Universal Registration Document 2020

6. Financial statements

In 2020, the assumptions concerning the shares of costs were reassessed, to reflect the long-term distribution between the three producers concerned of fixed storage costs for very low-level waste and low and medium-level waste. All the effects of this cost-share updating work have led to a €179 million increase in the provision (with an unfavourable effect of €50 million on the income statement, while the rest of the change was recognised via adjustments to fixed assets).

Also, since 31 December 2020, following the reclassifications presented in note 15.1.1 to ensure consistency with the most recent official breakdown of nuclear expenses attached to the amended ministerial order of 21 March 2007 on secure financing of nuclear expenses, the provision established for very low-level and low and medium-level waste also covers the treatment, conditioning and interim storage of waste; many of these operations were previously included in the provisions for nuclear plant decommissioning and waste removal and conditioning (reclassification of €979 million applied at 31 December 2020).

Finally, for very low-level waste, in February 2020, following public debate of 2019-2020 concerning the French National Plan for the Management of Radioactive Materials and Waste (PNGMDR), the conclusions of the Ministry for the Ecological and Inclusive Transition and the ASN pave the way for a change in regulations that would allow recycling of very low-level metal waste after processing: “The Government will make changes to the regulatory framework applicable to the management of very low-level waste, in order to introduce a new possibility of targeted exceptions, allowing recycling, after fusion and decontamination and on a case by case basis, of very low-level radioactive metallic waste.” A change to the regulations had been proposed by the General Risk Prevention Department (DGPR) and submitted to public consultation.

Long-lived low-level waste

Long-lived low-level waste belonging to EDF essentially consists of graphite waste from the ongoing decommissioning of the former UNGG (natural uranium graphite gas-cooled) reactors.

As this waste has a long lifetime but is lower-level than long-lived medium and high-level waste, specific subsurface storage requirements apply under the French Law of 28 June 2006.

Following the initial geological investigations, in July 2015 ANDRA remitted a report on the proposed storage centre for long-lived low-level waste on a site located in the Soulaines region (Aube) in France. This report was submitted to the ASN for its opinion. Uncertainties remain about the site’s capacity to accommodate all of the waste included in the baseline inventory of the long-lived low-level waste storage facility.

Further studies were planned under the 2016-2018 period of the National Plan for the Management of Radioactive Materials and Waste (PNGMDR), concerning both the feasibility of this storage centre and the search for additional waste management solutions. The ASN’s opinion on management of this waste, issued on 6 August 2020 after the work done over the period 2016-2018, and the orientations proposed by the head of the PNGMDR in the current elaboration phase of the fifth edition of the PNGMDR, set a horizon of 2023 for definition by ANDRA of several reference management scenarios, and of the needs for complementary concepts and the production of a file (equivalent to a Summary Preliminary Plan or avant-projet sommaire – APS) presenting the technical and safety options selected for storage of long-lived low-level waste.

Long-lived medium and high-level waste

Long-lived medium and high-level waste essentially comes from processing of spent fuel, and to a lesser extent waste resulting from nuclear plant decommissioning (metallic components that have been inside the reactor).

The French Law of 28 June 2006 requires reversible storage in deep geological layers for this type of waste.

The provision established for long-lived medium and high-level waste is the largest component of provisions for long-term radioactive waste management.

Until June 2015 the gross value and disbursement schedules for forecast expenses were based on a scenario of industrial geological waste storage, following conclusions presented in the first half of 2005 by a working group formed under supervision of the State involving representatives of the administrations concerned, ANDRA and the producers of waste (EDF, Orano, CEA). EDF applied a reasonable approach to information supplied by this working group, leading to a benchmark cost, for storage of waste from all producers, of €14.1 billion under the economic conditions of 2003 (€20.8 billion under 2011 economic conditions, based on the 2011 inventory).

In 2012 ANDRA carried out preliminary conceptional studies for the Cigéo geological storage project.

On this basis, ANDRA drew up figures which, in compliance with the Law of 28 June 2006, were subjected to a consultation process with waste producers started in late 2014 by the French Department for Energy and Climate (Direction générale de l’énergie et du climat or DGEC). In April 2015 EDF and the other producers sent the DGEC their comments on ANDRA’s report and a joint estimation of the target Cigéo storage cost due to divergences in the valuation of technical optimisations and their induced effects. All this information was included, together with the ASN’s opinion, in a report submitted to the Minister for Ecology, Sustainable Development and Energy.

On 15 January 2016 the Ministry of Ecology, Sustainable Development and Energy issued a Ministerial Order setting the target cost for the Cigéo storage project at €25 billion under 2011 year-end economic conditions. The cost as defined constitutes an objective to be met by ANDRA, in compliance with safety standards set by the ASN, working in close liaison with the operators of nuclear installations.

In application of this Ministerial Order, the cost of the Cigéo project will be regularly updated, at least at each key milestone in the course of the project’s development (authorisation to create the facility, commissioning, end of the “pilot industrial phase”, safety reviews) in accordance with the opinion of the ASN.

In April 2016 ANDRA sent the ASN a safety option report (DOS). The law of 11 July 2016 clarified the concept of reversibility.

On 11 January 2018, the ASN issued its opinion on the DOS. It considered that the Cigéo project had reached satisfactory overall technological maturity at that stage. This opinion included a requirement for examination of alternatives to the proposals for storage of bituminous waste at Cigéo. A group of experts appointed by the DGEC in September 2018 to draw up a report on current bituminous waste management concluded in September 2019 that various options were feasible (storage or neutralisation) but stressed the importance of continuing the studies in order to identify the most appropriate option.

Detailed design studies for Cigéo are currently being finalised by ANDRA. The Detailed Design Review by a group of independent experts, organised at the request of the DGEC, reported its conclusions in October 2020. While issuing a generally favourable opinion for the ANDRA’s submission, the Group made a certain number of recommendations for finalisation of the detailed design studies and the application for authorisation to create the centre, calling for closer involvement of EDF, Orano and the CEA on these matters.

Under the schedule prepared by ANDRA, the application to develop Cigéo (classified as a basic nuclear facility) is now due to be made in 2021, with a corresponding extension for obtaining authorisation. Producers are still currently working on the hypothesis that the first waste packages would be received in 2031.

On 3 August 2020, ANDRA filed an application with the Ministry for the Ecological Transition for Déclaration d’utilité publique (DUP) officially recognising the public utility of the Cigéo storage centre. After examination by the government departments, this application will give rise to a public debate expected to take place in the second quarter of 2021. Publication of the DUP decree, which would automatically confer compatibility on the planning documents, is expected in late 2021.

Finally, the French finance law for 2021, published in the Journal officiel of 30 December 2020, includes a change to the tax treatment of this project (based on storage tax instead of the standard tax regime). The associated measures remain to be defined and managed by the Government to prevent any cost increase for the Cigeo project.

Also, since 31 December 2020, following the reclassifications presented in note 15.1.1 to ensure consistency with the most recent official breakdown of nuclear expenses attached to the amended ministerial order of 21 March 2007 on secure financing of nuclear expenses, the provision established for very low-level and low and medium-level waste also covers the conditioning and interim storage of low and medium-level waste at the ICEDA storage facility (installation de conditionnement et d’entreposage des déchets activés). This facility, constructed at the Bugey power plant, received its first waste packages in September 2020 after the ASN authorised its commissioning on 28 July 2020. These nuclear expenses were previously covered by the provisions for waste removal and conditioning (the reclassification at 31 December 2020 concerned an amount of €675 million).