HORIZON NEWS - 01.02.2018

Statement and letter from Horizon in relation to today’s (1 February 2018) Daily Post article on radioactive waste:

“How and where to deal with radioactive waste for the long-term needs to be the subject of serious and considered debate. We offered in our response to Dr Clowes to discuss this issue with him in person but regretfully he instead chose to give an incomplete account of our position through the press, free of any context. We are now making the full letter public so people can see all that we said for themselves.

Radioactive waste has been stored safely and securely at Wylfa for decades and this will continue to be the case with Wylfa Newydd. However this is only part of the answer and we fully support the policy of both the Welsh and UK Governments that geological disposal is the safest long-term option. There is a strong and clear international consensus around this point and independent studies in the UK have also confirmed this.
 
Equally we are clear that where to site a geological disposal facility must be based on the principle of volunteerism, with local communities themselves deciding if they wish to even consider involvement in the process. The Welsh and UK government consultations currently underway are based firmly on this approach and we fully support this being a choice for Anglesey and its elected representatives.”
 
Letter

Dear Carl,

Thank you for your letter dated 29 September 2017, and apologies for the delay in me being able to reply to you.

Due to work and family commitments I was unable to get to the exhibition in Newborough, although I visited Fukushima in March this year, so I’ve seen for myself the scale of the issues facing the community and heard first-hand accounts from local people there who I spoke to.

Although my diary can be challenging, I would be very happy to meet you. In the meantime, thank you for setting out your questions, which I have answered below.

1. Horizon Nuclear Power Wylfa Ltd will be the Site Licensee responsible for the operation of the Wylfa Newydd plant once it is built. Irrespective of the final investors in Wylfa Newydd, Horizon Nuclear Power will remain the sole operator of the plant; it will not be operated by any foreign utility. 

Within Horizon we already have a wide breadth of operational staff who have many years of experience in the running of nuclear power plants. We’ve already started recruiting the wider operational workforce, including local experienced operators from Wylfa, and our technical apprentices who will be trained to maintain the plant. We have a number of years to train our staff to the high standards and expertise demanded by Horizon, and required by the Office for Nuclear Regulation, and we will achieve this in formal partnerships with internationally accredited training partners and operational partners.

It’s my job to make sure our operational workforce is ready for the operational phase of Wylfa Newydd from the mid-2020s onwards for at least 60 years. Regarding experience of operating the reactor technology itself, operational experience is a transferable skill. It’s like a 747 pilot retraining to fly an Airbus A380 – he or she is qualified, but needs training and experience on the specific aircraft type. This process is currently underway and will be ongoing as we ramp up our recruitment, and subject to a rigorous examination phase and successful completion – with Regulatory approval required – the person is formally authorised as competent to operate the plant.

You could also take examples of former Magnox staff who relocated – and retrained – to operate the PWR at Sizewell B, the only reactor of that type currently in the UK as it happens.

2. I’ve spoken to our sole Horizon representative at the Llangefni event you refer to, Richard Foxhall, and nobody approached him with questions or comments there.

Under legislation introduced by the UK Government, we are not able to even begin construction of Wylfa Newydd until we have produced – and had independently verified and approved - what is known as a Funded Decommissioning Plan. This will include an agreed waste management and decommissioning plan covering technical plans, cost estimates and independent funding arrangements to cover costs (in effect a ‘pension plan’ for the plant) . We cannot agree this level of detail without, of course, knowing the volumes of waste that will be produced.

We have submitted our Radioactive Substances Regulation Environmental Permit application to Natural Resources Wales, who are currently consulting with statutory and non-statutory stakeholders, and the public. Our application is available on our website at: www.horizonnuclearpower.com 

This is one of a number of permits that we need in order to operate Wylfa Newydd. The application outlines the expected total activity and volume of individual radioactive waste streams and spent fuel, to be generated over a 60 year period. This is based on the radioactivity of the waste at the point of generation, and does not take into account radioactive decay over the operational life of the station.

3. Dr Jones would have made his comment to you from an informed position. I would absolutely have no hesitation in agreeing with him.

4. Hitachi has made it very clear from the outset when they acquired us in 2012 that the business strategy would be looking to bring other investors on board ahead of the construction phase of Wylfa Newydd. It shouldn’t be a surprise to anyone when new shareholders in Horizon are announced. I don’t believe that the recently-announced off-shore energy contracts threaten the viability of our plans as, while we take nothing for granted and will continue to make the case for new nuclear, it continues to have cross-party-political support from the UK Government.

The UK needs a diverse mix of low-carbon electricity generation sources in order to meet its climate change commitments.  Nuclear’s ability to deliver high volumes of stable, low-carbon electricity makes it a vital part of the country’s current and future energy mix, playing its role to ensure a stable baseload supply. The ‘strike price’ has to take into consideration the development costs of any project, and these will vary from project to project.   However, we have always understood that it is a basic requirement of success for Wylfa Newydd that we achieve a fair and competitive price for the project.

We will continue to work together with all parties to drive costs down and deliver at a price that works for government, consumers and our investors. So no, I don’t think it threatens the viability of our Project.

5. The UK currently does not possess the capability to supply nuclear power stations to the industry, and needs new nuclear as part of the future mix of low-carbon generating capability.

I am entirely satisfied that Horizon will be utilising Japanese nuclear technology, specifically the Advanced Boiling Water Reactor as this technology has been built four times previously, each time to schedule and cost. We are confident the business risk can be managed adequately, while geologically the UK is in a region of low seismicity.

The mean height of the power station site is 15 metres above sea level, while the plant and its structures will be robustly designed to withstand a ‘once in 10,000-year event’, and incorporating ‘lessons learned’ from the Fukushima event in 2011 relating to, for example, the site layout design. Further confidence in our design can be gained from the Generic Design Assessment of the UK ABWR carried out by the technology provider, Hitachi-GE, while recommendations contained within the ‘Japanese earthquake and tsunami: Implications for the UK nuclear industry Final Report’ by the then HM Chief Inspector of Nuclear Installations, Dr Mike Weightman are also fully considered in the design of the plant (http://www.onr.org.uk/fukushima/final-report.pdf).

Regarding the Contract for difference, or ‘strike price’, each different low-carbon project of whatever technology will negotiate individually to reflect the cost of investment. Each project will have its own challenges and I’d expect to see a range of agreed prices across the wider low-carbon energy sector.

6. It isn’t Hitachi’s intention to sell Horizon after Wylfa Newydd has been established. As mentioned previously, it’s always been Hitachi’s intention to sell shares in Horizon, and whatever the share ownership position, Horizon will remain as the ‘enduring entity’ at Wylfa Newydd, under the full regulatory scrutiny of the Office for Nuclear Regulation and Natural Resources Wales.

7. Safety and security are and always will be our number one priority. The reactor control and information systems are not physically connected to the outside world, thereby negating the potential of a cyber-attack.

Aircraft impact is clearly a matter of foremost consideration in the design and regulation of nuclear plants. It has formed a significant aspect of the regulators’ Generic Design Assessment (GDA) of the UK ABWR, which was successfully concluded last week.

The next step in this process will be a detailed process of site-specific licensing, which will include consideration of the specific local hazards around Wylfa Newydd.

I assume when you say ‘climate change’ you refer to rising sea levels. The site is already 15 metres above mean sea level, and key buildings on the site itself will be raised, and watertight. A recent international research study led by Royal Netherlands Meteorological Institute - (A high-end sea level rise probabilistic projection including rapid Antarctic ice sheet mass loss, Environmental Research Letters [2017] https://phys.org/news/2017-04-sea-metres.html#jCp) - estimates that by the year 2100 oceans could rise by 3 metres, which is well below the base level of Wylfa Newydd. Full assessments of flood risk etc will be conducted as part of our consenting application process.

Processes and procedures for the management, processing and disposal of spent fuel and radioactive waste have been developed over the last 50 years or so, are very well understood, and subject to Regulatory approval and scrutiny - it’s been dealt with safely on the island for over 40 years already.

Very Low Level Waste will, as is current practice, be dispatched to licensed landfill sites, while Low Level Waste will be dispatched to the LLW Repository at Drigg.

Intermediate Level Waste and spent fuel will initially be stored safely and securely at the Wylfa Newydd site until such time as they can be dispatched to the proposed Geological Disposal Facility proposed by UK Government. We are currently obliged to make provision to store these on site for up to 140 years after the end of generation. Again, climate change does not present a credible risk in this regard.

I’ll ask my Executive Assistant to contact you shortly to arrange a meeting. You’d be very welcome to visit my office.

Regards,

Greg Evans,
Operations Director,
Horizon Nuclear Power Ltd