Universal Registration Document 2022

• 2020: A detailed design review by a group of independent experts, organised at the request of the DGEC, reported its conclusions. While issuing a generally favourable opinion for ANDRA’s submission, the experts 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.
• Also in 2020, 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). At the 2022 year-end, the associated measures still remain to be defined and bounded by the Government to prevent any related cost increase for the Cigeo project.
• 2021: After its filing by ANDRA in August 2020, its examination by the government departments and a public inquiry from 15 September to 23 October 2021, the application for a Déclaration d’utilité publique (DUP) officially recognising the public utility of the Cigéo storage centre received a favourable opinion from the inquiry commissioners on 20 December 2021;
• 2022: On 8 July 2022, the DUP decree was published.

The delivery horizon for the first waste packages was also clarified. It should begin between 2035 and 2040 according to the ANDRA report of October 2022 summarising the consultations on the pilot industrial phase and governance of the Cigéo project, whereas at the end of 2021, producers were working on the hypothesis that the first waste packages would be received in 2031. Consequently, the provision has been updated to reflect this deferred reception date for the first packages, with no significant impact.

On 16 January 2023, ANDRA filed its application for authorisation to create Cigéo (DAC) with the Ministry for the Energy Transition. This step marks the start of a new phase: examination of the project by the ASN, after which the project could be authorised and construction could begin. Based on ANDRA’s latest schedule, the decree authorising creation is now expected for 2027 (instead of 2025 as previously).

ICEDA

The provision established for long-lived medium and high-level waste, also includes €773 million to cover the conditioning and interim storage of long-lived medium-level waste, principally at the ICEDA conditioning and storage facility (Installation de Conditionnement et d’Entreposage des Déchets Activés).

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. Two waste packaging campaigns were completed in 2022, as expected.

15.1.1.3 Provisions for nuclear plant decommissioning

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 of 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 its dismantling, as a significant modification 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 modifications 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 scope of the laws 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 purposes.

The ongoing dismantling operations concern plants that were constructed and operated before the nuclear fleet currently in operation, known as “first-generation” plants, the Superphenix plant, and the Irradiated Materials Workshop in Chinon. 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). For the Fessenheim PWR plant, the dismantling application is currently under examination by the ASN, and the operations completed concern the pre-dismantling phase.

Each of these operations is a first for EDF, and apart from the PWR, 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 PWR is benefiting from past experience (essentially in the US and limited). The Chooz plant also has the specificity of being located in a cave: this means it is also 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 yet 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.

The decommissioning provisions cover future decommissioning expenses as described above (excluding the cost of removing waste from the site and storing it, which is covered by the provisions for long-term waste management).

Details of changes in provisions for nuclear plant decommissioning are as follows: