Universal Registration Document 2021

6. Financial statements

The detailed design review by a group of independent experts, organised at the request of the DGEC, reported its conclusions at the end of 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), previously due to be made in 2021, should now be made in 2022. This will delay the granting of authorisation by an equivalent period, and it is now expected in 2025. However, producers are still currently working on the hypothesis that the first waste packages will be received in 2031.

In August 2020 ANDRA filed an application for a déclaration d’utilité publique (DUP) officially recognising the public utility of the Cigéo storage centre. This was examined by the government departments and subjected to a public inquiry from 15 September to 23 October 2021, and the inquiry commissioners issued an unreservedly favourable opinion on 20 December 2021. Publication of the DUP decree, which will automatically confer compatibility on the planning documents, is expected in early 2022.

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, 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). These nuclear expenses were previously covered by the provisions for waste removal and conditioning.

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. The ASN’s decision approving and governing the conditioning of long-lived medium-level waste into packages at the ICEDA facility was formally received on 19 July 2021. At the end of 2021 the first waste packages were sealed, in compliance with the authoriations granted and the commissioning schedule.

15.1.1.3 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. 593-20 to L 593-25 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 the INB, 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 of nuclear 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 Health Code (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 dismantling operations concern mainly plants that were constructed and operated before the nuclear fleet currently in operations, known as “first  generation” plants, and the Superphenix plant and Irradiated Materials Workshop. These operations cover four different 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.

Based on the ongoing decommissioning operations at permanently shut-down plants (particularly the experience gained from the Chooz PWR), the studies conducted for the Summary Preliminary Plan for the two 900MW reactors at Fessenheim, and the preparatory work for dismantling of Fessenheim, it was possible at the end of 2021 to establish a detailed reference estimate of future decommissioning costs for the nuclear fleet currently in operation (“second generation” plants). However, 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 or APS). 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 the ASN on 2 December 2020. After the filing date, the ASN will examine the documents for a period of 3 to 5 years. 2021 was marked by the complete defueling of reactor 1, preparations for decontamination of the primary circuit which will take place in 2022, dispatch of the first operating waste to the ICEDA facility, and dispatch of the uppermost parts of the steam generators to the subsidiary Cyclife Sweden for processing, in line with the objectives of the work and studies done in preparation for decommissioning of Fessenheim.

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).