In accordance with the French Environmental Code, the provisions proposed by EDF during reviews after the 35th year of operation will be submitted reactor by reactor to the ASN for authorisation, after a public enquiry. For Tricastin 1, the VD4 (pilot plant) started on the 1st of June 2019 and ended with re-coupling on 23 December 2019, after the ASN had given its authorisation to restart. The periodic review findings report (RCR) was transmitted in February 2020 and will be the subject of a public enquiry in 2021, after publication of the generic ASN opinion on the VD4. The ASN opinion on the Tricastin 1 periodic review report is expected to be issued in late 2021 or early 2022. It is likely to include site-specific requirements in addition to the requirements of the generic opinion, impacting industrial load and costs. As of 10 February 2021, the VD4 is in progress for the Bugey 2, Bugey 4 and Tricastin 2 nuclear units.
In 2016, the Board of Directors considered that all the technical, economic and governance conditions necessary to align the depreciation period of the French nuclear fleet with the Group’s industrial strategy were met (see notes 1.3.4 “Management judgements and estimates” and 1.3.4.1 “Depreciation period of nuclear power plants in France” of the appendix to the consolidated financial statements at 31 December 2020). It therefore approved the extension in the consolidated financial statements of the depreciation period for 900MW PWR plants outside Fessenheim from 40 years to 50 years, without anticipating the decisions of the ASN on EDF provisions on a reactor-by-reactor basis after each 10-year inspection. It cannot be ruled out that the extension of the operating life of certain 900MW reactors may not be authorised, but an important step has been taken with the generic opinion issued by the ASN on 23 February 2021. With regard to the Fessenheim nuclear power plant, Reactor no. 1 was shut down on 22 February 2020 and Reactor no. 2 on 30 June 2020.
The continuing of operation of the other series of France’s nuclear fleet (1,300MW and 1,450MW), which are more recent, remains an industrial objective for the Group.
The Group cannot guarantee that it will receive the expected operating lifespan extension from the competent authorities. Furthermore, such extensions could also be obtained under certain conditions, the financial impact of which, in particular in terms of investments, could affect the Group’s strategy with respect to extending the operating life of its reactors or the Group’s ability to pursue its global investment strategy. These events could have a significant negative impact on the Group’s financial position.
In the United Kingdom, the ongoing analysis of graphite ageing in the AGR (Advanced Gas Reactor) reactor may lead to prolonged unavailability or early shutdown of the reactors. The cracking of graphite subjected to irradiation must be carefully monitored, with inspections carried out regularly, and controlled by theOffice for Nuclear Regulation (“ONR”), to ensure that there is sufficient knowledge of the core to justify continued operation. In August 2020 and November 2020 decisions were made to terminate the operation of the Hunterston B power plant no later than 7 January 2022 and the Hinkley Point B power plant no later than 15 July2022. Operations may cease before these dates if a new safety case is not approved.For Hinkley Point B this safety case is required to restart the two reactors currently shut down for graphite inspection.
The current planned operating period for the reactors in EDF Energy’s existing nuclear fleet ranges from 41 to 47 calendar years for advanced gas reactors (AGRs) and is40 years for the Sizewell B pressurised water reactor (PWR). Since EDF Energy acquired them, the operating lifespan of the AGR power plants has been extended by 8 years on average and the objective is to increase the operating life of the PWR power plant by 20 years after the currently planned 40 years (see section 1.4.5.1.2.2“Nuclear generation”). Nevertheless, given the nuclear safety rules applicable in theUnited Kingdom and AGR reactor technology in particular, the Group cannot guarantee that EDF Energy will obtain the necessary authorisations from the ONR when the time comes to operate its existing nuclear reactors until the currently planned (AGR) or potential (Sizewell B) end of operation date, or that such authorisations will not be obtained under conditions involving significant expenditure or investment by the Group.
In view of the risk of early shutdown due to difficulties in preparing the safety case owning to the graphite inspection at Hunterston B and Hinkley Point B, EDF Energy has set itself the target of having a safety case for the removal of fuel at these two plants as from May 2021. An accelerated fuel withdrawal strategy would be implemented in the event of any risk of an early shutdown of the other AGR plants. If this strategy were to be adopted, it may require that the value of the assets be re-examined.
Given the ageing of the British fleet and the many technical difficulties encountered, the future level of output of the AGR reactors currently in service is very uncertain.
For nuclear reactors where EDF is not in charge of operation but has financial interests (United States, Belgium, China), the Group is also financially exposed to some risks. The Group may need to contribute up to the amount of its share to costly repairs or modifications to be carried out on these units or to events that may have an impact on their operating lifespan, production or availability. As in France and theUnited Kingdom, the nuclear safety authorities in these countries may take decisions that require additional works or controls, in particular as regards exploiting feedback from international experience and anticipating potentially precursory events.
Furthermore, despite the quality of operations and the changes made by the Group to its nuclear facilities, it cannot be ruled out that some of these facilities will be subject to special operating conditions to reinforce the operating safety margins at the initiative of the nuclear operator responsible for nuclear safety or at the request of the Nuclear Safety Agency.
Finally, a potential serious nuclear accident not involving the Group but with widespread consequences worldwide could lead the Safety Authorities to require new reactor upgrades applicable to the Group’s reactors, and to those in which the Group has a stake.
The provisions set aside by the Group for the decommissioning of nuclear facilities and for the treatment and ultimate disposal of radioactive waste, including long-lived waste from spent fuel treatment and decommissioning, may prove to be insufficient. In particular, decommissioning existing nuclear facilities may present currently unforeseen difficulties or be much costlier than anticipated. In addition, these operations must address the CSR challenge of waste management and the circular economy.
The amount of dedicated assets in France allocated by the Group to cover the costs of its long-term nuclear business commitments(radioactive waste and decommissioning) might need to be revised upwards or require additional expenditures.
The decommissioning operations underway in France (see section 1.4.1.1.2.3“Decommissioning of nuclear power plants”) concern plants that were built and operated before the current nuclear fleet, including the Superphenix plant (“first generation” plants). These operations cover four different reactor technologies: heavy water reactor (Brennilis), sodium-cooled fast reactor (Superphenix at Creys-Malville),graphite-moderated and gas-cooled reactor (NUGG reactors at Chinon, Saint Laurentand Bugey) and the 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. The decommissioning of the PWR at Chooz A does benefit from some feedback (essentially American and of a limited nature) but it has the innovative specific feature of being located in a cave, which also makes it an unusual operation for which experience is not immediately transferable and which includes specific risks.
