Universal Registration Document 2021

3. Non-financial performance

3.5.4.3 Management of environmental risks

Environmental risks, including those associated with climate change, are fully integrated into the Group’s EMS and internal control system in coordination with Group risk management. They are subject to action plans resulting from strategic priorities in the Group’s CSR policy.

3.5.4.3.1 Identifying the environmental risks

The identification of environmental risks is part of the Group’s overall risk management system (see chapter 2 “Risk factors and control framework”). Each company draws up its own risk map, based on the Group’s methodology, and defines action plans to reduce and limit its risks. As in previous years, the most significant factors pertain to the following subjects:

Main environmental risks
Risk factors Activities most affected

Climate change and GHG emissions

Power and heat generation activities from fossil fuel
  • The impacts of EDF’s activities on the air, water and soil and waste production
  • Protection of biodiversity and services provided by ecosystems
  • The management of water resources
Power generation activities (nuclear, thermal, hydropower, wind and solar power)

The main change concerns the observation of the effects of climate change with higher temperatures in summer and droughts increasing the pressure on both environments and some of the Group’s business lines such as hydropower and nuclear activities.

At the end of 2021, the Group has eight high-threshold SEVESO sites (1) and 32 low-threshold sites (2).

3.5.4.3.2 Managing the environmental risks

In order to control risks of industrial incidents or accidents that could harm the natural environment or public health, EDF has implemented a Group environmental management system. The system is based on an active investment policy incorporating:

  • the best available technologies (BAT) for protecting the environment;
  • an industrial asset decommissioning programme for assets no longer in operation, which includes decontamination operations where necessary;
  • an employee training and awareness-raising programme for all stakeholders, including feedback from crises lived and drills;
  • inspections and audits at generation and tertiary sites;
  • a crisis management policy.
Crisis management policy

The Group crisis management policy which requires the regular testing of crisis systems through an annual programme of crisis response drills (see section 2.1.3.6 “Crisis management and business continuity”). The industrial incident at the Lubrizol Seveso site in France (non-EDF site) led to a change in the regulatory framework and generated specific internal feedback in order to identify avenues for progress in the layout and protection of storage facilities.

High-stake environmental event (EVE) (3)

Locally, each of the Group’s operational units and companies identify events that could have an environmental impact, manage emergency situations that could result from them, conduct corresponding crisis response drills, implement investigations and monitoring corrective actions, and communicate on environmental events under its responsibility.

No EVE Actions to closely supervise and monitor production processes have made it possible to avoid high-stake environmental events with a significant impact on the environment. Certain operational events such as hydrocarbon leaks and alignment deficiencies in effluent transfers may result in litigation arising from complaints lodged by NGOs or associations and notices to comply issued by national regulatory authorities (ASN, DREAL, etc.).

In 2021, €7,000 in penalties were imposed on EDF for shortcomings in adhering to current regulations on monitoring and control, in application of the Environmental Code, at the Bugey and Gravelines sites. The corrective actions undertaken led to the resolution of these two situations.

(1) These sites include Bellefontaine B, Pointe Jarry, East Port and Jarrie in France, Hole House in the UK, and Collalto, Cellino and San Polito in Italy.

(2) Upper and lower threshold: industrial sites are “Seveso” classified according to their technological risk depending on the quantities and types of hazardous products they handle. There are two different thresholds which classify sites as “Seveso low-threshold” or “Seveso high-threshold”. The requirements vary significantly between these two types; they are very restrictive for the high threshold, particularly with regard to the safety management system, informing the public and the prevention plan, etc.

(3) High-stake environmental event: an event causing serious environmental damage (areas, resources and natural environments, sites and landscapes, air quality, animal and plant species, biological diversity and equilibriums) combined with extensive media coverage or a financial impact of more than €3 million. An event causing environmental damage and likely to affect human health falls within the scope of a high-stake environmental event for the EDF group.