Since 2000, EDF has become fully responsible for the decommissioning of this facility in place of the CEA (1). The deconstruction works included in the scope of the Decree authorising partial decommissioning were finalised by end-2020. The safety concrete for the effluent processing station has been demolished, and the spoil removed. Following the final inspections, decommissioning works to allow this zone to be entirely relisted as a conventional zone will be completed in 2023. At the same time, examination of the decommissioning dossier (2) with a view to the publication of a full decommissioning decree (allowing decommissioning of the reactor block itself) is ongoing, with:
Following this public inquiry, on 17 January 2022, the Brennilis Local Information Commission (CLI) issued a favourable opinion on the proposed application. In addition, the enquiry commission appointed by the Rennes administrative court to conduct the public enquiry also issued a favourable opinion on 2 March 2022. The ASN recently indicated its aim of a decree being published during the first half of 2023, which would mean it coming into force at the end of 2023.
In 2020 and 2021, the first two caps were cut and the cutting of the last cap ended in March 2022. It was removed at the end of July and replaced by the “rotating confinement structure” (structure de confinement tournante, SCOT) from which the in-water cutting of the internal components of the reactor vessel will be carried out; this work is scheduled to continue through until 2026.
the industrial strategy of the dismantling of the NUGG reactors was thoroughly reviewed at the end of 2015 with the shift from “in-water” dismantling to “in-air” dismantling. It calls for:
This new strategy entails decommissioning work on the reactor caissons coming to an end between 2063 and 2093, depending on the reactors in question.
Updating the industrial decommissioning scenario for first-generation power plants, particularly NUGG plants, led to a €590 million increase in the provision at 31 December 2015.
In a cover letter accompanying the decisions of 17 March 2020 supporting the technical options chosen, the ASN took the view that EDF should aim to shorten the schedule for completing this work “in view of the legal obligation for the decommissioning of each reactor to take place as quickly as possible”. EDF confirmed the implementation of a regular review of the schedule based on the results obtained on the industrial demonstrator and the first reactor. At this stage, the lack of any new developments has meant the schedule cannot as yet be improved upon.
Construction work on the Graphite Industrial Demonstrator (Démonstrateur Industriel Graphite, DIG) was completed in late 2021. The first tests, carried out in September 2022, concerned the development of tools allowing “the recovery of graphite bricks” from reactors and the progressive design of the robotic arms required to decommission NUGG reactors.
Following the inspection of “the maturity of coordination of complex projects” completed in November 2020 (an exploratory approach by a team bringing together the ASN, the French Radiation protection and Nuclear Safety Institute (Institut de radioprotection protection et de sûreté nucléaire, IRSN) and the French General Directorate for Energy & Climate (Direction générale de l’énergie et du climat, DGEC), EDF’s answers and commitments were supplied to the ASN in May 2022.
From a regulatory point of view, the dossier for the decommissioning of the Saint- Laurent silos was submitted to the ASN in electronic format on 30 September. The decommissioning dossiers for Chinon A2 and A1 and the dossiers for substantial changes to the decrees for Chinon A3, Saint-Laurent A, and Bugey 1 were filed on 15 December 2022, in line with the rulings by the ASN in March 2020. Meanwhile decommissioning works other than in the reactor vessel are ongoing on all 3 sites.
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 (3). The aim of decommissioning operations is to restore the condition of sites and enable the land to be reused for industrial purposes.
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 (4). In addition, dedicated assets have been gradually established since 1999 (5).
The external audit mandated by the 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., Superphenix, 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 “a long-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’s 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.
The response to this follow-up letter was sent on 21 February 2022, resulting in the establishment of an action plan in respect of the points for progress referred to above.
For the risks associated with these projects, see section 2.2.4, “Risks related to opertaional performance”, “Risk 4A – Management of large and complex industrial projects (including EPR projects)”.
EDF is both the owner and manager of the Flamanville 3 EPR (6) project, with capacity of circa 1,600MW.
Since being submitted to the ASN in March 2015, the commissioning request dossier has been updated several times, in 2017, 2021, and 2022. A further update is scheduled in 2023 prior to start-up, in particular to take into account the outcome of the most recent examinations and requests from the ASN.
(1) Decree No. 2000-233 of 19 September 2000.
(2) Filed in 2018.
(3) See section 6.1, note 15 of the appendix to the consolidated financial statements for the fiscal year ended 31 December 2020.
(4) See section 6.1, note 15.1.3 “Coverage of EDF’s long-term nuclear commitments”.
(5) See section 6.1, note 15.1.2.2 “Strategic allocation and composition of dedicated assets” in the appendix to the consolidated financial statements for the year ended 31 December 2022.
(6) European Pressurised water Reactor.
