ESRS E2 Pollution

Pollutants generated by Enea Group companies include dust generated during the combustion of coal (which, in addition to soot, also contains heavy metals), pollution associated with the transportation of coal to generating units, and pollution of rivers resulting from the operation of hydroelectric power plants, caused by the disruption of the morphological continuity of rivers.

The Enea Group has not adopted a pollution policy that would be uniform across the organization. Pollution is most relevant to conventional power generation companies and LWB, and is therefore regulated on a case by case basis at the level of distinct Group companies and is usually part of the implemented environmental management systems. The procedures adopted by the companies concern their own operations, whereas the bodies responsible for their implementation are environmental protection teams. The procedures and instructions are updated continuously to comply with applicable laws and integrated permits. These are internal documents and are not publicly disclosed.

At the Group level, there is no separate policy on the substitution and minimization of the use of potentially hazardous substances. The same applies to the individual Group companies. However, all Group companies limit the use of such substances to the extent necessary for their maintenance and repair activities.

There is no uniform incident and emergency prevention policy at the Group level, but most of the Group companies have adopted regulations on incident and emergency prevention and strictly adhere to these arrangements. They are presented in the table below. The procedures that have been put in place help prevent the occurrence of incidents and emergency situations, because they also include preventive measures and actions, not just those taken in response to an incident or emergency situation, e.g. Program for the prevention of major industrial accidents at Enea Elektrownia Połaniec or Program for the prevention of major industrial accidents related to the storage and use of hazardous substances and materials at the Zachód Heat Plant adopted by Enea Ciepło.

Most Enea Group companies took measures related to pollution in 2024 – their scope was focused on their own operations and will be continued in the following year. The result of the measures taken is the collection of information on pollution and its reduction.

In 2024, the vast majority of Enea Group companies did not record any situations that required corrective action to be taken in relation to persons adversely affected as a result of actual material impacts. In early spring 2024, Enea Elektrownia Połaniec received a complaint about dust from the Pióry furnace waste landfill. The dust was caused by strong, gusty winds and a prolonged absence of precipitation. In order to counteract this phenomenon, preventive action involving the gelling of waste will be accelerated. This measure will limit the dusting that occurs during adverse weather conditions in early spring.

Pollution-related operating expenses (OpEx) and capital expenditures (CapEx) incurred in the reporting period and intended to be incurred in the following years for activities in the area of pollution are presented below. Most Group companies finance pollution-related activities from their own funds. Enea Wytwarzanie uses financing in the form of an intragroup loan and funds from a centralized cash management system. Financing from the same sources is intended to be continued in the coming years.

No pollution targets have been set at the Enea Group level. The Group intends to adopt targets as part of the work on its ESG Strategy. To date, no need has been identified to set targets at the Group level, because most of the negative impacts related to pollution are located at the level of generating companies. The monitoring of the effectiveness of the measures described in section E2-2 includes, without limitation, the continuous monitoring of emissions of SO₂, NOx, CO and other substances, monitoring of waste gas emissions and monitoring of the quality of wastewater discharged into water bodies. This monitoring is carried out in accordance with the procedures described in section E2-1.

Pollutant emissions to air and water in 2024.

Pollution levels in the Enea Group remained at a similar level to previous years.

Pollution information has been compiled in accordance with KOBIZE reporting guidelines. The companies continuously measure dust, SO₂, NO₂, CO, NH3, HCl emissions (Enea Wytwarzanie and Enea Elektrownia Połaniec also measure NOx, HF and mercury). The measurements are carried out by means of automatic measuring systems (AMSs) that fulfill the requirements of PN-EN 14181 and are connected to emission computers that collect and present data in the form of synoptic images and reports. Moreover, periodic monitoring of metals and metalloids and SO₃ is carried out once a year. For ash bunkers, transfer bunkers, limestone meal bunkers and hydrated lime bunkers, periodic monitoring of dust emissions is carried out every two years. Other substances are calculated based on indicators determined by unit measurements and the amount of fuel burned. Unit measurements are taken by companies holding the required accreditation obtained from the Polish Center for Accreditation. Data recorded by continuous monitoring are collected in the form of AMS system reports. At Enea Wytwarzanie, all emission data are collected in the Company’s Environmental Pollution Database. Moreover, employees keep spreadsheets, of which the primary one is the Environmental Charges Model (MOŚ), which is saved on a network drive.

The companies monitor the quality of the wastewater discharged into surface waters. The data on water pollution have been provided in accordance with the report to the European Pollutant Release and Transfer Register (PRTR). Samples are taken and tested by laboratories accredited by the Polish Center for Accreditation in accordance with applicable standards. In addition to the composition of the wastewater, its temperature, electrical conductivity and pH are also measured. Measurements of the quality of substances in water and wastewater are carried out periodically in accordance with the testing schedule. Flow rates are determined using calibrated measuring instruments such as electromagnetic flow meters, flow sensors and ultrasonic flow meters.

Data from periodic measurements carried out for reporting purposes are recorded in the form of reports on measurements and analyses.

Potentially hazardous substances are used in the Enea Group for energy generation, energy distribution and coal mining, and leave the Group’s facilities in the form of emissions.

Substances used for production purposes include substances used for electricity generation and machine and equipment maintenance. Fuels, cleaning agents and substances used in laboratories were not taken into account. The weight of potentially hazardous substances was determined on the basis of warehouse information and safety data sheets for each substance. Where only the volume of a substance was known, its weight was estimated using standard volumes for substances of this type. For Enea Operator, the classification into hazard categories was based on product types rather than safety data sheets. Potentially hazardous and particularly concerning substances emitted in 2024 were determined based on the emission of pollutants into water and air from indicator E2-4. The substances and the emitted pollutants were categorized into the appropriate hazard classes in accordance with the classification in Part 3 of Annex VI to Regulation of the European Parliament and Council (EC) No. 1272/2008(33).