The Chooz A PWR decommissioning operations are continuing with the cutting and removal of the vessel internals according to schedule, after the reactor pool was filled with water in 2018 and the vessel was opened in March 2017.
The feedback from the PWR at Chooz will enable consolidation, as far as possible, of the studies and estimates on the future costs of decommissioning the nuclear fleet currently in operation (“second generation” power plants). The first reactor of the Fessenheim power plant was definitively shut down on 22 February 2020. The second was shut down on 30 June 2020. These two reactors will be the first of the nuclear fleet currently in operation to benefit from this feedback for their decommissioning. Nevertheless, neither EDF, nor any other operator, has yet undertaken a decommissioning programme on a scale comparable to that of the Group’s current PWR fleet and the estimates therefore involve risks that are associated in particular with this scale effect.
The timing and cost of the work are also dependent on administrative authorisations and the availability, at the necessary time, of radioactive waste storage centres or other facilities necessary for the conditioning, treatment or storage of waste containers.
In addition to these technical and industrial sensitivity factors, the amount of provisions currently set aside may change in the coming years. Indeed, the assessment of the need for these provisions is sensitive to the assumptions used for costs, planning, inflation rates and long-term discount rates, and to any change in the regulations, in particular those relating to the scope of expenses to be covered.The amount of these provisions, in accordance with the French Environmental Code, is subject to control by the administrative authority, which verifies in particular the adequacy of the provisioned expenses and imposes a cap on the discount rate for the provisions.
Given these sensitivity factors, changes in certain parameters may require significant adjustments of the provisions booked and, therefore, the Group cannot guarantee that the provisions booked will equal the costs actually incurred at the relevant time, which would have an adverse impact on the Group’s financial position (see note 15 of the appendix to the consolidated financial statements for the fiscal year ended 31 December 2020). The Group regularly conducts an update of the key assumptions underlying the provisions (see note 15 of the appendix to the consolidated financial statements for the fiscal year ended 31 December 2020).
With regard to the provision for decommissioning of nuclear power generation facilities in France, the amount of expenses under economic conditions at the end of 2020 is estimated at €27,093 million, the corresponding provision is €17,489 million. As for the last core provision, costs based on year-end economic conditions are estimated at €4,258 million and provision at present value amounts are valued €2,711 million, as the discounting effect is very significant due to distant waste storage maturities. Note 15.1.1.5 “Analyses of sensitivity to macro-economic assumptions” of the appendix to the consolidated financial statements for the fiscal year ended on 31 December 2020 indicates the analyses of sensitivity of provisions and Group’s results to a discount rate change, for the different types of provisions.
The provisions of Framatome and Cyclife France (formerly SOCODEI) relating to basic nuclear facilities in France amounted to €78 million and €62 million respectively (see note 17.1 “Other provisions for decommissioning” of the appendix to the consolidated financial statements for the year ended 31 December 2020).
In the United Kingdom, under the agreements concluded in connection with the restructuring of British Energy, the costs of decommissioning EDF Energy Nuclear Generation Group Ltd.’s existing nuclear power plants will be paid by the Nuclear Liabilities Fund (NLF). If the assets of this Fund prove insufficient, these costs will be borne by the UK Government (see section 1.4.5.1.2.2 “Nuclear Generation”). In 2019, EDF Energy and the UK Government (BEIS) began discussions with a view to clarifying the conditions for implementing the above-mentioned agreements, in particular as regards determining the decommissioning costs to be recovered by EDFEnergy from the Nuclear Liabilities Fund and the conditions under which the UK authorities may exercise their option to acquire the nuclear power plants at the end of the defueling phase. These discussions led to an agreement in principle in 2019 and are continuing with a view to reaching comprehensive and binding agreements.
In any event, the agreements in force provide that the expenses related to the unloading and evacuation of the fuel are covered by the NLF and consequently justified by EDF Energy and approved by the French government; failing this, they would remain the responsibility of EDF Energy.
For nuclear power plants which EDF does not operate, but has financial interests in (China, United States, Belgium), the Group is exposed financially in proportion to its contribution to future decommissioning costs.
Failure to control the costs, the time-frame for completion and the associated provisions with respect to the decommissioning of nuclear facilities for which the Group is liable would have a negative impact on the Group’s financial position and reputation.
As a nuclear operator or producer of radioactive waste, within the meaning of the legislation applicable to waste, the Group could be held liable, in particular in the event of an accident involving damage to third parties or to the environment in connection with spent fuel or waste. The Group may be held liable even if these products are handled, transported, held, stored or warehoused by parties other than the Group, in particular, in France, the Orano Group and the French National Agency for Radioactive Waste Management (ANDRA), particularly in the event of any failure by any of the latter.
In France, EDF is liable for all radioactive waste produced during:
The long-term management of radioactive waste has been the subject of various studies under programme laws no. 91-1381 of 30 December 1991 on research on radioactive waste management and no. 2006-739 of 28 June 2006 on the sustainable management of radioactive materials and waste. All of the Group’sLong-Lived High-Level and Intermediate-Level waste may not constitute “ultimate radioactive waste” within the meaning of Article L. 542-1-1 of the French Environmental Code. In this case, it may not be possible to store this waste directly in a deep geological repository, especially since the Nuclear Order of 10 February 2016 issued pursuant to Act no. 2015-992 relating to the energy transition for green growth allows for the reclassification of radioactive materials as radioactive waste and vice-versa by the administrative authority. Moreover, the Group has no control over the time taken by the public authorities to issue permits for such ultimate storage, nor over the technical guidelines that are set forth. This is likely to create uncertainties regarding the fate of the waste, the liability and the resulting costs for EDF.
EDF has allocated provisions for the long-term management of waste, assessed on the assumption of geological storage, which is the international solution of reference for the ultimate storage of long-lived high-level radioactive waste and on the basis of a reasonable version of the work carried out in 2006 by a working group comprisingANDRA, the public authorities and radioactive waste producers (see note 15.1 of the appendix to the consolidated financial statements for the year ended 31 December2020). Following new calculations of the costs of deep storage under the supervision of the DGEC in conjunction with EDF, the Minister of Ecology, Sustainable Development and Energy, in an order of 15 January 2016, set the new reference cost at €25 billion under the economic conditions of 31 December 2011. This cost was taken into account in the Group’s financial statements at the end of 2015 (see note 15.1 of the appendix to the consolidated financial statements for the year ended 31 December 2020). The current estimate is based on the preliminary design assumptions and will be regularly revised based on the progress of the project, as stated in the Ministerial order. Opinion no. 2018-AV-0300 from the French Nuclear Safety Authority dated 11 January 2018 relative to the safety options file presented by Andra for the Cigeo project to store radioactive waste in a deep geological layer specifies that the project has achieved satisfactory overall technological maturity at the stage of the safety options file. The reservations that remain and the supplementary investigation being carried out for Andra to obtain approval for the construction of the geological storage area starting in 2022 could lead to a revision of the provisions for long-term radioactive waste management.
