Universal Registration Document 2020

2.2.4 Operational performance

This section describes the most significant risks related to the control of the Group’s operating activities across its various industrial activities and projects, including EPR.

Failure to achieve the expected operating results may lead to a direct deterioration in the Group’s financial position, reputation and ability to transform.

4A – Management of large and complex industrial projects, including EPR projects.

Criticality in view of the control actions undertaken: Strong.

As part of its activity and in its capacity as project owner or prime contractor, the Group is called upon to carry out projects that are very complex, require significant investments and lengthy procedures for construction and regulatory approvals.

The most significant projects in progress concern the completion of large-scale nuclear projects and primarily EPR projects. These projects entail a major risk for the Group.

Other ambitious projects may involve, in France or internationally, offshore facilities for new energies (off-shore wind power in France), the installation of new meters (Linky in France, handled by Enedis) on an entire distribution network concerning tens of millions of customers, in France or the United Kingdom, the implementation of hydraulic projects, or large scale projects relating to the existing nuclear facilities(Grand Carénage project and decommissioning projects).

Complex projects subject to numerous uncertainties

The implementation of these projects may give rise to numerous technical, industrial, operational, economic, regulatory, political, environmental or acceptability risks that could jeopardize project schedules, associated costs or profitability.

These projects are large-scale and long-duration projects; they involve numerous industrial partners. There may also be difficulties in terms of relationships with the partners involved with EDF in these projects. For example, trade tensions between the United States and China could have an impact on the conduct of some of these projects given the technologies and partnerships implemented (see risk 4E). Tensions between the United Kingdom and China, and changes in the strategy of our Chinese partner, could in particular weigh on the development of the partnership with CGN.

The health crisis has notably affected the deployment of these major projects and could, if it were to worsen, lead to delays or additional costs, linked in particular to public health requirements that might be imposed (social distancing, curfews, etc.). La crise sanitaire a affecté le déploiement de ces grands projets et pourrait, si elle devait s’aggraver, induire des retards ou des surcoûts, liés notamment aux contraintes sanitaires imposées (gestes barrières, couvre-feu…).

Financing and authorisations for major projects

These projects require, among others, administrative authorisations, licenses or permits which may be subject to disputes, withdrawals or delays in obtaining them.

They also involve significant investments, for which the financing and pricing conditions may still be subject to confirmation or modification. Given the economic, sanitary or institutional climate or depending on the appropriate progress of the pending projects, obtaining such funding may be delayed.

To date, the legal framework relating to the European taxonomy for sustainable finance (draft delegated act on taxonomy) proposed by the Commission does not include nuclear power, which is dealt with in a specific process. If this process were to result in the exclusion of nuclear power, this would be seriously detrimental to theGroup’s ability to finance future major nuclear projects (see risk 1A).

CSR issues

A very large number of stakeholders may be involved in these projects which may, for example, need to be associated with territorial development projects or suffer from difficulties related to local acceptance. In order to improve this project control, the Group has embarked on an overhaul of its project management and has defined a “Commitments” policy that requires an analysis to be carried out of the associated risks and security issues. This project management takes into account, in accordance with EDF’s vigilance plan, the potential impacts of projects on human rights, the environment, health and safety, as well as the CSR issues of dialogue and consultation with stakeholders, territorial development, development of industrial sectors, ethics and responsible land management (see sections 3.2, 3.3, 3.4 and 3.6).

Performance

The success of the EPR projects, in particular, will determine the future of the nuclear industry. As such, it represents a key issue for the Group. Since December 2019, theGroup has been implementing the Excell plan, which aims to enable the French nuclear industry to successfully complete its nuclear projects (see section 1.4.1.1.1.).

Such situations could, in particular in the event of non-compliance with the Group’s contractual commitments or the Group’s potential exposure in the event of major contingencies arising from the completion of these projects or the operation of these reactors, have a major impact on the Group’s business, results, asset value, financial position, reputation, organisation and outlook.

Operational control of EPR projects

France

EPR Flamanville 3

The Flamanville 3 project (see section 1.4.1.1.3.1 “Flamanville 3 EPR project”) is a major industrial, regulatory and financial challenge for the Group. In particular, meeting the timetable and cost objectives is still dependent on:

• implementing the action plan on a hundred welding seams to be reworked on the main secondary circuit piping (VPP and ARE⁽¹⁾), as well as those of the 8 containment crossings for which ASN has requested immediate repair. For these penetration weld repairs, the preferred option of reworking by remotely-operated robots could run into difficulties, particularly in view of the innovative nature of this option and the delay in the appraisal by the ASN. On this point, the ASN authorisation is currently expected to be issued in the first quarter of 2021. The repairs to all these welds are critical to the completion of the EPR project within the target schedule;
• the documentary or corrective actions under study and their validation by the ASN following the incomplete observance of the 2006 study handbook for the location of the installation of three noozles on the main primary circuit in respect of which a significant event was declared to the ASN on 2 March 2021;
• the re-testing by sampling prescribed by the ASN on the welds of the main primary circuit;
• the successful completion of the start-up tests still to be carried out and the transfer of all the systems to the operator;
• obtaining the various authorisations that must still be issued by the ASN, in connection with the examination of the technical files related to EPR licensing. In this context, a decree of 25 March 2020 extended the maximum time limit for commissioning the reactor to April 2024;
• the ageing of equipment and materials due to the duration of the work;
• the emergence of any other risks, including while the works are continuing.

In a press release dated 9 October 2019, the Group noted that the provisional timetable for implementing the preferred scenario for reworking the feed through welds, subject to validation by the ASN of this scenario and the date on which it would be implemented, meant that the fuel could be loaded at the end of 2022. At the end of 2020, a review of the impact of the first lockdown on the construction site did not lead to a change in the fuel loading date and construction cost targets announced in October 2019, but showed that there is no longer any leeway for the project, either in terms of schedule or cost.