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List of contributors and participants

Dean E. Abrahamson, M. D., is an assistant professor in the Depart­ments of Anatomy and Laboratory Medicine at the University of Minne­sota. He is president of the Minnesota Committee for Environmental Information and vice president of the Scientist’s Institute for Public In­formation in New York. He is author of several articles on electric power and nuclear waste emission and has been active in Minnesota and across the country in stimulating informed public discussion of these subjects.

Stanley I. Auerbach is director of the Ecological Sciences Division of the Oak Ridge National Laboratory. He has served as the chairman of the Committee on Radioecology of the Ecological Society of America, as secretary of the Ecological Society of America, as chairman, Division of Ecology, of the American Society of Zoologists, and as a member of the Public Affairs and Study Committee of the Ecological Society and of the National Academy of Sciences Advisory Committee on Research to the Secretary of Agriculture. Among his publications in the field of radiation ecology are “The Soil Ecosystem and Radioactive Waste Disposal to the Ground” and “Strontium-90 and Cesium-137 Uptake by Vegetation un­der Natural Conditions.” He has supervised and directed research by members of his group which has resulted in approximately 300 additional reports and publications in the field of radiation ecology.

Donald E. Barber, a member of the advisory committee for the conference, is an associate professor in the School of Public Health at the University of Minnesota. He has responsibility for teaching radiological health and health physics.

John R. Borchert is professor of geography and director of the Center for Urban and Regional Affairs at the University of Minnesota. His interest in the effects of nuclear power arises from his responsibilities as a member of the Minnesota Pollution Control Agency as well as from his Center’s activities.

A. Philip Bray is manager of Systems Engineering for the Atomic Power Equipment Department of the General Electric Company in San Jose, California. He is responsible for the basic design details and evalua­tion of all General Electric boiling water reactors in the nuclear power field. He has been in the nuclear field for over 13 years and has been with the Atomic Power Equipment Department since 1959. Mr. Bray has been involved in all aspects of power reactor design, operation, and licensing. He has served with an Industry Advisory Task Force on Emergency Core Cooling for Power Reactors and participated in all their activities follow­ing an appointment by the aec in 1966.

William A. Brungs is director of research at the Newtown Fish Toxicology Laboratory, Federal Water Pollution Control Administration, in Cincinnati, Ohio. He is a Certified Fisheries Scientist by the American Fisheries Society, and has directed research to determine water quality requirements of aquatic life. He was formerly associated with the Public Health Service in Cincinnati as an aquatic biologist studying the distribu­tion of radionuclides in freshwater environments.

Barry Commoner is professor of plant physiology and director of the Center for the Biology of Natural Systems at Washington University, St. Louis, Missouri. He has been chairman of the Department of Botany at Washington University and an active investigator of fundamental prob­lems on the physiochemical basis of biological processes. He has served as chairman of the Committee on Science in the Promotion of Human Wel­fare of the American Association for the Advancement of Science and was appointed to the Committee on Environmental Alteration. He is a founder of the St. Louis Committee for Environmental Information. He holds a deep interest in the interaction between science and social problems. His book, Science and Survival (Viking Press, 1966), deals with the serious threats to human survival resulting from modern technological changes and the resultant responsibilities of scientists and citizens.

Merril Eisenbud is administrator of the Environmental Protection Administration of the City of New York. He is a past president of the Health Physics Society and has served on the Board of Directors of the American Nuclear Society. He has served on the Expert Panel on Radia­tion Hazards of the World Health Organization, the Toxicology Com­mittee of the National Research Council, and the National Council on Radiation Protection and Measurement. He is past chairman of the Public Health Service’s Advisory Committee on Environmental Radiation Ex­posure and of the New York State General Advisory Committee on Atomic Energy. He is a consultant to the World Health Organization, the Public Health Service, and the aec. From 1959 to 1968, he was with the New York University Medical Center, and from 1949 to 1959 he was a staff member of the Health and Safety Laboratory, aec.

Harry Foreman, M. D., is director of the Center for Population Studies at the University of Minnesota. He has worked for many years in research on and the teaching of biological effects of radiation. Dr. Fore­man has served as a consultant on the biological effects of ionizing radia­tion to a number of governmental and industrial organizations. At present, he serves as a consultant to the Northern States Power Company.

S. David Freeman is director of the Energy Policy Staff of the President’s Office of Science and Technology with the responsibility for coordinating energy policy on a government-wide basis. As an engineer, he has designed steam electric power plants and hydroelectric stations for the Tennessee Valley Authority; he has also served as an attorney for the tva. He was assistant to the chairman of the Federal Power Commission from 1961 to 1965, playing a leading role in the conduct of fpc’s National Power Survey and planning the execution of the fpc’s electric power and natural gas regulatory programs.

Harold P. Green is professor of law and director of the Law, Sci­ence, and Technology Program at the George Washington University National Law Center, Washington, D. C. He has worked in the Office of the General Counsel of the aec. He is consulting editor of the Commerce Clearing House A tomic Energy Law Reporter and the author of numerous articles on atomic energy law, government security law, and the relation of law to science and technology.

Ernest D. Harward is chief, Nuclear Facilities Branch, Division of Environmental Radiation, Bureau of Radiological Health, U. S. Public Health Service. He entered the Public Health Service in 1952. Before taking his present position in 1965 he was regional program director for Radiological Health, dhew Region IX, San Francisco. From 1955 to 1961 he was detailed by the Public Health Service to the U. S. Navy, Nuclear Propulsion Division, and was assigned to the Pittsburgh Naval Reactors Operations Office of the aec, where he served as radiological health consultant during the development and initial operation of the Shippingport Atomic Power Station.

Congressman Craig Hosmer is the ranking minority member on the Joint Committee on Atomic Energy and chairman of the Republican Con­ference Committee on Nuclear Affairs. Congressman Hosmer worked for the aec as a lawyer at the Los Alamos Scientific Laboratory before being elected to Congress. He is a member of the subcommittees on Military Applications, Raw Materials, Research, Development and Radiation, and Communities and Legislation. His grasp of the technical complexities of the nuclear field is such that he is one of the few laymen elected to regular membership in the American Nuclear Society.

M. King Hubbert is a research geophysicist with the United States Geological Survey, Washington, D. C. He is a member of the National

Academy of Sciences and a fellow of the American Academy of Arts and Sciences. He has spent ten years as a member of the National Academy of Sciences-National Research Council Committee on Geologic Aspects of Radioactive Waste Disposal, advisory to the aec. He was also a member of the National Academy of Sciences Committee on Natural Resources, advisory to President Kennedy, and was the author of the Committee’s report, Energy Resources (nas-nrc Publication 1000-D, 1962). He is the author of the section on “Energy Resources” of the nas-nrc report, Re­sources and Man (W. H. Freeman & Company, 1969), The Theory of Ground-Water Motion and Related Papers (Hafner Publishing Company, 1969), and sixty-some articles in scientific journals.

Herbert S. Isbin is a professor in the Department of Chemical En­gineering at the University of Minnesota. His interest in the relation be­tween nuclear power and the public arises from his responsibility of teach­ing nuclear engineering and his membership on the Advisory Committee on Reactor Safeguards.

Joseph A. Lieberman is assistant administrator for research and development of the Consumer Protection and Environmental Health Service. He has been chief of the Environmental and Sanitary Engineering Branch of the Division of Reactor Development, assistant director for nuclear safety in the Division of Reactor Development and Technology, secretary of the Subcommittee on Waste Disposal and Dispersal of the National Academy of Sciences Committee on Biologic Effects of Radia­tion, chairman of the Waste Disposal Subcommittee of the American Standards Association, the aec member of the Federal Council for Science and Technology Committee on Water Resources Research, a technical delegate to the 1958 and 1964 Conferences on Peaceful Uses of Atomic Energy in Geneva and the World Power Conference in Melbourne. Dr. Lieberman is the author of a number of articles on the environmental en­gineering aspects of nuclear power and nuclear safety.

James T. Ramey is a Commissioner of the Atomic Energy Com­mission, Washington, D. C. Before his appointment to the Commission in 1962, Commissioner Ramey served as an assistant general counsel of aec and as staff director of the Joint Committee on Atomic Energy. He has been actively involved in the improvement of aec contracting policies and procedures, has stressed the importance of health and safety for atomic energy employees, and has actively followed the aec reactor safety pro­gram designed to ensure that adequate safety features are built into all nuclear plants. He has taken a special interest in legal and regulatory aspects of the aec’s work and has been a leader in effectively streamlining its regulatory program over the past several years.

Lester Rogers is director of the Division of Radiation Protection Standards, aec. Mr. Rogers has worked in the field of radiation protection since 1949. He is a Certified Health Physicist, American Board of Health Physics, and is a member of the International Commission on Radio­logical Protection Committee No. 4. He has served as United States rep­resentative and consultant to panels of the International Atomic Energy Agency on the transport of radioactive materials and toxicity classification of radionuclides.

Lloyd L. Smith, Jr., is a professor in the Department of Entomol­ogy, Fisheries, and Wildlife at the University of Minnesota. He has long been involved with and concerned about the ecological effects of water pollution. He has served and is serving as an advisor to governments on such problems.

J. Newell Stannard is professor of radiation biology and bio­physics and pharmacology at the University of Rochester, Rochester, New York. He is also associate dean for Graduate Studies at the University Medical School. Dr. Stannard is currently president of the Health Physics Society and chairman of Scientific Committee No. 34 on Maximum Per­missible Exposure Limits for Radioisotopes of the National Council on Radiation Protection and Measurements (ncrp). He is interested in re­search on biological effects of radiation at the cellular and whole organism level.

Arthur R. Tamplin is a research scientist at Lawrence Radiation Laboratory, Livermore, California. He has been responsible for develop­ing an adequate state-of-the-art ability to predict the ultimate distribution within the biosphere, particularly the concentration in man, of each radio­nuclide produced in the explosion of a nuclear device. As an employee of the Rand Corporation of Santa Monica, California, from 1959 to 1963 he worked on various problems of national defense—primarily, target search and identification and biological and chemical warfare. While at Rand, he also worked on problems associated with the space program and the bio­logical effects of cosmic rays and oxygen regeneration.

Charles L. Weaver has been associated with radiological health activities since 1954. During the period 1954-1957, as an officer in the Chemical Corps of the U. S. Army, he was the on-site radiological safety officer for weapons tests both at the Nevada Test Site and the Eniwetok Proving Grounds. He was assistant radiological safety officer on the staff of the Assistant Manager for Test Operations, Albuquerque Operations Office, AEC, 1957-1961. In 1960 he joined the U. S. Public Health Service, and in 1966 he was designated director, Division of Environmental Ra­diation, Bureau of Radiological Health. He has had the responsibility for the planning, conducting and coordinating of operational and research and development activities required for the surveillance of radiation ex­posure of the population from all sources of radiation except for occupa­tional or medical use. Mr. Weaver is a member of the Health Physics

Society and executive secretary of the Environmental Radiation Exposure Advisory Committee, Bureau of Radiological Health, Environmental Health Service.

Carroll W. Zabel is the recent past chairman of the Advisory Com­mittee on Reactor and Safeguards and currently is director of nuclear research at the University of Houston.

INDEX

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source: Reprinted, with permission, from V. A. Nelson, “Effects of Strontium-90 + Yttrium-90, Zinc-65, and Chromium-51 on the Lar­vae of the Pacific Oyster, Crassostrea gigas” (M. S. thesis, University of Washington, 1968).

[2]1 = Number of lots. b2 = Mean plus standard deviation. *p < .05.

hubbert. A question that is uppermost in my mind with regard to long-range policy pertains to the present rash of light-water reactors. Ac­cording to aec sources, there is a promise of an acute shortage of 235U in about 25 years as a result of the consumption by the light-water reactors now being built. Yet, the breeder program has been extremely slow getting started. According to the latest time schedule that I have seen, full-scale industrial breeders will not be in operation until the middle 1980’s. It seems to me a very shortsighted policy to authorize the installation of the current rash of large-size light-water reactors under such a situation. Could someone comment on this?

ramey. It is true there was a large surge of reactor orders in the years 1965-1967, averaging 20 plants a year. One year nuclear plants com­posed almost 50 per cent of total capacity ordered. However, in 1968 and 1969, the ordering has gone down some. The power industry has always been cyclical in orders, and the government does not have any control over the ordering of power plants whether they are nuclear or coal fired. This is a part of the private enterprise system. It has been projected that by 1980, there would be around 150,000 megawatts of power produced by nuclear plants, which would amount to, perhaps, 25 per cent of ca­pacity at that time, and that the raw material reserve could begin to get tight in the 1980’s and 1990’s. On the other hand, there has been a tre­mendous exploration program going on for uranium. The current uranium areas are being expanded, and I don’t believe that anyone in the industry or in the aec believes we are in trouble in plans for phasing from a light — water industry to a breeder economy. On the other hand, we all would like to move as fast as possible on the breeder program. The aec is seeking proposals now on the first phase of building the 200 to 500 megawatt demonstration plants that will provide the basis for going into the liquid metal fast-breeder program.

commoner. I am struck by Mr. Ramey’s plea that the aec has no control over free enterprise and the nuclear power industry. That’s an in­consistent position. If that’s the case, why did the Price-Anderson Act ever get enacted? The nuclear power industry, when in need of federal help and regulation on the insurance problem, got it and I don’t see why, if Dr. Hubbert is right and the aec does have the responsibility over our nuclear future, the aec couldn’t make stringent requirements for the kinds of re­actors that are built. I would like to ask, too, whether the Fermi reactor situation has any bearing on this?

hosmer. As to the raw material situation, the energy division of the Chase Manhattan Bank has just completed a study of raw materials through the period 1980 which concludes that, at $10 or less per pound, there is plenty of uranium; the study stops at 1980. But, if you talk with the various material suppliers in this country, they seem to be worried more about oversupply than undersupply and, to back up the supply of uranium by 1980, there is plenty of plutonium coming out of existing light-water reactors to re-cycle, if it is necessary. As a matter of fact, it will be necessary to do so, unless breeders come along very fast, in order to keep the economics of light-water reactors in line. In addition to that, the aec has indicated that by 1973 it will be lowering the barriers on the importation of uranium which may be enriched in United States diffusion plants. So, again there is an extra source. I don’t think, Dr. Hubbert, there is any cause for concern about the supply of raw materials.

ramey. On his first point, Professor Commoner is glib regarding the things that he thinks government agencies can do or ought to do. In this case, it would be regulating the marketing of the largest capital-intensive industry in this country. Just speaking in the context of the possible, the aec does have a number of responsibilities, one of which has been to pro­vide research and development assistance in this emerging technology, but, in its regulatory authority, the aec has been limited to the safety of atomic power plants. If rather extreme regulations were undertaken, it could be handled, presumably, by the agency of government which regu­lates the economic aspects of electric power production — the Federal Power Commission. However, the new chairman of the fpc has indicated that even in environmental matters, he didn’t think that the fpc would be moving very fast or very far in regulating the power industry.

I assume that the second question refers to the impact of the suc­cesses and the problems of the Fermi reactor on the breeder program. The Fermi reactor was authorized and its design and construction began in the 1950’s. It had a whole series of problems in its design, construction, and operation. There was a fuel element failure a couple of years ago, and the reactor is now being re-worked, as far as the utility group that is sponsor­ing it is concerned, as a kind of a testing facility as a part of the fast-breed­er program. The mishap that they had did slow up, to some extent, the de­velopment of liquid metal fast-breeder reactors. A lot of time has been spent determining how the accident occurred and how it could have been prevented. The new designs for demonstration plants are rather different from the Fermi reactor, and the industry and the aec staff are satisfied that engineering means are available in the technology for building safe reactors of this general type.

borchert. A question from the audience is addressed to Dr. Auer­bach: There has been some publicity about a proposed Union Carbide breeder reactor for the Minnesota shore of Lake Superior. Can you tell us anything of these plans? Do you know of any ecological or limnological studies of the lake that could help in evaluating the wisdom of such an es­tablishment?

auerbach. I do not know of any Union Carbide plant on Lake Su­perior.

hosmer. That question may be traceable to speculation about the possibility of building the fourth enrichment plant. Some figures have been developed to compare the cost of putting it on Lake Superior and using a nuclear power plant to power it with the cost of enlarging some of the ex­isting enrichment plants. It was a speculative cost-study based on hy­pothesis; no intention to put in a plant existed.

freeman. I might add that a fourth enrichment plant would not be needed, at the earliest, before 1980 or later, and the possibility that it might be built on Lake Superior is quite remote at this time.

commoner. If I recall correctly, Mr. Hosmer said that the aec is simply given standards by the frc and the other agencies — that it doesn’t set the standards, it simply applies them. If any standard involves a moral judgment between risks and benefits, where is the moral judgment with respect to a reactor made? Is it made in the frc or in the aec?

hosmer. It is made at least in three different places: first, at the In­ternational Council on Radiation Protection, the common fountain that produces all of these standards; second, the National Council on Radia­tion Protection, which has some additional inputs; and third, the Federal Radiation Council itself. These are where the so-called moral judgments are made. Incidentally, Dr. Commoner, apparently you have made the moral judgment that you, at least, don’t like nuclear power. You didn’t put the problem in the context of electrical energy for the United States, the

requirements for which double in less than every 10 years. We cannot con­sider nuclear power plants in a vacuum. They are part of the electrical energy supply problem. If there are risks and benefits in nuclear power, there are risks and benefits in conventionally generated power, and the same for going without power. There may even be a fourth alternative in cutting down the population somehow. But this total sweep has to be analyzed — the nuclear power question is only one segment of the total problem.

commoner. By historical accident, the nuclear power industry has become the arena in which these questions are being discussed. Of course, the risk-benefit evaluation must also be applied to other power plants, ul­timately on the level that Dr. Hubbert talked about. My own position is that it has become quite clear that we cannot operate this country very long on the principle of continuous intensified growth. Now, if the nuclear power industry is already worried about the economic consequences of the kinds of issues that are raised, just start thinking about the economic im­pact of restrictive growth. The country has got to be prepared to take moral stands on that issue, too.

But Mr. Hosmer hasn’t answered my earlier question. How can the icrp, meeting in Europe, understand the value of a reactor in Minnesota? If there is to be a moral judgment regarding the value of the activity that puts out the radioactivity, there is no way of reaching that judgment with­out knowing what that activity is and what its benefits are. There is no such thing as a standard achieved in the halls of the icrp or in the frc, in the abstract. The standard exists only in application to the specific activity that is under consideration and what I am concerned about is who applies it?

hosmer. The state political boundaries are totally arbitrary. Why shouldn’t you leave it up to the people of south Minnesota or east Minne­sota or west Minnesota? It’s got to be some reasonably sized area of com­munity interest in which you make these decisions, and the communities affected don’t always fall entirely within the bounds of one state.

ramey. These risk-benefit judgments should probably be made at the regional level, in relation to the regional need for power and how it can best be met by nuclear, fossil, or other plants. At that level and at the plan­ning stage, conservation groups, utilities, politicians, and the public can take these things into account before a specific license application is made. By the time a license is applied for, matters may have polarized to the point that the proper overall risk-benefit ratios sometimes can’t be made.

borchert. If the aec begins to move seriously toward the encour­agement of regional environmental councils, it might find models in Min­242

nesota, because the last session of the state legislature enabled the creation of regional planning councils.

The next question, directed to Dr. Green, regards the Price-Ander- son Act. Isn’t it true that utilities carry a considerable amount of insurance in addition to Price-Anderson? Have there been many claims requiring settlement using Price-Anderson coverage?

green. It’s true that utility companies carry various kinds of insur­ance. Under the Price-Anderson Act itself, utilities are required to carry $82 million in private insurance, which is the maximum available from the insurance industry. Probably the utilities also carry property insurance, boiler insurance, workman’s compensation insurance, health and accident insurance, life insurance on the lives of their executives, and so on. There have not been any claims under the Price-Anderson Act, to the best of my knowledge — the safety record in the nuclear industry is truly remarkable.

The point that Mr. Ramey and Mr. Hosmer make about our desper­ate need of nuclear power in order to make sure that 20 to 30 years from now when we flick the switch on the bathroom wall an electric light, razor, and toothbrush will go on is an impressive argument, but we should look at it in perspective. The fact that we are talking about nuclear power in it­self involves an accident of history —the accident of World War II, in which the atomic bomb was developed — the historical fact that Congress created an aec, and, even more important than that, the fact that Congress created a Joint Committee on Atomic Energy. There is no doubt in my mind that if, in 1946, we had created some other kind of commission or some other kind of joint committee — for example, a commission to maxi­mize the productivity of power produced from fossil fuel without polluting the environment and a companion joint committee — we wouldn’t have to be concerned about using nuclear power today to meet the threat of a dwindling fossil fuel supply.

eisenbud. I find myself in sympathy with much of what has been said about the need for cost-benefit analysis and, having been in the nu­clear field for many years, I think this is a good arena in which to try it out. We have relatively more information about radioactivity than we do about other environmental hazards, and it is unquestionably the focus for greater attention. We can agree on principle, we can disagree on detail. But if a community is going to make a cost-benefit decision, it must have facts. I’m worried about some of the facts in this volume. For example, Dr. Commoner, I don’t know the exact context of what you quoted from the 1953 aec report about 9CSr and splinters of the bone (p. 226 above), but I can assure you that by 1953, we in aec had already developed tech­niques for measuring 90Sr in milk and were already monitoring the milk of at least one city on a regular basis. We were also making 80Sr measure­ments in samples of human bone. You also referred to the traces of 131I in the thyroids of cattle. I have tried to work backwards, by two meth­ods, to see what 10 pCi per thyroid would mean in terms of total deposi­tion of iodine in the United States. By one method of calculation, I esti­mate the deposition at any given time to 5 Ci, by the other, 50. This is a working range in which we can discuss the matter. The total amount of radioiodine discharged to the atmosphere from all of the power reactors in this country is very, very much less than that. However, there are hun­dreds of curies of radioiodine shipped to the hospitals in this country for treatment of hypothyroidism and thyroid cancer, and much of this does find its way into the atmosphere — but not in sufficient quantities to ac­count for the 1962 report that you referred to, which was curious. It was learned as a result of that report and some work Van Middlesworth did at the University of Tennessee, that the thyroid gland accumulates ra­dium; during that period there were traces of radium reported in thyroids at about the levels you were discussing.

auerbach. I would like to clarify Dr. Eisenbud’s comment about the pervasive contamination of the environment implied by Dr. Commoner’s remarks when he spoke of the 1 pCi/g of radioiodine found in the cattle thyroids at the Nevada test site in the period 1959-1961. At that time, there were, as he says, no weapons tests going on on a worldwide basis. There were three small, or relatively small, nuclear power reactors oper­ating in the eastern part of the United States. If they were to contribute to Nevada radioiodine, that iodine would have to travel several thousand miles to get there. The most likely source of radioiodine in those cattle around the Nevada test site was some nuclear rockets being tested at that time. But a more important consideration, which Dr. Eisenbud has men­tioned, is that the method of measuring radioiodine in thyroid at low levels is a very tricky one, and that up to 50 per cent of the quantity reported as 131I could be radium, which is in the soil as radon and evolves 24 hours a day from the soil. Radium and radon are also among the by-products of fossil fuels.

Dr. Commoner also mentioned the higher radioiodine activities in March 1968 reported by the Public Health Service. Of these values, the Public Health Service analyzes in detail only thyroids which have an amount greater than 50 pCi/g; below that, the figure was obtained simply by multiplying numbers which lack confidence limits. It is interesting, though, that these higher values, above 50 pCi/g, were measured a couple of months or less after the Chinese weapons tests began — these are still going on and are sending radioactive materials across the ocean. Another factor about radioiodine that should be kept in mind is that the quantity of radioiodine found in cattle is much greater than that found in humans. Lastly, the actual quantity currently reported by Dr. Van Middlesworth at the University of Tennessee Medical School at Memphis is somewhere around.3 pCi/g of thyroid, which is an essentially negligible quantity in the environment.

commoner. I said that recent results reported by the Public Health Service in the period January to March 1968 are much more striking than the early ones. In this period of time, there were no nuclear explosions capable of nationwide dispersal of radioactive iodine; there were no Chi­nese explosions. In that period, values as high as 68 pCi/g of iodine were observed in the thyroid gland. The earlier values of 1 pCi do involve the radium problem, and if this discussion had taken place in 1963, the re­marks made by Dr. Eisenbud and Dr. Auerbach regarding the obscurity of the significance of the 131I data because of the radium question would be pertinent. Now that we know, from the Rad Health data, that values as high as 68 pCi/g have been found in the absence of any nuclear tests, we ought to look for a continuous source. The very small amounts of 131I that are used in medical treatments cannot possibly account for such levels in cattle thyroids. Finally, in my calculation I of course took into account the fact that 131I levels are lower in humans than cattle. I would like to know why the aec staff has not been tracking down the origins of the 131I appearing in cattle thyroids in the expectation that they might learn some­thing useful about nuclear reactors and processing plants.

eisenbud. The total amount of iodine released by all of the reactors that we are talking about is a very small fraction of the iodine used in medical practice. The ratio is probably 100 to 1.

ramey. I would just like to comment again that Dr. Commoner is being awfully moral in relation to the Atomic Energy Commission. I should point out, though, that he is out on a limb on 131I. His data are wrong, and he is making false assumptions and interpretations which would be easy to check. He put this in an article some time ago, I believe. I should think he would want to spend some time working this over, and we should be glad to check these data over with him.

audience. What would be the average per-capita dose to the popu­lation of the Minneapolis-St. Paul area from discharges of the Monticello plant at the aec maximum permissible level?

eisenbud. This area contains 1.6 million people. The regulations specify quite clearly that the most-exposed individual in the population cannot receive more than.5 roentgen. When these regulations are followed with a boiling water reactor, the per-capita dose for a population of 10 million people would be.04 mrem.

borchert. Another question from the audience: What is the cost of concentrating, handling, and disposing of high-level radioactive wastes and who pays the cost? The question is asked in the context of the general economic framework in which we are often asked to consider growth with the nuclear power industry.

ramey. The utility that owns the reactor and the fuel is responsible and pays the cost for getting it reprocessed. Under the present system, the high-level wastes will be stored, temporarily, at the site of the reprocessing plant for a period of up to five years. During this time, they will become concentrated and put into solid form and then transported to a federal repository. So, the utility wifi be paying a chemical company or whoever runs the reprocessing plant for the reprocessing, handling, and storing of the wastes for this intermediate period. Then, the utility will pay the gov­ernment for storing the wastes permanently at the federal repository.

borchert. Mr. Ramey, could you refer to some source of data on this which gives the cost and relates it in some way to the economic structure of the industry?

ramey. There is one private organization in business, Nuclear Fuel Services, which has a schedule of charges for reprocessing and for stor­age. There have been a number of economic studies on how much it costs to reprocess and store high-level wastes and how much that adds to the cost of producing power. It is a relatively small amount. The aec has a section in its Reactor Development Division which would be the best source for economic studies and the general picture. Nuclear Fuel Services would be the best source for specific charges and rates. At this time, the General Electric Company is also building a reprocessing facility near Morris, Illinois, and will be in business, I believe, in 1971. An interested person could also get specific costs and charges from them.

audience. Are there any other payments that have been made under the Price-Anderson Act that need to be mentioned to augment the answer that Dr. Green gave to an earlier question?

ramey. I would hesitate to try to give any specifics or even any ranges. In Burlington, Vermont, someone at the press conference on September 11, 1969, asked me what amount of indemnity was required under the Price-Anderson indemnity provisions and I stated that it was in the range of $70 to $75 million. I was immediately jumped by someone saying it was a terrible thing that a Commissioner did not know the pre­cise amount. Of course, I have now done my homework on this and now know that the amount is $82 million. These figures are all in the accept­

able range. Among scientists, of course, even a factor of 2 doesn’t make any difference — it has to be a factor of 10 before anybody gets interested. On the property side, there were some small payments made in connection with an accident at Waltz Mill, but the figure was small.

audience. How did California obtain the right to control emission of C02 from automobile exhaust pipes? Was that unilateral?

hosmer. The automobile is a $4,000 mass-produced item, and California is an automobile market of 20 million people. Since the emis­sions were local and not national or interstate, this issue could be handled locally, and Congress permitted California to introduce higher standards because they don’t interfere with the rest of the country. By contrast, nuclear power plants are multi-million dollar investments and affect the whole region in which they exist — possibly the whole country. The situa­tion is simply not comparable.

commoner. This is an interesting question about the automobile and the nuclear power industry. The federal government has dropped an antitrust action against the auto industry designed to force the introduc­tion of pollution controls. The state of California is thinking of carrying out that suit.

hosmer. Dr. Commoner, the federal government did not drop any suit against the automobile industry. It agreed to a consent judgment against the automobile industry.

commoner. The legal proceedings under the antitrust act were halt­ed, and judgment entered against the industry. The reason this came under the antitrust act was that the technological development of auto­mobiles, even though they are sold in small economic units, represents a huge industry-wide operation. The federal government felt originally, although it has changed its mind, that this national issue required national action. So, I’m not impressed with Mr. Hosmer’s argument that the auto­mobile, because it is small and operates locally, can be regulated state by state whereas the nuclear power plant can be regulated only nationally. Anti-pollution devices in cars pose some technical problems similar to those in the design of a nuclear power reactor.

freeman. I do think it important to understand that the Attorney General and his assistant for antitrust did not drop the lawsuit against the automobile industry short of a complete victory. The consent judgment contains an agreement by the companies which admits each and every allegation made in the complaint and, for that reason, the Justice Depart­ment agreed to the consent judgment. It was a complete victory, effective immediately, rather than a lawsuit that might have taken a couple of years. audience. As all seem to agree that releases from reactors in Minne­sota will be far below what would be permitted by aec regulations. Why are the proposed Minnesota regulations not acceptable to either industry or the AEC?

ramey. This enters the area of preemption discussed earlier. Many of us thought that we were states’ righters, and wanted to cooperate with the states in getting nuclear energy and other things going in a new tech­nology sense. In the 1950’s, when I was staff director of the Joint Com­mittee and Mr. Hosmer was a member, we prepared a report on the possible roles of the states in atomic energy. Then the aec submitted a couple of different bills proposing a role for the states. Finally, in 1959, Congress passed what are called the federal-state amendments, setting forth an interim method, for the next 10 to 20 years, for delegating to the states the authority to regulate radioisotopes. The biggest source of radia­tion for most people is medical radiation from X ray machines, radium, and so on, which traditionally has been regulated by the states. It was thought that by delegating the authority to regulate radioisotopes pro­duced in reactors under aec authority, and by providing for the aec’s assistance to the states, the states’ activities in controlling an important part of radiation could be improved. In the last 10 years, under this authoriza­tion, aec has entered into agreements with twenty-one states providing for this type of program. Interestingly enough, Minnesota is not one of the agreement states. Frankly, it would be desirable for Minnesota to con­sider such an agreement because, even though the state has some good radiation people in its health group, with the aec’s help it could perhaps train and upgrade still more people in this very important field. And the medical field actually involves far more radiation than do effluents of power plants.

The second area that the states could participate in to a greater extent right now, and the aec is embarking on this program with the Public Health Service, is in the monitoring of the effluents from nuclear power plants. Experimental or demonstration programs are under way at several of the nuclear power plants such as Dresden (Illinois). If states are truly concerned about the monitoring of effluents, they could, in cooperation with the aec and the Public Health Service, have a positive role in getting themselves equipped. The 1959 federal-state amendment to the Atomic Energy Act of 1946 indicated that there could be later changes. In this country, the proper process would be to make a case before Congress whether or not the law ought to be amended to permit the states to par­ticipate in the regulation of the nuclear power plants. The various pro­posals and motivations involved would then be aired in the normal con­gressional process.

borchert. Mr. Ramey, do I summarize correctly, then, that the concern is not with the level of releases that are suggested in Minnesota as compared with the aec standards, but rather with the legal fact that the aec feels that Congress has preempted the field and with the concern that you expressed that other areas of radioactive risk are more urgent and more practical for the states to concern themselves with? Is this what you are saying?

ramey. No. But your second point has some basis; these other areas are more important in terms of the priorities of what the states ought to be concerning themselves with. However, there are problems with the specific regulation that’s involved in the order of the permit issued by the Minne­sota Pollution Control Agency. As I understand it, the mpca’s regulation is based on an average, and sets the average as a limit — even though every­body knows that sometimes you go over the average and sometimes you go under it. Similarly, as I understand it, mpca has provisions which would require frequent start-up and shutdown of the plant, perhaps monthly, to investigate whether or not there are any leaky fuel elements that might give off very minor amounts of fission products. From a safety standpoint, one normally prefers to have a plant stay in operation. The start-ups and shutdowns pose more problems than the benefits to be derived from seek­ing answers to questions of whether or not there are any minute leaks in fuel elements. This example shows the intimate relation between the per­mit that is regulating effluents and the actual design and operating mode of the reactor. It requires a terrific amount of technical knowledge and review in order to come up with the right kind of a design and the right kind of operating mode.

audience. Is the aec looking into the question of lowering its Part 20 standard on radioactive effluents?

ramey. The aec has looked at it from time to time, and we are doing so even more carefully now. There is a general admonition in the FRC Guide to keep radiation as low as practicable. One method would be to interpret what is as low as practicable. This matter is not so urgent as some of the other things that we are working on, but we are going to reach some decision, again not looking at just one state and not necessarily at just one type of radioactivity. [On March 28, 1970, the aec issued for public comment proposed revisions to regulations 10CFR20 and 50 which would provide further assurance that radioactive releases from nuclear plants remain “as low as practicable” below the established standard. See aec Press Release No. N-48 dated March 28, 1970.]

zabel. When I was on the icrs, the question came up in connection with one of the plants that was operating, Why should the limit be so high?

The records of that particular plant showed that levels in operating ex­perience had been low, and it would have been possible to lower the rates. During an extended discussion of that particular reactor, the icrs finally concluded that the higher levels should be maintained as limits for the time being. I still feel that they could have been lowered, and eventually they will be. However, if an ironclad limit is set, action must be taken when the limit is exceeded even temporarily. Because of operational problems and because of such hazards as shutdowns’ putting stress on parts of the plant, immediate action in the case of a temporary excess may not be the most desirable thing to do. It depends upon the particular situation, icrs encourages the plants to keep it very, very low, but leaves the limit high enough to permit freedom of judgment on the safest action under specific circumstances. If the limits are too low, the effect on flexibility might be a more critical condition than if the limits are higher and emissions are low on the average.

borchert. Why are means or averages used instead of absolutes in the statement of standards?

brungs. In terms of temperature standards, in most cases we are talking about a maximum temperature over a given period of time rather than averages, because averages can vary quite a bit, depending upon the season.

stannard. One reason for using averages in population standards is that we are dealing, not with a situation where a given event, such as a blow on the head, is certain to give damage, but with overall effects of radiation on a population at levels where somatic changes are much less significant than genetic. Also because the figure for average exposure has already incorporated several safety factors, it is considered possible to allow certain individuals, or small segments of the population, somewhat more exposure than the average because we are dealing only with a low probability of something happening and that something carries a wide range of biological significance. Finally the measurement of individual doses in a large population is a large undertaking and we would be dealing with an average anyway.

ramey. My reference was to setting an absolute limit at about 2 per cent of the mpc level, based on the average experience predicted by the utility in terms of how it is expected to operate the nuclear power plant. Everybody knows that the effluent discharged wifi fall above and below an average — one day or one week it might be 1 per cent and another week 4 per cent. So an absolute limit at that very low level is impractical.

audience. In building reactors, is a safety factor included in the same way it is in building a bridge?

stannard. The safety factor is included in every calculation and every decision on standards, physical, biological, and engineering. Prob­ably the largest safety factor of all is the assumption that the biological effects of radiation that we are interested in actually follow a linear rela­tionship to dose with no threshold. That is a very large assumption, and it introduces a safety factor of considerable importance. Yet, even with that safety factor, others on the order of 10 or more are put into standards because those with responsibility for setting standards feel it is necessary to be conservative. One of the reasons that many who participate in standard-setting want a good reason for further tightening these standards is that already many safety factors have been included. Several papers in this volume have pointed out an important reason for using such factors — namely, that there are other factors in the environment that may impinge on the health of man. This is where we need to place our efforts and our money.

audience. If we know there’s danger of risk in these systems, why don’t we modify the system?

commoner. A brief, and understandable, reply is that what you propose will cost a lot of money.

audience. If there is any possibility of hazard from the wastes from nuclear power plants, why do we build them?

hosmer. It is a matter of having to accommodate to the world in which we live. We need to produce electricity. The chances of damage to any individual in society from any of the effluents of a nuclear plant are so low that there would be fewer people hurt by them than there would be if the same amount of electricity was being produced by a coal plant powering pollutants into the air. But society has forced upon us many, many risks. Crossing the street is a risk. You cannot live in our society without moving around.

tamplin. The fact that the reactors may not come anywhere near delivering the dosage that is allowable under the radiation protection guideline is a wonderful thing, because the radiation protection guideline is not necessarily safe. The guideline is inappropriately too high. Dr. Stan­nard presented a figure on the number of genetic deaths for 1 roentgen of radiation, the figure in icrp Publication No. 8. The genetic deaths in the first generation have built into them an imagined elimination rate of 2.5 per cent, a rate which is not necessarily established for human popula­tions. If something like the radiation protection guideline is the law, then the population could eventually be exposed to that rate generation after generation. Then this 2.5 per cent imagined elimination rate, which may be an actual rate of 50 per cent per year for the population, is meaning­less. The number of mutations in the population might increase at the 2.5 per cent elimination rates, taking something like 50 generations for it to build up its maximum. But, at that time, the number of genetic deaths will be the number that Dr. Stannard had recorded for infinity. Also, that number was four times the existing death rate at 1 roentgen per genera­tion, not 5 roentgens per generation.

audience. How much more, in mills per kilowatt hour, would it cost to generate power under mpca standards than it would under aec standards?

commoner. This is the key question in most massive pollution prob­lems, Why not simply accept the lower risk and have the public or society accept the added cost of reducing the risk? An answer is to let the price of electricity go up; if people are willing to pay more for electricity in order to avoid certain dangers, that is a perfectly feasible thing to do in our society. It hasn’t been approached this way because all the costs and bene­fits are not yet out in the open. In many cases, pollution problems will be solved simply by people’s expressing their willingness to pay more for the product in order to avoid pollution.

audience. Dr. Auerbach, have you been satisfied with existing en­vironmental monitoring programs?

auerbach. I would not be at all surprised if they are inadequate, but I have not commented on that. The responsibility for developing an ade­quate monitoring procedure is a responsibility of the utility. The utility has the responsibility of assuring the public that its nuclear power plant will meet all of the present safety requirements. I don’t think that the present safety requirements need to be changed or that there is any tech­nical justification for changing the standards. But, I do think that the pri­mary responsibility of informing the public about a particular plant lies with the utility company, and not necessarily with the federal government.

As for the costs for pollution, I think that Dr. Commoner has a valid point. However, if society wants to pay for increased pollution control, it has yet to demonstrate this on a local level. For example, society does not want to vote bond issues for local sewage treatment plants. The challenge is to come up with the necessary funds at the local level if we are indeed interested in a clean environment.

audience. Mr. Ramey remarked that atomic power plants are aesthetically pleasing. Who says they are and is it so?

ramey. Relatively speaking, nuclear plants are aesthetically pleasing when compared with fossil-fueled plants. Anyone who has visited or ob­served a coal plant is not exactly impressed with its aesthetic appearance,

whereas I think many of the nuclear plants have a modern, rather striking, architecture. Of course, aesthetics are quite a personal thing.

commoner. Then, too, there are people who find a blemished dis­ease-marked apple more aesthetically pleasing than a nice smooth one because it gives them a feeling that there haven’t been so many insecticides on it. It depends on who you are.

I have been asked whether the mpca standards represent the conse­quences of an informed public opinion or, rather, the opinions of some small group. I have the general impression that there has been a greater public input into the considerations of the mpca than there has been in almost any other reactor problem that I know about. The influence of public views is probably better represented by the mpca judgment than it has been anywhere else, and I think that is a very good direction in which to go.

audience. Dr. Hubbert indicated that the United States has only a 25-year supply of 2S5U. Is it his opinion that the present program of rapid installation of reactors that principally consume 28 5U may have been ill — advised?

hubbert. Yes, that is substantially my opinion. My statement was based on two recent reports of the aec. On page 14 of the aec report of February, 1967, entitled Civilian Nuclear Power, the 1967 Supplement to the 1962 Report to the President, the following statement was made on page 14: “With reactors of current technology, the known and estimated domesic resources of uranium at prices less than $ 10 per pound of uranium oxide (U308) are adequate to meet the requirements of the projected growth of nuclear electric plant capacity in the U. S. for about the next 25 years.” Since that statement was made, the projected growth has been increased from 95,000 to 145,000 megawatts of nuclear power capacity by 1980.

Evidence for a shortage of uranium before 1980 was also presented by Rafford L. Faulkner, Director, Division of Raw Materials of the aec, in an address before the Conference on Nuclear Fuel — Exploration to Power Reactors, held in Oklahoma City on May 23, 1968. More recently, however, as a result of the realization of this impending shortage, an accelerated program of uranium exploration has been begun and, accord­ing to the aec Annual Report for 1968, has met with some success.

In view of this limited supply of 235U, the present program of rapid installation of 235U-consuming, light-water reactors, impresses me as hav­ing been ill-advised. If fission nuclear power is not to be short-lived, breeder reactors are imperative. In the 1962 report on Energy Resources of the National Academy of Sciences Committee on Natural Resources, advisory to President Kennedy, top priority was given to the development of breeder reactors. However, according to Milton Shaw, Director, Divi­sion of Reactor Development and Technology of the aec, in his paper “The Fast Breeder Reactor Program” (given before the American Power Conference in Chicago on April 23, 1968), the breeder-reactor program before 1967 had been carried out at a leisurely pace, and in an atmosphere of complacency. “There was much less substance than image to the in­dustrial breeder program,” stated Shaw, “for there appeared to be ample time.” Subsequently, something approaching a crash program on industrial breeder reactors has been launched but, according to the published time schedule, these are not expected to be in operation before about 1985.

ramey. Dr. Hubbert is entitled to his views. He has been trained in geology and knows a great deal about natural resources, but he is not an expert in nuclear power. In 1962, the aec, in a response to a request from President Kennedy prepared a report called “Civilian Nuclear Power, A Report to the President, 1962.” This report discussed what the future of atomic power should be and stated that the fast breeder program, particu­larly the liquid metal fast breeder, should be the top priority program. It has been a growing program, and it is now the program on which we are expending our greatest effort. Of course, there are back-up programs in the breeder field, in case, for some unanticipated reason, we do not make it with the prime candidate. The current commercial development of light — water reactors will not waste our natural resources, in that the plutonium that the reactors produce will be useful either as a recycle fuel or as a fuel in the fast breeders, when they come in in the late 1970’s and in the 1980’s. Secondly, a good part of the uranium that isn’t burned up in commercial light-water reactors is reusable. So, I don’t think the criticism that Dr. Hubbert is leveling is quite so strong as he makes out. I would point out, however, that after an analysis of the resources available, he made it very clear that we are going to need nuclear power, certainly in the next cen­tury and the centuries to come.

audience. Wouldn’t the artificial release rates of thousands of curies of tritium and xenon per annum from the stack of the Monticello plant be detrimental to the public? I understand that the maximum release there would be 41,400 curies of radioactivity a day.

bray. I’m not familiar with the number you are quoting, but it ap­pears to me to be higher than the anticipated stack release rate from the Monticello plant. To give a dose of 500 mrem/year to a person who stands all year at a fence on the boundary of the property, the release rate would have to be.48 curies, or 480,000 /лСі/sec. The anticipated release rate of the Monticello plant is expected to be less than that. Its emissions are consistent with the regulations, and it is on that basis that the project was reviewed by the aec.

ramey. I would like to refer this question to Mr. Lester Rogers, director of the Division of Radiation Protection Standards, one of my aides.

Rogers. With respect to number of curies, you really have to speak also in terms of particular nuclides in the gaseous release from boiling water reactors. Many short half-lived noble gas radionuclides are released. While the total number of curies released may be high, their signficance, so far as exposures of people goes, is very small. The regulations provide that the maximum permissible release rate shall not result in an exposure rate anywhere on the boundary of the site of more than 5 rem/yr (integrated exposure outdoors over a period of 365 days a year, 24 hours a day). Actual exposures to members of the public would be substantially less. The farther away from the reactor they are, the less the exposure, as Dr. Eisenbud has calculated and presented in his paper.

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One of the most important field studies has been conducted at the Dresden Nuclear Power Station in Illinois by the Bureau’s Radiological Engineering Laboratory, Cincinnati, Ohio, in cooperation with the Com­monwealth Edison Company, the Illinois State Health Department, and the AEC.

This site was selected because of the extensive operating experience with Dresden 1 and the development of other nuclear facilities on the same site. Dresden 1 has been in operation since 1962, and at the time of the study’s inception was the largest (200 megawatts electrical) operating boiling water reactor. The specific objectives of the study were to: (a) de­velop better data on which to base guidance for environmental surveil­lance programs; (b) obtain a more comprehensive knowledge of the prob­lems associated with effluent monitoring from nuclear facilities; (c) in­crease the depth of technical knowledge within the Bureau of Radiologi­cal Health in order to better assist states in developing surveillance pro­grams; and (d) evaluate the movement of radionuclides from nuclear fa­cilities into and through the environment.

Emphasis was placed on identifying critical pathways of radioactivi­ty from source to man including delineating any reconcentration media or indicator radionuclides within the pathways, and correlating stack dis­charges with the associated environmental levels produced. Since the site will soon contain other reactors and a fuel reprocessing plant, the effect of multiple sources may be investigated at a later date.

Various samples were collected at the Dresden Station for radio­nuclide analysis in three general areas: gas and particulates in the reactor discharge lines, liquid wastes, at various points within the plant, and sam­ples taken in the environment. This sampling procedure made it possible to determine the significant nuclides in the plant before release and to cor­relate these known quantities discharged with any radionuclides detected in the environment. Critical radionuclides and their pathways through the environment that could cause significant exposure to man were identified. Techniques employed to measure radionuclides during the study were of a type more sensitive than those normally used in routine environmental surveillance programs. This enabled a detailed quantitative evaluation of specific radionuclides to ensure that all possible “critical” radionuclides were identified.

The final report for this field study has been published (Radiological Engineering Laboratory, Division of Environmental Radiation, 1969), and some results can be summarized as follows: First, the critical pathway for possible exposure of the population from this reactor was determined to be via the atmosphere through the discharge of noble gases. Based on survey instrument and dosimeter measurements around the site, the aver­age exposure at the sampling locations during the study was estimated to be less than 5 mrem per year. A more precise estimate was difficult be­cause gaseous releases from Dresden have resulted in environmental ra­diation levels which were only marginally above background.

Second, both in-plant and environmental samples were collected over a period of several months for analysis. The types of samples col­lected were: in-plant — primary coolant, recycled demineralized water, fuel pool water, waste neutralizer tank, laundry wastes, delay line, con­tainment building ventilation filters, and turbine building ventilation fil­ters; plant discharges — water from discharge canal, and gas, particulate filters, and charcoal iodine filters from the stack; environs — plume, milk, cattle thyroids, rabbits, com kernels and husks, leafy vegetables, grass, soil, drinking water, rainwater, snow, river water, silt, and fish. The inter­pretation of data obtained from the analysis of the environmental samples indicates no detectable radioactivity resulting from the operation of the plant which could be considered a source of population exposure. These results are shown in the accompanying tabulation: levels of radioactivity in positive samples are given; negative samples included soil, leafy vege­tables, fish, grass, milk, rabbits, drinking water, river water, and rainwater.

In order to provide data on a pressurized water reactor to augment the field data obtained at Dresden 1, a study was initiated at the Yankee Atomic Power Station in Rowe, Massachusetts. Since the fieldwork was only recently completed, results of this study are not yet available; how­ever, these will be published as soon as all of the data have been evaluated

(Radiological Engineering Laboratory, Division of Environmental Ra­diation, 1970).

A similar study is currently under way at the Nuclear Fuel Services, Inc., spent-fuel processing plant in New York State. The routine dis­charges from a fuel reprocessing plant are somewhat different from a nu­clear power plant in both magnitude and in character. The results of this field study are expected to contribute significantly to our ability to monitor this type of facility adequately.

Applicants who propose to build and operate nuclear reactors are re­quired to include in their applications all technical information required to support the application. For instance, the application must include a safety analysis containing the technical information required for an evaluation of: the safety of the proposed activities, including the suitability of the site; the design of the proposed facility and all its appurtenances; reactor performance specifications and plan of normal operation; a detailed description of the op­erating organization and plans for quality control to be exercised during fabri­cation and construction; and the safeguards to be engineered into the facility to prevent the occurrence of accidents and to minimize the consequences of any accident which might occur.

Thus, the safety analysis must include: a description of the nuclear proc­esses to be performed; a description of the design of the facility pertinent to nuclear safety; the meteorological, hydrological, geological, seismological, and other data pertinent to an evaluation of the suitability of the site for the pro­posed facility; a description of the proposed operating procedures; and a de­scription of the emergency plans which would be observed in the event of an accident.

In addition, the safety analysis includes an accident analysis in which the applicant must postulate all credible accidents which could result in the re­lease of radioactivity to the environment. The application must contain infor­mation demonstrating that adequate safeguards have been engineered into the facility to prevent the occurrence of such accidents and must also demonstrate that even in the unlikely event such an accident occurs despite the engineered safeguards, there will be adequate protection for the general public. The re­
quired safety analyses are so detailed that they often consume several pounds of paper.

All information contained in the application and all correspondence be­tween the aec and the applicant, including additional information requested by aec, is placed in the aec’s Public Document Room in Washington where it may be examined by any interested member of the public.

Each application for a permit to construct a nuclear reactor is meticu­lously reviewed by the technical specialists in the aec’s regulatory staff and independently by the Advisory Committee on Reactor Safeguards. The acrs is an independent committee established in 1957 by Congress to advise the aec on matters of reactor safety. It is composed of scientists and engineers who are specialists in the various disciplines important to reactor safety.

The reports of the acrs and the technical analyses of the safety considera­tions relevant to a proposed reactor prepared by the aec’s regulatory staff are made public before the hearing on the construction permit application.

Next, an Atomic Safety and Licensing Board is appointed to conduct a public hearing held on each application to construct a power reactor. The Board consists of two members who are technically qualified, and one of whom is experienced in the conduct of administrative proceedings. Due notice must be given to state and local officials in the area of proposed construction, who are afforded the opportunity to offer evidence, interrogate witnesses, and advise the aec as to the application without having to take a position for or against the granting of an application, although they may do so if they wish. Any affected person who wishes to express his views on the proposed plant may make an appearance and present his case. For his convenience the Board is required to hold its hearing in the vicinity of the proposed nuclear facility. The only thing asked of the witness is that he confine his evidence to the issues over which the aec has jurisdiction.

The Board has the responsibility of assuring that a complete review has taken place and that the health and safety of the public is fully protected. The decision of the Board is subject to review by the aec upon its own initiative or upon petition by a party to the proceeding. Recently, an Atomic Safety and Licensing Appeal Board was established by the aec to take responsibility for certain licensing proceedings. Like acrs, the aslab is composed of experts who, though compensated for their services by aec, are not, except in rela­tively few instances, government employees, but for the most part are inde­pendent experts acting in their capacity as consultants.

Before a construction permit is issued, the aec must first find that: there is reasonable assurance that the applicant will comply with the aec’s regula­tions; the health and safety of the public will not be endangered; the applicant is technically and financially qualified to engage in the proposed activities; and the issuance of the license will not be inimical to the common defense and se­curity or to the health and safety of the public.

All permits contain such terms and conditions, in addition to those gen­erally prescribed in the Atomic Energy Act and the aec’s regulations, as the aec considers necessary to protect health and safety. And permits are subject to amendment, revision, or modification by reasons of amendments to the Act or such further regulations or orders as the aec considers appropriate to pro­tect health and safety.

All steps to this point are required to get permission to construct a nuclear power reactor. At this point, about 1 and Vz years’ effort has been expended on the application by the aec regulatory staff and acrs, the licensing board, and possibly the aslab or the commissioners themselves. During the time the applicant has supplemented his original application several times in the form of responses to questions and clarification on points which may have arisen. The review has been extensive and intensive, drawing on a pool of highly skilled, multi-disciplinary personnel available nowhere else in the world, let alone in the country. A few of the kinds of scientists and engineers involved were physicists, chemists, nuclear engineers, mechanical engineers, civil en­gineers, metallurgists, health physicists, meteorologists, seismologists, geol­ogists, ecologists, hydrologists, and more. Today is a time of specialization. One needs not just chemists, but organic chemists, inorganic chemists, physical chemists, and radiochemists. One needs physicists, nuclear physicists, and so on. There is much that is known in these fields — and it all must be pulled to­gether into a cohesive, scientific judgment that A equals В or A does not equal B.

But what I have described so far is just the beginning. As construction proceeds, the aec’s Division of Compliance inspects constantly to assure that requirements of the construction permit are being met. During this period the applicant is submitting to the regulatory staff more and more details on its facility, including plans for operation and procedures for coping with emer­gency situations, and pertinent details on the final design of the reactor itself — such as containment design, nuclear core design, and waste disposal systems. Once again the Division of Licensing and Regulation makes detailed reviews of the information and presents an analysis of it to the acrs. Then the acrs re­ports, and its report is again made public.

Only after the acrs and the aec regulatory staff have completed all their preoperational safety reviews does the aec, at its discretion, issue a license for the reactor actually to operate. The aec may on its own motion, and it must upon the request of any affected person, schedule another public hearing be­fore final action on the operating license. If a license is issued, it may be made provisional for an initial period, at the end of which another review is made to determine conditions for the full term license.

Further, no individual may be the operator of a power reactor unless he is licensed to do so by the aec. Operators must pass an examination which in­cludes an operating test and a written examination on their knowledge of spe­cific details of the facility and the procedures used in its operation.

In summary then, the aec, pursuant to requirements of statute and imple­menting regulations, conducts a detailed examination of the multitudinous factors which affect the ultimate question of whether a particular reactor can be constructed and operated at a particular site within the standards and guides established by the United States government for the health and safety of the American public. These carefully meticulous aec procedures and the license which may be issued pursuant to them were arrived at following the expen­diture of hundreds of millions of dollars on biology, medicine, and reactor safety research and development. This matter does not end with the issuance of a license. The licensee remains subject to aec rules and regulations, and continuing inspection and reviews are made throughout the life of the reactor.

If ever conditions or circumstances are found which may be questionable, the aec has ample authority to shut down the reactor and order any and all safety measures which may be necessary.

This book is based upon a symposium, “Nuclear Power and the Public,” which was held at the University of Minnesota on October 10 and 11, 1969. The meeting was a timely one, judging from the nationwide atten­tion it attracted and the continuing and lively public interest in the many issues raised and discussed. Yet, much of the material covered had already been of concern for decades. Certainly since the early days of the Manhat­tan Project, the dissemination of radioactivity into the environment from atomic energy activities has received considerable attention from plan­ners, administrators, and others responsible for the activities, all of whom had public safety in mind. In the mid-fifties, many scientists from outside the atomic energy field began to direct their attention to the potential ef­fects of dissemination of radioactivity into the environment, particularly as related to fallout from weapons testing. Then, in the sixties, the rising potential of nuclear energy as a power source began to start widespread concerns among many segments of the populace. This phase of develop­ment is a particularly intense one because it is reinforced by a general con­cern about many kinds of pollutants and by a serious questioning concern­ing the meaningfulness of new technologies to the lives of individuals and the effects of such technologies upon environmental quality.

In Minnesota, current public interest in the potential side effects of nuclear power is specifically focused on the first of a series of high mega­wattage nuclear power plants being built on the Mississippi at Monticello, about forty miles upstream from the Twin Cities.

About four years ago, officials of the principal power company in the region, Northern States Power, having just faced protracted public criti­cism concerning the environmental effects of a large fossil-fueled plant then being completed, made the decision to use nuclear fuel for their next major power plant. Company officials reasoned that a plant of this type would neither produce the soot, smoke, and noxious chemicals nor suffer the fuel transportation and storage problems of fossil-fueled plants; fur­thermore, its radioactive discharges would be only a small percentage of the levels permitted by the Atomic Energy Commission. Thus, nsp appar­ently believed there would be little public criticism and concern. For a long time, there was little public reaction, but, bit by bit, more and more citizens’ groups began to express their concerns and fears about the plant whose construction had been approved by the aec.

Late in 1967, the governor appointed a new commission, the Minne­sota Pollution Control Agency (mpca), with powers to regulate the dis­charges of nuclear power plants. In May 1969, after numerous hearings attracting widespread and active public participation and after consulting an outside specialist, the mpca issued a waste discharge permit for the Monticello plant. Rather than settling the matter, this permit has attracted attention throughout the United States, and the issues at stake in Minne­sota have become the subject of a nationwide polemic sharply focusing on the benefits and risks associated with the use of nuclear energy, the roles of the aec in regulating and promoting the use of nuclear energy, the va­lidity and safety of the radiation standards promulgated by the aec and the Federal Radiation Council, the rights of states to set more stringent regulatory standards than the federal government relating to radioactive discharges, and, in fact, the whole gamut of the environmental question. That permit is the basis of a suit brought by the power company to test whether the mpca does, indeed, have the legal right to set emission stand­ards for radioactivity. The decision will be a landmark that will shape the development of nuclear technology throughout the nation.

It was in this milieu that the symposium was held. The symposium was conceived and planned to bring together competent scientists working in the field of radiation effects and recognized authorities in the many fields of endeavor that bear upon these problems to elucidate objectively the divisive points of view on nuclear power and face one another in a neu­tral forum to present sound and verifiable information and debate the is­sues. It was the hope of the planning committee that the academic atmos­phere would promote unfettered discussion wherein proponents of diverse views could face each other in a calm, reasoned manner appropriate to men who respect one another.

It can readily be demonstrated that the future and well-being of the people of the United States, for better or worse, is inextricably interrelated with the production and use of energy. With the consumption of electric power having doubled every ten years for the past three decades and the prospect of the rate of consumption accelerating even more, we face a

Editor’s Preface

conflict between society’s demand for electrical energy and the recognition of the detriment from ever-increasing levels of pollution resulting from production and use of that energy. It is to this conflict that the contribu­tors address themselves in this volume.

The participants in the symposium were selected because of their rec­ognized expertise and their diverse points of view on the various aspects of the nuclear power controversy. The case for nuclear power as a solution to the “energy crisis” — both in its role for conserving the fossil fuel re­sources of the earth and its favorable situation with respect to environ­mental pollution vis-a-vis fossil fuels — is made by Commissioner Ramey and Congressman Hosmer. Basic information on boiling water reactors and the discussion of the multiple safeguards designed and built into the reactors are presented by Mr. Bray. Drs. Eisenbud and Stannard discuss the development of radiation exposure standards and emphasize the wide safety margin for the public which is built in by the conservative assump­tions and estimates made in setting up these standards. Dr. Auerbach re­views the research that has been done on the potential long-term effects on the environment resulting from low level radioactive discharges into wa­terways, and Mr. Lieberman and his co-authors devote their discussion to environmental monitoring and the actual findings that have been observed following long-term radioactive discharges. The consequences of thermal discharges into rivers and lakes and the effect on biota are the subject of Mr. Brungs’s contribution. Dr. Tamplin develops a position for the inade­quacy of current radiation standards for the protection of the public. Dr. Commoner makes a case for the right of the public to decide the cost — benefit question, as does Dr. Green in his discussion of the inadequacies of public hearings on the siting and construction of nuclear plants. Mr. Free­man and Dr. Hubbert discuss the “energy crisis,” with Hubbert presenting world fuel inventories for electrical power development and Freeman dis­cussing government policies with respect to these inventories.

Although it is readily apparent from the discussions, wherein the contributors had the opportunity to question one another and the audience also participated, that the symposium may not have allayed concern about nuclear power plants, the basic positions and the principal arguments are well delineated. In time, answers to many questions herein will be forth­coming. The conference and this book are key contributions to the histori­cal evolution of the nuclear power controversy.

As the current publicity and concern about environmental decay build toward their crescendo, more and more thought, efforts, and re­sources will be directed toward the solution of these problems. It is axio­matic that the costs for clean-up and the preservation of the environment

will be staggering. Because of that, the case can be made that, to a large extent, the success of such endeavors will depend upon cheap and abun­dant electric power. In view of the prime role of energy in the treatment and care of environmental decay, it is vital that we come to grips with the power production-pollution dilemma as quickly as possible. It is the be­lief of many that nuclear power, particularly for the future, is the answer. It may well turn out that pollution from electric energy production by nu­clear power is a wise trade-off for the gains made by providing energy cheaply and conveniently so the work of cleaning up the environment can proceed expeditiously.

As part of the introduction to this work, I am happy to include re­marks prepared by William G. Shepherd, Vice President for Academic Administration at the University of Minnesota, who officially expresses the support of the University for holding the symposium and for the pub­lication of this volume. Similarly, I am happy to include remarks prepared by Harold LeVander, governor of the State of Minnesota. “On Ecology” is evidence of his opinion of the importance of contributions to solutions of the environmental problems besetting this country.

The symposium in October 1969 was sponsored by the Center for Population Studies and the Center for Urban and Regional Affairs at the University of Minnesota. Members of the planning committee were Dean E. Abrahamson, Donald E. Barber, John R. Borchert, Harry Foreman, Herbert S. Isbin, and Lloyd L. Smith, all of whom are included in the List of Contributors and Participants on page 259. Among those whose sup­port made the symposium possible are the Minneapolis Chamber of Com­merce, the St. Paul Area Chamber of Commerce, the Minnesota Pollution Control Agency, and the United States Atomic Energy Commission.

The symposium was financed by generous donations from the Day­ton Corporation; the Farmers and Mechanics Savings Bank of Minneapo­lis; the First National Bank of Minneapolis; the First National Bank of St. Paul; General Mills, Inc.; the Knutson Companies, Inc.; Marquette National Bank; Minnesota Mining and Manufacturing Company; the Northwestern Bell Telephone Company, Minneapolis; the Northwestern Bell Telephone Company, St. Paul; Northwestern National Bank; and the Minnesota Pollution Control Agency. The United States Atomic Energy Commission was not asked to contribute funds until after the program had been set up; in addition to providing several speakers, the Commission contributed to the publication costs of this volume.

Harry Foreman, m. d.

June 1970

audience. Comment on this flexibility, please. Can CFR 20.160E allow the aec to limit discharges below mpc when the mpd is exceeded in a sample of food?

auerbach. The flexibility, as I understand it, is partly based on the nature of the population that is to be exposed, or may be exposed, to the radiation. I should make the point that under the recommendation of icrp, the basic limitations are the dose to the population; if the limitation of exposure for the general population is.17 mrad, that governs and over­rides the mpc’s.

audience. Does heat have any proved effect on algal growth? Could you name specific studies? Are there any other studies under way?

brungs. Even without citing sources — which would take research because I’m a fisheries biologist and not an algologist — I can say that any biological process, such as metabolism or growth, is affected by tempera­ture. Within limits, as the temperature rises, the rate of these biological processes would increase also, and therefore, algal growth would increase. Obviously, if the temperature goes beyond too high a level, the algae can actually be killed off. The growth will increase, then start decreasing, and eventually, mortality will occur. For specific references, I’d prefer to con­sult my files rather than rely on memory.

audience. What is the current state of knowledge concerning the concentration of tritium in the environment and in body tissue?

tamp lin. I know that there has been some discussion of the possi­bility that tritium is one of the radionuclides that will concentrate when moving up through food chains to man. This question came up with re­spect to the Lake Cayuga reactor. We heard about possible concentration in the food chain there, and we looked into it. Our opinion was that the question being asked could be resolved if someone made a detailed study on the concentration of deuterium over this period of time. Tritium has a mass of three, compared to hydrogen’s one, and will react at a rate differ­ent from hydrogen within the various biological systems. The difference in the reaction rates between tritium and hydrogen could cause tritium to concentrate. When we looked at the data that was available — deuterium to hydrogen ratios and tritium to hydrogen ratios — we concluded that tritium probably would not be concentrated in man by more than a factor of three. The data were not sufficient to indicate that tritium would not be concentrated by as much as a factor of three.

audience. Great emphasis is placed on elucidation and anticipation of problems and finding solutions. In your evaluation, is the aec providing the public with adequate safeguards in plants presently built? Would the Minnesota Pollution Control Agency limit on plant operation improve or make more hazardous plant operation at Monticello?

bray. I definitely endorse the degree of public safety being provided by the reviews of the aec based on my experience with the applications that we have brought forth with our clients. I have always been impressed with the detailed evaluation techniques, the multitudinal questions, and the meticulously detailed review of the dockets of the applications that have been made. First, one goes in with a preliminary safety analysis re­port and then amendments are made. The amendments are based upon questions raised by the regulatory staff and answered by the applicants. The technical level of these questions and answers is a manifestation of the high degree of safety that is sought.

With respect to the second question, I don’t think it is a question of improving or making plant operation more hazardous. It is a question of using different limits than are now invoked for plants being operated. It is a question of whether the limits can be complied with or whether the means by which they could be carried out should be made clearer. These limits are not yet agreed upon.

tamplin. Should the Minnesota limits become law in the state of Minnesota, would you be able to meet them?

bray. There is still a question of fully appreciating what each part of the limits means. There are questions with respect to measurement tech­niques and procedures. I’m not fully familiar with the limits since they are still the subject of discussion. Until it is clear what is being requested, I’m not able to comment on whether we could meet the mpca limits.

audience. Mr. Tamplin, would you please show the calculations which allow you to make the statement about dose rates you made at the start of your paper—that mpc for air for one year for 13TCs gives a dose of 2,555 rads to children?

tamplin. The mpc for air is 2 X Ю9 ftCi/ml. Since there are 10® ml in a cubic meter, we next get 2 X Ю-3 /лСі/m3. If this concentration is maintained for a day, 24 hr, we end up with 48 X 10’8 /лСі hr/m3. There have been a number of experiments performed which have measured the concentration in air and then measured the concentration that gets de­posited out of the air. From that comes a ratio called deposition velocity; by assuming that cesium is on small particles in the atmosphere (which is likely), we arrive at a deposition velocity of 17 meters (m) per hour. When these two numbers are multiplied, the deposition is.82 ^Ci/m2. Starting with this deposition on forage and considering the facts that a cow eats over 45 m2 of forage per day, that 1 per cent of the cesium she takes in goes out in each liter of her milk (1 per day), and that cesium has a half-life in the child’s body, the result is that a deposition on forage of.12 /tCi/т2 is equivalent to 1 rad received by a child drinking 1 liter of milk per day. This kind of information is tabulated for all the radionuclides listed in the chart of nuclides (UCRL 50163, Pt. IV, p. 86).

The only channel of solar-energy flux which lends itself readily to large-scale industrial power production is water power. According to the Federal Power Commission, the maximum ultimate water-power capacity of the United States is approximately 161,000 megawatts. Of this, the present installed capacity of 45,000 megawatts amounts to 28 per cent. The corresponding water-power capacity for the whole world is estimated to be about 2.9 million megawatts. Of this, it is significant that the conti­nents of Africa and South America, both of which are deficient in coal, have the highest capacities —780,000 and 577,000 megawatts, respec­tively.

The total installed water-power capacity of the world by 1964 amounted to 210,000 megawatts, which is only about 7.5 per cent of its potential capacity. The total installed electrical power capacity of the world is about 734,000 megawatts, which is only a quarter of the poten­tial water-power capacity.

It appears, therefore, that if fully developed, the world’s water-power capacity would be comparable to the world’s present rate of energy con­sumption. Offsetting this, however, would be the necessity of a prior in­dustrialization of the areas where the power is potentially available. Also, there is the problem of silting reservoirs. Most water-power sites require dams on storage reservoirs, and only about one to three centuries are re­quired to fill the reservoirs with sediments. Unless a solution to this prob­lem can be found, water power also may be relatively short-lived.

Although considerable effort has been directed toward accident considerations (e. g., emergency core cooling and containment), normal plant releases are also of extremely high importance. The reason I have thus far dwelt upon accident considerations is that accidents are the only means by which it can be hypothesized that appreciable radioactivity could be released from a nuclear plant to the public. Under normal opera­tion there are traces of radioactive release, but they are always well within release rates established by the aec. In fact, they are kept at insignificant levels.

Before embarking on a discussion of the radiological systems asso­ciated with normal releases from a nuclear plant, I shall set forth the philosophical aspects of the design — the design criteria.

Appreciation for Background or Boundary Conditions. It doesn’t make any sense to design a dirt-free automobile tire for use on country roads. It doesn’t make any sense to design a silent controller for use on a jackhammer. In both cases the design objective — dirt-free and noiseless — are frustrated by the original environment.

This same design consideration faces the nuclear industry, reflected in the questions, What is the proper goal in the reduction of radioactive releases when our environment is naturally at a radiation level? What does radiation-free or — clean mean when people naturally receive from 100 to 300 milliroentgens equivalent for man (mrem) per year depending on where they live, what they do, and whether they travel by air or land? The answers demand that design objectives and goals be set properly with respect to background or boundary conditions.

Appreciation of Governmental Criteria. A system designer or a utility employee who operates a nuclear plant must comply with all of the applicable regulations with respect to radioactive release. The design may be based on more stringent considerations also for other reasons, but all of the applicable regulations will be met.

In the case of nuclear power reactor design, appropriate government criteria and regulations do exist, aec regulation 10CFR20 (Code of Fed­eral Regulations, Title 10, Pt. 20) provides the basis for accident consid­erations, and 10CFR20 regulates the allowable releases for normal oper­ation. Most people in the industry believe that of all the government regulations, these two are based on firm ground with respect to allowable releases.

Secondary Goals — Good Neighbor Policy. In addition to determin­ing the natural background and the applicable government regulations, a third very important design question has been, What goals for release minimization should be employed, including all practical considerations? For instance, the normal radioactive background dose to persons in a certain locality might be 200 mrem/yr. Thus, although the government regulation for radiation doses contributed by a nuclear plant to any neigh­bor is 500 mrem/yr, designers would attempt to keep the plant discharges below 5 mrem/yr to any neighbor averaged over plant life in order to make the contribution of the nuclear power plant insignificant (approxi­mately 1 per cent of allowable) with respect to the exposure the public normally receives. This is not to say that should something unusual happen within the plant and the release climb to a rate of 25 mrem/yr for a short period of time, the plant would be causing a critical radioactive release and would shut down. No, it would simply be exceeding the design objec­tive — releases would still be at one-twentieth of the government regula­tion. A weekend air flight to visit a relative in Denver might be more consequential as far as radiation is concerned.

Thus, in any consideration of design action taken in a nuclear plant to handle radioactive release, one must always remember the normal radiation levels that exist, all of the government regulations which are in force, and also the design attitude toward the desired insignificance of any releases.

Once the aec regulatory staff concludes that the “reasonable assur­ance” test has been met, it abandons all pretense of being in any sense the applicant’s adversary and becomes the applicant’s enthusiastic ally doing all within its power to procure speedy issuance of the construction permit. This begins with the staff’s safety analysis report, which goes to great pains to allay and soothe any concerns which members of the pub­lic might have by sweeping negative considerations under the carpet. Here are some specific examples from the regulatory staff’s safety analysis re­port issued on February 20, 1969, in the Consolidated Edison Indian Point No. 3 case. Indian Point No. 3 is a pressurized water reactor de­signed to produce 965 megawatts electrical, with an ultimate capacity of 1,033 megawatts electrical, to be immediately adjacent to two other Con­solidated Edison nuclear power plants of lesser capacity. It was projected that in 1980 almost 60,000 people will live within a З-mile radius of these plants, and more than 312,000 would live within a 10-mile radius.

The regulatory staff’s safety analysis report was 66 double-spaced pages with an additional 37 pages of appendixes. If one reads this docu­ment carefully and objectively, he cannot escape the conclusion that it is a sugar-coated presentation designed primarily to persuade the reader

* There has been only one case in which an adverse report has been issued. In the Bodega Head case, the acrs issued a favorable report, whereas the aec Regulatory Staff issued a negative report. The applicant, Pacific Gas and Electric Company, promptly withdrew its application.

that all is sweetness and light and that hazards are nonexistent. For ex­ample:

a. The report nowhere points out that the Indian Point No. 3 reactor has a capacity far in excess of that of any other nuclear power plant op­erable in February 1969. As of the date of the report, the largest operable privately owned nuclear power plant in the United States had a capacity of only 567 megawatts electrical. A candid safety analysis would have disclosed this fact and would have discussed the safety significance of the move toward substantially larger reactors. The trend toward larger reac­tors with higher power levels, and the problem of extrapolating from the experience with smaller reactors, have been matters of considerable con­cern to the aec for the past several years. As stated in the 1964 report of the Energy Policy Staff, Office of Science and Technology, Considerations Affecting Steam Power Plant Site Selection (S. David Freeman, a con­tributor to this volume, is director of this staff): “With the growth in size and power level of power reactors, the necessity for, and use of, en­gineered safety features has become an increasingly vital and integral con­sideration in reactor safety design and evaluation.”

b. The report states that Consolidated Edison’s environmental mon­itoring program, in operation since 1958, “has demonstrated that Indian Point Unit No. 1 has had no adverse effect on the environment.” It would be more candid to state that the monitoring program has not produced any evidence of such adverse effect.

c. The report states that the containment structure “will… re­main functional in the event of an earthquake acceleration of 0.15 g.” This is, of course, a prediction based only on untested theoretical analyses.

d. The conclusion is that discharges of radioactive effluents will be “only a small fraction” of the limits specified in Part 20 of the aec’s reg­ulations and that “calculated radiological doses” in the event of an acci­dent are “well within” the aec’s guidelines. This is an invitation to the unsophisticated reader to conclude that no adverse effects will occur. Ac­tually, even these low levels are not known to be safe.*

e. Various safety features of the reactor are discussed and given the

* In the Calvert Cliffs case, the Atomic Safety and Licensing Board suggested that under some circumstances it might be appropriate for the Board to “question the validity” of Part 20 “as establishing the outer limits of acceptable risk.” The Com­missioners thereupon issued a memorandum chastising the Board for this suggestion. The Commissioners apparent attitude that Part 20 is sacred and beyond challenge in specific cases seems strangely inconsistent with one of the provisions of Part 20 it­self, which states that requirements more stringent than those established in Part 20 may be imposed in any specific case if the aec deems such action “appropriate or necessary.” (10CFR§20.502.) staff’s blessing without any indication that they have never been tested in the crucible of experience.

f. There is no explicit recognition anywhere in the report that even minimal risks to the health and safety of the public are involved. And al­though the staff’s ultimate conclusion that there is reasonable assurance of no undue risk would clearly seem to require some finding that the risks which do exist are outweighed by benefits so as to be not “undue,” the report does not discuss benefits at all. Apparently, the entire safety analy­sis proceeds on the assumption that every nuclear power plant is per se sufficiently beneficial to outweigh risks, obviating any necessity for weigh­ing the risks of this particular plant against the benefits of this particular plant.

It is clear, I believe, that the aec regulatory staff, having concluded that there is “reasonable assurance of no undue risk,” becomes an advo­cate of that conclusion and an ally of the applicant in attempting to allay public concern and to get the nuclear power plant licensed and built. This attitude carries over into the hearing. In the uncontested hearing the appli­cant and the aec regulatory staff sing a beautifully harmonious duet. As the aec’s Regulatory Review Panel pointed out in 1965: “It has been the policy of the aec staff counsel to limit cross-examination of the applicant to clarification of those matters which have not already been resolved, with the one exception that cross-examination is normally used to bring out the fact that minimal discharges of radiation are to be expected from routine operations and to bring out some of the plant safeguards in ac­cident situations” (Report to the Atomic Energy Commission, July 14, 1965, p. 41; emphasis added).

The staff’s benevolent attitude is further evidenced by an intriguing footnote in the decision of the Atomic Safety and Licensing Board in the Malibu case. That case involved the question whether an earthquake fault at the site might result in permanent ground displacement. The record in this case included a report by the United States Geological Survey stating that the probability of permanent ground displacement in the next half century was “negligible.” The footnote indicates that this report was based on a report prepared by the Survey’s field geologists which concluded that the probability of faulting was “very low.” The field geologists’ language was changed by their supervisor to “negligible” at the suggestion of the aec regulatory staff*

* One of the field geologists who wrote the original report stated: “Negligible to me means can be neglected. We could not say that the probability of faulting could be neglected.” 2 Commerce Clearing House Atomic Energy Law Reporter, 11,248, at p. 17,459-3. In the Matter of Department of Water and Power of the City of Los Angeles (Malibu Nuclear Power Unit No. 1), З A. E.C. 122, at 124 (1966).

One effective way of placing benefits and risks in appropriate bal­ance is through the development of standards. As the Federal Radiation

Council (1960) stated to the President: “The fundamental problem in establishing radiation protection guides is to allow as much of the benefi­cial uses of ionizing radiation as possible while assuring that man is not ex­posed to undue hazard. To get a true insight into the scope of the problem and the impact of the decisions involved, a review of the benefits and the hazards is necessary.”

From the outset of the nuclear power program, we recognized the need to evaluate the degree of risk that could be accepted and the benefits that would result. It was clear that we could not go forward with nuclear power on a case-by-case basis. Instead, it became necessary to develop and adopt radiation exposure standards which would reflect the levels of acceptable risks.

The impressive record of radiological safety in the nuclear energy field is based on a system of such standards. These standards have been carefully developed over a period of many years by national and interna­tional experts, and they are based on the results of an extensive research program on radiation and its effects on man and the biosphere. These are not aec standards. Rather, they reflect a consensus of the world’s best available expertise — and this is independent expertise. They reflect the combined judgments of the Federal Radiation Council (frc), the Na­tional Academy of Sciences, the National Council on Radiation Protec­tion and Measurement (ncrp), and consultants selected for expertise in the various areas of interest. Also carefully considered are the recommen­dations of the International Commission on Radiological Protection

(iCRP).

The effectiveness of this approach brings me to my second theme — namely, that we ought to place greater emphasis on the use of standards in our approach to controlling the environmental effects of steam electric power plants. This means viewing the problems more from the standards viewpoint — giving thought to the development and improvement of ade­quate standards and criteria rather than taking an ad hoc approach to at­tacking or defending individual plants or individual hazards.