6. Financial statements

32.1.3 Decommissioning provisions for nuclear power plants

EDF bears full technical and financial responsibility for decommissioning of the nuclear plants it operates. The decommissioning process is governed by French Law of 13 June 2006, Decree 2007-1557 of 2 November 2007, and the French Environment Code (Articles L. 593-25 and following). It involves the following operations for each site:

  • a shutdown declaration, to be made at least two years prior to the planned shutdown date:
    • since the Energy Transition Law of 17 August 2015, the final shutdown, which takes place during the operating phase of the basic nuclear facility, is considered separately from dismantling, as a notable change of lesser importance (simply requiring a declaration by the operator to the Minister and the ASN);
  • an application for decommissioning, which after examination by the authorities and a public inquiry, leads to a single decree authorising the decommissioning;
  • key progress reviews with the ASN, included in a formal safety procedure specific to dismantling operations;
  • an internal authorisation procedure for the operator, independent of operational personnel and audited by the ASN, allowing some specific work to be started ahead of the authorised safety procedure;
  • finally, once these operations are complete, declassification of the facility to remove it from the legal regime governing basic nuclear facilities.

The decommissioning scenario adopted by EDF complies with France’s Environmental Code, which requires as short a period as possible to elapse between final shutdown and dismantling in economically acceptable conditions and in compliance with the principles laid down in Article L. 1333-1 of the Public Health Code (radioprotection) and section II of Article L. 110-1 of the Environmental Code (protection of the environment). The intended end-state is industrial use: the sites will be restored to their original condition and will be reusable for industrial facilities.

The ongoing operations concern plants that were constructed and operated before the current nuclear fleet (“first-generation” plants), and the Superphenix plant and Irradiated Materials Workshop. These operations cover four different technologies: a heavy water reactor (Brennilis), a sodium-cooled fast-neutron reactor (the Superphenix at Creys-Malville), natural uranium graphite gas-cooled (UNGG) reactors (at Chinon, Saint Laurent and Bugey) and a pressurised water reactor (PWR at Chooz). Each of them is a first for EDF, and apart from the PWR, they concern reactor technologies for which there is little or no international experience. They therefore require development of new methods and technologies that are riskier than technologies for which feedback already exists. Decommissioning of the Chooz PWR is benefiting from past experience (essentially in the US and limited), but the reactor has the specificity of being located in a cave, making this a unique operation, generating experience that is not immediately transposable and involves specific risks.

The experience gained from dismantling the Chooz PWR will nonetheless make the studies and estimates of future decommissioning of the nuclear fleet currently in operation (“second-generation” plants) as robust as possible. But so far, neither EDF nor any other operator has begun a decommissioning programme on a scale comparable to the current PWR fleet, and as a result the estimates include both opportunities and risks, especially the risks associated with the scale effect.

The decommissioning provisions cover future decommissioning expenses as described above (excluding the cost of removing and storing waste, which is covered by the provisions for long-term waste management).

The preliminary dismantling plan and the orientations for the fourth periodic review of Fessenheim (RP4) were sent to the ASN in July 2018. The Consolidated Preliminary Plan (avant-projet consolidé or APC) was finalised in late 2018, with more in-depth studies for derisking of the Summary Preliminary Plan (avant-projet sommaire or APS). Studies in 2019 focused on preparing the dismantling plan, with the objective of filing the dismantling and RP4 documents in mid-2020.

On 30 September 2019 EDF sent the Minister for the Ecological and Inclusive Transition and the ASN its application requesting approval for the termination of operations, and a declaration of the permanent shutdown of both reactors at Fessenheim nuclear power plant, scheduled for 22 February 2020 for reactor 1 and 30 June 2020 for reactor 2 (see note 3.1.6).

Details of changes in decommissioning provisions for nuclear power plants are as follows:

(in millions of euros)31/12/2018IncreasesDecreasesDiscount effectOther movements31/12/2019
Provisions for decommissioning nuclear plants in operation

Provisions for decommissioning nuclear plants in operation

31/12/2018

12,480

Provisions for decommissioning nuclear plants in operation

Increases

2

Provisions for decommissioning nuclear plants in operation

Decreases

(20)

Provisions for decommissioning nuclear plants in operation

Discount effect

488

Provisions for decommissioning nuclear plants in operation

Other movements

294

Provisions for decommissioning nuclear plants in operation

31/12/2019

13,244

Provisions for decommissioning permanently shut-down nuclear plants

Provisions for decommissioning permanently shut-down nuclear plants

31/12/2018

3,505

Provisions for decommissioning permanently shut-down nuclear plants

Increases

103

Provisions for decommissioning permanently shut-down nuclear plants

Decreases

(121)

Provisions for decommissioning permanently shut-down nuclear plants

Discount effect

206

Provisions for decommissioning permanently shut-down nuclear plants

Other movements

-

Provisions for decommissioning permanently shut-down nuclear plants

31/12/2019

3,693

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

31/12/2018

15,985

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

Increases

105

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

Decreases

(141)

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

Discount effect

694

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

Other movements

294

DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

31/12/2019

16,937

For nuclear power plants currently in operation (PWR pressurized water reactor plants with 900MW, 1,300MW and N4 reactors)

Until 2013, provisions were estimated based on a 1991 study by the French Ministry of Trade and Industry, which set an estimated benchmark cost for decommissioning expressed in €/MW, confirming the assumptions defined in 1979 by the PEON commission. These estimates had been confirmed from 2009 by a detailed study of decommissioning costs conducted by EDF at the representative site of Dampierre (four 900MW units), and its results were corroborated by an intercomparison with the study carried out by consultants LaGuardia, based mainly on the Maine Yankee reactor in the US.

In 2014 the Dampierre study was reviewed by EDF to make sure that the previous calculations were still valid in view of recent developments and experience, both internationally and internally. For this revision, the decommissioning provisions for plants in operation were based on costs resulting from the Dampierre study, in order to incorporate best estimates and feedback from inside and outside France. This change of estimate had no significant impact on the level of provisions at 31 December 2014.

Between June 2014 and July 2015, an audit of dismantling costs for EDF’s nuclear fleet currently in operation was conducted by specialised consulting firms, at the request of the French Department for Energy and Climate (Direction générale de l’énergie et du climat or DGEC). On 15 January 2016 the DGEC published a summary of the audit report. It stated that although estimating the cost of decommissioning nuclear reactors is a demanding exercise due to relatively limited past experience, the prospects of changes in techniques, and the distant timing of the expenditure, overall, the audit confirmed EDF’s estimate of decommissioning costs for its nuclear fleet currently in operation. The DGEC also made a number of recommendations to EDF following this audit.