After a two month wait, the UK/Ireland Nuclear Free Local Authorities has just received a cryptic reply from Labour’s Nuclear Minister in response to our concerns about the future of Britain’s aging ‘Advanced’ Gas-Cooled Reactor (AGR) plants.
Four AGR plants – Hartlepool, Heysham-1, Heysham-2, and Torness – remain operational, each equipped with two gas cooled reactors. They first began generating in either 1983 or 1988, with an estimated operational life of 30 years. The plants are currently expected to cease operations by 2028, but in the Labour Party energy manifesto ‘Mission Climate’, the party pledged to ‘extend the lifetime of the existing plants until 2030’.
The AGR fleet has been operating for many years longer than intended. The NFLAs are concerned that the graphite moderators within each reactor are degenerating, compromising safety. We have previously raised our concerns with senior officials in the Office for Nuclear Regulation (ONR). It is our view that it is this independent regulator which has the expertise and the legal responsibility to determine whether to further extend the operating dates that should do so, and that it is ‘frankly not the business of Ministers’.
Consequently in his letter to Nuclear Minister Lord Hunt, NFLA Chair Councillor Lawrence O’Neill posed the central question:
‘Can the Minister therefore please reassure me that Labour Ministers will not seek to apply pressure on EDF to make an application to operate these plants beyond 2028, unless they genuinely wish to do so, and more importantly will not apply pressure on the independent regulator ONR to automatically sign off on any application without rigorous scrutiny?’
In his reply, Lord Hunt says cryptically that:
‘Decisions regarding the future operation of the Advanced Gas-cooled Reactor fleet or any nuclear power station in Great Britain would be for the operator, EDF Energy, (and) the ONR. The ONR would not allow a reactor to operate, return to service or extend its operating life if it judged that it was not safe to do so’.
We are hoping that the Minister means that it will fall to the operator EDF Energy to determine if it wishes to apply to the ONR for permission to extend the operating life of any, or all, of the AGR plants, but that it will be the responsibility of the ONR to decide if it can grant that permission based upon the safety case submitted.
This is a situation that the NFLAs shall continue to watch.
Ends//..For more information contact NFLA Secretary Richard Outram by email to richard.outram@manchester.gov.uk
Note to Editors
Letter sent to Nuclear Minister Lord Hunt 22 August 2024
The Rt Hon Lord Hunt of Kings Heath OBE,
Minister of State for Energy Security and Net Zero,
Department for Energy Security and Net Zero
C/o Ministerial Correspondence Team
Dear Minister,
I am writing to you as Chair on behalf of the UK / Ireland Nuclear Free Local Authorities. May I firstly congratulate you upon your appointment within the new Labour Government, and secondly state that the NFLAs look forward to working with you and your Ministerial colleagues over the coming years.
For your information by way of introduction, the Nuclear Free Local Authorities were established in 1981 as the collective voice of local authorities opposed to nuclear power and nuclear weapons and in favour of renewables and peace. Our membership comprises local authorities in Scotland, England, Wales, Northern Ireland and the Republic.
Our Secretary, Richard Outram, is a member of the DESNZ NGO Forum. This letter represents a follow up to the question Richard posed to you at a meeting of the Forum on 30 July relating to the concerns we all share about the continued safe operation of the Advanced Gas Cooled AGR reactor fleet in the UK:
In the Labour Party energy manifesto ‘Mission Climate’, it states that the Labour Government would ‘extend the lifetime of existing plants’ until 2030.
The Advanced Gas Cooled Reactor fleet has been operating for many years longer than intended and the graphite moderators in these reactors are now fracturing compromising safety.
The Nuclear Free Local Authorities have raised our safety concerns with the Office of Nuclear Regulation.
The ONR is now requiring the operator EDF to carry out regular safety checks and report back.
EDF must demonstrate to the ONR if they wish to continue operations beyond the agreed closure date of 2028 that they can do so safely.
It is up to the independent regulator to determine if this is so and is frankly not the business of Ministers.
Can the Minister therefore please reassure me that Labour Ministers will not seek to apply pressure on EDF to make an application to operate these plants beyond 2028, unless they genuinely wish to do so, and more importantly will not apply pressure on the independent regulator ONR to automatically sign off on any application without rigorous scrutiny?
Minister, if you will please bear with me, I should like to outline what our safety concerns are.
Hartlepool, Heysham-1, Heysham-2, and Torness, each equipped with two gas cooled reactors, first began generating in either 1983 or 1988, with an estimated operational life of 30 years.
Over 300 fuel channels and 10 layers of graphite bricks make up the core of each AGR. Operator EDF Energy has described the graphite structure as ‘the major safety requirement of the core’. [i] Each graphite brick is loosely connected to its neighbouring bricks by graphite ‘keys’ and there are also ‘keyways’ at the top and bottom of each brick. The continued integrity of the structure is vital to operational safety as it provides pathways for the fuel rods, which generate the fission reaction, to be loaded and for the control rods, which moderate the reaction, to be inserted.
Over time and due to operational stresses, the bricks begin to crack, and the mass of the graphite also suffers a reduction through a process called ‘radiolytic oxidation’. Although there are tolerances, a high failure rate, particularly of the ‘keyways’, would compromise safety if control rods can no longer be inserted. EDF Energy conceded in 2014 that ‘Brick cracking could be one of the lifetime-limiting features of the AGR’.[ii]
The function of the graphite core and the impact of aging is detailed by the Office of Nuclear Regulation (ONR) on its website:
https://www.onr.org.uk/civil-nuclear-reactors/graphite-core-ageing.htm
‘As well as moderation, the fundamental safety requirements of an AGR core include allowing free movement of control rods, free movement of fuel and directing the flow of coolant gas to ensure adequate cooling of the fuel and core structure. Essentially, significant weight-loss and cracking may compromise these safety requirements.
‘During operation, the graphite slowly loses weight due to oxidation caused by the reactor’s carbon dioxide coolant gas. Loss of weight affects both the mechanical properties of the graphite brick, and reduces its effectiveness as a moderator.’
In 2006, the renowned independent and government nuclear consultant, the late John Large, first raised concerns about the risk to operational safety of graphite cracking. We also raised our concerns as far back as 2014 and more recently in correspondence, and in meetings, with officials from the ONR.
Our concerns and activities on this issue were outlined in our briefing No 250 ‘Update on the AGR closure programme’, dated 17 October 2022:
In 2023, the operating lives of Hartlepool and Heysham-1 were extended by two years from 2024 to March 2026, however the closure of Heysham-2 and Torness had previously been brought forward from 2030 to March 2028 because of ‘impacts on the graphite cores’. In January 2024, EDF published its ‘UK Nuclear Fleet Stakeholder Update’ in which it is stated that: ‘The prospect of further AGR lifetime extensions ([of] four power stations) will be reviewed again by the end [of] 2024 and the ambition is to generate beyond these dates, subject to plant inspections and regulatory approvals.’ [iii]
The Office for Nuclear Regulation is empowered as an arms-length, statutory body under the 2013 Energy Act to ‘provide efficient and effective regulation of the nuclear industry, holding it to account on behalf of the public’ with the Act defining its five statutory purposes which included nuclear safety at licenced sites.
Although Labour Ministers may aspire to ‘extend the lifetime of existing plants to 2030’ it is the independent regulator who has statutory responsibility for (and indeed has the only expertise in) conducting the plant inspections and regulatory approvals of AGR plants and it must remain the agency responsible for determining how long any such plant remains in operation. EDF as the plant operator must also independently make a commercial decision as to whether to seek approval for any extension in operations from the ONR.
Rather than commercial considerations or political expediency, safety must remain the paramount consideration throughout this process.
As NFLAs, we shall consider it our role to remain observant of developments and to continue to challenge Ministers, regulator and industry should this be needed.
Minister, I was pleased to hear that in your verbal response to Mr Outram’s question that you referenced your high regard for the rigour with which the industry regulator approaches their task of maintaining nuclear safety, and our understanding is that you recognise and concur that it is the ONR which shall ultimately make the decision on whether operational extensions on AGR operations should be granted.
To provide reassurance to our member authorities, and the many NGOs, activists and community members for which this is an issue of concern, I would be most grateful if you could reply with a clear statement that this is this Government’s shared position on the matter.
Thank you for reading this letter and in anticipation of your early reply. Please direct this to NFLA Secretary Richard Outram by email to richard.outram@manchester.gov.uk
Yours sincerely,
Councillor Lawrence O’Neill,
Chair, UK/Ireland Nuclear Free Local Authorities
[i] Office for Nuclear Regulation, Conditions on the graphite cores in nuclear reactors, 28 March 2014
https://www.onr.org.uk/foi/2014/2014020215.htm
[ii] Ditto
[iii] EDF Energy, UK Nuclear Fleet Stakeholder Update, January 2024
The reply received from Lord Hunt dated 29 October reads:
Cllr Lawrence O’Neill
By Email: richard.outram@manchester.gov.uk
Dear Cllr O’Neill,
Thank you for your letter of 22 August on behalf of the UK / Ireland Nuclear Free Local Authorities. Thank you also for your kind message of congratulation. I was pleased to be able to attend the NGO forum and to engage with your colleague Richard Outram. I look forward to meeting you at a future forum.
Please be assured of the Government’s commitment to the safety of members of the public, workers, and also protecting the environment. The United Kingdom has a strong regulatory system, and the Office for Nuclear Regulator (ONR) is a trusted, independent regulator.
The ONR was recently commended by an IAEA peer review team for its mature regulatory framework, openness, and commitment to transparency. We can all have confidence in the technical robustness and independence of its judgements, and the candour with which it communicates.
Decisions regarding the future operation of the Advanced Gas-cooled Reactor fleet or any nuclear power station in Great Britain would be for the operator, EDF Energy, the ONR. The ONR would not allow a reactor to operate, return to service or extend its operating life if it judged that it was not safe to do so.
I hope this response is reassuring to your members.
Yours sincerely,
RT HON LORD HUNT OF KINGS HEATH OBE
Minister for Energy Security and Net Zero