Universal Registration Document 2022

Introduction

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
  • Climate change and GHG emissions

 

Power and heat generation activities from fossil fuel

  • Impacts of EDF’s activities on the air, water and soil and waste production
  • Protection of biodiversity and services provided by ecosystems
  • Management of water resources
  • Impacts of EDF’s activities on the air, water and soil and waste production
  • Protection of biodiversity and services provided by ecosystems
  • 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 2022, 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 2022, the amount of criminal fines ordered against EDF amounted to €3,000 (with the fines being suspended), for a breach of legislation relating to the protection of protected species at the Vieux Pré hydroelectric site in Pierre Percée (Meurthe-et-Moselle). Following the event, an agreement was entered into with local fishery stakeholders, providing for the financing by EDF of an annual action programme.

Reduction of chemical risks

When it is technically feasible, in order to reduce pollution risks, the Group’s entities have also implemented a programme to eliminate or substitute certain chemical substances with more environmentally-friendly products. This work focuses as a priority on CMR (carcinogenic, mutagenic, or toxic for reproduction) substances or those considered subject for concern.

Substitution and disposal

Substitute products are often environmentally certified, e.g. cleaning products (regarding our subsidiaries Citelum, Électricité de Strasbourg (ÉS) and data centres). Following on from the R&D studies, substitutions are implemented, such as: environmentally acceptable oils for hydraulic production, fluids for thermal and nuclear power plant turbines in France and the United Kingdom, varnishes and paints (Industrial Division, Property Management and Citelum), and the decision by the Real Estate Department to stop using pesticides.

PCBs and PCTs

EDF, Hydro, Property Management, Enedis and ÉS are continuing with their programmes to decontaminate equipment with concentrations higher than 50 ppm for PCBs (4) and PCTs (5). These action plans continued in 2022 and are on target. For the “Electrical Equipment Laboratory” Department at the site in Les Renardières, the matter was fully handled last year. Complete disposal is set for the end of 2025 for EDF IES. Thermal and nuclear generation lines no longer have any equipment exceeding the threshold.

(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 establishments 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 establishments 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 balance) 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.

(4) PCB: Polychlorobiphenyls.

(5) PCT: Polychloroterphenyls.