EDF / 2020 Universal Registration Document

1 THE GROUP, ITS STRATEGY AND ACTIVITIES Description of the Group’s activities

Radioactive Waste Management In the UK, radioactive waste is classified into four categories: Low Level Waste (LLW), for which a near surface disposal route exists – including the LLW Repository at Drigg West Cumbria; Intermediate Level Waste (ILW), for which no disposal route is currently available in the UK; High Level Waste (HLW) is defined as radioactive waste in which the temperature may rise significantly as a result of the radioactivity, so this factor has to be taken into account in the design of storage and disposal facilities; Higher Activity Waste (HAW) – this is effectively HLW, ILW and any LLW that are unsuitable for near-surface disposal. EDF Energy nuclear generation’s strategy for LLW and HAW reflects that the UK and Scottish Governments are focused on application of the waste hierarchy (reduce, reuse, recycle, recover). The use of a range of waste recycling and disposal routes will help to make the best use of the UK’s Low Level Waste Repository (LLWR) in Cumbria. Only a disposal route for LLW currently exists in the UK. HAW is stored for the medium-term in safe, purpose built facilities at EDF Energy’s stations while longer term national solutions are being established within England and Scotland. Spent fuel from the AGRs is transported to Sellafield nuclear reprocessing site (owned by Sellafield Limited, a subsidiary NDA) for long term storage. PWR spent fuel from Sizewell B is stored on site in a purpose built spent fuel dry storage facility which will safely store all of the spent fuel that will be generated over Sizewell B’s life. Following long-term surface storage, the Sizewell B PWR spent fuel will be disposed to a future UK geological disposal facility. The AGR spent fuel arrangements were agreed at the time of the restructuring of British Energy and through them EDF Energy pays for long term storage (and in previous years reprocessing) of spent nuclear fuel. Sizewell B’s fuel storage strategy is approved by the NDA as it is funded by the Nuclear Liabilities Fund. EDF Energy has policies to continually improve and minimise the spent fuel and waste arising through the company’s wider safety, sustainability and environmental policies. Regulatory notice Radioactive waste In the United Kingdom, EDF is required, under nuclear site licence Condition 34, to ensure, so far as is reasonably practicable, that radioactive material and radioactive waste on its sites is adequately controlled or contained so that it cannot leak or escape. The Environment Agency regulates the disposal of radioactive waste from licensed nuclear sites under the environmental permitting (England and Wales) regulations 2016. These regulations also regulate what was previously governed by Pollution Prevention and Control, Water Resources Act discharge consents, Flood Risk activity consents and Waste Management licensing.

The Committee on Radioactive Waste Management (CoRWM) published its recommendations for the long-term management of higher activity waste in 2006. In response, the UK Government decided to prefer the use of deep geological disposal facilities for the storage of higher activity waste in England. It set the framework for the management of long-term storage through geological storage, combined with a safe and secure interim storage.

Financing of decommissioning and radioactive waste management

Regulatory notice

Decommisionning of nuclear facilities In the United Kingdom, EDF is subject to nuclear site licence Condition 35 which forms the basis for the detailed decommissioning plans and programmes required by the ONR, but its requirements must be taken into account with other legal provisions such as the nuclear reactors (Environmental Impact Assessment for Decommissioning) regulations 1999 which require an assessment of the environmental impact of decommissioning and mitigation measures to reduce the environmental impact. Decommissioning is usually carried out in stages, with ONR formal approval required to move on to the next stage. The ONR may order operators to start or cease decommissioning at any time and must approve decommissioning plans for each stage of the decommissioning process. EDF Energy is party to a suite of agreements (the Restructuring Agreements) that set out how qualifying decommissioning and uncontracted liabilities costs will be funded by the NLF as well as include a guarantee by the UK Government for the costs of decommissioning the existing nuclear plants. The NLF was funded initially through a UK Government contribution and since privatization by EDF Energy Nuclear Generation Ltd. making quarterly payments to the NLF under the terms of a contribution agreement. In 2020, the UK Government made an additional contribution to the NLF of £5 .billion. EDF Energy has been in discussions with the UK Government to agree changes and clarifications to the Restructuring Agreements to provide for efficient recovery of qualifying costs and clarity that once the AGR stations have finished defueling that they will transfer to the Nuclear Decommissioning Authority (NDA) for subsequent decommissioning activities. Also see note 15.2.1 “Regulatory and contractual framework” of consolidated accounts. Prospective operators of nuclear power plants are required to submit in their FDP a Decommissioning and Waste Management Plan (“DWMP”), setting out the operator’s costed plans for meeting its decommissioning and waste management and disposal obligations, and a Funding Arrangements Plan (“FAP”), explaining how the operator will make financial provision for its obligations. Chapter 1 of Part 3 of the Energy Act 2008 (“EA 2008”) sets out the rules governing the decommissioning and clean-up of nuclear sites, along with detailed provisions on FDPs. Also see note 15.2.3 “Provisions for nuclear plant decommissionning” of consolidated accounts.

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EDF - UNIVERSAL REGISTRATION DOCUMENT 2020