How to get new nuclear built faster
Let's allow any design approved in the US or Europe to be built in Britain
Back when he was Chief Scientific Advisor Sir Patrick Vallance made a rather smart suggestion: that medicines already recognised as safe by regulators in places like the EU, US, or Japan should be automatically approved as safe in the UK.
It is hard to argue with his logic. The sooner Brits get access to life-saving drugs the better. But at the moment, drug companies are unlikely to prioritise regulatory approval in the UK over the US or Europe for the simple reason that there are more Europeans and Americans (who by the way pay a lot more) than there are Brits. As a result, there was a risk that Brits would be left at the back of the queue for new medicines.
To be clear, any drug approved as safe and effective in Europe or America is extremely unlikely to be rejected by our own regulator down the line. So by automatically approving drugs approved in the US or EU, what’s known as unilateral recognition, Sir Patrick’s plan would cut unnecessary delays and get drugs to patients sooner.
There’s an added bonus too. If the MHRA, the UK’s medicine regulator, no longer has to review applications that have already been approved elsewhere, then it can use that capacity to do really innovative and useful things like developing new approval pathways for precision medicine.
The case for unilateral recognition for medicines was overwhelming so at the last proper Budget the Chancellor Jeremy Hunt announced that the Government would fully adopt Sir Patrick’s drug approval plan. Yet Sir Patrick’s arguments for unilateral recognition apply way beyond just medicines.
The case of nuclear
When it’s completed in 2028, Hinkley Point C in Somerset will be the first nuclear power station built in Britain in over three decades. It will also be the second most expensive nuclear power station built in history on a pound-for-megawatt basis.
In fact, at a cost of £32bn (£10m per MW) Hinkley Point C will cost 5 times more than it costs to build a new nuclear power plant in South Korea.
Hinkley Point C uses EDF’s EPR-1750 reactor design, while South Korea uses KEPCO’s APR-1400 design. South Korea’s reactors are extremely reliable with unplanned outages causing about three times fewer capacity losses than in the US and six times lower than the UK’s fleet. Yet, if South Korea’s KEPCO wanted to build a nuclear power station in Britain, it’d have to be prepared to wait.
Before you can even apply for planning permission to build a nuclear power station in Britain, you need to have completed a Generic Design Assessment. In essence, at an early stage you share your design with the Office for Nuclear Regulation (ONR) and the Environment Agency (EA) who then assess the design on the grounds of safety, environmental impact, and waste management. It’s a lengthy process that typically takes four years. Since the process was created, only four reactor designs have been approved (there are two small modular reactors, known as SMR, designs going through the process currently). Yet, KEPCO’s APR-1400 isn’t one of them.
So if South Korea’s KEPCO wanted to build a reactor in Britain, they’d have to wait at least four years before they could even lodge a planning application – itself, a long, expensive, and bureaucratic process with an outcome that’s far from certain to be positive.
Learning-by-doing
Part of the reason why South Korea’s costs are so low compared to the UK is that they build fleets of reactors rather than one at a time. Every time they build a reactor they learn something new and become productive.
Hinkley Point C by contrast is the first nuclear power station built in the UK in decades. But, even over a single project massive efficiency gains from learning-by-doing can be achieved. For example, EDF claims that welding for the second reactor is being done four times faster than for the first reactor.
One major driver of Hinkley Point C’s costs is that EDF were effectively forced to build a first-of-its-kind reactor design by the Office for Nuclear Regulation. To win regulatory approval in the UK, EDF had to make roughly 7,000 design changes from the reactor design they use in France. Not only do the design changes mean that 25% more concrete and 35% more steel is needed during construction, but also that many lessons EDF have learnt the hard way in France can’t be easily applied in the UK.
Are we ready for SMRs?
And as the nuclear industry looks to move to the next generation of small modular reactors, regulators like the Office for Nuclear Regulation and the Environment Agency will have their work cut out for them. Two have already come forward, but there are a number of SMR builders who will be likely to lodge applications.
Unilateral recognition offers a solution. Why not automatically approve designs accepted as safe elsewhere in the world by respected regulators like the US Nuclear Regulatory Commission?
Applying this approach to nuclear power would have a number of benefits. Unilateral recognition on reactor safety would mean that tried-and-tested designs such as KEPCO’s APR-1400 could be brought to the UK in at least four years less time than it’d currently take. After all, KEPCO’s APR-1400 was approved as safe for use in the US in 2019.
But this wouldn’t be the only benefit. It would also free up our regulator to focus on investigating and reviewing new SMR designs instead of duplicating work done by other regulators.
There’s an opportunity for the UK’s nuclear regulator to play a globally important role in the development of SMRs. The ONR already takes a relatively unique approach to nuclear regulation. Rather than setting specific rules (e.g. reactor walls need to be this thick) the ONR’s approach is goal-based (e.g. can you survive a 1 in 10,000 year earthquake). You might quibble with the goals (and the evidential burden reactor designers face to prove they can meet them) but it opens the door to genuinely innovative new approaches to reactor design. Britain could be the global destination for SMRs as a result, but only if the ONR has the spare capacity to do it.
Do we really want our regulators to spend years doing something their American equivalents have already done? Or would we rather that they focused on investigating the designs of new SMR startups? I think the answer is obvious.
The good news is that in their recently published Civil Nuclear: Roadmap to 2050, the Department for Energy Security and Net Zero made a commitment to maximise the use of “regulatory assessments undertaken in other countries on designs proposed for Britain”. Depending on what this means in practice, this could really speed things up.
There might be some complications, admittedly. Just as with medicines, there might be UK-specific concerns, such that the regulators are entitled to insist on more information for example around impact on nature. In practice this might mean unilateral recognition of nuclear design regulation might work more like a fast-track where UK regulators grant approval in principle, but on top of that add a small amount of UK-specific scrutiny.
By providing clean, reliable baseload power, nuclear will play a vital role in keeping the lights on while we transition to a Net Zero energy system, yet at the moment there’s not a clear plan to actually deliver the threefold increase in nuclear the government has promised for 2050. If nuclear costs remain at Hinkley Point C levels (or get worse) then we are at serious risk of more energy bill misery.
A plan to get nuclear costs down is desperately needed. There can’t be a better place to start than removing a regulatory barrier to a low-cost tried-and-tested design that’s been approved as safe by the US and the EU. Adopting the same approach we are already taking to medicines to nuclear power would do just that.
Astonishingly, Great Britain was the first nation to build a grid scale nuclear power plant - Calder Hall.
It was decided by the UK Government to proceed with the civil nuclear power programme in 1952, and construction at Calder Hall began the following year.
Construction began in 1953 and was carried out by Taylor Woodrow Construction using 1950s engineering and construction techniques, was completed in 1956 and was officially opened on 17 October 1956 by Queen Elizabeth II.
Originally designed for a life of 20 years from respectively 1956-1959, the plant was after 40 years until July 1996 granted an operation licence for a further ten years.
The station was closed on 31 March 2003, the first reactor having been in use for nearly 47 years.
So four years from conception to going on line, taking three years to build.
Says it all...
I wrote a submission to the TxP Progress prize on a very similar basis but with additional suggestions around locating these reactors on MOD land to bypass certain planning restrictions
https://open.substack.com/pub/penthouseprocrastination/p/nuclear-britain?r=3hckn&utm_medium=ios&utm_campaign=post