IMO implores for Ontario nuclear investment

By Toronto Star


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A speaker with Ontario's Independent Electricity Market Operator used haiku to cap a seminar that painted a dire long-term outlook for the province's electricity needs.

"Coal power closing. Soon we could be in the dark. Help us. Please build now," said Dan Rochester, head forecaster with the IMO.

The most pressing issue is finding ways to cope with the provincial government's decision to phase out coal-fired generation, which accounts for roughly a quarter of Ontario's total electricity output, by 2007.

Even if coal is not completely eliminated, Ontario will face an electricity shortage by 2009, Rochester said in a presentation recently at the Canadian Nuclear Society Conference in Toronto.

The good news is that Ontario should be fine for the next 18 months.

"We're in the best shape we've been in years going into the summer," Rochester said after his speech.

Two nuclear reactors at the Bruce station and one at the Darlington generating station are back online and TransAlta Corp.'s natural gas-fired generator in Sarnia is coming into service, so demand for electricity should be met, he said.

The provincial government has publicly stated the need to invest as much as $40 billion over the next 15 years to expand generating capacity, Rochester noted.

That certainly got the crowd salivating. After all, they would love to get their hands on some of that cash.

The nuclear power industry's main rivals are electricity producers that use natural gas.

Pierre Charlebois, acting chief nuclear officer at Ontario Power Generation Inc., described the option of extending the life of the Darlington and Pickering A and B nuclear power plants.

He said the public has lost confidence in OPG because of problems refurbishing the Pickering A nuclear generating station. That project has been weighed down by delays and huge cost overruns.

"We need to get more independent third parties driving the nuclear option," Charlebois said.

To bolster trust in nuclear power, the nuclear industry needs to show it has "world-class management," said Andrew Johnson, vice-president of power marketing at Bruce Power.

"We are not there right now," he added.

Building new nuclear capacity may seem like a no-brainer to the nuclear industry, but seemingly compelling alternatives do exist, he suggested.

"The gas lobby is equally persuasive."

Natural gas-fuelled plants have the key advantage of relatively low capital outlays and quick build times — two to three years — to increase capacity, Johnson said.

But the nuclear industry must hammer home the fact that, while less money is needed to build natural gas-fired plants, the fuel costs are much higher than uranium and are very volatile, he said.

North American natural gas reserves are finite, and have a remaining lifespan of about 80 years using optimistic estimates, he added.

Nuclear producers are guilty of over-optimism, he added, citing huge cost overruns and unrealistic time frames for bringing capacity back on line.

The solution, Johnson argued, includes showing that nuclear power can provide lower-cost electricity at a more stable price.

To convince the public, the nuclear industry must offer fixed — and guaranteed — supply prices, Johnson said.

The competition will not ignore the nuclear industry's past mistakes, he added.

"We must make sure we don't, either."

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Stop the Shock campaign seeks to bring back Canadian coal power

Alberta Electricity Price Hikes spotlight grid reliability, renewable transition, coal phase-out, and energy poverty, as policy shifts and investor reports warn of rate increases, biomass trade-offs, and sustainability challenges impacting households and businesses.

 

Key Points

Projected power bill hikes from market reforms, renewables, coal phase-out, and reliability costs in Alberta.

✅ Investor report projects 3x-7x bills and $50B market transition costs

✅ Policy missteps cited in Ontario, Germany, Australia price spikes

✅ Debate: retain coal vs. speed renewables, storage, and grid upgrades

 

Since when did electricity become a scarce resource?

I thought all the talk about greening the grid was about having renewable, sustainable, less polluting options to fulfill our growing need for power. Yet, increasingly, we are faced with news stories that indicate using power is bad in and of itself, even as flat electricity demand worries utilities.

The implication, I guess, is that we should be using less of it. But, I don’t want to use less electricity. I want to be able to watch TV, turn my lights on when the sun sets at 4 p.m. in the winter, keep my food cold and power my devices.

We once had a consensus that a reliable supply of power was essential to a growing economy and a high quality of life, a point underscored by brownout risks in U.S. markets.

I’m beginning to wonder if we still have that consensus.

And more importantly, if our decision makers have determined electricity is a vice as opposed to an essential of life – as debates over Alberta electricity policy suggest – you know what is going to happen next. Prices are going to rise, forcing all of us to use less.

How much would it hurt your bottom line if your electricity bill went up three-fold? How about seven-fold? That is the grim picture that Todd Beasley painted for us on Tuesday’s show.

Last week, he launched a campaign on behalf of Albertans for Sustainable Electricity, called Stop the Shock. He shared the results of an internal investor report that concluded Alberta’s power market overhaul would cost an estimated $50 billion to implement and could result in a three to seven-fold increase in electricity bills.

Now, my typical power bill averages $70 a month. That would be like having it grow to $210 a month, or just over $2,500 a year. If it’s a seven-fold increase that would be more like $5,000 a year. That may be manageable for some families, but I can think of a lot of things I’d rather do with $5,000 than pay more to keep my fridge running so my food doesn’t spoil.

For low-income families that would be a real hardship.

Beasley said Ontario’s inept handling of its electricity market and the phase-out of coal power resulted in price spikes that left more than 70,000 individuals facing energy poverty.

Germany and Australia realized they made the same mistake and are returning some electricity to coal.

Beasley shared a long list of Canadian firms – including our own Canadian Pension Plan – that are investing in coal development around the world. Meanwhile, Canadian governments remain in a mad rush to phase it out here. That’s not the only hypocrisy.

Rupert Darwall, author of Green Tyranny: Exposing the Totalitarian Roots of the Climate Industrial Complex, revealed in a recent column what he calls “the scandal at the heart of the EU’s renewable policies.”

Turns out most of their expansion in renewable energy has come from biomass in the form of wood. Not only does burning wood produce more CO2, it also eliminates carbon sinks.

To meet the EU’s 2030 target would require cutting down trees equivalent to the combined harvest in Canada and the United States. As he puts it, “Whichever way you look at it, burning the world’s carbon sinks to meet the EU’s arbitrary renewable energy targets is environmentally insane.”

Beasley’s group is trying to bring some sanity back to the discussion. The goal should be to move to a greener grid while maintaining abundant, reliable and cheap power, and examples like Texas grid improvements show practical steps. He thinks to achieve all these goals, coal should remain part of the mix. What do you think?

 

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Scotland’s Wind Farms Generate Enough Electricity to Power Nearly 4.5 Million Homes

Scotland Wind Energy delivered record renewable power as wind turbines and farms generated 9,831,320 MWh in H1 2019, supplying clean electricity for every home twice and supporting northern England, according to WWF data.

 

Key Points

Term for Scotland's wind power output, highlighting 2019 records, clean electricity, and progress on decarbonization.

✅ 9,831,320 MWh generated Jan-Jun 2019 by wind farms

✅ Enough to power 4.47 million homes twice in that period

✅ Advances decarbonization and 2030 renewables, 2050 net-zero goals

 

Wind turbines in Scotland produced enough electricity in the first half of 2019, reflecting periods when wind led the power mix across the UK, to power every home in the country twice over, according to new data by the analytics group WeatherEnergy. The wind farms generated 9,831,320 megawatt-hours between January and June, as the UK set a wind generation record in comparable periods, equal to the total electricity consumption of 4.47 million homes during that same period.

The electricity generated by wind in early 2019 is enough to power all of Scotland’s homes, as well as a large portion of northern England’s, highlighting how wind and solar exceeded nuclear in the UK in recent milestones as well, and events such as record UK output during Storm Malik underscore this capacity.

“These are amazing figures,” Robin Parker, climate and energy policy manager at WWF, which highlighted the new data, said in a statement. “Scotland’s wind energy revolution is clearly continuing to power ahead, as wind became the UK’s main electricity source in a recent first. Up and down the country, we are all benefitting from cleaner energy and so is the climate.”

Scotland currently has a target of generating half its electricity from renewables by 2030, a goal buoyed by milestones like more UK electricity from wind than coal in 2016, and decarbonizing its energy system almost entirely by 2050. Experts say the latest wind energy data shows the country could reach its goal far sooner than originally anticipated, especially with complementary technologies such as tidal power in Scottish waters gaining traction.

 

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Biggest offshore windfarm to start UK supply this week

Hornsea One Offshore Wind Farm delivers first power to the UK grid, scaling renewable energy with 1.2GW capacity, giant offshore turbines, and Yorkshire coast infrastructure to replace delayed nuclear and cut fossil fuel emissions.

 

Key Points

Hornsea One Offshore Wind Farm is a 1.2GW UK project delivering offshore renewable power to about 1 million homes.

✅ 174 turbines over 407 km2; Siemens Gamesa supply chain in the UK

✅ 1.2GW capacity can power ~1m homes; phases scale with 10MW+ turbines

✅ Supports UK grid, replaces delayed nuclear, cuts fossil generation

 

An offshore windfarm on the Yorkshire coast that will dwarf the world’s largest when completed is to supply its first power to the UK electricity grid this week, mirroring advances in tidal electricity projects delivering to the grid as well.

The Danish developer Ørsted, which has installed the first of 174 turbines at Hornsea One, said it was ready to step up its plans and fill the gap left by failed nuclear power schemes.

The size of the project takes the burgeoning offshore wind power sector to a new scale, on a par with conventional fossil fuel-fired power stations.

Hornsea One will cover 407 square kilometres, five times the size of the nearby city of Hull. At 1.2GW of capacity it will power 1m homes, making it about twice as powerful as today’s biggest offshore windfarm once it is completed in the second half of this year.

“The ability to generate clean electricity offshore at this scale is a globally significant milestone at a time when urgent action needs to be taken to tackle climate change,” said Matthew Wright, UK managing director of Ørsted, the world’s biggest offshore windfarm builder.

The power station is only the first of four planned in the area, with a green light and subsidies already awarded to a second stage due for completion in the early 2020s, and interest from Japanese utilities underscoring growing investor appetite.

The first two phases will use 7MW turbines, which are taller than London’s Gherkin building.

But the latter stages of the Hornsea development could use even more powerful, 10MW-plus turbines. Bigger turbines will capture more of the energy from the wind and should lower costs by reducing the number of foundations and amount of cabling firms need to put into the water, with developers noting that offshore wind can compete with gas in the U.S. as costs fall.

Henrik Poulsen, Ørsted’s chief executive, said he was in close dialogue with major manufacturers to use the new generation of turbines, some of which are expected to approach the height of the Shard in London, the tallest building in the EU.

The UK has a great wind resource and shallow enough seabed to exploit it, and could even “power most of Europe if it [the UK] went to the extreme with offshore”, he said.

Offshore windfarms could help ministers fill the low carbon power gap created by Hitachi and Toshiba scrapping nuclear plants, the executive suggested. “If nuclear should play less of a role than expected, I believe offshore wind can step up,” he said.

New nuclear projects in Europe had been “dramatically delayed and over budget”, he added, in comparison to “the strong track record for delivering offshore [wind]”.

The UK and Germany installed 85% of new offshore wind power capacity in the EU last year, according to industry data, with wind leading power across several markets. The average power rating of the turbines is getting bigger too, up 15% in 2018.

The turbines for Hornsea One are built and shipped from Siemens Gamesa’s factory in Hull, part of a web of UK-based suppliers that has sprung up around the growing sector, such as Prysmian UK's land cables supporting grid connections.

Around half of the project’s transition pieces, the yellow part of the structure that connects the foundation to the tower, are made in Teeside. Many of the towers themselves are made by a firm in Campbeltown in the Scottish highlands. Altogether, about half of the components for the project are made in the UK.

Ørsted is not yet ready to bid for a share of a £60m pot of further offshore windfarm subsidies, to be auctioned by the government this summer, but expects the price to reach even more competitive levels than those seen in 2017.

Like other international energy companies, Ørsted has put in place contingency planning in event of a no-deal Brexit – but the hope is that will not come to pass. “We want a Brexit deal that will facilitate an orderly transition out of the union,” said Poulsen.

 

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Lawmakers question FERC licensing process for dams in West Virginia

FERC Hydropower Licensing Dispute centers on FERC authority, Clean Water Act compliance, state water quality certifications, Federal Power Act timelines, and Army Corps dams on West Virginia's Monongahela River licenses.

 

Key Points

An inquiry into FERC's licensing process and state water quality authority for hydropower at Monongahela River dams.

✅ Questions on omitted state water quality conditions

✅ Debate over starting Clean Water Act certification timelines

✅ Potential impacts on states' rights and licensing schedules

 

As federal lawmakers, including Democrats pressing FERC, plan to consider a bill that would expand Federal Energy Regulatory Commission (FERC) licensing authority, questions emerged on Tuesday about the process used by FERC to issue two hydropower licenses for existing dams in West Virginia.

In a letter to FERC Chairman Neil Chatterjee, Democratic leaders of the House Energy and Commerce Committee, as electricity pricing changes were being debated, raised questions about hydropower licenses issued for two dams operated by the U.S. Army Corps of Engineers on the Monongahela River in West Virginia.

U.S. Reps. Frank Pallone Jr. (D-NJ), the ranking member of the Subcommittee on Energy, Bobby Rush (D-IL), the ranking member of the Subcommittee on Environment, and John Sarbanes (D-MD), amid Maryland clean energy enforcement concerns, questioned why FERC did not incorporate all conditions outlined in a West Virginia Department of Environmental Protection water quality certificate into plans for the projects.

“By denying the state its allotted time to review this application and submit requirements on these licenses, FERC is undermining the state’s authority under the Clean Water Act and Federal Power Act to impose conditions that will ensure water quality standards are met,” the letter stated.

The House of Representatives was slated to consider the Hydropower Policy Modernization Act of 2017, H.R. 3043, later in the week. The measure would expand FERC authority over licensing processes, a theme mirrored in Maine's transmission line debate over interstate energy projects. Opponents of the bill argue that the changes would make it more difficult for states to protect their clean water interests.

West Virginia has announced plans to challenge FERC hydropower licenses for the dams on the Monongahela River, echoing Northern Pass opposition seen in New Hampshire.

 

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Maryland’s renewable energy facilities break pollution rules, say groups calling for enforcement

Maryland Renewable Energy Violations highlight RPS compliance gaps as facilities selling renewable energy certificates, including waste-to-energy, biomass, and paper mills, face emissions and permit issues, prompting PSC and Attorney General scrutiny of environmental standards.

 

Key Points

Alleged RPS noncompliance by REC-eligible plants, prompting PSC review and potential decertification under Maryland law.

✅ Complaint targets waste-to-energy, biomass plants, and paper mills

✅ Facilities risk loss of REC certification for environmental violations

✅ PSC may investigate nonreporting; AG reviewing evidence

 

Many facilities that supply Maryland with renewable energy have exceeded pollution limits or otherwise broken environmental rules, violating a state law, according to a complaint sent by environmental groups to state energy and law enforcement officials.

Maryland law says that any company that contributes to a state renewable energy goal — half the state’s energy portfolio must come from renewable sources by 2030 — must “substantially comply” with rules on air and water quality and waste management. The complaint says more than two dozen power generators, including paper mills and trash incinerators, have records of formal or informal enforcement actions by environmental authorities.

For years, environmental groups have criticized Maryland policy that counts power plants that produce planet-warming carbon dioxide and health-threatening pollution as “renewable” energy generation, and similar tensions have emerged in California’s reliance on fossil fuels despite ambitious targets, but lawmakers concerned about protecting industrial jobs have resisted reforms. The renewable label qualifies the companies for subsidies drawn from energy bills across the state.

In a complaint filed this week, the groups asked the attorney general and Public Service Commission to step in.

“We’re subsidizing companies to produce dirty energy, but we’re also using ratepayer money to support companies that in many instances are paying environmental fines or just flouting the law,” said Timothy Whitehouse, executive director of Public Employees for Environmental Responsibility. “There’s no one to hold them to account in Maryland.”

A spokeswoman for Attorney General Brian Frosh said his office would review the complaint, which was signed by Whitehouse and Mike Ewall, executive director of the Energy Justice Network.

Public Service Commission officials said the facilities must notify them if found out of compliance with environmental rules, while at the federal level FERC action on aggregated DERs is shaping market participation, and the commission can then revoke certification under the state renewable energy program. In a statement, commission officials said they would launch an investigation if any facility had failed to notify them of any environmental violations, and encouraged anyone with evidence of such a transgression to file a complaint.

Companies named in the document accused the groups of painting an inaccurate picture.

“This complaint is based on misleading arguments designed to halt waste-to-energy practices that have clear environmental benefits recognized by the global scientific community,” said Jim Connolly, vice president of environment, health and safety for Wheelabrator, which owns a Baltimore trash incinerator.

Maryland launched its renewable energy program in 2004, diversifying the state’s energy portfolio with more environmentally friendly sources of power, even as regional debates over a Maine-Québec transmission line highlight cross-border impacts. Under the program, separate from the electricity they generate and sell to the grid, renewable power facilities can sell what are known as renewable energy certificates. Utilities such as Baltimore Gas and Electric Co. are required to buy a growing number of the certificates each year, essentially subsidizing the renewable energy facilities with money from ratepayer bills.

A dozen types of power generation qualify to sell the certificates: Solar, wind, geothermal and hydroelectric plants, as well as “biomass” facilities that burn wood and other organic matter, waste-to-energy plants that burn household trash and paper mills that burn a byproduct known as black liquor.

The complaint focuses on waste incinerators, biomass plants and paper mills, all of which environmental groups have cast as counter to the renewable energy program’s environmental goals, even as ACORE criticized a coal and nuclear subsidy proposal in federal proceedings.

“By subsidizing these corporations, Maryland is diverting the hard-earned income of Maryland ratepayers to wealthy corporations with poor environmental compliance records and undermining the state’s transition to clean renewable energy,” Whitehouse and Ewall wrote.

For example, they note that the Wheelabrator plant in Southwest Baltimore has been fined for exceeding mercury limits in the past. That occurred in 2011, when the plant settled with state regulators for violations in 2010 and 2009.

Connolly said there is “no question” the facility complies with Maryland’s renewable energy law.

Incinerators in Montgomery County and in Fairfax County, Virginia, that are owned by Covanta and sell the energy certificates in Maryland have been cited for accidental fires inside both facilities. The Maryland incinerator violated emissions rules in 2014, the same year that New Jersey forbade the Virginia facility from selling energy certificates into that state’s renewable energy program over concerns it wasn’t following ash testing regulations.

James Regan, a spokesman for Covanta, said both facilities “have excellent compliance records and they operate well below their permitted limits.” He said the Virginia facility is complying with ash testing requirements, and that both facilities emit far lower levels of pollutants such as particulate matter than vehicles do.

“It’s clear to us there’s a lot of misleading and wrong information in this document," Regan said.

The Environmental Protection Agency endorsed waste-to-energy facilities under former President Barack Obama because, while burning household trash emits carbon dioxide, scientists said that still had a smaller impact on global warming than sending trash to landfills, even as industry groups have backed the EPA in a legal challenge to the ACE rule as regulatory approaches shifted.

Environmentalists and community groups say the facilities still are harmful because they emit high levels of pollutants such as mercury, nitrogen oxides and lead. The concerns prompted Baltimore City Council to pass an ordinance in February that tightened emissions limits on the Wheelabrator facility, even as the new EPA pollution limits for coal and gas plants are being proposed, so dramatically that the company said it would no longer be able to operate once the rules go into effect in 2022.

The complaint does not mention the century-old Luke paper mill in Western Maryland that long faced criticism for its participation in the renewable energy program, but which owner Verso Co. closed this year.

It does say several of paper company WestRock’s mills in North Carolina and Virginia have faced both formal and informal EPA enforcement actions for violation of the Clean Water Act, including evolving EPA wastewater limits for power plants and other facilities, and the Clean Air Act. A WestRock spokesperson could not be reached for comment.

The complaint also says a large biomass facility in South Boston, Virginia, owned by the Northern Virginia Electric Cooperative has a record of noncompliance with the Clean Air Act over three years.

John Rainey, the plant’s operations director, said it “experienced some small exceedances to its permit limits,” but that it addressed the issues with Virginia environmental officials and has installed new technology.

All those plants have sold credits in Maryland.

Whitehouse said the environmental groups’ goal is to clean up Maryland’s renewable energy program. They did not file a lawsuit because he said there was no clear cause of action to take the state to court, but said he hopes the complaint nonetheless spurs action.

“It’s not acceptable in a clean energy program that we’re subsidizing some of the most dirty sources of energy,” he said. “Those sources aren’t even in compliance with the law, and no one seems to care.”

 

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Indian government takes steps to get nuclear back on track

India Nuclear Generation Shortfall highlights missed five-year plan targets due to uranium fuel scarcity, commissioning delays at Kudankulam, PFBR slippage, and PHWR equipment bottlenecks under IAEA safeguards and domestic supply constraints.

 

Key Points

A gap between planned and actual nuclear output due to fuel shortages, reactor delays, and first-of-a-kind hurdles.

✅ Fuel scarcity pre-2009-10 constrained unsafeguarded reactors.

✅ Kudankulam delays from protests, litigation, and remobilisation.

✅ FOAK PHWR equipment bottlenecks and PFBR slippage.

 

A lack of available domestically produced nuclear fuel and delays in constructing and commissioning nuclear power plants, including first-of-a-kind plants and the Prototype Fast Breeder Reactor (PFBR), meant that India failed to meet its nuclear generation targets under the governmental plans over the decade to 2017, even as global project milestones were being recorded elsewhere.

India's nuclear generation target under its 11th five-year plan, covering the period 2007-2012, was 163,395 million units (MUs) and the 12th five-year Plan (2012-17) was 241,748 MUs, Minister of state for the Department of Atomic Energy and the Prime Minister's Office Jitendra Singh told parliament on 6 February. Actual nuclear generation in those periods was 109,642 MUs and 183,488 MUs respectively, Singh said in a written answer to questions in the Lok Sabah.

Singh attributed the shortfall in generation to a lack of availability of the necessary quantities of domestically produced fuel during the three years before 2009-2010; delays to the commissioning of two 1000 MWe nuclear power plants at Kudankulam due to local protests and legal challenges; and delays in the completion of two indigenously designed pressurised heavy water reactors and the PFBR.

Kudankulam 1 and 2 are VVER-1000 pressurised water reactors (PWRs) supplied by Russia's Atomstroyexport under a Russian-financed contract. The units were built by Nuclear Power Corporation of India Ltd (NPCIL) and were commissioned and are operated by NPCIL under International Atomic Energy Agency (IAEA) safeguards, with supervision from Russian specialists, while China's nuclear program advanced on a steady development track in the same period. Construction of the units - the first PWRs to enter operation in India - began in 2002.

Singh said local protests resulted in the halt of commissioning work at Kudankulam for nine months from September 2011 to March 2012, when he said project commissioning had been at its peak. As a consequence, additional time was needed to remobilise the workforce and contractors, he said. Litigation by anti-nuclear groups, and compliance with supreme court directives, impacted commissioning in 2013, he said. Unit 1 entered commercial operation in December 2014 and unit 2 in April 2017.

Delays in the manufacture and supply by domestic industry of critical equipment for first-of-a-kind 700 MWe pressurised heavy water reactors -  Kakrapar units 3 and 4, and Rajasthan units 7 and 8 - has led to delays in the completion of those units, the minister said, as well as noting the delay in completion of the PFBR, which is being built at Kalpakkam by Bhavini. In answer to a separate question, Singh said the PFBR is in an "advance stage of integrated commissioning" and is "expected to approach first criticality by the year 2020."

Eight of India's operating nuclear power plants are not under IAEA safeguards and can therefore only use indigenously-sourced uranium. The other 14 units operate under IAEA safeguards and can use imported uranium. The Indian government has taken several measures to secure fuel supplies for reactors in operation and under construction, amid coal supply rationing pressures elsewhere in the power sector, concluding fuel supply contracts with several countries for existing and future reactors under IAEA Safeguards and by "augmentation" of fuel supplies from domestic sources, Singh said.

Kakrapar 3 and 4, with Kakrapar 3 criticality already reported, and Rajasthan 7 and 8 are all currently expected to enter service in 2022, according to World Nuclear Association information.

 

Joint venture discussions

In February 2016 the government amended the Atomic Energy Act to allow NPCIL to form joint venture companies with other public sector undertakings (PSUs) for involvement in nuclear power generation and possibly other aspects of the fuel cycle, reflecting green industrial strategies shaping future reactor waves globally. In answer to another question, Singh confirmed that NPCIL has entered into joint ventures with NTPC Limited (National Thermal Power Corporation, India's largest power company) and Indian Oil Corporation Limited. Two joint venture companies - Anushakti Vidhyut Nigam Limited and NPCIL-Indian Oil Nuclear Energy Corporation Limited - have been incorporated, and discussions on possible projects to be set up by the joint venture companies are in progress.

An exploratory discussion had also been held with Oil & Natural Gas Corporation, Singh said. Indian Railways - which has in the past been identified as a potential joint venture partner for NPCIL - had "conveyed that they were not contemplating entering into an MoU for setting up of nuclear power plants," Singh said.

 

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