EDF / 2019 Universal registration document

1. The Group, its strategy and activities Description of the Group’s activities

Deconstruction of the Chooz A plant is continuing to schedule with cutting and extraction of the internal components of the reactor vessel (following the filling of the reactor pool in 2018). Chooz A is a pressurised water reactor using a technology similar to the 58 units in operation, but of an older design. It was commissioned in 1967 and operated until 1991 (final ending date for power generation). The reactor location, in a rocky cave in a hillside, means that access conditions and entry and exit of materials are more difficult than those of the rest of the existing PWR fleet. After EDF chose to opt from 2001 for a strategy of decommissioning without any period of dedicated waiting time for radioactive decrease and following adoption in 2007 of the decree for complete decommissioning, the decommissioning was launched and is expected to come to an end by 2022, that is to say 15 years after it was authorised. This duration was chosen by EDF for the decommissioning of the Pressurised Water Reactors. Following the filling of the Crey-Malville reactor vessel at the end of 2017, the decommissioning process continued with construction of the cutting workshop for caps of the reactor vessels, followed by opening of the vessel in 2019 and the removal of its two central caps. Regarding Brennilis, pursuant to a 2008 agreement  (1)  with the CEA, EDF has become fully responsible for deconstruction of this facility (pursuant to French Decree no. 2000-233 of 19 September 2000, EDF became responsible for the operation of the Brennilis plant, taking over from the CEA). The deconstruction works included in the scope of the Decree authorising partial decommissioning are currently being finalised: the safety concrete for the effluent processing station has been demolished, and the spoil removed. The results of the final inspections of the spoil will allow the area to be backfilled: this will be the end of the authorised works. Meanwhile, in 2018 EDF made a decommissioning application with a view to the publication of a complete decommissioning decree, allowing decommissioning of the reactor block itself. The decision of the Administrative Court of Appeal of Lyon of 4 December 2014, by restoring the validity of the ICEDA building permit, led EDF to relaunch the study of a file on the complete dismantling of Brennilis, taking into consideration any new regulations arising since the creation of the previous file, in particular the application of the BNF regulations. The complete dismantling file was thus submitted at the end of July 2018. 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. This new alternative combined with the proposed sequencing of operations took into account the results of the 2013-2015 pre-project studies, which show a significant prolongation of the operations to dismantle the caisson (about 25 years instead of 10 as originally planned), and the need to make the operation less risky by completely dismantling an initial series unit before dismantling the other 5 units. The new dismantling strategy was presented to the ASN’s Audit Council in March 2016 and June 2017. At the ASN’s request, a group of independent experts was commissioned to assess the robustness of the proposed dismantling whose chief features were confirmed. The update of the industrial scenario for the dismantling of first generation plants, in particular in regard to the NUGG reactors, had led to an increase in the provision of €590 million on 31 December 2015 (see note 29.1 of the appendix to the consolidated financial statements at 31 December 2015). The strategy file, the safety option report for the reactors, and the detailed timetable for operations over the 2017-2032 period were sent to the ASN in 2017. These provided supporting grounds for the technical options adopted, in particular the decommissioning sequencing for the six reactors: construction of an industrial demonstrator to test the tooling to be used during ■ the “in-air” dismantling of the first caisson; realisation of an “in-air” dismantling of an initial series unit, followed by the ■ realisation of a complete feedback procedure before engaging in the industrial dismantling of the other NUGG reactors; for the other caissons, work to develop a secure configuration after ■ electromechanical dismantling and the demolition of the peripheral buildings and structures (reactor buildings, pool hall, etc.) will be carried out for some in advance in regard to the previous scenario.

This new scenario forecasts an initial removal of the graphite from the first NUGG reactor by 2044 and pushes back the need for a disposal outlet for the other graphite waste to after 2070. In 2018 the ASN issued its main questions and conclusions about the NUGG strategy file. The “in-air” dismantling of all the reactors, the relevance of an industrial demonstrator, and the planning of the first “initial series unit” dismantled reactor (Chinon A2) is globally accepted. Discussions went on with regard to the schedule for dismantling the other five reactors. The schedule proposed by EDF would allow substantial feedback (decommissioning of a first reactor) before beginning virtually simultaneous decommissioning of the other five reactors. EDF was heard on 12 February 2019 by the ASN’s Audit Council on this particular topic in order to present all information supporting the planning proposed by EDF. In view of this, draft ASN resolutions were made available for consultation by the public between July and November 2019. These drafts specify the date on which the regulatory applications allowing decommissioning operations will be made, as well as the decommissioning programme which must be included in these applications. In these drafts, the ASN recognises the complex nature of the operations to be undertaken, the soundness of the risk management strategy put forward by EDF (industrial demonstrator and significant feedback from the first reactor). The final resolutions are due to be approved by the ASN College during 2020 (see note 32.1.3 of the appendix to the consolidated financial statements at 31 December 2019 “Decommissioning provisions for nuclear power plants”). Shut down of the Fessenheim plant 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 in France at 63.2GW, thus requiring EDF to take all necessary measures to close the two Fessenheim reactors. The early closure of the Fessenheim plant would give EDF the right to compensation, as recalled by the Constitutional Council in its decision of 13 August 2015, on the occasion of the review of the constitutionality of the aforementioned law. Discussions have taken place between EDF and the French State with a view to a memorandum of understanding including both a schedule of detriment issues granting entitlement to compensation and determination of the terms of this compensation. Having been advised of the favourable opinion of the working group made up of independent Directors, in a meeting on 6 April 2017, EDF’s Board of Directors took note of the inevitable and irreversible closure of Fessenheim subject to a number of conditions being met, and then authorised the Chairman and CEO to sign the compensation agreement negotiated with the French State, as approved by the European Commission, no later than the date on which the request to terminate the authorisation to operate the Fessenheim plant would be submitted. On 25 January 2019, the Ministry of Ecological and Solidarity Transition published the draft multi-year energy programme for the 2019-2023 and 2024-2028 periods which specifies that “the Fessenheim nuclear power plant should be decommissioned by spring 2020”. In view of this, and in the light both of the production capping referred to above, deadlines for new hydraulic tests and the periodic safety inspections specified in Articles L. 593-18 and L. 593-19 of the French Environment Code, and the fact that EDF could not continue to operate the Fessenheim plant, fresh negotiations were undertaken with the aim of adjusting some of the draft agreement requirements. Meeting on 4 April and 20 September 2019, the EDF Board of Directors authorised EDF to conclude the amended agreement. This was signed on 27 September 2019. On 30 September 2019, EDF sent the French Ministry for Ecological and Inclusive Transition and the Nuclear Safety Authority the request to terminate the operating authorisation, together with a declaration of the definitive shutdown of the Fessenheim nuclear power plant’s two reactors: shutdown of reactors 1 and 2 was planned for 22 February and 30 June 2020 respectively.

(1) Following this agreement, the CEA has become fully responsible for the decommissioning of Phénix.

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EDF | Universal registration document 2019