newcleo was launched in 2021 to be a disruptor in the field of nuclear energy. Its mission is to generate safe, clean and inexhaustible energy for the world, through a radically innovative combination of existing, accessible technologies.
A “BIG MONTH FOR NUCLEAR IN THE UK” BY. LINCOLN HILL / DIRECTOR OF POLICY AND EXTERNAL AFFAIRS
“BIG MONTH FOR NUCLEAR IN THE UK £1.7BN ALLOCATED FOR A NEW LARGE-SCALE NUCLEAR POWER STATION NEW NUCLEAR BILL TO BOOST PRIVATE CAPITAL + CUT BUILD COSTS £210M TO BACK @ROLLSROYCEUK SMALL MODULAR REACTOR PLAN £120M FOR FUTURE NUCLEAR PROJECTS #NETZERONEEDSNUCLEAR ” Kwasi Kwarteng, Secretary of State for Business, Energy and Industrial Strategy
For this edition’s column, it gives me enormous satisfaction to quote the Secretary of State when he said it was a “Big month for nuclear in the UK”: As a nuclear industry, we have had our best few months since 2013 at least. The announcements have arrived like buses, and we’re happy to get on board. They show conviction on the part of the UK Government that nuclear is essential to our net zero future. They support the confidence of the finance community that nuclear projects will be investible propositions. They also show an ambition for the UK to be a leader in nuclear technology again. The £1.7 billion allocated for a new large -scale station is, as our Chief Executive Tom Greatrex said, a historic step forward. The money represents the first direct government investment earmarked for a new nuclear project in more than 25 years. It could go a long way to cutting that critical cost of capital, and in giving investors the confidence that the Government believes in nuclear and means to get new stations built. That confidence can also help control financing costs and making nuclear power cheaper. The Regulated Asset Base Bill, which we have called for as a leading priority for months if not years, should have the same effect. The small revenue stream it allows during construction should reduce borrowing costs and deliver
savings of at least £30 billion over the lifetime of a project. The RAB model is also a known quantity for investors, as around £160 billion of assets in the UK operate under this basis. This record, combined with the sharing of risk between public and private sectors, can further improve investor confidence in UK nuclear projects. The cash for SMRs will build momentum for Rolls Royce and the consortium through the crucial development phase, and show investors that the Government is serious about nuclear as a green technology. SMRs present a further opportunity for exports of British nuclear IP, to a market that could be worth hundreds of billions. Dozens of nations around the world are looking at nuclear as a clean, reliable, sovereign energy option, and SMRs are ideal for those particularly with smaller grids. Lastly, the Future Nuclear Enabling Fund worth £120 million sends a signal that the Government wants to seek out solutions for nuclear development and help support them. That marks a key change in thinking, with the public sector taking a more active role in pushing clean technologies toward deployment. As we look to bring new nuclear back to a golden site like Wylfa, this support is most welcome. Why the flood of good news? First of all, credit to the hard work of people across the industry in sustaining the case for nuclear through thick and thin.
Second, the energy trilemma—how to make energy sustainable, affordable and accessible, and sovereign. Nuclear is the only technology that provides one solution to all three parts. As the gas crunch has sent emissions, prices, and grid instability skyward, policymakers have seriously evaluated what nuclear offers. The interconnector outage and unfavourable weather conditions have then intensified the urgency of investment in reliable, predictable power sources. Energy has a real impact on living standards in the UK and all over the world, and having control over those costs holds a great deal of political attraction. To that, we can add the thousands of well-paid, long-term jobs that nuclear projects bring, and the winning formula starts to emerge. From there, it has been refreshing then to see the Leader of the Opposition, Shadow Chancellor and Shadow Business Secretary, as well as the Prime Minister and Kwasi Kwarteng, talking about the importance of nuclear investment, and when the chips are down, support nuclear financing legislation going through Parliament. This broad-based support provides the industry some security for the vital long-term projects on which we are about to embark. As we have learned from many false dawns, nothing is in the bag until it’s in the ground, but there is real cause for optimism as we approach the New Year.
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TO INNOVATE | TO CHANGE | TO SUCCEED
DECOM2022 attracts delegates from across the decommissioning sector, nationally and internationally. The NIA’s conference is run by the industry, for the industry. This conference will be a platform for discussing lessons learned and progress across the industry. With an international audience of 300, more than 12 high-profile speakers and an extensive range of corporate sponsors and exhibitors, DECOM2022 will be the essential event of 2022. We will discuss how we leverage innovation and embrace the changes we are facing as an industry to become an increasingly more efficienct, effective, and attractive market for talent and investment.
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