Universal Registration Document 2021

6. Financial statements

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 was to 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.

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, included 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.

In addition, 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 authorisations granted and the commissioning schedule.

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. 593-20 to L. 593-25 and R. 593-65 to R. 593-74 in France’s Environment 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 Environment 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 Environment 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 mainly 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 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.