Universal Registration Document 2020

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 28 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).

28.3 Decommissioning provisions for nuclear power plants

EDF bears full technical and financial responsibility for decommissioning of the basic nuclear facilities (installations nucléaires de base, INB) it operates. The final shutdown and decommissioning process is governed by legal provisions and regulations set out in Articles L. 593-25 to L. 593-20 and R. 593-65 to R. 593-74 in the Environmental Code. It involves the following operations for each INB:

• a definitive 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 of theINB, which takes place during its operating phase, 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);
• a dismantling plan compiled by the operator and sent to the Minister in charge ofNuclear Safety, which after examination by the authorities and a public inquiry, leads to a decree prescribing dismantling that authorises the start of dismantling operations;
• key-stage progress reviews submitted for the ASN’s approval, with a safety file specific to the dismantling operations to be performed;
• an internal control process concerning significant changes introduced by the operator in the case of operations that must be declared to or approved by the ASN;
• finally, once these operations are complete, declassification of the facility, which removes 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 HealthCode (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 nuclear fleet currently in operation, known as “first-generation” plants, and the Superphenix plant and Irradiated Materials Workshop. These operations cover four different reactor 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 at Chooz, 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 plant has the specificity of being located in a cave, making this a unique operation, generating experience that is not immediately transposable and involves specific challenges.

The experience gained from dismantling the Chooz PWR will nonetheless improve the robustness of the studies and estimates of future decommissioning costs for the nuclear fleet currently in operation (“second-generation” plants). 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 associated with the scale effect.

At Fessenheim, the two pressurised water reactors were shut down definitively on 22 February 2020 and 30 June 2020 respectively, in accordance with the law and before the end of their technical operating life. The Consolidated Preliminary Plan (avant-projet consolidé or APC) was finalised in late 2018, with more in-depth studies and derisking of the Summary Preliminary Plan (avant-projet sommaire orAPS). The dismantling plan was sent to the ASN in September 2019 together with the declaration of the permanent shutdown of this INB. The studies conducted in 2019 and 2020 focused on preparing the dismantling plan, which was sent to theASN on 2 December 2020. After the filing date, the ASN will examine the documents for a period of 3 to 5 years.

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).

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