EDF / 2020 Universal Registration Document

6 FINANCIAL STATEMENTS

Notes to the consolidated financial statements

15.1.1.3

Decommissioning provisions

The ongoing operations concern 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. The experience gained from dismantling the Chooz PWR will nonetheless improve the robustness of the studies and estimates of future decommissioning costs for the nuclear fleet currently in operation (“second-generation” plants). But so far, 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. 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).

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. 593-25 to L. 593-20 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.

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

Discount effect

Other movements

31/12/2020

31/12/2019

Increases

Decreases

(in millions of euros)

Provisions for decommissioning nuclear plants in operation Provisions for decommissioning permanently shut-down nuclear plants DECOMMISSIONING PROVISIONS FOR NUCLEAR POWER PLANTS

13,244

-

(43)

474

(900)

12,775

3,693

133

(138)

306

720

4,714

16,937

133

(181)

780

(180)

17,489

Other movements notably include reclassification of the decommissioning provision concerning the two Fessenheim reactors from “Provisions for decommissioning nuclear plants in operation” to “Provisions for decommissioning permanently shut-down nuclear plants” following their final shutdown in the first half of 2020. For nuclear power plants currently in operation (PWR pressurized water reactor plants with 900MW, 1,300MW and N4 reactors) Until 2013, provisions were estimated based on a 1991 study by the French Ministry of Trade and Industry, which set an estimated benchmark cost for decommissioning expressed in €/MW, confirming the assumptions defined in 1979 by the PEON commission. These estimates had been confirmed from 2009 by a detailed study of decommissioning costs conducted by EDF at the representative site of Dampierre (four 900MW units), and its results were corroborated by an intercomparison with the study carried out by consultants La Guardia, based mainly on the Maine Yankee reactor in the US.

In 2014 the Dampierre study was reviewed by EDF to make sure that the previous calculations were still valid in view of recent developments and experience, both internationally and internally. For this revision, the decommissioning provisions for plants in operation were based on costs resulting from the Dampierre study, in order to incorporate best estimates and experience from inside and outside France. This change of estimate had no significant impact on the level of provisions at 31 December 2014. Between June 2014 and July 2015, an audit of dismantling costs for EDF’s nuclear fleet currently in operation was conducted by specialised consulting firms, at the request of the French Department for Energy and Climate (Direction Générale de l’Énergie et du Climat or DGEC). On 15 January 2016 the DGEC published a summary of the audit report. It stated that although estimating the cost of decommissioning nuclear reactors is a demanding exercise due to relatively limited past experience, the prospects of changes in techniques, and the distant timing of the expenditure, overall, the audit confirmed EDF’s estimate of decommissioning costs for its nuclear fleet currently in operation. The DGEC also made a number of recommendations to EDF following this audit.

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EDF - UNIVERSAL REGISTRATION DOCUMENT 2020