Universal Registration Document 2022

4H – Industrial safety violations and impact on environmental assets, including biodiversity

a) Main risks

The Group operates or has operated facilities which, as part of their day-to-day operations, can be, may be, or may have been the cause of industrial incidents or accidents having environmental impacts (air, soil and water pollution risks) or health impacts.

Furthermore, all the Group’s facilities and projects are concerned with biodiversity issues and, more generally, ecosystems, with particular reference to the issues of temperature and water extraction connected with climate change, especially in France where EDF is a major landowner and natural resource manager.

The stakes are all the higher since the energy transition introduces new or enhanced requirements in terms of biodiversity protection, pollution control and control of impacts on the environment as a whole.

The Group’s facilities may be located in industrial areas where other activities subject to similar risks exist, which means that the Group’s own facilities may be impacted by accidents occurring at neighbouring facilities owned by other operators and not under the Group’s control.

The Group owns 40 facilities classified as Seveso under the European Directive for the prevention and management of major industrial risks. These are essentially storage or warehousing facilities for oil, gas or chemicals.

Measures taken for industrial safety and the control of these risks may not be fully effective, which could have consequences for people, property and immediate surroundings. The Group may be held liable.

In case of a major accident, insurance policies for civil liability and damage taken out by the Group could prove to be inadequate, and the Group cannot guarantee that it will be able in the long run to maintain a level of cover at least equal to current cover levels.

Risks specific to nuclear facilities are further developed in section 2.2.5 “Specific risks related to nuclear activities”. Risks specific to hydraulic facilities are set out in 4E above.

An industrial safety failure may have a negative impact on the Group’s operational activity, its financial or legal position regarding its duty of vigilance, environmental assets, or its reputation, and may affect the Group’s ability to achieve its Corporate Responsibility goals pertaining to biodiversity (see section  3.2.1. “Issues, commitments and governance of EDF as regards Nature”).

b) Control actions

The risk management studies carried out on each industrial site integrate potential health or environmental impacts: compliance with regulations, monitoring, prevention and protection of soil, water, and air, and potential health effects. In addition, they include avoidance measures for accident situations. In this respect, feedback from the fire that occurred on 26 September 2019 at the Seveso-classified Lubrizol plant in Rouen was included in the analyses. The Group’s French Seveso sites all implement the regulatory requirements applicable to this type of facility. In addition, those sites all responded to the requests of the Prefects following the fire at the Lubrizol plant. The additional post-Lubrizol decrees on the storage of flammable liquids and toxic materials are applicable and therefore integrated into the Group’s ICPE (facilities that are classified for the protection of the environment) industrial facilities.

The industrial and natural risks (RIN) network within EDF ensures that the new requirements are monitored, appropriated and integrated on the sites.

Furthermore, the Group is committed to biodiversity through its corporate social responsibility concerns relating to the preservation of the planet’s resources (see section 3.2 “Preserving the planet’s resources”).

2.2.5 Specific risks related to nuclear activities

5A – Failure to comply with the objectives for operation and/or for extending the operating life of nuclear power plants (France and United Kingdom)

a) Context

The fleet of nuclear reactors that the Group currently operates in France is highly standardised (see section  1.4.1.1.2.1 “EDF’s nuclear feet in France ans its operation”). This enables the Group, in particular, to achieve economies of scale, to apply improvements made to its newest reactors to all reactors and, in the event of a reactor malfunction, to anticipate the measures to be taken with the other reactors. The Group has been aiming for several years to continue operating its nuclear power plants in France beyond 40 years.

On 15 December 2021, EDF announced the occurrence of the phenomenon known as “stress corrosion” near welds in the safety injection system (SIS) pipes as part of the ten-year inspection of reactor No. 1 at the Civaux plant. Similar defects have been detected in other plants. Dealing with these phenomena may involve checks and repairs leading to unscheduled shutdowns and have an impact on nuclear generation.

During the periodic reviews carried out during the ten-yearly inspections (VD) and following the Fukushima accident in Japan, the Group drew up a major work programme, called “Grand carénage”, the principle of which was approved by the Board of Directors.