In a judgement issued last month the ONR rapped the CGN/EDF developers for the 'slow' development of the safety case and said that their 'response revealed a number of potential shortfalls related to the status of the safety case planning and arrangements (including organisational)'. Most tellingly, the ONR has given the developers a large number of 'follow-up' points to which they need to adequately respond before they can be given the go ahead after the later stages in the 'generic design assessment' (GDA) process run by the ONR
Although the ONR has stressed that there is nothing fundamentally wrong with the developer's proposals, the evidence is that the sheer extent of 'follow up' point materials must severely question any financial estimates of the plant's costs that have been based on the plant being built in China. This is the 'Fanggchengang 3' power plant being built in South China.
This conclusion is based partly on the experience of the last GDA process which involved the approval of Hitachi's ABWR plant which is earmarked for development in Wylfa. The construction of the Wylfa ABWR plant is now doubtful following reports that Hitachi cannot find investors. This failure has been ascribed, at least in part, to extensive cost increases racked up as a result of safety improvements needed for the plant. The cost of building the plant increased by more than a third after the ONR's GDA was completed in 2017.
Yet the ONR's commentary comprising its 'follow up' points for the HPR1000 is 50 per cent longer compared to those given to Hitachi in the same stage of the GDA for the ABWR. On this basis the cost increases for the Chinese plant could be even larger, proportionately, than what Hitachi's proposal suffered compared to any prior expectations based on plants built in the East.
Some western commentators have been keen to exclaim how quickly and cheaply the Chinese can build reactors (although recently the reactor rollout in China has slowed markedly compared to expectations) but the arduous passage of the proposed Hualong reactor design through the GDA is one reason why costs and practices in the East should not be so easily used as a basis for what happens in the West. As the developers put it themselves in their own GDA submission, perhaps with a bit of an understatement: '
‘The HPR1000 (FCG3) design has evolved under the Chinese regulatory system, which is acknowledged to be possibly different from that of the UK in requirements and relevant good practices, including Codes of Practice’.
The GDA process is likely to be completed in early 2022.