Pag Four THE MICHIGAN DAILY Saturday, January 26, 1974 ,,, P 9R ,. Nuclea By MARY SINCLAIR NCLEAR POWER is "the biggest single risk that any civilization has ever taken." These are the words of Sen. Howard Baker, (R.Tenn.), who appeared in a recent ABC-TV documentary on nuclear power. This statement accurately describes the real and incredible dimensions of the health and safety issues for human life and for the whole future of the planet that are at the heart of the nuclear power controversy. The statement by Sen. Baker is true for two major reasons: * Any event that could disperse a nuclear reactor core has a damage potential in terms of a death toll that could run into millions of lives and a permarent contamination of large areas that is beyond any other event that is humanly imaginable. The hazard of the long-lived highly toxic wastes that the nuclear fission plant must produce in order to operate will persist for thousands of centures - requiring perpetual care from all future generations. A safe place for the long-term storage of these hazardous wastes does not exist today, even though the drive to build many large nuclear plants continues. IN SPITE OF the sweeping risk of this technology that affects every person in the country, how many students or faculty mem- bers, on this campus or any campus, under- stand the nature of this risk and how it was prepared for them? The general public is even less informed - having been lulled into apathy by billions of dollars of advertising and promotion put out ,by the utilities, electrical manufactur- ers, and the Atomic Energy Commission, telling them nuclear power is "safe, clean, and economical." In reality, nuclear power is none of these. It is, instead, in the words of Supreme Court Justice William Douglas, "the most danger- ous technology ever devised by man." The national safety and radiation and rulemaking hearings held in 1972 indicated many areas in which the safety research and operating experience was not adequate for the safe broad .deployment of this tech- nology. RECENT IMPROVED safeguards for the operation of nuclear plants have corrected some of the deficiencies, but many im- portant areas of research still have not been completed. The AEC likes to project the image that its function is "to perform as a referee serv- ing the public Interest," but in reality, the Atomic Energy Act of 1954, by which the current nuclear power program was estab- lished, charges the AEC with not only the regulation but the promotion of nuclear pow- er. Therefore, there has never been a single license denied for a nuclear power plant as the result of a public hearing. In fact, citizens who seek to enter the public hearing required by law at the con- struction license phase of every n-plant are warned by their attorneys that they are in a "no-win" controversy where the most they can hope to accomplish it to bring the nature of the issue in the current development of nuclear power to the public through the testi- mony of the expert witnesses and the cross- examination that is part of the licensing procedure. ALTHOUGH THE AEC claims its principal licensing responsibility is to protect the health and safety of the public, the fact is that all manner of activities take place prior to the public hearing, to predetermine the outcome of the hearing and to prejudice the findings of the hearings themselves. An unrf By ERIC SCHOCHK D THE CURRENT residents of this planet. have the right to force a burden on the human race for the next 100,000 years which, if neglected, could have harmful effects on a vast number of human beings - and all other forms of life? Are we certain that we can protect our- selves from such a tragedy now, much less for countless generations to come? These are questions that must be faced, for it is within the next few years that the decisions will be made determining the ex- tent to which this country and others wil supply needs for energy with nuclear pow- er. Oddly enough, the questions facing us are profoundly moral in nature, despite the high ly technical problems involved in the pro ductions of electricity by nuclear fission. Nuclear fission can produce vast amounts of electrical power. The technical problems can be solved, possibly to a very high degree of statistical safety. But it is the quirks of human nature that are the most troubling. ONE OF THE MOST difficult problems of nuclear energy is the development of safe methods of storing the toxic waste materials created. The two major byproducts of fission are strontium-90 and cesium-137 with half-lives of approximately 30 years. It has been esti- mated that wastes from a large nuclear economy (400 plants or more) would have to be stored under constant vigilance for 100,- nn ..aa- energy olicy ignor For example, the AEC has permitted huge expenditures of funds by the utilities at pro- posed reactor sites before a hearing is even announced. In the Midland case, Consumers Power Company and the Dow Chemical Com. pany had already committed $54,000,000 to the site preparation and construction of the proposed plants before the construction lic- ense hearing was even announced. This situation is now partially corrected. A recent AEC ruling forbids spending mon- ey on site preparation but permits the utilit- ies to order the reactors themselves prior to any public hearing. This is allowed- even though the National Environmental Policy Act requires a consideration of all alterna- tives before any choice for power generation is made. Although the AEC contends that in the public hearings required by law at every construction site that citizens are equal par- ticipants with the applicant and the agent in the proceedings, the realities that citizens encounter are quite different.) ever, in an Atomic Energy proceeding many of the minds are made up prior to the initiation of the public hearing and the taking of evidence. A major agony, therefore, is that of the Regulatory Staff of the Utility Executive who feels im- posed upon by having to go through a public hearing after the Director of Reg- ulation has satisfied himself that the pro- posed power plant is safe and may be licensed for construction or operation. And a major irony is that if at the point of hearing a member of the public who may be affected intervenes, the AEC, without regard to the mandatory r- quirement for hearing and because of its administrative inconsistencies, places every barrier possible in the way of the intervenor securing a real public hear- ing. "THE BASIC problems facing inter- venors as well as all other parties who participate in public hearings stem pri- marily from the fact that the Atomic . . . . e 4.... competent technical authority. I would E estimate that perhaps $500,000 is the t sum needed to fund an adequate inter- l vention. Very often an intervenor finds it almost impossible to obtain the serv-t ices of qualified persons to serve as c experts. Too often, the intervenor has felt that he was in contest with not only thet utility and the nuclear vendors, but alsol with the Atomic Energy Commission. I If local intervention is to serve as a check on deployment of unsafe reactors or of unsafe siting, the ntervenors must have access to some independent author- ity with which to challenge the organ- ized technical resources of the utility..." (No intervening group has ever been able to raise any sum even remotely approaching the amount that Dr. Lapp believes is neces- sary for an adequate n-plant licensing re- view.) FINALLY, a report completed in October, 1973, under a grant offered by the National Science Foundation has a number of ob- servations to make particularly in regard to the Atomic Safety and Licensing Boards (ASLB) of the Atomic Energy Commission. A principal conclusion of this National Sci- ence Foundation report is that "because of the composition, predilection and defined role of ASLB's, citizen group opponents of nuclear power plants are denied substantive de process and therefore, meaningful par- ticipation with the opportunity to affect de- cisions concerning the licensing of nuclear power plants .. . "The process is characterized by the confrontation of a special interest group (utilities) - affluent, deep in manpower and financial resources, supported in its con- tentions by statistics of growing population and increased consumption of electricity and by recollection of the brownouts and black- owts of recent years and aligned with other nowerfl interests (vendors) and with a fed- eral agency (AEC) - and an ad hoc under- fmded, desnerate group of citizens seeking to ward off or otherwise influence the im- nosition of a technology which they feel is unacceptable and inherently dangerous." FTNALLY, LET US address oursebvcs to AEC's claims to a "defense in depth" ap- proach to safety. The AEC claims that the containment ves- sels are "massive structures that ace de- signed, built, and operated in accordance with stringent standards and criteria to as- sre that the multinle barriers preventing re- lese of radioactive material are riot vio- lated." But what are the facts? Myron Cherry, attorney for the Midland citizen inteivenors, has repeatedly asked for the research data 'which supports the claim that the pressure vessel cannot be ruptured and has consistently been denied this in- formation by the AEC. The remarks of a senior engineer from AEC's national labora- tory at Oak Ridge (which appeared in Sci- ence, September 15, 1972) suggest that it is doubtful whether such data exist at all. This engineer said: "What bothers me most, is that after 20 years we are still making purely subjective judgments on what is important and what is not in reactor safety. Purely by decree, some things, like the rupture of a reactor pressure vessel, are ruled impos- sible. To decide these things without some objective measure of probabilities, is, to me, almost criminal." THE HIGH QUALITY workmanship and materials that the AEC claims to insist upon is challenged by the many documented in- stances of poor quality control and the lack 110rali es pub of adequately trained personnel at construc- tion sites. This includes the Midland and Palisades plants. In fact, on the basis of the serious un- resolved questions on safety and duality control, as well as the lack of any real solution to the high level waste problem, the Rand Corporation advised the California Legislature to explore every alternative and to go to nuclear only as a last resort. They stated that if nuclear power had to be used, it should be placed far from population cen- ters and valuable agricultural land. The emergency core cooling system that the AEC cites as its ultimate safeguard in its "defense-in-depth" in the event the cool- ing water was lost through a pipe rupture has never been tested under anything approach- ing actual operating conditions. The fact is that six pilot tests were conducted on this system at ASC's Idaho Testing Station and all six tests failed. "In spite of the sweeping risk of this technology that affects every person in the country, how many students or faculty members on this campus or any campus, understand the nature of this risk and how it was prepared for them?" Because it affected all reactors, the na- tinmal safety rule-making hearings w e r e called in Washington in January, 1972. These hearings have resulted in some improve- ments in design. (however, another series of tests of the emergency core cooling system were conducted last summer and they also failed.) A coalition of over 60 environmental and citizens groups (now grown to over 100) immediately entered those hearings to re- present the public interest. This coalition is called the Consolidated National Intervenors, with headquarters at 153 "E" Street, S.E., in Washington, D.C. AEC: II 7 '.ION CHERRY, the attorney for the Energy Commission is both promoting intervening citizens in the Midland n-plant and regulating atomic energy at the gave an address before the Midland same time. Congress should take from Bar Association in February, 1971, analyz- the Commission one of these responsibil- ing the AEC licensing process. He made the ities." following revealing comments: ". . . one must first recognize that an Atomic Energy Commission public hear- ing is unlike any animal we, as lawyers, have ever seen. "In most administrative agencies of which I have knowledge, the decision- making process is in large part a function of the public hearing. In other words, minds are made up and decisions are rendered after the evidence has been sifted and accepted or rejected. How- Nuclear consultant Ralph Lapp, also ad- dressed himself to the problem of the citizens and the n-plant licensing hearing in his testimony for the National Interven- ors during the national safety rule-making hearings. His testimony (dated March 23, 1972) states in part: " . ..If he (the layman) objects to the siting of a nuclear plant in his vicinity, he is at a disadvantage in intervening to oppose the nuclear utility, the intervenor needs time, money and availability of esolved question Of the powe NUCLEAR POWER, as the Washington Postt has commented, "is growing at a dif-1 fictilt time. The public, sensitive about dan- gerous pollution from its present poweri plants, is becoming aware that atomic plants may have dangerous pollution of theiri own ..."I This increased awareness has led to a muchi wider interest in the licensing process of+ the Atomic Energy Commission - a process+ designed to assure that the public and the environment are protected as the amount of electricity generated by the atom increases. This is a healthy attitude, and one which the AEC welcomes. CONGRESS HAS established a framework for the AEC to license the construction and operation of nuclear power plants. The re- view procedures require: (1) a detailed safe- ty and environmental review of proposed nuclear power plants by the AEC Regula- tory Staff, (2) a review of the safety aspects by a group of independent senior experts who make up the statutory Advisory Committee on Reactor Safeguards (ACRS), (3) public hearings before atomic safety and licensing boards, and (4) a continuing AEC inspec- tion program throughout the lifetime of the plant. The AEC's principal licensing responsibil- ity is to protect the health and safety of the public. Before the AEC will issue either a construction permit or an operating license for a nuclear power plant, it must also satis- fy itself that full consideration has been given to environmental values in plans for construction and operation of the plant. Fur- ther, it must be satisfied that adequate safe- guards have been provided for the protection of fissionable material and that the activi- ties of the plant will not create or main- tain a situation inconsistent with the na- tion's antitrust laws. ONCE A UTILITY has selected a site for a nuclear plant and concludes to its satis- faction that the location will meet the AEC's requirements concerning, among other things, population density, seismicity, geology, hy- drology, meteorology, and environmental pro- tection, an application for a construction per- mit and an environmental report are filed with the AEC. If our Regulatory Staff deter- mines that the application is complete, it accepts it and begins a thorough safety and environmental review to assure that all ne- cessary siting and design requirements have been satisfied. This review will continue for a year or more. When the Regulatory Staff is nearing com- pletion of its review, it makes public its Safety Evaluation Report and meets with the Advisory Committee on Reactor Saf3guards (ACRS) to outline its conclusions with re- spect to the safety of the proposed plant. The ACRS also hears from the applicant, and under new procedures which we have just adopted, interested members of the public also may present their views to the ACRS and attend the meetings at which the AEC staff and the applicant make their presenta- tions. ic risk PUBLIC HEARINGS in all parts of the untry, including Midland, where this issue id been raised for consideration by the in- rvening citizens, were recessed in order to low the AEC to consider this matter. Lic- ising of all plants was stopped for months r this reason. This delay was clearly the sult of the internal AEC conflict over ie adequacy of the safety of this system ad therefore of nuclear plants. The Commission had to define ways. to tablish adequate criteria for the regulation the plants. In July 1971 a court decision so required the AEC to conform to the ational Environmental Policy Act passed 1 1969. This also stopped licensing for many nonths Nevertheless, a , public relations ave was set in motion by utilities and elec- ical manufacturers, blaming "environmen- alists" (as all citizens with questions of any :ind who intervene at nuclear plants are alled) for the delay and the consequent scalation of costs of nuclear plants. THE CONTROVERSY over the adequacy of he emergency core cooling system still 'ages. On Sept. 10, 1973, the Advisory Com- nittee on Reactor Safeguards (the nrincipal ateguard committee for the AEC) stated, 'The Committee reaffirms its position that .. design changes to improve ECCS cap- ability should be sought." In spite of this, the AEC, mindful, no doubt, >f its legal obligation to promote nuclear power, has issued 20 operating -licenses and 22 construction permits since May, 1972. At that time, only 18 plants, mostly of the small experimental size, were operating. We do not ask for "risklessness" in our society, but this reckless plunging of this country into a proliferation of large, untested nuclear plants is inviting the ultimate catas- trophe - the "biggest risk ever taken by any civilization." Mary Sincleair is Co-Director of Consolo- dated National Intervenors, and holds a Mas- ters degree in Nuclear Power Environmental Cormunications from the University. atching 'r plants three member atomic safety and licensing board composed of two technical experts and a lawyer. These hearings are usually held in the area where the plant is proposed. Members of the public, and state and local officials may participate in the hearings and may be admitted as parties to the nroceed- ing with the same rights as the utility appli- cant and the Regulatory Staff. At the con- clusion of the hearing, the licensing board issues a decision to grant or deny the ap- plication. That decision is subject to appeal to the AEC Appeals Board and the Federal courts. A SIMILAR safety review is conducted by the AEC and the ACRS on the application for an operating license as the plant nears com- pletion, although a hearing is not manda- tory. In many recent cases, however, public hearings have been requested by interested parties and held at the operating license stage. No discussion of nuclear plant licensing would be complete without a discussion of the "defense-in-depth" approach to safety which is followed by the AEC. The basic features of nuclear power plants are much the same. They include massive structures that are designed, built and oper- ated in accordance with stringent standards and criteria to assure that the multiple bar- riers preventing release of radioactive ma- terial are not violated - either by internal forces or by natural external forces such as earthquakes and tornadoes. THE "DEFENSE-N-DEPTH" involves three successive and mutually reinforcing levels of defense which would have to be breached before there could be a serious accident which would affect the public. The first level of defense involves design- ing the plant to assure safety in normal oper- ation through the use of high quality work- manship and materials. The second level in- cludes built-in safety systems designed to detect flaws; to prevent minor accidents from escalating into larger ones; and ta shut. down the reactor, if necessary. The third level of safety is based on the unlikely assumption that severe failures will occur in spite of the other levels of protec- tive devices built into the reactor. Accord- ingly, additional safety systems and features are provided' to limit the consequences of such postulated major accidents. The emer- gency core cooling system, about which so much has been written and said and which has been the subject of an AEC public rule- making change, is part of this third line of defense. NUCLEAR POWER reoresents a unique situation in the United States. For the first time we have introduced a technology where precautions have been taken from the outset. The safety record is excellent, but this is no reason to relax our vigilance. Reactors are not without risk. We do not have risk- lessness in this society. Our aim at the Atomic Enerav Commission is to reduce the this planet has not yet experienced. Furthermore, we cannot guarantee t h a t future generations will not inadvertently re- lease these highly dangerous materials into the environment. Yet the creation of such wastes forces us to guarantee just that. THERE IS A more immediate problem,' however. We can control the technical prob- lems, but how do we control civil and inter- national strife, revolutions, psychoses, sab- oteurs of all types, variously-motivated hi- jackers and all sorts of criminal and psycho- pathic personalities? In September, 1972, hijackers of a South- ern Airways jetliner threatened to crash it into the Oak Ridge nuclear power plant in Tennessee. Fortunately the threat was not carried out, but other than evacuation of the plant, it was apparent that there was no way in which the situation could be dealt with by the authorities. As the number of nuclear plants increases, so does their avail- ability for purposes of blackmail, vengeance and sabotage. Not only do we face the possible dangers of purposeful destruction, but the possibility of a breakdown resulting in a "major" acci- dent as well. A major accident could result in the destruction of an area the size of New York City. ONE AEC expert, Walter Jordan, has not- ed that we do not yet know whether we have reduced the risk of accident to a tolerable level of say, one in 10,000 (his figure). Photo courtesy Time-Life Constructing nuclear plants: Shall we continue? to mention the vastly increased chances of cancer and defective children). Another potential problem which until re- cently has drawn little attention is the pos- sibility of the theft of nuclear materials. Recent popular magazine articles have concluded that it would be fairly easy, un- der present security arrangements, to steal enough fissionable material to make a pri- vately-owned atomic weapon, which could be used to blackmail an entire region of the country. THE SCENARIOS RAISED above :ire not new, and they are generally dismissed by cident minimal, the risk may still be too high. Sen. Mike Gravel (D-Alaska) has put it in terms of gambles which are proper and those which are immoral. Any society will have to risk gambles if stagnation is not to result. but it must differentiate between those that are necesary or promising and those which .should be avoided. In the current energy crisis it is argued that we must step up our nuclear energy pro- duction if we are to supply all our needs and be dependent on no other nation for energy. Proponents also argue that such clean and