In addition, the construction work on the DIG is completed and the building was accepted in late 2021.
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 63.2MW, 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 remuneration and determination of the terms of this compensation. In accordance with the Decree of 18 February 2020 repealing this authorisation, reactors no. 1 and no. 2 were definitively shut down on 22 February 2020 and 30 June of the same year, 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. 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 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 December 2020, with the aim of obtaining the Decree prescribing decommissioning operations in 2025; this will mark the start of the decommissioning phase. In the end of 2020, 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.). At year-end 2021, the trajectory of activities in preparation for decommissioning is consistent with the forecast schedule, including, in particular, the end of fuel removal from unit 1 and the transfer to Cyclife Sweden of the upper portions of the six spent steam generators. In early 2022, the MSNR and the ASN acknowledged receipt of the “index B” Fessenheim decommissioning application, which was submitted on 23 December 2021 in response to the MSNR’s letter of 4 August 2021, which marked the resumption of its investigation.
Furthermore, engineering studies on the decommissioning of Fessenheim have continued, so that the conclusions of the preliminary designs carried out on preparatory activities, on dismantling work, and on the suitability of the treatment channels for nuclear waste can be used to provide a reference for the decommissioning estimate for the PWR fleet.
In addition, Decree no. 2021-1785 of 24 December 2021 authorised the taking of water from and discharges into the Grand Canal in Alsace for the cooling of various auxiliary circuits at Fessenheim.
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.
In addition, dedicated assets have been gradually established since 1999 to cover long-term nuclear commitments (see section 6.1 “Consolidated financial statements at 31 December 2021”, note 15.1.2.2 “Strategic allocation and composition of dedicated assets”). Article L. 594-2 of the French Environmental Code and its implementing regulation specified which liabilities are not associated with the operating cycle and must therefore be covered by dedicated assets (see in section 6.1, note 15.1.3 “Coverage of EDF’s long-term nuclear commitments”).
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” was held from December 2020 to May 2021, 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 historic shut down facilities excluding PWR technology, i.e., Superhelix, Brennilis, and the 6 NUGG reactors. The final audit report was delivered to the audited party on 9 July 2021. The DGEC’s follow-up letter was issued on 22 November 2021 and the audit report was posted on the Ministry’s website.
The report notes “an organisation structurally oriented toward completing decommissioning projects”, a “costing and annual review process [that] is robust, and provides proper traceability of assumptions used and original data” and “along-term industrial approach to overcoming the few remaining technological challenges”. Finally, the report confirms that “provisions are consistent with the basic scenarios of the projects and cover the full range of expenses of the audited scope” and determines they “are adequately sized” after testing the size of EDF’expenses and provisions.
In addition to the current mastery of processes and organisations, two minor deviations of little significance were reported (and were corrected during the revision of the estimates at year-end 2021). Areas for improvement were identified in connection with project planning, measuring the level of project maturity and the risks and uncertainties quantification process. They do not call into question the conservative assessment of the associated decommissioning and waste management costs. The audit report also highlights a set of good practices that are rarely implemented in decommissioning projects.
For the risks associated with these projects, see section 2.2.4 “Operational performance related risks” – “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 has submitted to the ASN a further update to the request for application for commissioning on 4 June 2021.
For this purpose, the project must undergo an environmental assessment based on the updated environmental impact study. This is a new regulatory procedure required by an amendment to the French Environmental Code. The ASN referred the matter to the Environmental Authority in early September 2021, which issued its opinion on 22 December 2021. It requests that the application, prepared on the basis of an impact study EDF carried out for the purpose of a future commissioning authorisation be completed on several points and, in particular, that it address the impacts of the prior construction phases of the Flamanville EPR and the Cotentin Maine very high voltage power line.
On 8 October 2020, pursuant to the French Environmental Code, the ASN authorised the arrival of nuclear fuel at the Flamanville 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. The 245 fuel assemblies necessary for loading (241 assemblies for the first core, 4 assemblies for the reserve) were accepted at the end of the first half of 2021. The first regulatory fuel inspection (Euratom) was performed at the end of August 2021.
