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By Regan Scott

Europe & EDF: a seventy page formal letter has been sent by Brussels competition officials to the UK government about the Hinkley deal with EDF.

The best source so far on the ‘strike price’ deal, it shows there are two contracts, one to cover the investment and build period, and the better publicised strike price deal for a 35 year price guarantee, proofed for inflation, and set at £92.50.per megawatt hour. This is twice the current price for UK wholesale electricity. By 2058, the end of the strike price, it would be worth a wholesale guarantee price of £279 per MWh, compared to the present price of about £45.

The letter says ‘ the information provided does not substantially support’ the view that the proposed state aid is needed. It is estimated at between £5 billion and £17.5 billion.

Brussels asks lots of questions and unpicks arguments, asks EDF competitors to send evidence (and citizens like us too) and looks likely to investigate and report by the end of the summer when EU Competition Commissioner Almunia ends his period of office.

To understand the Brussels approach, we need to know that state aids as such for energy are not banned. The questions are: is it necessary, are the terms fair and likely to be successful (getting nukes built) and proportionate to the problem. Watch these spaces.

The letter reveals that there was no open bidding for the Hinkley project, that UK taxpayers (or electricity bill payers through a levy) will foot the bills but exactly how is not specified ( or has been redacted).  Brussels says overall energy prices are so difficult to predict that long term guarantees don’t look wise. EDF reveals formally it wants to develop Oldbury (just up the Avon estuary beyond Hinkley) as well as Sizewell.  A subsidiary Elexon of the National Grid (privatised) will handle the strike price payments. The first investment contract will have UK government guarantees, and private investors – other energy firms, private equity, the Chinese nuclear energy companies – will get their money back first if the project goes wrong.

The prospect that EDF will not actually own and control Hinkley or Sizewell is set out in the EU letter which explains that investment will be EDF (45-50%), Areva (10%), China General Nuclear Corporation and China National Nuclear Corporation (30-40% combined) and other investors (up to 15%). So China and outside investors could get as much as 55% ! By any count, that’s a controlling interest, so maybe we should think it’s not going to be an EDF owned project at the end of the day. The rate of return on capital for investors enjoying the subsidies is put at 9.75 to 10.25%.  Analysis of economic models in the letter suggests that EDF could make 7.5% return on capital without any state aids. It is therefore being suggested that this might be a real ‘earner’ !

The status, reliability and development time for the EPR is also revealed. Finland’s Olkiluoto EPR started in 2005 and is unfinished and subject to a reciprocal legal dispute involving several £ billion. EDF France’s Flamanville EPR started in 2007 and is massively behind time. Neither have received any subsidies. Meanwhile Russia’s Rosatom have agreed to build another Finnish plant with their own reactor design and match the current wholesale price of about £45 per MWh. Hinkley is planned for a  construction period of 10 years, a 60 year life, plus 20 years decommissioning. Unit 2 is planned to complete 12-18 months after the first but there is a strange reference in the Brussels letter to a ‘long stop’ date for the second reactor build. This is assumed to take 8 years, but on EPR experience to date, could be much longer. It seems the investment guarantees run for four years longer than the official dates, so maybe Hinkley site will be busy not for the planned 10 years, but another 4 at least…..Were planning  inspectors pulling wool over eyes about build disruption ?

Brussels says officially ( better source than some journalists !) that since there are not any actually up and running EPRs (EDF’s chosen design from French nuclear engineers Areva), costs and efficiency etc can’t be confidently predicted in any case, especially over 10 years and another 35 to pay for it all.

Financial contracts and the funding arrangement for decommissioning are still not decided by the UK, so Brussels may make a conditional decision leaving some questions still open by the end of the year. Discussions also continue (!) on a price re-opener clause for EDF, and arrangements (if any) to claw back excess profits.

There is a useful discussion about the insurance costs and accident risks, which suggests that the so called ‘top-end’ risk – a big accident – is not being met by EDF but by the taxpayer, as we always assumed.

The economics of it all and the impact on energy markets is to be assessed for Brussels by two experts from Imperial College, London.

Brussels also rejects the ‘lights out’ argument on the basis that nuclear will be too late in any case.

Overall, the UK argument that a 10 year build guarantee and a 35 year price guarantee are necessary to cover costs and give a commercial return is rejected since it implies that profit will only be made in the last 25 years of the site’s life. Closely associated is Brussels saying that while the UK gives guarantees, EDF promises legally nothing in return, and faces no penalties for under performance: it is not therefore a public interest deal.

Brussels will also examine how the EDF/UK contracts might undermine fair competition from renewable energy developments and companies, which unlike nuclear may be genuinely ‘new’.

Experts agree that high levels of radiation can kill and that there is no such thing as a safe dose of radiation: even at low levels, the potential for harm exists. The existing guidelines for ‘safe’ levels are based on the data obtained from the Japanese atom bomb explosions of 1945. The fact remains, however, that so-called ‘safe’ exposure rates over the last 70 years have steadily been revised downwards as we find out more about the harmful effects of radiation exposure. (there are occasional exceptions – after the Fukushima accident in April 2011, the Government in Japan increased the permissible safe level of exposure for school children by 20 fold.¹ Ministers defended the increase in the acceptable safety level as a necessary measure to guarantee the education of thousands of children. ²)

As can be seen from this diagram, although there is clear agreement about the danger of high levels of radiation, experts do not agree on whether very low levels of radiation are beneficial, neutral or harmful. The majority of studies assume a ‘linear no-threshold (LNT)’ approach to exposure and health – the higher the ‘dose’, the greater the health impact. ³

In recent times the way that exposure to radiation is assessed has been criticised. The amount of radiation a person is exposed to has traditionally been calculated by averaging it out over their whole body (Joules per Kilogram mass of tissue ⁴). However, radiation is often concentrated in high energy hot particles which if inhaled or ingested do a lot of damage to the surrounding cells.

It is like comparing the amount of heat in a nice hot bath with the heat in a burning cigarette. The hot bath may contain far more heat, but when the heat is concentrated in the end of the cigarette it is far more painful and damaging when applied to the skin.

The upshot is that “dose” becomes a meaningless measure. Comparisons of external dose received are not comparable to internal dose when considering low dose, short range radiation effects on DNA especially from exposure to high density alpha radiation.

Children are more sensitive to radiation than adults. Generally, when cells, organs or tissues are developing, as they are in children, they are more likely to be affected if radiation interacts with them. Thus age is another factor which has to be taken into consideration when assessing the effects of low level radiation.

A 2007 study of Swedish children exposed to fallout from Chernobyl while they were foetuses between 8 and 25 weeks gestation has found that the reduction in IQ at very low doses was greater than expected, given a simple Linear No threshold model for radiation damage.⁵ Similarly, Dr Alice Stewart showed that foetal damage could be caused by x-rays of pregnant women, a finding which led to the curtailing of the use of x rays during pregnancy and early childhood.⁶

paintings of insects with genetic deformations from the area around chernobyl by Cornelia Hesse- Honegger 7

In 2002 the German government sanctioned the compiling of a report looking at the level of leukaemia in the under-fives in the 5 kilometre radius of all German nuclear power plants. This study, known as the kikk report (Kinderkrebs in der Umgebung von Kernkraftwerken), was published in 2007. It identified a two-fold increase in the number of leukaemia cases.⁸ Similar studies carried out in France and Switzerland echoed these findings.⁹ In the UK, the Health Protection Agency’s sub-committee, the Committee on Medical Effects of Radiation in the Environment (CoMARE) published its 14^th report looking into these worrying findings abroad. Although COMARE also found an increase in childhood leukaemias, it argued they were not statistically significant, a claim hotly contested by COMARE’s critics.¹⁰

Nuclear Power stations are allowed to emit a certain level of radioactive material into the atmosphere. An average of the amount emitted is calculated over the whole year, however, in reality, most emissions from nuclear reactors are not spread evenly across the whole year but happen during short refuelling episodes which occur about once a year and which last a few days or so. In September 2011, Germany released data tracking half-hourly releases of radioactive gases from a power station (Gundremmingen Nuclear plant in Southern Germany) for the very first time anywhere in the world. This is shown in the chart below for 7 days in September 2011. The chart shows that the normal emission concentration during the rest of the year was about 3 kBq/m³, but during refuelling on September 22 this sharply increased to ~700 kBq/m³. In other words, a spike. It shows that Nuclear power stations can emit much larger amounts of radioactive gas during refuelling than during normal power operation. In order to refuel, reactor pressure vessels must be opened up: this releases large volumes of radioactive gases and vapours to the local environment.¹¹

Estimates suggest that people living near the Gundremmingen plant will be exposed to doses of radiation up to 500 times higher during the emissions spikes than they are during the rest of the year. The spikes of UK reactors may not be as high as in Germany because the German power stations are inland and cannot release emissions into the sea,but even if UK spikes were only a fraction as high they could still be a risk to health. German physician Reinhold Thiel, warns of the probable health impacts of large emission spikes:
“Especially at risk are unborn children. When reactors are open and releasing gases, pregnant women can incorporate much higher concentrations of radionuclides than at other times, mainly via respiration” ¹²

It has long been suspected that children conceived after parental exposure to radiation carry an increased risk of genetic defects. A study published in 2001 on the cleanup workers of Chernobyl showed a surprisingly large number of genetic aberrations in the children of these people, even in cases when the exposure levels to the radiation had been considered low.¹³ The study concluded:

“The very fact that much lower doses of radiation than previously generally believed can double the number of genomic changes needs serious attention”

1 http://www.nuc.berkeley.edu/node/3919
On April 19, the Japanese government sharply ramped up its radiation exposure limit to 2,000 millirem per year (20 mSv/y) for schools and playgrounds in Fukushima prefecture. Japanese children are now permitted to be exposed to an hourly dose rate 165 times above normal background radiation and 133 times more than levels the U.S. Environmental Protection Agency allows for the American public. Japanese school children will be allowed to be exposed to same level recommended by the International Commission on Radiation Protection for nuclear workers.

2 http://www.guardian.co.uk/world/2011/may/02/parents-revolt-radiation-levels
Ministers have defended the increase in the acceptable safety level from 1 to 20 millisieverts per year as a necessary measure to guarantee the education of hundreds of thousands of children in Fukushima prefecture.

3 http://www.atsdr.cdc.gov/hac/pha/oakridgey12/oak_p6.html
APPENDIX D: ATSDR’S DERIVATION OF THE RADIOGENIC CANCER COMPARISON VALUE

4 https://rpop.iaea.org/RPOP/RPoP/Content/InformationFor/HealthProfessionals/1_Radiology/QuantitiesUn
its.htm

5 Chernobyl’s subclinical legacy: Prenatal exposure to radioactive fallout and school outcomes in Sweden “We use prenatal exposure to Chernobyl fallout in Sweden as a natural experiment inducing variation in cognitive ability. Students born in regions of Sweden with higher fallout performed worse in secondary school, in mathematics in particular… From a public health perspective, our findings suggest that cognitive ability is compromised at radiation doses currently considered harmless.“

6 Alice Mary Stewart : “Her pioneering study of x-rays as a cause of childhood cancer, which she worked on from 1953 until 1956, were initially regarded as unsound, but her findings on fetal damage caused by x-rays of pregnant women were eventually accepted worldwide and the use of medical x-rays during pregnancy and early childhood was curtailed as a result.“

7 Cornelia Hesse-Honegger,scientific illustrator and science artist, was born in 1944 in Zurich, Switzerland. For 25 years she worked as a scientific illustrator for the scientific department of the Natural History Museum at the University of Zurich. Since 1969 she has collected and painted leaf bugs, Heteroptera. Her watercolours are exhibited internationally at museums and galleries. Since the catastrophe of Chernobyl in 1986, she has collected, studied and painted morphologically disturbed insects, which she finds in the fallout areas of Chernobyl as well as near nuclear installations.

8 Leukaemia in young children living in the vicinity of German nuclear power plants Peter Kaatsch, Claudia Spix, Renate Schulze-Rath, Sven Schmiedel and Maria Blettner
Int. J. Cancer: 1220, 721–726 (2008) 2007 Wiley-Liss, Inc.

9 A French study (GEOCAP) of childhood leukaemia near nuclear power plants (NPPs) has found a statistically significant increase in leukaemia in children below age 15 in 2002-2007 within 5 km of 19
French NPPs Sermage-Faure C, Laurier D, Goujon-Bellec S, Chartier M, Guyot-Goubin A, Rudant J, Hémon D, Clavel J. Childhood leukaemia around French nuclear power plants – the study, 2002-2007. Int J
Cancer. 2012 Jan 5. doi: 10.1002/ijc.27425. http://ije.oxfordjournals.org/content/early/2011/07/11/ije.dyr115.full.pdf+html
Spycher BD, Feller M, Zwahlen M, Röösli M, von der Weid NX, Hengartner H, Egger M, Kuehni CE. Childhood cancer and nuclear power plants in Switzerland: A census based cohort study. International Journal of Epidemiology (2011) doi:10.1093/ije/DYR115.

10 Dr Ian Fairlie was written a critique of the 14th Annual Report of the independent Government committee COMARE (the Committee on Medical Aspects of Radiation in the Environment). Dr Fairlie’s analysis of the report identifies a number of areas of concern. In the conclusions to his assessment of the COMARE report he argues the data in the COMARE Report indicates a 22% increase in various types of leukaemias and non-Hodgkins lymphoma. COMARE’s Report is regrettable as it may mislead members of the public into thinking there are no increases in leukaemias near UK nuclear power stations when in fact this may not be the case.

11 International Physicians for the Prevention of Nuclear War (IPPNW) Spikes of radioactive emissions during inspection and refuelling Gundremmingen Nuclear Power Station, Bavaria, Germany

12 as above

13 Study of mutation rate in offspring of Chernobyl liquidators Weinberg et al (2001 Proc. R. Soc. Lond. B 268 1001–5) The research involved the use of rapid molecular genetic screening methods on the DNA to detect mutations. The authors report an unexpectedly high (seven-fold) increase in the number of DNA mutations among children conceived after parental exposure over those in the their older siblings who were conceived before the accident. The authors conclude that `low doses of radiation can induce multiple changes in the human germline DNA’.