Universal Registration Document 2021

2. Risk factors and control framework

The Group’s nuclear operating companies regularly receive international evaluation teams (WANO(1) Peer Review and OSART from the IAEA(2)).

Clear and honest information communication on the events and their possible impacts are promoted within the Group. This high-quality dialogue is sought and maintained with the salaried personnel and its representatives, subcontractors, the supervisory authorities (Nuclear Safety Authority in France, Office for Nuclear Regulation in the United Kingdom), local communities and all other nuclear safety stakeholders.

The Nuclear Safety Council, which the Chairman & Chief Executive Officer of EDF chairs, meets several times a year and periodically reviews the annual assessment of the EDF group’s nuclear safety. A General Inspector for nuclear safety and radiation protection (IGSNR) is appointed by the Chairman & Chief Executive Officer to whom he or she reports. He or she carries out inspection assignments regarding all of the nuclear activities of the EDF group. Each year, he or she issues an opinion on safety within EDF. His or her report is presented to and discussed by the Nuclear Safety Council. It is then made public (see section 1.4.1.1.4.3).

5D – Control of the fuel cycle

Summary : In addition to the control of nuclear safety (risk 5C), the operation of existing nuclear facilities (risk 5A) and new nuclear projects (risk 4A), the Group is exposed, in the context of nuclear activities, to the control of the nuclear fuel cycle.

Criticality : ●● Intermediate

a) Context

The Group’s operating costs include nuclear fuel purchases.

EDF is supplied with uranium, conversion and enrichment services, fuel assembly supplies and spent fuel reprocessing operations for its nuclear fleet in France and the United Kingdom.

In France, EDF has booked provisions for spent nuclear fuel management operations (transport, processing, conditioning for recycling) (see note 15 of the appendix to the consolidated financial statements for the fiscal year ended 31 December 2021) based on the price and volume conditions of the master agreement signed with Orano in December 2008 and broken down in the successive implementation agreements (see section 1.4.1.1.2.3 “The issues relating to the nuclear activity”). These provisions amount to approximately €10 billion.

Note 15.1.1.5 “Inflation rate, discount rate and analyses of sensitivity” and note 15.1 “Nuclear provisions and dedicated assets in France” of the appendix to the consolidated financial statements ended 31 December 2021 show the connection between “costs based on year-end economic conditions”, which represent estimated amounts as at 31 December 2021, and “provisions made at present value”.

b) Main risks
Nuclear fuel supply 

Prices and volumes are subject to fluctuations that depend on factors beyond the Group’s control, including political and economic factors (in particular, profitability outlook for mining investments, supply/demand imbalance or a tension on the supply side, associated, for example, with the occurrence of an operating incident in a uranium mine or cycle plant, a delay in the commissioning of a new mine or an event leading to institutional instability in a producing country, or restrictions/ sanctions/embargos).

Nuclear fuel logistics

The storage and transport of new or spent nuclear fuel is an industrial activity that requires specific safety and security measures. These requirements could become more stringent, generating additional difficulties and costs for the Group.

In the event of the collapse of this industrial logistics system, the Group could reduce or even interrupt all or part of the electricity generation at the affected sites, either due to the non-delivery of new assemblies or to the saturation of storage facilities, which could have a negative impact on the Group’s financial position (see section 1.4.1.1.2.3 “Issues relating to the nuclear activity”).

Transport of nuclear materials continues to be highly constrained, particularly with regard to the increase in security and regulatory requirements; in line with the management of the “yellow vests” (gilets jaunes) crisis, the Covid-19 pandemic was well anticipated and did not disrupt transport, but reminded us that the situation remains precarious.

Given the saturation of the existing storage pools and the risk of the impossibility, in the long term, of implementing multi-recycling in its third generation pressurised water reactors or recycling in fourth generation “GEN IV” reactors (abandonment of the ASTRID fast neutron reactor project), the fuel cycle could be called into question. This could have both operational and financial consequences.

Provisions for spent fuel disposal

The amount of provisions currently booked to cover the period not covered by the current agreement with Orano should be reassessed if the terms under which this agreement is renewed prove more costly than those currently applicable.

The contracts entered into in France and abroad may not sufficiently protect the Group from sudden or significant price increases. When these contracts expire, the Group may not be able to renew them, in particular at an equivalent price. This could have an adverse impact on the Group’s financial position.

c) Control actions

The supply risk management strategy consists of progressively securing the portfolio through competitive long-term contracts in line with the objectives for covering requirements presented to the Board of Directors. Fixed price contracts are preferred, or contracts including a limited market price component, the latter systematically including ceilings/floors to reduce exposure to the market.

In the field of transport, the control actions implemented by EDF include strengthening the unpredictability of transport and ties to the authorities (HFDS/ IRSN/ASN), the prevention and reduction of potential impacts on the fleet, as well as the development of alternative levers (anticipation of deliveries, inter-unit transfer, etc.).

The control of spent fuel storage capacity is essential to preserve the balance of the closed cycle. A new large capacity spent fuel storage pool will be commissioned by EDF in 2034 at the Orano site in The Hague (see section 1.4.1.1.2.3 “Issues relating to the nuclear activity”). In the meantime, Orano plans to densify its existing pools on the site and is developing a dry storage solution for spent fuel.

Finally, EDF’s strategy for the fuel cycle is to maintain the long-term perspective of a closed cycle based on GEN IV reactors.

(1) WANO : World Association of Nuclear Operators

(2) OSART : Operational Safety Analysis Review Team ; AIEA: Agence Internationale de l'énergie Atomique - Internaional Agency of Atomic Energy