In 2018 and 2019, the ASN investigated the dossiers submitted by EDF and made available to the public for consultation between 11 July and 12 November 2019: these draft decisions called for works to start from 2055 onwards, with the exception of “TTS” lead units. The provisions relating to decommissioning of NUGGs were updated on 31 December 2019 in order to take these draft decisions into account. In its opinion of 18 October 2019, the IRSN stated that “the schedule is based on more realistic time frames than those underpinning the previous strategy. The most recent studies provide additional insights into the complexity of the operations to be undertaken.”
The ASN rulings published on 17 March 2020 have established a prescriptive framework for the operations and dossiers to be completed within the next 5-7 years on each of the sites. Unlike the aforementioned draft rulings submitted for public consultation, these defer the issue of the schedule for operations until the investigative phase for dossiers relating to decommissioning.
However, in a cover letter accompanying these rulings dated 13 March 2020, the ASN deems that EDF should attempt to significantly shorten the schedule for completing the operations “in view of the statutory obligation to decommission each reactor in as short a time as possible”. EDF confirmed the implementation of a regular review of the schedule based on the results obtained on the industrial demonstrator and the first reactor.
In connection with its subsidiary Graphitech, EDF is working on avenues for schedule optimisation that should make it possible to include a schedule similar to that of the draft ruling submitted for public consultation in the dossiers filed in 2022 (decommissioning of reactors other than “TTS” lead units from 2055 onwards).Consistently with these works, and in the absence of any further information from tests using the industrial demonstrator and the first real-life operations, there was no change in 2020 to the valuation of the estimated provisions at the end of December 2020.
On 20 November 2020, an ASN exploratory procedure designed to verify the maturity of EDF for running complex projects was completed. The Graphite Industrial Demonstrator (DIG) and Chinon A2 projects were inspected by a team comprising members from the ASN, IRSN, and DGEC. The draft follow-up letter was received on 18 February 2021, describing the ASN’s satisfaction in respect of the way the overall procedure had been carried out, the identified strengths, and the areas for improvement that had been noted. All of the requests are being examined and will be discussed with the ASN in early March.
The external audit mandated by DGEC on “responsibilities in respect of decommissioning facilities currently permanently shut down and the management of radioactive waste from these facilities” commenced on 3 December 2020 for a provisional period of 6 months, pursuant to the letter of instruction received on
5 June 2020 from the General Directorate of the French Treasury (DG Trésor) and the DGEC. This audit covers legacy shut down facilities excluding PWR technology, i.e., Superphenix, Brennilis, and the 6 NUGG reactors.
Fessenheim: Article L. 311-5-5 of the French Energy Code, introduced by the French Energy Transition Act promoting green growth dated 17 August 2015, caps installed nuclear power generation capacity in France at 63.2GW, thus requiring EDF to take all necessary measures to close the two Fessenheim reactors.
On 27 September 2019, EDF sent the Minister of Ecological and Solidarity Transition and the Nuclear Safety Authority the declaration of the permanent shutdown of the two Fessenheim reactors and, on 30 September 2019, a request for termination of the authorisation to operate this plant. The submission of this request and declaration follows the signing, on 27 September 2019, by the French State and EDF, of the MOU establishing the schedule of detriment issues granting entitlement to compensation and determination of the terms of this compensation. Pursuant to the French Decree dated 18 February 2020 terminating this authorisation,
reactors 1 and 2 were permanently shut down on 22 February 2020 and 30 June 2020 respectively.
Pursuant to the MOU, compensation includes:
The French State decided to proceed with payment of the entirety of the fixed component, the amount of which was evaluated at € 370 million (payment appropriations provided for by French Budget Act for 2020 2019-1479 dated
28 December 2019 and French Amended Budget Act for 2020 2020-1473 dated
30 November 2020). This amount may be readjusted as necessary, depending on actual post-operation expenses, BNF taxes, and staff redeployment costs.
EnBW, EDF’s partner in the plant, will under certain conditions be entitled to a share of lost earnings in proportion to its contractual rights to the plant’s generation capacity. For its part, the Swiss company CNP (Centrales Nucléaires en Participations SA) decided to end its involvement in the partnership. Once EDF took note of CNP’s decision the contract between the two firms ended on 31 December 2017.
The decommissioning dossier was filed with the Minister of Ecological and Solidarity Transition and the ASN in November 2020, with the aim of obtaining the Decree prescribing decommissioning operations in 2025; this will mark the actual start of the decommissioning phase. In the meantime, the PREDEM Fessenheim project has been put into place to coordinate all the end-of-operation procedures (permanent locking-out and removal of certain equipment and support functions, removal of fuel, decontamination of primary circuits, etc.).
Since the beginning of operations at its power plants, EDF has made provisions to cover decommissioning operations, engineering, monitoring and maintenance of facilities, and site security (see section 6.1, note 15 of the appendix to the consolidated financial statements for the fiscal year ended 31 December 2020). The aim of decommissioning operations is to restore the condition of sites and enable the land to be reused for industrial purposes.
Dedicated assets have been gradually established since 1999 to cover long-term nuclear commitments (see section 6.1 “Consolidated financial statements at
31 December 2020”, note 15.1.2.2 “Strategic allocation and composition of dedicated assets”).
Article L. 594 of the French Environment Code and its implementing regulation specified which liabilities are not associated with the operating cycle and must therefore be covered by dedicated assets (see section 6.1 “Consolidated financial statements at 31 December 2020”, note 15.1.3 “Coverage of long-term nuclear commitments”).
See also section 2.2.4, “Operational Performance”, risk factor “4A Management of large and complex industrial projects, including EPR projects”.
EDF is both the owner and manager of the Flamanville 3 EPR (European Pressurised water Reactor) project.
The request for application for commissioning, submitted in March 2015, has been examined once and was updated in June 2017. A file amending this request was submitted in April 2019. EDF will submit to the ASN a further update to the request for application for commissioning in the first half of 2021. A full update of the impact study has also been commenced, for submission at the same time.
On 8 October 2020, pursuant to the French Environment Code, the ASN authorised the arrival of nuclear fuel at the Flamanville EPR reactor site, after an on-site inspection on 18 and 19 August 2020 and after public consultation on the draft authorisation from 31 August to 21 September 2020. The ASN also authorised the use of radioactive gases to carry out efficiency tests on certain filtration systems.
In addition, on 15 October 2020, pursuant to the French Defence Code (code de la défense), the Senior Civil Servant for Defence and Safety (Haut Fonctionnaire de Défense et de Sécurité, HFDS) authorised the holding, use, and transfer of nuclear materials for the site. The first fuel assemblies were delivered on site on
26 October 2020.
In a Decree dated 25 March 2020, the commissioning deadline specified in the Authorisation Decree (DAC) was postponed until 11 April 2024, to take into account the weld repairs whilst maintaining flexibility.
