Appendix #4 Footnotes 1.) Ralph E. Lapp, The Logarithmic Century, (Prentice-Hall, Englewood Cliffs, N.J.; 1973); pp. 84-85. 2.) ibid.; pp. 85-86. 3.) E. J. Hoffmann, "Overall Efficiencies of Nuclear Power" 4.) 4.) Lapp, op. cit., pp. 97-98. 5.) Allen L. Hammond, et. al., Energy and the Future, (published by the American Association for the Advancement of Science, Washington, D.C., 1973); pp. 4-7, 12 & 48. See especially p.48 for estimates of comparative reserve supplies of all depletable and renewable energy resources in the U.S. 6.) Resources for the Future, Inc., Mr. Harry Perry, ed., "Energy Research and Development--Problems and Prospects", prepared at the request of Henry M. Jackson, Chairman, Committee on Interior and Insular Affairs, United States Senate, pursuant to Senate Resolution #45, A National Fuels and Energy Policy Study; U.S. Gov. Printing Office, Ser. No. 93-21 (92-56), (Washington, 1973); pp. 26-27. Figures taken from U.S. Geological Survey Circular 650, (Washington: 1972). 7.) ibid., p. 27. Figures taken from: National Petroleum Council, "U.S. Energy Outlook," final report (December, 1972), p.184. 8.) ibid., p. 30. Figures taken from data supplied by the U.S. Atomic Energy Commission. Thank you very much for sending me an advance copy of WASH-1250. You indicate in your letter which accompanied the report that you can entertain comments received "within the next thirty days, but probably not very much beyond that time". It is now 34 days from the date of your letter and I can only hope that these extra few days do not prevent your consideration of my comments. In that regard I would like to note that you are using as my address that of the Scientists' Institute for Public Information in New York. Were you to send things directly to me here in Minnesota I would receive them at least a week sooner which would somewhat facilitate my ability to respond in a timely manner. The draft report is represented as being the product of a cooperative effort by a number of AEC divisions and offices and includes contributions from AEC laboratories. The stated purpose of the report is to place before the public a fairly comprehensive statement of fact regarding the safety and environmental aspects of nuclear power reactors and their support facilities in a manner "to inform the public". Accordingly, the reader could be expected to believe that WASH-1250 contains a comprehensive and candid representation of the complete fission reactor fuel cycle. As the report includes a section headed "Benefits and Risks" there is reason to expect that both benefits and risks are fully discussed, quantified to the extent permitted by present knowledge, that areas of uncertainty are clearly identified, and that some comparison is made between "benefits and risks" associated with various means of satisfying energy needs. As my work of the past several years has been directed toward a consideration of public policy with respect to energy supply and demand, and as I have attempted to the best of my ability to carry out my work in a manner to inform the public as to the alternatives and implications of various segments of energy policy, I think that I have some feeling for the questions and expressions of concern which have been voiced concerning nuclear power. Appendix #5 73 2105 Mr. Milton Shaw My comments are directed to three questions. (1) Is the report complete?, (2) Is what is in the report accurate?, (3) Will the report provide a satisfactory response to the questions which have been raised concerning nuclear power? There are several sections of the report upon which I have not attempted to comment. These are the sections on thermal releases and the discussion of the effects of those releases, the sections concerning regulatory matters, and some of the sections which are intended to provide a background description of nuclear power plants or to present certain technical terms or concepts which may not be familiar to the reader who has not previously considered matters of this kind. Is the Report Complete? It is immediately apparent that the report is not only incomplete but that it is grossly incomplete. I cite only a few examples. Although plutonium is mentioned as a reactor fuel in several places, nowhere is there a discussion of the health and safety hazards associated with plutonium nor of the grave uncertainties in the present knowledge of plutonium hazards and hence of appropriate standards relating to plutonium exposures or "acceptable" environmental concentrations. Although plutonium recycle is indicated in at least one figure in the report, there is no description of the quantities of plutonium produced, associated with the various transportation and fabrication operations, nor of the implications of plutonium bearing wastes. I find no mention of the problems associated with safeguarding special nuclear materials nor of the implications of diversion of such materials. In the sections dealing with potential accidents the possibilities of accident due to human error, by deliberate sabotage, or by various other - classes of accidents are ignored. In addition, although there has been considerable public discussion connected with the conclusions presented in WASH-740, there seems to be no reference either to that report nor to the potential consequences of an accident such as those with which WASH-740 deals. There also seems to be no mention of the Price-Anderson Act nor of its historical and policy implications. I find the failure to consider WASH-740 and Price-Anderson Act particularly distressing in view of the stated purpose and breadth of the report. There are numerous other matters which appear to be completely Ignored by WASH-1250. It is not that minor and secondary matters fail to be discussed but rather that issues which are central to a consideration of the benefits and risks of nuclear power are not mentioned. Appendix #5 Mr. Milton Shaw Is WASH-1250 Accurate as Far as It Goes? It is important to recognize that in view of the gross omissions it is intrinsically impossible for the discussion of many other matters to be in any way complete. Again, only a few examples are mentioned here. Early in Section 4 we find, "Thus, the questions that need to be answered are: What are the implications or effects of these small additional [radiation] doses on man, and are the annual doses going to remain small as the nuclear industry grows". The discussion of the implications and risks from exposures to radiation is contained in Section 4.1.5 and in Appendix I. · To fully discuss all of the gross distortions, errors, and omissions in the consideration of risks and implications as presented in these sections would require more time that I have available for these comments. The discussion of risks is totally inadequate. It is as though the authors of these sections were completely unaware of the intense debate over radiation effects and radiation standards which has taken place during the past several years. Perhaps the staff of the Atomic Energy Commission could review the many reports and documents which pertain to that debate and might begin with the recent National Academy of Sciences' summary report, although a comparision of the NAS report with WASH-1250 cannot fail to be acutely embarrassing to the Atomic Energy Commission. Chapter 6, "Benefits and Risks", is likewise grossly incomplete, fraught with error, and in addition contains a large quantity of irrelevant materials. This chapter begins with a recitation of certain sections of the National Environmental Policy Act of 1969, which would lead the reader to expect to find the chapter comparable to the detailed statement required by NEPA. Nothing could be further from the truth. Not only are the risks associated with nuclear fission fuel cycle represented in such a way as to make WASH-1250 appear ludicrous, but no systematic attempt seems to have been made to evaluate or even delineate the risks associated with alternative means of producing power and no attempt whatsoever seems to have been made to evaluate the benefit side of the equation. Thus, I am forced to conclude that chapter 6 is largely irrelevant, meaningless, and so incomplete as to be of no value. Does WASH-1250 Satisfy Its Intended Purpose? No! Not only does this report totally fail in meeting its stated purpose, but it will further stand as evidence that the Atomic Energy Commission has no intention of being candid in its representation of the implications, risks, or benefits for that matter, of nuclear power. Had this report shown evidence of being a full and candid representation of the factors which relate to nuclear power issues, it could have provided the public with badly needed Appendix #5 Mr. Milton Shaw information and served to enhance the credibility of the Atomic Energy Commission. None of these objectives have been met and I can only conclude that the Commission has intentionally and willfully sought to be misleading, or worse. This report stands as another convincing piece of evidence that the Atomic Energy Commission is incapable of meeting its charge to protect the public health and welfare. In Summary I cannot find words to adequately express my outrage and profound disappointment engendered by WASH-1250. The report is disgracefully incomplete, woefully inaccurate and suggests that the Commission's veracity is yet at issue. I hope that these comments are of some help to the Commission and I would welcome the opportunity to discuss them at whatever length would be useful to you. |