The Social Construction of Ignorance: Cochran and the Fast Reactor Canard

Thomas B. Cochran is a lobbyist employed by the Natural Resources Defense Council, to attack nuclear power on a full time basis. As befits a Lobbyist, Cochran is well compensated. In 2006 Cochran was one of the 5 highest paid employees of the NRDC, with a total compensation package approaching $200,000. In 2006 the largest single foundation donor to the the NRDF was the Energy Foundation, an environmental funding NGO, that also funds many other anti-nuclear "environmental organizations. The NRDC has been a recipient of funding from the Pro-coal Joyce Foundation, which has served as a conduit for funding of pro-coal lobbying, and propaganda activities to a number of environmental organizations. The NRDC has also been the recipient of funding from the infamous Tides Foundation, which allegedly provides sub-rosa funding services between supposedly ideologically pure organizations and environmentally tainted funders. The NRDC also receives funding by the Ted Turner foundation, a funding source controlled by natural gas baron, Ted Turner, who along with T. Boone Pickens is on of the architects of the natural gas-renewables alliance.

Cochran is a long time critic of nuclear power, whose criticism seemingly do not squarely put him in the nay sayers camp. Cochran is not as obviously a fake expert as is Amory Lovins, but there are some red flags. Cochran is a Nuclear proliferation expert and nuclear proliferation canard has been a major item in the the anti-nuclear propaganda story. Alex DeVolpi writes,

A. David Rossin, a former DOE official who had substantial nuclear-technology experience before entering government service, writes that long ago he first heard from Tom Cochran of the NRDC the term “weapons-usable.” Rossin agrees that — despite the large body of contradictory evidence — the term is often applied by “today’s nonproliferation activists” indiscriminately to “all isotopes of plutonium."

The Hoffnagles offer a category of "denialist" strategies, Impossible expectations (and moving goalposts). it is fair to ask if the nuclear proliferation argument against nuclear power is not an anti-nuclear ploy. Since Cochran testified before the DoE Blue Ribbon Commission last week, it is legitimate to ask if his testimony amounted to knowledge pollution or if it expressed a fact and science based set of rational beliefs.

Cochran's testimony before the Blue Ribbon Commission included a challenge to the legitimacy of the Commission, that the Commission was not lawfully constituted:

The Commission membership is not balanced as required by law. First, let me make that we do not question the integrity of the members of the Commission, for which we have regard, and we recognize your dedication to public service. The issue arises from the legal requirement that committees under FACA be balanced in terms of the points of view represented, and from the common-sense view that if you desire to succeed you shouldn’t begin by locking out constituencies that you need for success. This commission is not balanced and important points of view are not represented on the Commission.

This objection appears to have been proforma, and intended to lay the groundwork for a subsequent propaganda anti-nuclear campaigns against the Blue Ribbon Commission report, which is likely to make recommendations that the NRDC and its fossil fuel industry paymasters oppose. Cochran articulated the NRDC's interests, as one of fair representation,

NRDC, other NGOs and individuals with long interest and sometimes active participation in federal policy related to the management and disposal of nuclear wastes share a range of views from a position that nuclear power should compete for market share without further federal subsidies to the belief that the role of nuclear power should not be expanded due to cost, proliferation, safety and waste management considerations. Many believe further nuclear subsidies carry high opportunity costs in mitigating climate change. The views of these groups and individuals are not represented on the Commission. . . .

Cochran then cleverly set the commission up for failure by suggesting who should be represented in its membership, and what it should try to accomplish. First,

Attachment 3 is a statement of Principles for Safeguarding Waste at Reactor Site. This statement was produced and circulated long before the formation of the Blue Ribbon Commission. It is signed by representatives of some 170 national and local groups in 50 states— a very large, thoughtful constituency that are actively participating in matters now under consideration by the Commission. In NRDC’s view these groups have essentially no representation on the Commission. The DOE and the Obama administration should have been aware of this statement, the long involvement of many of these organizations in the “issues under consideration” by the Commission, and should have made sure that they were represented on the Commission just as the nuclear industry is well represented.

The Commission cannot expect to be an effective voice in solving the nuclear waste problem if it excludes representation of important constituencies from participating in its discussions and formulating its recommendations. If you expect to reform the process for managing and disposing of spent fuel and nuclear waste, you best not begin by locking out of the process important constituencies whose inclusion is needed to reach a durable consensus on future policy.

Secondly Cochran recommended goals for the commission,

The Commission should focus on getting the geologic repository program back on track. Regardless of whether U.S. nuclear capacity increases, decreases or stays approximately the same, and regardless of which nuclear fuel cycle is adopted or when, the United States needs one or more geologic repositories for the sequestering of spent fuel and high level radioactive waste for very long periods. Consequently, in our view the highest priority of the Blue Ribbon Commission is to get the repository program back on track. This should be the focus of your efforts and recommendations of your interim report. The issue of what is the preferred future fuel cycle can wait.

These two suggestions, taken together are a trap, likely to lead the Commission into failure in its assignment. The groups which Cochran recommends for inclusion in the Commission, undoubtedly include "Not in My Back Yard" (NIMBY) constituencies. The recommendation of a geologic repository program is likely to bring out NIMBY opposition in force.

Cochran then clearly joined the anti-nuclear cam by attacking the fast reactor option for closing the fuel cycle:

The wide spread use of fast reactors and a closed fuel cycle to burn selective actinides for waste management purposes has essentially no chance of succeeding within any policy time frame that is relevant to resolving either current nuclear waste storage issues or the problem of decarbonizing the U.S. electric power generation sector. Continued U.S. research and development (R&D) on advanced reprocessing will also fan global interest in plutonium separation and utilization technology and thereby increase nuclear weapons proliferation risks.

Closed fuel cycle schemes to reduce repository requirements typically require that on the order of one-third of the reactor capacity be comprised of fast reactors. The precise fraction is not important here—only to note it is a large fraction. To achieve such a balanced ratio of fast to thermal reactor capacity in the United States in the next few decades would require roughly that the next 50 gigawatts-electric (GWe) of reactor capacity built in the United States to be fast reactors, e.g., 50 fast reactors each about the average size of U.S. nuclear power reactors operational today. The Commission should acknowledge the fundamental reasons why this outcome is highly unlikely in the next few decades or for that matter in this century.
History has not been kind to fast reactors. They have cost considerably more than thermal reactors, and seem likely to stay that way, and have proven to be much less reliable than thermal reactors.

There are several acts of knowledge pollution here. First Cochran is aware that fast reactors are not the only plutonium burning option. If he is unaware of the Molten Salt Reactor actinide burning option, then his competence as a nuclear proliferation/nuclear arms control expert is open to question. In effect Cochran attempts to fines all plutonium burning breeder options by dismissing fast reactors. In doing so he ignores the potential nuclear waste disposal use of Molten Salt Reactors. Canadian Reactor Scientist, David LeBlanc has recently pointed out the developmental potential of the Denatured Molten Salt Reactor (DMSR). The DMSR could be quickly developed, because its design utilizes already mature, tested, technologies, it is highly safe, and can use any possible nuclear fuel. ORNL originally proposed the DMSR because it had outstanding proliferation prevention characteristics. These proliferation prevention features would undoubtedly undercut Cochran's objection to plutonium burning closed fuel cycle reactors, and thus would destroy his attempt to destroy the nuclear power option by setting the bar to high.

That Cochran is aware of the Molten Salt Reactor option is beyond dispute. He is a listed co-author report on the history and current developmental status of Fast Breeder Reactors, titled "Fast Breeder Reactor Programs: History and Status. " Cochran co-authored a chapter of that report which includes a discussion of the Molten Salt Reactor:

Although the highest priority was given to LMFBRs, several other types of breeders were considered, and reached various stages of development in the United States. In addition to the LMFBR, these included the gas (helium) cooled fast breeder, and two thermal-neutron reactor types, the light-water breeder reactor and the molten-salt breeder reactor (MSBR). The fast-neutron breeder reactors were designed to breed plutonium from uranium-238, while the thermal-neutron breeder designs were optimized to breed uranium-233 from thorium-232.

Perhaps the most interesting alternate concept explored in this early work was the molten-salt breeder, which still has advocates.47 In this reactor, the fuel and coolant are combined in a molten mixture of fluoride salts. The salt flows through the reactor core, through an intermediate heat exchanger, and then back to the reactor core. Molten-salt reactors were first proposed by Ed Bettis and Ray Briant of Oak Ridge National Laboratory (ORNL) during the post-World War II attempt to design a nuclear-powered aircraft.48 Two molten-salt reactors were built at ORNL. The first was a prototype aircraft reactor, the 1.5 MWt Aircraft Reactor Experiment (ARE), which operated for 100 hours in October 1954. The second, the graphite-moderated 8 MWt Molten Salt Reactor Experiment (MSRE), operated between June 1965 and December 1969, demonstrating the technical feasibility of the molten-salt breeder concept.

In 1972, ORNL proposed a major development program that would have culminated in the construction and operation of a demonstration reactor called the Molten Salt Breeder Experiment. The total program cost was estimated at $350 million over a period of 11 years.49 Those who would have had to approve the funding of the program were already heavily committed to the LMFBR, however. The ORNL proposal was rejected by the AEC partly because it wished to reduce the number of breeder candidates to be developed and because the breeding ratios projected for the molten-salt reactor were low compared to those foreseen for the fast-neutron reactors.50 In January 1973, ORNL was directed to terminate MSBR development work. The program was reinstated a year later, and in 1974 ORNL submitted a more elaborate proposal calling for approximately $720 million to be spent over an 11-year period. This proposal was also rejected, and, in 1976, ORNL was again ordered to shut down the MSBR program “for budgetary reasons.”

Thus clearly Cochran is aware of the MSBR's existence, and has some idea about its potential. Yet in his testimony before the Blue Ribbon Commission, Cochran omitted mention of the Molten Salt Reactor based closed end fuel cycle options. Given the statement on the Molten Salt Reactor which Cochran allegedly co-authored, the omission of mention of a Molten Salt Reactor closed fuel cycle option appears to have been deliberate. Cochran ignored important information, which would have given the the Blue Ribbon Commission an attractive option that would have offered a potential contribution to managing the problem of used light water reactor fuel, while also offering a potential source of low cost nuclear generated low carbon electricity. Thus even as he ignored the potentially attractive DMSR option, Cochran sought to block all use of closed end fuel cycle approaches to the LWR nuclear waste issue, by an attack on the LMFBR. This argument fails the standard, of rational fact and science based discourse.

A canard, is a story intended to distract its hearers from an important truth. Cochran's attack on fast reactors thus is a canard intended to distract the Blue Ribbon Commission from the promising solutions to the problems of current nuclear technology offered by molten salt nuclear technology. I can only conclude that Thomas Cochran engaged in deliberate acts of knowledge pollution during his testimony before the DoE's Blue Ribbon Comission on the Nuclear Future.

Blue Ribbon Commission Hearings: Makhijani and Knowledge Pollution

The so called Blue Ribbon Commission on the American Nuclear Future held two meetings on May 25 and 26. The Tuesday meeting featured Lobbyists of various strips, including a number of well known nuclear naysayers. But even the naysayers may have something to contribute. Arjun Makhijani, for example offered an account of the issues posed by used nuclear fuel in a once through fuel cycle. Makhijani, a well known nuclear naysayer, reviewed some, but by no means all of the facts, and the his selectivity was telling. Among the options which Makhijani failed to discuss, were recycling so called nuclear waste in CANDU type reactors, and using fissionable waste as LFTR start up charges. Makhijani clearly demonstrates that there is a large amount of fissionable material is still found in used nuclear fuel. Residual U-235 is about 0.68% of the total used fuel material resources, but that is already a concentration high enough to power Pressurized Heavy Water Reactors. In addition the used fuel contains about 0.99% plutonium isotopes, a majority of which are fissionable and can also be used as PHWR fuel.

In addition, while points to the fast breeder nuclear disposal option, Makhijani fails to note that in addition to LMFBR option and the the potential use of so called nuclear waste as PHWR fuel, the fissionable materials in used nuclear fuel can be used as start up charges for various types of Molten Salt Reactors.

Makhijani notes that the the existing american nuclear fleet can be expected to produce 100,000 tons of used nuclear fuel during its operational life. This would be the equivalent of 700 tons of U-235, and a 1000 tons of plutonium isotopes. Used as start up charges for LFTR one to one converters, this would potentially produce enough sustainable energy to power the entire United States economy at current high energy levels. No wonder Makhijani chose to ignore the MSR/LFTR fissionable byproducts disposal option, despite well documented proposals for Oak Ridge, and Moscow.

In addition to his neglect of promising options for the disposal of the potentially most dangerous constituents if used nuclear Makhijani vastly exaggerates the problems posed by nuclear fuel reprocessing, and the dangers posed by its consequences. For example, claims that fuel reprocessing would add one cent per kWh to electrical costs. But in fact the picture is more complex than that. In LFTR one to one converters, the cost of the start up charge is a one time expense. Once conversion begins, LFTR fuel related costs would decrease dramatically. One thousand tons of reactor grade plutonium, could potentially start LFTRs capable of producing 1000 GWs of electricity, enough to supply about 80% of American energy. Since there would be very little subsequent fuel costs given the LFTR, even Makhijani estimated 8 trillion dollar cost for processing the plutonium out of used nuclear fuel be offer quite a bargain.

A further problem with Makhijani's account is related to his claim that ~12,000 to 14,000 nuclear bombs could be constructed from spent nuclear fuel. This assumes an error that is widely voiced by nuclear critics that the plutonium found in used nuclear fuel is easily weaponizable. First, while it has been demonstrated that fuel grade plutonium can produce nuclear explosions, this is not the same thing as saying that reactor grade plutonium is weaponizable. It has been argued that heat and radiation from a RGP device would rapidly render it inoperative. A strong case can be made that it is not. in addition, even a device made from RGP would require testing.

Thus given the great expense and difficulty of plutonium extraction from used reactor fuel, which Makhijan himself outlines, the reliability problems associated with RGP weapons, and the questionable yield, even if such a weapon worked at all, would be nuclear proliferators are likely to prefer lower cost, more predictable and reliable nuclear options. South Afriuica demonstrated in the 1970's and 80's that a low cost uranium enrichment program was possible, and could lead to the development of of reliable and predictable nuclear weapons. The successful South African proliferation model, as well as those followed by Pakistan and North Korea, suggest that focus on plutonium in used nuclear fuel as a proliferation too is highly misguided. Rather than focusing on the unlikely proliferation path that plutonium isotopes in used nuclear fuel provide, proliferation prevention efforts should focus on successful proliferation paths that are already in place. if we are incapable of stopping proliferation by low cost, tested methods, it is foolish to focuse on higher cost, and far more problematic proliferation methods. The entire proliferation issue as outlined by Makhijan is nothing but a canard habitually used by the anti-nuclear lobby.

in addition to his choice to ignore several promising technologies that could potentially disposed of most or even all fissionable materials and other actinides in used nuclear fuels, Makhijan chose to downplay the potential of fast breeder reactors. He does so by ignoring fast breeder programs in Russia and india, that are very close to yielding commercial prototypes. In particular the Indians plan to bring commercial fast breeders into serial production during this decade, and similar goals are possible for Russia. The Indians plan to bring as many as 320 fast breeders online by 2050, and use their surplus fuel to power Generation III+ PHWRs. Although Makhijan is undoubtedly aware of Indian plans,he focuses instead on,

Japan’s commercialization date for sodium-cooled breeders is now2050.

And instead of focusing on promising Molten Salt Reactor technology, Makhijan suggests

If we are going to develop long-ter nuclear technologies, why not focus on nuclear fusion, which has almost none of the disadvantages of fission?

In fact one of the most promising schemes for fusion development, the so called fusion-fission hybrid, uses molten salt technology that similar to that which would be also used in the LFTR, and indeed at a significant level of investment the LFTR can be ready for serial manufacture in factories within 10 years, so it would not be even a particularly long term project.

Arjun Makhijani, despite his pose as a voice of science and reason, is thus another agent of knowledge pollution, who seeks to spread doubt and confusion about important issues.

The Blue Ribbon Commission has its work cut out for it, if it is to get past the Knowledge polluters.

Carnival of Nuclear Energy 3 returns to Next Big Future

Brian Wang has posted the Third Carnival of Nuclear Energy on Nexr Big Future, after the Carnival's visit to Nuclear Green last week. This Carnival features a sampling of posts from Dan Yurman's Idaho Samizdat, Barry Brool's BraveNewClimate, Meredith Angwin of Yes Vermont Yankee. Rod Adams of Atomic Insight, NEI's Nuclear Notes and Brian himself.

The Social Construction of Ignorance: Amory Lovins and Energy

My definition would be a real expert is someone with a thorough understanding of the field they are discussing, who accurately represents the scientific literature and the state of understanding of the scientific enterprise. - Denialism Blog

The question of who is an expert is a central one in the problem of knowledge pollution. Very often knowledge pollution occurs because fake experts are given credibility by the mainstream media and by people who should know better.

The Denialism Blog also quotes the Oxford English Language Dictionary.

One whose special knowledge or skill causes him to be regarded as an authority; a specialist. Also attrib., as in expert evidence, witness, etc.

The Denialism blog also references Federal Judicial rules of evidence and other determinants of expert status within a Court Room setting,

Luckily the justices didn't just leave it at the federal rules of evidence and Blackmun created a set of guidelines for judges to determine if the expert was "reliable". They require the theory presented by the witness to have undergone peer review, show falsifiability, empirical testing, reproducibility, and a known error rate for a scientific theory to have some validity in addition to the general acceptance rule of Frye. While the individual states remain a patchwork of Frye, Daubert, and Frye-plus rules for admissibility of evidence, at least federally this is the new requirement (although it still does suffer from being a bit vague).

The experts that present such evidence must have some credentials and/or experience with the discipline, and the evidence they present must pass these tests. It's actually not a half-bad way to identify a trusted source, in particular if the judge is intellectually honest about the witness meeting these requirements.

The Denialism Blog also points to the work of philosopher and physical chemist Janet D. Stemwedel on evaluating the credibility of scientists, and the scope and limitations of scientific expertise. Beyond the scope of the the Denialism Blog and Stemwedel's discussion of scientific credibility and expertise limitations, a retired nuclear physicist who represented the United States as a technical expert, in nuclear arms reduction verification talks with the Soviet Union, Alexander DeVolpe offers discussions of fake expertise on the topic of nuclear proliferation.

While DeVolpi makes significant contributions to answering the question, "who is an expert on nuclear proliferation," I am going to focus on a single figure who DeVolpi has singled out for criticism as a fake expert on nuclear proliferation and nuclear energy. That fake expert is anti-nuclear expert par-excelente, Amory Lovins, who DeVolpi charges engages in a charade of expertese on nuclear matters. DeVolpi

applies qualitative tests to Lovins’ 1980 predictions about (1) nuclear-power’s demise, (2) weapons-proliferation propensity, and (3) plutonium-demilitarization utility. NONE of his predictions have come to pass. His most egregious flaw is total lack of statistical context; his papers fail scientific-publication standards. Lovins has been so indifferent to scientific methodology that he should not be accorded credibility. While still adamant about nuclear power’s demise and proliferation risk, he now concedes that commercial reactors effectively demilitarize weapons materials.

DeVolpe's discussion of Lovins Charade of nuclear expertese meets the the Denialism Blog's definition of fake expertise,

a fake expert is usually somebody who is relied upon for their credentials rather than any real experience in the field at issue, who will promote arguments that are inconsistent with the literature, aren't generally accepted by those who study the field in question, and/or whose theories aren't consistent with established epistemological requirements for scientific inquiry.

It should be pointed out that Lovins has never answered DeVolpe's critique of his expertise, but then Lovens has failed to respond to many accusations regarding lapses in his expert facade. Robert Bryce and David Bradish have offered critiques of Lovins' pretended anti-nuclear expertise, and indeed his pose as an energy expert. Despite promises of comprehensive answers to the charges Bryce and Bradish made against his claim to expertise, Lovins has never responded to Bryce, and abandoned his attempt at self-defense against Bradish charges. Indeed both Bryce and Bradish, along with energy writers Vaclav Smil, Peter Huber and Mark Mills, raise fundamental doubts about Lovins claim to expertise on all energ matters. Bobert Bryce asked Smill,

In your writings, you point out how many times Amory Lovins, the energy efficiency advocate who heads the Rocky Mountain Institute, has been wrong in his predictions regarding the adoption of renewable energy. I laughed out loud when I read your line, “Inexplicably, Lovins retains his guru aura no matter how wrong he is.” Why has Lovins been wrong so often? And why does he continue to get so much fawning press coverage?

To which Smill responded

mory has become a celebrity after wholesaling his fairy-tale of “soft” decentralized small-scale energies as THE solution (with its deep countercultural, Berkeleyish appeal), and it is the first law of celebrity-hood that, right or wrong, coherent or not, you retain the status. Combine that with the just-noted mass scientific ignorance of the population and with Amory’s sleek offerings of no-pain solutions (nothing will cost anything, or as he famously put it, “abating climate change for fun and profit”) and you have new believers signing up every time he speaks. By the way, by this time we all should have been driving nothing but Lovinsian hypercars (something like 200 mpg, made like new Boeing 787s solely from carbon composites) whose conceptual design he launched more than a decade ago; have you seen any?

Bryce notes that common and largely unanswered charges made by Lovins critics include foure Lovin's claims made that have proven to be in error, Those claims are,

1. Renewables will take huge swaths of the overall energy market. (1976)
2. Electricity consumption will fall. (1984)
3. Cellulosic ethanol will solve our oil import needs. (repeatedly)
4. Efficiency will lower consumption. (repeatedly)

The first claim comes with an illustration that clearly illustrates the failure of the first Lovins' prediction. This graph shows Lovins's forecast that "soft technologies" would 50% of all energy in 2010, while natural gas and could produce a declining percentage of energy, while energy use is declining through greater efficiency. Lovens has never acknowledged the extent of his erroneous predictions, or offered an explanation of his past forecasting mistakes. Alexander DeVolpi observed,

None of Lovin’s predictions have come to pass. That’s startling in itself, except that he keeps shifting to new topics, dropping the worn out ones. He’s still flailing nuclear power, but 30 years later it keeps on going. He’s still faulting its proliferation propensity, but not a single instance can be found in 30 years. Only by the processes of uncovering omissions or directing inquiry can one find that he now realizes that commercial reactors can effectively demilitarize weapons materials, a position he adamantly and eloquently opposed for the past 30 years.
Since there are no assigned traffic cops in this business, it is left up to some of us volunteers to try to straighten things out. Nevertheless, Lovins has a strong reserve of believers for his soft-energy goals. I too share some of that optimism, but not at the sacrifice of quantitative evaluation and humble context for alternatives. However, when his enthusiasm spills over into matters of which he has no expertise — trained or acquired — everyone should be wary.

In fact the increase in energy efficiency, although real over time, has not displaced carbon-emitting technology to anything like the extent which Lovins foresaw. One of the major problems with Lovins forecast of efficiency related declines in energy use is his ignorance of Jevons Paradox. David Bradish offered a discussion of Lovins errors with respect to Javons Paradox. In the second Gristmill response to Bradish, Lovins wrote

Mr. Bradish has posted part three of his critique, claiming that RMI has overlooked Jevons Paradox, which undoes and reverses the intended energy savings from more efficient end-use. We have rebutted this invalid claim in a response to Mr. Bradish's cited primary source -- an article by Robert Bryce in his newsletter. Completion of our response was delayed by travel, but we expect to finish it shortly, and will then post it on RMI's website, in this blog, and (Mr. Bryce has assured us) on his site.

In fact the case against Lovins as an energy expert is much stronger than DeVolpi is aware. Lovins' promised response to Bryce and Bradish has never appeared.

It would thus appear that Amory Lovins is both a fake expert on nuclear power and on energy issues in general. Lovins' accounts of nuclear energy and other energy related matters must be regarded as disinformation, and is a grand source of knowledge pollution. Amory Lovins is a discredited fake expert, but word of how discredited he is has not reached the mainstream media or energy decision makers. People would like to believe that what Lovins says is true, and key political decision makers as well the media look to Lovins to reassure them about difficult energy matters. Yet among energy experts, Lovins must be considered among the living dead, one who can offer no legitimate claim to expertise, who has no credibility. Lovins is to energy expertise what Zombie are to living human beings.

The Social Construction of Ignorance: Knowledge Pollution and Nuclear Power

In the first essay in this series, I focused on a complaint by Stephen Gloor, that Rod Adams has engaged in a form of denialism in his advocacy of nuclear power. Gloor failed to demonstrate his case against Adams with actual quotations, and instead rested his argument on a series of unproven charges. I agued that not only were Gloor's charges unproven, but that there is ample evidence in Adams writings that they are completely false. Indeed it would appear that Gloor's charges against Adams had an ironic aspect.

In the second essay of this series, I suggested that "denialism" is a form of knowledge pollution, and pointed to the writings of the Hoofnagel brothers and Kenneth Boulding for a better understanding of what constitutes knowledge or information pollution.

In his essay, The Pollution of Information, Kenneth Boulding offers what my be described as a brief attempt at a phenomenology of knowledge pollution. Kenneth Boulding notes that

we can speak of information pollution when the information system produces images of the world which are unrealistic in the sense that they do not correspond to some external reality.

He adds

information is polluted when people tell lies or when error is perpetuated.

In addition Boulding points to another form of knowledge pollution

what might be described as ignorance, when we do not know things which would get us out of trouble if we did know them.

Boulding points out three cases examples of the production of knowledge pollution: The first is to be found in the operation or rather the dysfunction of the price system.

The

second source of information pollution results from the development of large scale organizations and the inevitable hierarchy which results. A hierarchy pollutes information, again because of a kind of distortion of the payoffs. A person rises in a hierarchy by pleasing his superior. He frequently pleases his superior by telling him what that superior wants to hear. Even at the subconscious level, therefore, there is a constant tendency for hierarchy to corrupt communications, and for necessary information to be filtered out before it reaches the top decision makers. The bigger the organization, the more likely are its top decision makers to be living in a wholly imaginary world.

Despite its disfunction,

The market, interestingly enough, even though as we have seen it has its own problems of information pollution, is itself a certain safeguard against hierarchy, simply because it permits the coordination of many different organizations without hierarchical control.

A third source of information pollution originates from

the problem of saliency. All human beings suffer from some kind of information overload, and under these circumstances it is the dramatic and salient information which breaks through the barriers that we all set up against information input. Hence our images of the world are perverted in the direction of the dramatic and away from those things which happen to be true and important but are not dramatic.

Bouldomh adds,

The only remedy for this form of information pollution is social science, and indeed the whole scientific revolution depends essentially on the development of techniques of sampling and testing which are designed to purify the information streams from error. Science is a kind of sewage plant of the information system, oxidizing error into harmless gas and returning a purer flow of information back into society.

Given that Boulding himself seems to acknowledge the inadequacies of Boulding's account of information pollution, I am going to attempt to suggest a relationship from the Hoofnagles' account of "denialism" and Bouldings of information pollution. First "denialism" attempts to use the effects of information overload, to prevent effective social responses to bad news, that suggests that business as usual may not be in order.. This is is obviously the case for the with the by now well documented disinformation campaign of the tobacco lobby. Exxon Mobil deliberately decided to emulate the tobacco lobby's disinformation campaign in order to spread doubt about Anthropogenic Global Warming, The point of such campaigns is to protect the marketing of products that carry a high social cost, that is not reflected in the market cost.

"Denialist" campaigns do not succeed in a vacuum. Smoking is extremely addictive behavior, and as the Bill Wilson and company long ago taught us, denial is a useful tool in avoiding the difficult decision to give up an addictive behavior. The Tobacco Lobby was able to fend off efforts to transfer some of the social costs of smoking to the market cost of cigarettes for a long time. In the case of fossil fuels, the fossil fuel lobbies have so far successfully avoided including the cost of carbon mitigation in the market cost of fossil fuels. Our current way of life is dependent on fossil fuels, and the notion that we are doing serious damage to the climate by greenhouse gas emissions, suggests that large, and even unfathomable changes will occur in our lives during the near future. The potential immensity of the change, and our potential for loose are something we would prefer to not think about. We really don't want to change. Thus the denialist campaign against the AGW concept strikes a responsive cord in the minds of many people who are comfortable with a way of life in which fossil fuels play a prominent role. My name is Charles B., and I am addicted to a way of life that requires the burning of an immense amount of coal, oil, and natural gas.

Denialism is not always motivated by market consideration. For example, the belief of a former President of South Africa, that AIDS was not caused by the the HIV virus. The issue here is that if people acknowledged the relationship, they would be forced to give up or modify certain sexual practices. The issue of behavior change thus lies at the heart of the denial of a AIDS-HIV relationship

The controversy over evolution would seem to involve beliefs, rather than behavior. But in this case, there is a behavioural component, that has to do with the distribution of authority in certain religious communities, and the boundaries of religious and secular knowledge. Fundamentalist preachers question evolution because their most cherished doctrine, the tithe, does not seem connected to the survival of the species. Ironically, the Tithe itself evolved in Judaism, and later Christianity.

If opposition to nuclear power is a form of denialism, what is it exactly that is being denied? Nuclear critics rest their cases on several arguments.

* Nuclear power is unsafe

* The problem of nuclear waste is a huge problem that threatens the future survival of people and indeed all life on earth.

* There is no known solution to the problem of nuclear waste.

* Nuclear power leads inevitably to the proliferation of nuclear weapons. Nothing short of outlawing the use of nuclear power can prevent inevitable nuclear wars.

* Unlike renewable electrical generation sources, nuclear power is hugely expensive.

* It takes too long to build nuclear plants. We can never mitigate AGW in time if we choose to use nuclear power.

What we find in every case of denialism we have looked at, the denialist rejects information that is the consensus of scientists. If we thus find that these views of nuclear critics contradict the conclusion of scientists, then we can begin making the case that the anti-nuclear stance is a form of denialism. I will next attempt to review the relationship between the scientific views on the issues raised by nuclear critics.

The social construction of ignorance: Manufacturing doubts

Are critics of nuclear power engaged in "Denialism? "

When nuclear critic Stephen Gloor accused nuclear supporter Rod Adams of "Nuclear Denialism" he included a list of six characteristics of denialism:

1. Allege that there's a conspiracy. Claim that scientific consensus has arisen through collusion rather than the accumulation of evidence.
2. Use fake experts to support your story. "Denial always starts with a cadre of pseudo-experts with some credentials that create a facade of credibility," says Seth Kalichman of the University of Connecticut.
3. Cherry-pick the evidence: trumpet whatever appears to support your case and ignore or rubbish the rest. Carry on trotting out supportive evidence even after it has been discredited.
4. Create impossible standards for your opponents. Claim that the existing evidence is not good enough and demand more. If your opponent comes up with evidence you have demanded, move the goalposts.
5. Use logical fallacies. Hitler opposed smoking, so anti-smoking measures are Nazi. Deliberately misrepresent the scientific consensus and then knock down your straw man.
6. Manufacture doubt. Falsely portray scientists as so divided that basing policy on their advice would be premature. Insist "both sides" must be heard and cry censorship when "dissenting" arguments or experts are rejected.

I am not particularly fond of the term "denialism," which refers to a set of related but not entirely identical problems. The problems are real, and centers on the problem of truth, and in particular truth as it relates to science. Most of the cases of "denialism" involve denial of the consensus findings of scientists. in the case of holocaust denial, the denial is of the consensus of historians, not of scientists, but otherwise the phenomena seems closely related.

The word denial itself, draws on the context of the Freudian theory of psychological defenses, and has been popularized by both the 12-Step movement and the work of Elizabeth Kubler-Ross on grief. Denial is usually taken to be something that the psychic does to prevent the processing of information, but in his book "The Image" the philosopher Kenneth Boulding laid out an account of human processing of new information. New information that is likely to change thinking is not instantly processed. Indeed, Burke argued, if the new information conflicts with existing beliefs, it may be at first, simply ignored. Later the information may be acknowledged as an exception to one's world view, which is maintained. If the information continues to require attention, then one's world view may be altered to account for it. Finally, if the attempt to alter the world view fails, a new world view may replace it. Thus assimilating new information is a cognitive process, that may run through several stages. The term denial thus may obscure the fact that a person or group of people said to be in denial are in fact in an intermediate stage of processing new information.

My problem with the term "denialism" is that it does not distinguish between a confused, complex and often prolonged process of cognitive change through which people change the structure of their knowledge, and deliberate attempts to obstruct the processing of scientific or other rationally constructed information. Kenneth Boulding calls this information pollution. I much prefer the term information polluters, to denialists. I will however, forego for the moment an attempt to sort through the issues involved, and will use the term "denialism," despite my reservations..

"Denialism" is thew topic of increasing study, and the contributions of Dr. Mark Hoofnagle, a surgeon nd his brother Chris Jay Hoofnagle, a lawyer, are almost always noted in accounts of "Denialism "research. The Hoofnagle's are representative 21st knowledge workers, they blog.

And indeed Gloor's list of denialist characteristics is largely derived from the Hoofnagle blog. There is,, however, on discrepancy. The Hoffnagle's do not count Gloor's number 6 (manufacture of doubt) as a separate characteristic of denialists. Rather the manufacture of doubt is the goal of the denialists tactics.

My initial response to Stephen Gloor's list was to find it highly ironic, because Gloor himself, and his anti-nuclear associates can be accused of pursuing denialist tactics against nuclear power. I would like to pursue during several more posts the notion that opposition to nuclear power almost always involves information pollution that resembles what the Hoofnageles call denialism.

Bellefonte-1 Moving Forward

Both WBIR TV, the Knoxville News Sentinal and Dan Yurman of Idaho Samizdat are all reporting, based on a newly released Environmental impact statement that TVA is moving toward a decision to complete the long delayed Bellefonte-1 nuclear unit.

TVA plans to complete work on its Watts Bar Unit 2 nuclear plant in 2013, and it is quite likely that construction of the Bellefonte-1 unit will not be long delayed after than. Realistic estimates peg the construction of Bellefonte-1 as being about 55% complete, with completion requiring about $3.5 more billion. It would not be surprising if the Bellefonte design is somewhat revised and its power output increased before renewed construction begins. Progress appears to be made in Korean evaluation of annular nuclear fuel, with up rates of 17.55% percent being reported, without major core redesign. Up rates of as much as 50% appear possible with core redesign. It appears that a major reconstruction of the Bellefonte core and other components will be required, so the movement to 50% annular fuel based up rate will probably be more than cost effective.

The Social Construction of Ignorance: Gloor and Adams

Social constructionism is a notion advanced by some sociologists that all human beliefs, including the beliefs of scientists, can be explained by reference to social context. Thus facts are nothing more than statements of things people have a agreed to believe. Thus at the bottom all knowledge has an irrational basis.

I find the constructionist view of science to be unsatisfactory, because it does not explain everything that needs to be explained about the power of science to change human society. At the same time the constructionist view helps to explain a lot about attempts to create doubt about views supported by well grounded scientific research.

During an exchange of comments that followed a cross posting on The Energy Collective, of my recent post, Was the Advent of the Power Reactor Premature,nuclear power critic, Stephen Gloor stated to Rod Adams

In you case you are a nuclear denier. Completely and steadfastly refusing to believe that nuclear power is incredibly expensive, cannot be rolled out fast enough to even scratch the surface of climate change, produces toxic waste that must be cleaned up by others and acts as a convenient cover for weapons making.

Gloor then went on to quote as essay by Pascal Diethelm1 and Martin McKee, titled "Denialism: what is it and how should scientists respond?"

First, let me deal with Stephen Gloor's charges against Adams. Gloor has a tendency to attribute mistakes to people who he disagrees with without documenting examples of the mistakes. In at least some cases the people involved may in fact appear to believe exactly the opposite of what Gloor says they do. Gloor alleges that Adams is

[c]ompletely and steadfastly refusing to believe that nuclear power is incredibly expensive,

Gloor ignores the fact that Adams repeatedly has discussed nuclear costs on his blog. Gloor may not agree with with what Adams says, but given the facts it is unfair to say that Adams is in denial about nuclear costs. Gloor also ignores something that has been repeatedly pointed out to him, namely that the Energy Information Administration has reported that nuclear power is less expensive per kWh than land based wind generation, Sea based wind power, solar thermal power, and photovoltaic power. When the cost of technology designed to deal with the problems of renewable intermittency and its lack of dispatch capacity is included in the cost of renewable energy, nuclear power is far less expensive than renewables.

Rod Adams was one of the pioneers of the idea lowering nuclear costs by factory construction of reactors. In 1996 Adams wrote,

one must realize that the curve is reset to a new value when a new product is introduced and that there must be competition in order to keep firms focused on lowering unit costs and unit prices. In the nuclear industry, new products in the form of bigger and bigger plants continuously were introduced, and, after the dramatic rise in the cost of fossil fuel during the 1970s, there was little competitive benefit in striving for cost reduction during plant construction.

When picking the proper size of a particular product, the experience curve should lead one to understand that high volume products will eventually cost less per unit output than low volume products and that large products inherently will have a lower volume than significantly smaller products.

Gloor claims that Adams is gnores the fact that nuclear power

cannot be rolled out fast enough to even scratch the surface of climate change, . . .

Yet Adams 14 year old proposal to build small easily transported reactors in factories offers rapid scalability of nuclear power with a potential to lower nuclear costs.

Thus far from being in denial about nuclear costs and scalibility, Rod Adams was already addressing the problem 14 years ago.

Gloor accuses Adams of denying the fact that nuclear power

produces toxic waste that must be cleaned up by others

In fact Adams has repeatedly discussed the so called nuclear waste issue, as recently as this month.

Finally Gloor accuses Adams of denying that

toxic waste that must be cleaned up by others and acts as a convenient cover for weapons making.

But John Hogan in a recent Scientific American blog post, noted that not only had Adams acknowledged proliferation concerns, but that Adams had told him that

The spread of nuclear power need not lead to nuclear weapons proliferation. Many countries that have nuclear power plants do not possess weapons. And almost every country that has nuclear weapons today acquired them before acquiring nuclear reactors. (Some commenters on Adams's blog have pointed out that India is an exception to this rule.) More importantly, nuclear power can promote peace by making nations less reliant on outside sources for energy. "You can write the history of world conflicts over the past 100 years as a battle over resources," Adams said.

Clearly then Gloor's claim that Rod Adams is in some sort of denial about nuclear power is unfounded in reality. Rod is not always right about every nuclear related issue, at least about those issues about which we have a disagreement, but Rod is a member of the reality based community. Rod can be counted on to engage in the judicious determination of facts. If there were examples of denial in the Energy Collective discussion, Adams was not the person who had provided them.

Gloor is, on the other hand, not a reliable source of information regarding the views of people with whom he disagrees.

The MSR, LMFBR decision: Reason and Science Take a Back Seat

Nuclear Green has in the past offered sketches of the early history of reactor design. The classic reactor design was created by Enrico Fermi, and featured a solid core. Fermi was a physicist, and in a way designed his first reactor as a physics experiment. From the view point of process, materials were placed in the nuclear core and then mechanically removed. What happened to the materials after their removal was not a part of the physicists business. There is no doubt that Fermi was the god father of the Sodium cooled fast breeder reactor. The late World War II Manhattan Project New Piles Committee, of which Fermi was a member discussed breeder options.

The World War II Metallurgy Lab of the University of Chicago was the nursery for both Argonne National Laboratory and Oak Ridge National Laboratory. Argonne basically was formed from Fermi's staff, and was lead by a long time Fermi protegee, Walter Zinn. As early as 1944, Fermi who was convinced of the importance of the breeder reactor project as a future source of energy, suggested to Zinn that he and his subordinates begin to develop sodium cooled breeder reactor technology. Alvin Weinberg described Zinn as the

gray eminence of nuclear development.

Argonne National Laboratory under Zinn was originally intended to be the center of national reactor design, although ORNL was to emerge as its rival during the 1950's. Weinberg notes,

WALTER (“WALLY”) HENRY ZINN was Enrico Fermi’s close associate during the Manhattan Project. After World War II he became the leading U.S. figure in the earliest development of nuclear energy. So pervasive was his stamp on nuclear development that a proper obituary to Walter Zinn must be nothing short of an account of the origins of nuclear energy and how Zinn profoundly affected its development.

Weinberg who was himself an important figure in the history of nuclear developments thus points out the importance of Zinn's role. While Weinberg was responsible for the suggestion to Hyman Rickover that the Light Water Reactor would prove more suitable for submarine propulsion than a sodium cooled reactor would, it was to Argonne and its director, Walter Zinn that Rickover turned to superintend its development. Zinn had a Rickover size ego, and when Rickover tried to control the Argonne group managing submarine reactor development. Zinn through Rickover out of Argonne, and Rickover retaliated by moving the submarine reactor project to Bettis Laboratory, controlled by Westinghouse.

Zinn was to leave Argonne in 1956 after pushing through the Experimental Breeder Reactor-1 (EBR-1) project. Zinn's departure from Argonne followed a serious accident with the EBR-1 and Zinn's future focus was on Light Water Reactors. Argon researchers continued to investigate liquid metal breeder technology.

Thus the initial prestige of the fast breeder concept was to rest primarily on Fermi's shoulders, with Walter Zinn playing an important role. Yet the Fast Breeder was problematic from the start. A report issued by Sandia Laboratory in 2007 focused on Liquid Metal Fast Breeder sodium related safety issues/ the report notes numerous safety hazards for Sodium cooled reactors. Among notable sodium related safety hazards are sodium fires, and the positive void coefficient reactivity hazard of sodium cooled reactors. Sodium firers can be caused by sodium contact with

* air
* water
* and concrete

The Sandia Report focuses on the void problem

A fundamental difference between water and sodium-cooled reactors is the void reactivity coefficient. If the water around the core is voided (boiled, drained) in a water-cooled (thermal) reactor during operation, the power level will automatically drop. The reactor is therefore said to have a negative void reactivity coefficient. In contrast, if sodium is voided in certain sodium-cooled fast reactors (particularly large reactors), it will cause the power level of the reactor to rapidly increase. This reactor is said to have a positive void reactivity coefficient. When the reactor power increases, it can lead to additional boiling and voiding until fuel melts. This positive feedback can lead to extremely rapid surges in reactor power, potentially damaging or melting fuel and cladding.

Multiple events can lead to core voiding during operation, and great care is taken in the proposed new reactors to ensure that these events are prevented. They include sodium boiling, loss of coolant accidents (LOCA), and gas bubble entrainment within the sodium. Sodium fires could lead to sodium boiling if an undercooling event is initiated without scram (reactor shutdown). A severe leak in the secondary system, perhaps coupled with cable fires could lead to this situation. A large leak in the primary system could also disrupt flow enough to induce sodium boiling in the core. A sodium leak in the primary system could also lead to either a LOCA or gas bubble entrainment event. A large primary leak could potentially uncover a portion of the core. If gas is pulled back into a leak in the primary system, the resulting bubbles could also reach the core.

Many of the problems of sodium cooled reactors were still unknown to Ed Bettis and his associates in 1947 when K-25 Physicist Cecil Ellis assigned them the task of developing a sodium cooled reactor for a nuclear powered aircraft. But as Ed Bettis later explained even then enough was known to understand that a sodium cooled reactor would be difficult to control as well as potentially dangerous.

There were significan problems with sodium cooled reactors, as Ed Bettis was to later explain:

By 1950, at various places in the country, work had progressed on the handling of high- temperature sodium metal to the point that it was being seriously considered as a coolant for nuclear reactors. Accordingly, a group of engineers and physicists at ORNL started design work on a solid-fuel-pin sodium-cooled reactor, with the fuel consisting of 235U (as UO2) canned in stainless steel. It was decided to make this a thermal reactor and to use BeO blocks as the moderator. The circulating sodium was to extract heat from the fuel pins and at the same time to remove heat from the moderator blocks. . . .

The solid-fuel-pin thermal reactor design was found to possess a serious difficulty when the design concept was projected to cover a relatively high-power reactor. The problem was the positive temperature coefficient of reactivity associated with the cross section of xenon at elevated temperatures.. . .

Th Xenon problem was serious enough to foce Bettis and his associates to look at an alternative.

This xenon instability was considered to be serious enough to warrant abandoning the solid-fuel design concept, because of the exacting requirement placed on any automatic control system by this instability.

But what sort of alternative reactor would solve the Xenon issue?

An obvious way to avoid the control problem would be to incorporate a liquid fuel that would have a large density change for a given change in temperature. If, upon heating and expanding, a portion of the fuel could, in effect, be made to leave the critical lattice, a self- stabilizing reactor would result.

Bingo! Ed bettis and his associates had discovered one of several MSR advantages, its self stabilization.

In 1950 the K-25 aircraft nuclear propulsion program was turned over to Fairchild Aircraft. which decided to move it to Ohio. The program staff was given a choice of following the program to Ohio, or to remain in Oak Ridge, where a new nuclear powered aircraft program was to emerge superintended by ORNL. A Brilliant Chemist, Raymond Clair Briant was to be the new Program manager, and Bettis approached Briant about the Molten Salt Reactor concept, and so the ORNL Molten Salt Reactor adventure was born.

In an often noted 1957 paper, "Molten Fluorides as Power Reactor Fuels"Alvin Weinberg proposed the construction of a liquid fluoride salts based thermal breeder reactor. The very concept than Weinberg announced was revolutionary. In 1959 the AEC commissioned an evaluation of three potential fluid fuel reactor technologies capable of breeding. They were"

* Aqueous Homogeneous Reactors

* A Liquid Metal Fast Breeder with a slurry rather than a solid fuel core

* The Molten Salt Breeder Reactor

Of the three the committee commissioned to write the report concluded that the MSR represented the smallest developmental challenge. Unfortunately the AEC did not also commission a direct comparison between the MSR and the standard Liquid Metal Fast Breeder Reactor. Had they done so they would have found that the Molten Salt Reactor was a far more practical reactor concept than the Liquid Metal Fast Breeder Reactor. This statement can be tested by comparing the developmental problems of the two MSR prototypes with the developmental histories of the early liquid sodium cooled breeders. While both MSR's performed as expected, with no major accidents this was not the case with early sodium cooled fast breeders. Compared to the Molten Salt Reactor, the LMFBR faced daunting and expensive to fix safety challenges. A list of major LMR accidents will be sufficient to make this point.

* The EBR-1 suffered a partial core melt down in 1955.

* The Fermi 1 suffered a partial core meltdown in 1966

* The Sodium Reactor Experiment suffered a partial core meltdown in 1959

In addition to these major accidents, LMFBRs have suffered numerous lessor accidents including sodium leaks with fires, and fuel cladding ruptures. I am not going to argue that these accidents mean that LMFBR are unsafe, or that safety progress has not been made in LMFBR design. Rather my point is that the MSR posed far fewer safety challenges than the LMFBR did in 1959, and a direct comparison of the two breeder technologies would have revealed this fact.

But safety was hardly the only area in which the MSR held advantages. In terms of materials problems, ORNL was able to come up with solutions quickly once problems were known. Thus in the early 1960's ORNL possessed a potential breeder technology that was safer than the more conventional LMFB and a technology that was likely to pose far fewer developmental challenges. There is evidence that the AEC was interested in the development of MSR technology. But that began to change with the arrival of LMFBR fan Glenn Seaborg as AEC Chairman, Milton Shaw, another LMFBR supporter, as AEC reactor Czar, and with the emergence of another LMFBR supporter, Congressman Chet Holifield, as a controlling influence over AEC policy. None of these people people would have favored a point by point comparison of the prospects of LMFBR and MSR technology. The decision to favor the LMFBR was thus political, and was not based, nor was it justifiable, on scientific or rational grounds.

Blog Carnival of Nuclear Energy Number Two

Welcome to the second Blog Carnival of Nuclear Energy, and special thanks to Brian Wang for hosting the first carnival, as well as getting the ball rolling for this one. The Carnival is a traveling show that will cover nuclear and other energy related blog posts. Topics covered will include reactors present and future, nuclear fuels and fuel cycles, environmental impacts, policy and more. Bloggers who write on nuclear, and nuclear related topics are invited to join the the carnival. in addition interested bloggers can participate in the blog carnival by hosting it from time to time.

Our first post is nearly three months old. It comes Gail Marcus' "Nuclear Power Talk" blog and is a brief memorial for Thomas Pigford. I have publishe two previously unposted Pigford related stories on Nuclear Green for anyone who would like to get a better idea who Pigford was. Marcus wrote:

Dr. Thomas H. Pigford, another icon in the story of nuclear power development, died this past week. Dr. Pigford is well known to many in the nuclear profession for his long and productive career, and for the number of important and lasting contributions he made to the nuclear field.

2. Yes Vermont Yankee blogger Meredith Angwin considers the difference between the Vermont picture of nuclear power and the picture which prevails in much of the world outside Vermont in a post titled Vermont and World Nuclear.

In Vermont, it becomes very easy to think that the whole world is anti-nuclear energy. Except for the people in Vernon who work at the plant, of course. The anti-nukes make a lot of noise, some of it not very rational. Senator Shumlin asserts we have abundant solar resources in Vermont (making me wonder whether he lives here). The same old crowd in Brattleboro keeps making the same old shut-it-down statements. And so forth.

3. Nuclear Fissionary's Jack Gamble offers Antinucler Spin Machine Exploiting Fossil Fuel Disasters This story discusses how the crazy anti-nuclear disinformation campaign twists the facts of fossil fuel related accidents to tar nuclear power with the same brush.

The antinuclear activists smell oil blood in the water and want you to beleive that oil spills, coal mine collapses, and natural gas explosions are reasons to avoid nuclear power. Luckily, raitonal people know that the Fossil Fuel Meltdown of 2010 is further proof that a revival of nuclear energy is long overdue.

4. Kirk Sorensen, on Energy From Thorium posted Dr. Alexander Cannara's deconstruction of
“Thorium Fuel: No Panacea for Nuclear Power”, by anti-nuclear disinformation specialists Arjan Makhijani & Michele Boyd. Caerara wrote Physicians for Social Responsibility:

Taking encouragement from your (PSR’s) website’s promise: “We encourage the submission of any comments…”, I’m writing you in hopes you’ll correct errors in a particular paper you’ve apparently promulgated to many interest groups like NIRS/IEER, worldwide, resulting in misleading them and our fellow Americans on an extremely important issue. As doctors give oath “to do no harm”, scientists & engineers too work under an implied oath to serve the needs of humanity, and to do so honestly & completely. The PSR/IEER ‘Fact Sheet’ you’ve unfortunately published fails that test. It lacks completeness, accuracy and so, responsibility. . . .

I’ll begin at the heart of the inaccuracy and misleading nature of the piece – it considers only solid nuclear fuels. As a result, it achieves three major failings: 1) it displays the authors as unaware of nuclear-reactor designs that are indeed safer than present LWR/BWR solid-fuelled systems; 2) it suggests PSR and/or IEER don’t have proper review procedures; and 3) it illustrates the danger of bias in content that gives the appearance of motivation to mislead readers.

None of the above are excusable, especially not for any organizations using the words “Responsible“ or “Resource Service” in their names. In other words, the result of the report’s failings is to mark it as an example of exactly the kind of misleading document we need less of today and in the future. Perhaps it’s served as a lobbying tool, but we have far too much of that everywhere today, as well. So, in the interest of responsibility to our fellow citizens across the globe, here are comments you say you “encourage”:

5. I have been aware for some time that the National Renewable Energy Laboratory appeared to be cooperating with the Wind Industry Lobby to the extent that the NREL could be described as an adjunct of the AWEA. "Uvdiv"of Capacity Factor recently posted a investigative report, FOIE email: NREL collaborated with the AWEA - The US wind industry lobby - in writing a government report controverting a wind industry critic.

6. Australian Climate Scientist and pro nuclear blogger Barry Brook of Brave New Climate, recently coauthored a short book, Why vs. Why: Nuclear Power. Professor Ian Lowe took the anti nuclear position. In a blog post, Why vs Why: Nuclear Power – new book by BNC author, Barry discusses the book and its launch. in Counterpoint ABC radio debate – Does being green mean going nuclear? Barry describes his debate with Professor Lowe on Australian Radio.

7. Nuclear Archer is offering posts on Generation IV nuclear materials, including one on "ferritic and austenitic stainless steel." The Archer tells us,

The austenitic steels are often used for higher temperature applications because they can withstand a hot, corrosive environment and maintain mechanical properties to somewhat higher temperatures than the ferritic grades. Both are used in large amounts in different parts of a modern, GenII light-water reactor. A Gen II reactor, or even the Gen III / III+ ones under construction, will see outlet temperatures in the low-300s Celsius. The GenIV concepts will push as far as 1000°C, and the current crop of materials would turn buttery there. The austenitic alloys show better resistance to creep at high temperature than the ferritics, but under neutron bombardment they also suffer void swelling which can compromise their mechanical strength.

8. The most discussed blogger on the Energy Collective at the moment is Senator Lemar Alexander of Tennessee. The Senator's most recent post, Oil Industry Can Learn from Nuclear’s Good Safety Record, pays tribute to the safety of the nuclear industry.

one of the most important lessons from the recovery of the nuclear industry has been that safety and efficiency go hand-in-hand and that a safe reactor will also be a much more profitable reactor.

9. What would the Blogspear be without bitchy gossip from and about energy blogging insiders. The Engineer-Poet a pronuclear Oil Drum contributer, who clearly has axes to grind with a number of people including anti-nuclear soothsayer, Michael Dittmar. A carnival should be fun, and the Engineer-Poet gets nasty in a fun sort of way:

Which brings us to my various rebuttals to false claims and ill-supported arguments made by Michael Dittmar. He makes a lot of those. Dittmar was shredded in the comments to his 4-part series posted on TOD. His economics, his timelines, his resource projections... every bit was shown to be based on little more than wishful thinking and the desire to continue Megatons to Megawatts. None of it held up under examination. His remedy to this was to sneak comments in just before the discussions closed, so that his claims would stand without response and give him the last word.

He didn't limit himself to his own guest posts. He tried it with this comment to another post in January. I caught him, and posted a reply showing that his claims were not firmly supported even by his own reference if one took more than a selective reading.

See it? Neither do I, because my rebuttal was "hidden" (censored) by an Oil Drum editor. Not even I have access to what I posted there. And I've been asking for it to be returned, either reposted or mailed back to me, from a few hours after the act until April 27. I posted it under the terms of the Creative Commons license, essentially giving it to all of humanity so long as credit is given. I never thought it would be stolen from everyone including myself, but that's what happened.

Rather, that's what some editor did. . . .

The blatant half-truths and untruths and artless evasions of Michael Dittmar in his four (four!) guest posts of last year got a great many people angry too

10. Dan Yurman of Idaho Samizdat is almost always serious, as he is in UAE picks site to build four reactors. With Dan you expect the facts, and here Dan delivers.

11. Brian Wang reports on the claim by a Chinese historian that the Soviets were close to attacking China with nuclear weapons in 1969 until there was intervention by the USA (Nixon and Kissinger). Nixon aide H.R. Haldeman tells in his 1978 memoirs a somewhat similar story about the episode.

12. Both Rod Adams and Brian Wang have been writing about Chinese nuclear plans, and Rob offers a hat tip to Brian in the course of his post. Brian reports that the a Chinese company has announced plans to build a dozen Westinghouse AP-1000 reactors before 2020. In addition the Chinese have plans to build a couple of 800 MW fast breeders and have entered talks with Russia, France and Japan about joint development of fast breeder technology. Rod notes the fast reactor plans of China and other countries, and suggests that the United States has fallen behind in breeder reactor development.

13. Dan Yurman reports in a May 20 post:

The long wait is over for Areva. The U.S. Department of Energy has offered a conditional commitment for a $2 billion loan guarantee to AREVA to facilitate financing of its Eagle Rock Enrichment Facility planned for development near Idaho Falls, Idaho. The conditional commitment was offered through DOE’s Loan Programs Office.

14 Brian want offers us a glimpse of a very advanced space technology, a nuclear fusion space plane based on magneto hydrodynamics and the inertial electrostatic confinement reactor.

A Rocket-Based-Combined-Cycle (RBCC) propulsion system employing ducted rocket operation and MHD airbreathing to accelerate the vehicle to Mach 12 in about 4 minutes within earth’s atmosphere, and then fusion rocket propulsion to continue vehicle acceleration above the sensible atmosphere for 28 minutes until Mach 26 (orbital speed) is reached. And, here, 18 metric tons of payload can be placed in low earth orbit with a takeoff weight of only 162 tons - about the same payload and takeoff weight as that of medium size airline passenger jets.

Funding estimates start at $10 billion.

15. No carnival would be complete without a surprise visit from celebrities, and Rod Adams offers us two celebrities, Robert Redford and Paul Newman. Rod contrasts Redford, who is involved with the anti-nuclear Natural Resources Defense Council to the Late Paul Newman, who staunchly supported nuclear power. It is too bad that we never got a chance to see Butch Cassidy and the Sundance Kid shoot it out in a talking heads debate over the costs and benefits of nuclear power.

16. Canadian energy issues blogger Stephen Aplin offers The right way to defeat nuclear proliferation. Stephen writes

When anti-nuclear activists play the proliferation card, their tactic is to conflate nuclear-generated electricity with nuclear weapons.Their arguments pretty much rest on that conflation. How valid is it? Not valid at all. It is like opposing gasoline-powered cars because napalm is made from gasoline.

Dick Smyser told the Oak Ridge Story, and Environmental concerns were a part of it

I found two unpublished posts related to Thomas Pigford today in a search of my old posts. I thought these were to good to leave under raps

One of the things that happened to me while growing up in Oak Ridge, is that I managed to assimulate the viewpoint of the atomic pioneers. I had no idea at the time of the importance of Eugene Wigner to the shaping of the ORNL/Oak Ridge mentality. In fact Wigner was often in the background and his thinking was communicated to Oak Ridge in ways we little suspected. Dick Smyser had a lot to do with the communications of the ORNL View to the community. Smyser was the editor and later the publisher of the Oak Ridger. Smyser was more than a jurnalist. His Brother-in-Law, Thomas H. Pigford, who was a former ORNL engineer, a Professor of Nuclear Engineering at the University of California, Berkele, and the only nuclear scientist to serve on the Three Mile Island Commission. The Pigford connection gave Smyser an added in with the ORNL staff, On addition Smyser had an "in house" expert he could turn to for insight, when he did not understand something. As a consequence Smyser not only kept Oak Ridgers well informed anout developments at the lab, but he helped to make Oak Ridge a uniquely nuclear literate community, I have little doubt that Weinberg sharred his thoughts with Smyser on more than one occasion, and Smyser had a social relationship with many ORNL scientists, and would have at leasst meet Wigner and been aware of his importance in creating in Oak Ridge a high level of nuclear literacy that extended beyond the scientific community. I am sure that I picked up terms like neutron economy and breeder blanket from the Oak Ridger, although I did not fully understand what they meant until I began to look closely ate the MSR in 2007. The MSR came well before the current energy crisis, but it was understood in Oak Ridge that the thorium fuel cycle MSR had the potential to provide all of the nation's energy in the future. By the 1960's the vision of a high tec future that would benefit not only the United States, but the world's poorest people, had taken hold in Oak Ridge, and the Oak Ridger reported on it.

Pigford was an expert on both the Uranium andthe thorium fuel cycle, and no doubt Dick Smyser learned something about those subjects from his brother-in-law.

So I grew up nuclear literate and exposed to the world view that lay behind the most daring scientific projects of Oak Ridge scientists. In addition Oak Ridge carried with it the Manhatten Project legacy. The story of K-25 particularly informed the Oak Ridge view of the world. K-25 was huge. It had been the world's largest building under one roof when it was completed during World War II. The isotope separation process used at K-25 was not perfected until construction was well underway. That sort of experience engenders a measure of self confidence. Oak Ridgers had considerable confidence in the power of their technology. They knew that a business as unusual sometimes needed to be set aside and that a great deal could be accomplished by people who were hard working and intelligent. The first atomic bomb that was dropped on Japan used uranium that was processed at Oak Ridge. From 8 tons of Uranium K-25 and Y-12 produced 64 kg of U-235. When the Little Boy bomb went critical, a little more than 1% of the U-235 in the bomb fissioned and about 0.6 g of that mass was transformed into energy. That bomb exploded with the energy equivalent of 20,000 tons of TNT. Most energy writers are unaware of the enormous amount of energy that can be extracted from tiny amounts of matter.

Oak Ridge Scientists conceived of the The Light Water Reactor and made major contributions towards its development, but Oak Ridge scientists knew that the LWR is a very inefficient means of turning matter into energy in a nuclear process. The Light Water Reactir core has to be far larger than a Molten Salt Reactor core. Small cores requite less material and labor to build. They are not necessicarily less safe.

The Oak Ridge vision was in no small measure formed by the natural setting of the city. Oak Ridge has a beautiful setting, and few places where the human species has found itself living can rivaled East Tennessee for natural beauty. Between 1942 and the present many people have lived in Oak Ridge for a short time, but those who tendede to stay, were people who enjoyed the natural setting. As a result Oak Ridge was a city of unusual environmental awareness.

ORNL uses the beauty of the Oak Ridge area as a selling point for employee recruitment.

It was inevitable that ORNL was to become a center of environmental research and from the 1970's onward took the scientific lead in pointing to potential environmental problems caused by CO2 emissions. Oak Ridge scientist understood that burning fossil fuels represented a long term threat to humanity and believed that nuclear power could make an important contribution to the successful prevention of that threat.

A Primer on Nuclear Safety: 1.4.3 Complexity and Three Mile Island

A Primer on Nuclear Safety:
1.4.3 Complexity and Three Mile Island
Supplemental View by Thomas H. Pigford

Introduction: As astonishing as it might seem Thomas Pigford was the only member of the Three Mile Island Commission who knew anything at all about nuclear safety. Pigford was Professor of Nuclear Engineering and Chairman of the Department of Nuclear Engineering at the University of California, Berkeley. He had also worked in reactor research at ORNL. Considering the availability of such luminaries as Edward Teller and Alvin Weinberg, both of whom had a long commitment to nuclear safety, as well as deep insight into the problems, the scientific and technical weakness of the Three Mile Island Commission and its staff is nothing short of astonishing. We ought to consider that the astonishing lack of nuclear safety knowledge on the Commission Staff and among the Commissioners to be proof of the incompetence of President Jimmy Carter as President of the United States. It is clear from some of Pigford's comments in his oral history. that some of the other Commissioners were nut cases. Russell Petersen wanted to eliminate Nuclear Power. Ted Taylor claimed to be doing research on solar heating of water, that he believed would make all commercial power plants obsolete. He expected to have his invention ready before the Commission's report was complete. Middletown, Pennsylvania Housewife Ann Trunk was sane, however.

Jimmy Carter appears to have paid little attention to the Commissions Report, did not ask any questions, and ignored their recommendations. Others, including reactor manufacturers, according to Pigford were much more responsive.

Pigford noted the amateurishness of the Commission staff:
"The staff report relies to a considerable extent upon excerpts from a book authored by E. Rolph without establishing the author's qualifications. Ms. Rolph did not testify in this investigation. The undue reliance upon this secondary source, without first establishing a primary source for its support and without establishing its reliability, is a further example of insufficient balance in this part of the investigation."

"In my view, the Rolph book does not express a comprehensive, accurate, and balanced knowledge of the NRC and of the nuclear industry."

Pigford in effect noted the extent to which Rolph unprofessional book, influenced not only the staff report, but also through the staff, the Commission's report.

In his oral history Pigford does state that he was able to request the placement of spacific individuals on his staffand indicated that he was satisfied with the staff he worked with.

Pigford correctly identifies that the the problem at Three Mile Island lay not with the the reactor system, but with the interplay between human judgement and what were relatively minor parts failures. Research on human judgement has demonstrated that the predictions of experts were less likely to correspond to outcomes, than predictions simply based on actuarial data. This research was based on situations in which people were not stressed by constant alarms, as the Three Mile Island operators were.

Pigford also noted that the accident tested a major nuclear safety concept, "defense in depth." Not only did the "Defense in Depth" work, but the overall outcome was better than previous speculative assessments of nuclear accidents (for example WASH-1400) had anticipated.

Supplemental View (to the Three Mile Island Commission Report) by Thomas H. Pigford

I generally concur with the conclusions and recommendations of the President's Commission on the Accident at Three Mile Island. However, some of the principal results of this investigation need clarification and discussion. Among these are some that warrant immediate, but necessarily limited, comment.

THE PERFORMANCE OF EQUIPMENT AND ENGINEERING SYSTEMS

The Commission has properly recognized that, with the very heavy emphasis upon equipment to attain reactor safety, there has been too little emphasis upon the adequacy of people to help achieve that safety. The lack of such people emphasis has been properly stressed in this report. However, that stress has now obscured the very important fact that, in spite of the very crucial errors of operators and supervisors at TMI-2, the safety equipment did indeed function. In spite of the open PORV, leaks in the vent gas system, and other equipment failures, the overall system of equipment was sufficiently good that, without the human errors, the accident at TMI-2 would have been only a minor accident.

The reactor containment and its auxiliary equipment did indeed function to protect the public. Except for the small fraction that escaped to the environment, the radioactivity was contained. The off-site radiation doses were small. We have found that the actual release of radioactivity to the atmosphere will have a negligible effect on the physical health of individuals. Equipment failures were not the proximate cause of the TMI-2 accident. The accident was, in fact, a demonstration that the equipment (?) effective.

Although there has been considerable speculation about how near TMI-2 came to a worse accident, our staff analyses show that even if all of the reactor fuel cladding had been oxidized to form hydrogen, or even if appreciable fuel melting or even a meltdown had occurred, the containment would still have survived and protected the public. The accident demonstrated that the "defense-in-depth" approach toward nuclear reactor safety has indeed yielded significant results.

The emphasis in this report upon equipment versus people obscures the fact that the equipment itself is only one product of the defense- in-depth or multiple-barrier design approach, which also encompasses the analysis of how equipment components must perform and how systems of equipment must operate. The accident demonstrated that this system of equipment performed better than expected. Earlier assumptions and studies by AEC/NRC (TID-14844 and WASH-1400) have suggested far greater core damage and greater releases of radioactivity from the fuel and into the containment under such degraded cooling conditions.

The accident also has demonstrated many areas wherein equipment modifications can result in further improvements in safety of existing and future reactors in this country.

These are important positive results from our investigation.

THE PEOPLE-RELATED PROBLEM

The nature of the people-related problems needs clarification. One such problem -- and a most serious one -- was the errors made by operators and operator-supervisors, whose training was insufficient in scope and understanding. Another was the failure of many individuals to respond adequately to the earlier experience from other reactors and to other advance information that might have alerted the operators and avoided the accident.

Another problem was the errors made by some NRC officials, who misinterpreted the release of radioactivity on March 30 and recommended evacuation, and who erroneously concluded on March 31 that the hydrogen bubble might explode. The public trauma from these mistakes resulted in severe but short-lived mental stress, which was evidently the only serious health effect of the accident.

Having identified the particular people problems involved, many of the necessary direct remedies are apparent. There seems to be some unwillingness to recognize that many of these remedies are already being implemented. The NRC and the nuclear industry have taken and are taking steps on a broad basis to analyze and rectify these problems, as evidenced by the post-TMI NRC bulletins and by the establishment of the utilities' Institute for Nuclear Power Operations (INPO) and the reinsurance program. After experiencing the shock and comprehending the cost of this accident, the nuclear industry clearly has set into motion programs to institute many of the remedies that this Commission seeks. The problem with "attitudes" emphasized in the Commission's report must refer largely to pre-TMI attitudes.

It is reasonable to expect that other such human-related problems, not uncovered by this investigation, may exist. That, and the need to instill and continue a strong emphasis upon reactor safety, suggest some of the broader institutional changes recommended in this study.

SCOPE AND LIMITS OF THE INVESTIGATION

The limits of this investigation and the effect thereof upon the Commission conclusions and recommendations need clarification.

This investigation was limited to the accident at TMI-2, and possible variations thereto, and, to a limited extent, similar transients at other places. The many other aspects of reactor safety were not investigated, although we do recommend that these be more systematically studied. The facts of the present investigation provide no basis for concluding that reactors are unsafe. They also show that, although more emphasis is needed on the analysis and planning for small-break accidents, the possibility of an accident of this type was known and had been analyzed and predicted prior to the TMI-2 accident. Therefore, any conclusions as to new fears of reactor safety do not arise from, and imply large extrapolations from, the facts of this investigation.

This investigation has not included a study of reactor siting. Consideration of the calculated "low population zone" occurred only in our consideration of its implication on the specification of radiation doses for evacuation decisions. Therefore, proposals made by some Commissioners to reverse existing site approvals in favor of more remote sites have no justification within the facts of this study.

We have recognized in this investigation that decisions as to whether or not safety improvements are to be implemented must be based, in part upon a weighing of the costs against the benefits. However, we did not evaluate the costs of possible safety modifications, nor did we evaluate the probabilities of some of the large hypothetical releases that have been postulated by some Commissioners. Such proposals, and claims as to risks therefrom, have no basis within the facts of this investigation.

We have not investigated the availability, cost, overall safety, and environmental effects of nuclear energy and of other energy alternatives. Nor have we investigated the effect of various energy alternatives upon the nation's economy and security. We have not examined the effect of a speed-up or delay of nuclear power upon the many energy problems that affect the nation. Therefore, proposals by some Commissioners to impose sanctions that afreet the availability of nuclear energy as an option are based upon their own personal extrapolations, which leap far beyond the facts of this investigation. The Commission, in its final consideration of the moratorium proposals, repudiated the issue by a vote of eight to four.

LACK OF INPUT FROM THOSE PARTS OF THE NUCLEAR INDUSTRY NOT INVOLVED DIRECTLY IN TMI-2

Through its investigation of the Nuclear Regulatory Commission, the Commission staff has uncovered problems and practices which have suggested extrapolations to those many parts of the nuclear industry not involved directly with the TMI-2 accident. However, little proof of the validity of these extrapolations has been established. Moreover, to my knowledge, no representatives of those other parts of the nuclear industry were interrogated or asked to present evidence on any of the relevant issues, except for one company interrogated within the narrow issue of the Beznau incident. This further limits the validity of the industry-wide extrapolations that are implied in many places in the report and that are implied in some of the moratorium recommendations still endorsed by some of the Commissioners.

ATTITUDES

The framing of the Commission's overall conclusion around the question of:

attitudes of the Nuclear Regulatory Commission and, to the extent that the institutions that we investigated are typical, of the nuclear industry . . .

requires comment and interpretation. "Attitudes," especially prior to TMI-2, were not directly examined, nor could they be. Valid conclusions can only be drawn on actions taken, i.e., problems addressed and not addressed, regulations issued and complied with, and the occurrence of events that reflect upon the adequacy of those processes. Even if attitudes could be assessed, it is not clear how they could be changed by any recommended rule, reorganization, or other mandated influence. It is more constructive to assume that attitudes are symptomatic of the forces at work in the systems, and it is those forces that must be addressed.

The actions already taken by the industry in setting up INPO, the Nuclear Safety Analysis Center, and the program of self-insurance against the cost of replacement power, with the self-policing actions thereby implied, signal a genuine, if somewhat belated, recognition of the need for greater effort to prevent nuclear accidents and to cope with their consequences. These actions show a significant change in industry attitude that can only be beneficial.

It becomes clear, as the theme of "attitudes" is developed in the Commission report, that what is of concern is an apparent failure of the system to incorporate an effective mechanism to assimilate lessons from plant experience and to incorporate the appropriate up-to-date technology, particularly as it applies to control room design, and to develop sufficiently trained and competent people to manage this technology. This is a more manageable and appropriate focus for the overall conclusion of this Commission.

I believe that such technology is being or will be used by the industry and that changes and improvements in design and operating procedure will be effected, not merely to satisfy critics nor to demonstrate attitudinal penitence, but on the basis of sound judgment resting on sound data.

COMMISSION JUDGMENTS ON OVERALL SAFETY

In its Overview, the Commission acknowledges that it has not examined "how safe is safe enough or the broader question of nuclear versus other forms of energy," recognizing the complexity of the issue and the limitations of staff. However, the Commission soon leaps this hurdle and speaks of the "risks that are inherently associated with nuclear power", and it holds that "equipment can and should be improved to add further safety." Even the conclusion that "accidents as serious as TMI should not be allowed to occur in the future" may imply that an assessment of risk and safety has been made. This conclusion is more understandable if interpreted in terms of what was really serious about this accident.

The only serious health effect was the mental stress resulting from the confusion and public misunderstanding concerning the March 30 release and the March 31 hydrogen bubble. The financial loss to the utility and ultimately to the rate payer is also serious.

Every technology imposes a finite degrees of risk upon society, both in its routine operation and in the occurrence of accidents. Over a long enough time period, even low probability accidents may occur. The essential question is the trade-off between the risks and the benefits. The Commission neither received any evidence nor reached any conclusions that the risks of nuclear power outweigh its benefits.

THE NRC "PROMOTIONAL PHILOSOPHY"

The NRC's assignment is indeed difficult, but not because of dichotomy of safety, on the one hand, and the industry's convenience, on the other. The problem is more complex. There is in each issue the element of how much cost, how many person years of expert analysis, and how much delay is justifiable to achieve an increment of safety. Seldom are these issues black and white, since the designers and engineers must recognize that absolute absence of risk in any project is unattainable, and that social costs accrue to both inaction and overreaction. Efforts to balance costs and benefits should not be considered evidence per se of a promotional philosophy.

It should be expected that industry will logically resist unwarranted changes proposed in the name of safety.

HYDROGEN FROM SMALL-BREAK LOCAS

Finding A.10 may be misinterpreted as suggesting that, because of the experience at TMI, the generation of large amounts of hydrogen gas is an inevitable consequence of small-break LOCAs. This misinterpretation leads to the erroneous conclusion that NRC overemphasis on large-break LOCAs, at the expense of small breaks, is what left the TMI operators unprepared for the hydrogen produced during the accident, since significant amounts of hydrogen are not predicted in the typical analyses of large breaks. Such inference is without basis. Large-break analysis or any-break analysis will predict the generation of large amounts of hydrogen whenever the cooling water added to the reactor core from the emergency systems is reduced to the extent that was done at TMI-2.

THE TWO-STEP LICENSING PROCESS

Finding G.6 implies that, in the two-step licensing process (construction permit and operating license), safety may be compromised due to the large financial commitment prior to the operating license stage, with the implication that insufficient information is known at the construction permit stage for an in-depth safety review. A review of actual license applications will reveal that major safety features are sufficiently described at the construction permit stage. The issuance of an operating license several years later facilitates consideration of appropriate technological developments and feedback from operating plants which may be factored into the design toward the end of the construction period. Safety review in licensing is not a discrete two step process. There is, and should be, continuing dialogue between the NRC staff and the applicant during this interim period.

SINGLE-FAILURE CRITERION Finding G.8.a that applicants "are not required to analyze what happens when two systems or components fail independently of each other" conveys some misunderstanding of the "single-failure" criterion. The requirement is that the applicant must show that applicable off-site radiation exposure limits will not be exceeded in the event of an accident initiated by:

a. any credible component failure, and in which

b. either all external or all internal power supply to the plant is lost, and

c. there is, in addition, failure of that single active component whose failure would most worsen the results of the accident.

Although confusingly called a "single-failure" criterion, it is clear that this criterion requires the assumption of at least three failures.

It is further required that if failure of one component causes failure of other components, the entire series of failures must be regarded as one failure. The single-failure criterion is applied on a system-by-system basis, which implies single-failure tolerance in each of the systems.

SAFETY-RELATED ITEMS

Finding G.5.b concerning NRC's handling of "safety-related" items needs clarification in several respects. First, the well-established practice of the NRC is to require that any component, system, or feature needed for the prevention or mitigation of a serious accident must meet documented requirements of quality, redundancy, testability, environmental qualifications, etc., and must be categorized as "safety-related." Although other components, systems, or features are classed as non-"safety related," they must meet requirements appropriate to their operational function. NRC practice is to subject all "safety-related" items to review. Additionally, non-"safety-related" items are reviewed by NRC to reassess their possible reclassification.

Second, in analyzing postulated accidents, one is not permitted to assume that an active non-"safety-related" item will be capable of performing its function. As a result, either an active item must meet "safety-related" requirements of quality, etc., or no credit can be taken for its functioning in an accident.

In the TMI-2 accident, it appears that the NRC's preoccupation with the "safety-related" item list was not the fault, but rather the safety analyses did not take into account the actual lack of training, the inadequate operating procedures and practices, and their potential capability for producing an accident if the PORV stuck open.

Finally, the NRC is in some degree responsible for the level of safety consciousness in the industry. In this sense, NRC's emphasis on "safety-related" categories has probably been less influential than its reluctance to give credit for safety innovations and its requirement that the industry comply with many technically unreasonable rules. These practices encourage the industry merely to comply with NRC rules.

With regard to finding G.8.C, it is not the reliance on "artificial categories of 'safety-related' items" which has caused NRC to miss important safety problems. Rather, it was the failure to recognize that some items not part of the safety system may challenge that system at an undesirable frequency. Moreover, the capability of the operators to defeat the safety system was not given sufficient attention. These important issues are apart from safety-system classification and the single-failure criterion.

PLANT INSTRUMENTATION Finding G.5.f does not provide a balanced account of all the considerations identified by the Atomic Industrial Forum (AIF) in its 1978 response to an NRC proposal to institute a new guide requiring a wider range of response for in-plant instrumentation, nor does it recognize the seeming lack of technical basis for the NRC request.

The relevance to the TMI-2 accident of the AIF response is not clear, since the range of the in-plant instrumentation at TMI-2 was adequate for diagnosis and plant control during the accident. Instead, the problem during the TMI-2 accident was that only part of the range of the in-plant instrumentation was displayed to the operators, and the manner of display was in some ways inadequate. Additionally, the operators misinterpreted some instrument readings. However, a greater range of instrument response might have aided the later assessment of the core damage that occurred.

BACKFITTING

Finding G.8.h, that there is no systematic backfitting review on a plant-by-plant basis of operating plants and plants under construction, appears to take too little account of the NRC's Systematic Evaluation Program (SEP), initiated more than 3 years ago. Under this program, operating plants have been categorized by NRC, issues have been identified by NRC, and information about older plants has been supplied to NRC by the utilities. In a number of cases, physical modifications of operating plants have been made in order to comply with updated NRC requirements. In some areas, such as that of the upgrading of emergency plans cited in the Commission's report, progress does appear to have been somewhat slow.

INDEPENDENT TESTING BY I&E

In finding G.9.a and recommendation A.ll.d, the recommended improvement of NRC's inspection and auditing of licensee compliance with regulations, and the need for major and unannounced on-site inspections of particular power plants, is logical. It calls for NRC to do more of what it already does and to do it better. In fact, NRC has, for over a year, stationed full-time inspectors at some operating nuclear power plants. At some plants, unannounced on-site inspections appear to be so frequent as to be commonplace.

The implication that NRC's I&E inspectors should do a substantial amount of independent testing of construction work and should place little reliance on work done by the utility is clearly impractical because of the enormous resources that would be required. Careful auditing of industry's testing is the only practicable and effective approach.

EMERGENCY PROCEDURES

In addition to the fact that some of the existing TMI-2 procedures were unworkable, as indicated in the Commission's report, the procedures did not provide a step-by-step pathway for identifying the problem implied by the information available in the control room. Given the philosophy that the operators had to adhere closely to written procedures, the unavailability of diagnostic procedures and training in their use was a significant factor among the causes of the TMI-2 accident.

THE MAJOR PROBLEMS WITH NRC'S APPROACH TO REACTOR SAFETY

The Commission report has identified many mistakes by NRC personnel in their handling of the TMI-2 accident and deficiencies in NRC's regulatory practices. However, this criticism does not reach some essential elements of the problem. I believe that the following are some of the more important problems at NRC:

• Lack of quantified safety goals and objective. When a safety concern is postulated, there is no yardstick to judge the adequacy of mitigating measures.

• Inability to set priorities and to allocate resources in proportion to the estimated risk to the public. In my view, a disproportionate effort is being required for some issues that have only a marginal impact upon risk to the public.

• Lack of experienced staff. An undesirably large proportion of NRC staff and management have little or no practical experience in designing or operating the equipment that they regulate.

• Arbitrary requirements. Too many of the NRC requirements are mandated without valid technical backup and value-impact analysis.

• A stifling adversary approach. The existing process inhibits the interchange of technical information between the NRC and industry. It discourages innovative engineering solutions.

• Ineffective evaluation of operations. NRC has no effective system for evaluating data from operating plants. Data should be analyzed systematically to identify trends and patterns.

• Lack of a comprehensive system approach to the whole plant. A large percentage of the NRC staff are specialists focusing upon narrow topics. There are relatively few systems engineers within NRC who can integrate individual safety features into an overall concept and who can place issues into perspective.

• An overwhelming emphasis on conservative models and assumptions. Realistic analyses are needed to identify the margins of safety and to aid competent decisions.

THE STAFF REPORT

The tight schedule and deadline for the Commissioners' report has allowed little opportunity for careful review of the staff reports upon which our findings are to be based. Some staff reports are not yet completed. There are several parts of some key staff reports with which I cannot agree, particularly the staff report on the NRC.

THE STAFF REPORT ON THE NUCLEAR REGULATORY COMMISSION

The staff report on the Nuclear Regulatory Commission is a companion document published by the Commission. Some deficiencies in this report are already reflected in earlier comments on findings and conclusions concerning the NRC. Having reviewed that report in search for understanding for many of the findings and conclusions adopted by this Commission, I noted several deficiencies, varying from technical error to unbalance in the investigation. Two examples are given below.

Performance Characteristics of Large Light-Water Reactors

The staff report contains generalities by an NRC staff member, who seriously questioned the state of knowledge of the performance characteristics of the larger light-water reactors in this country, an opinion apparently also echoed by some other individuals within NRC. The cited statement was adopted by the authors of this staff report. However, the staff report reflects no attempt by the staff to obtain evidence from the nuclear industry on this issue, even though the various companies in the nuclear industry are the parties impugned by the cited statements.

Statements were recently obtained from Saul Levine, director of NRC's Office of Nuclear Regulatory Research, and from two different companies that design light-water reactors and that are not connected with the TMI-2 accident. It should not be construed from reference to "economy of scale" that the regulators were being asked to accept reduced ; safety margins. Rather, the growth was largely achieved by adding more fuel assemblies of the same or similar volumetric and linear power density, and by adding more heat transfer loops having the same mechanical and hydraulic characteristics as in the plants previously licensed. Saul Levine said, "as far as I know, there have been no size-dependent factors found in the operation of large reactors to affect the safety of the plants adversely." There appears no supportable suggestion that safety was compromised as a result of the extrapolation of technology.

The unqualified acceptance of the cited testimony in the staff report is an indicator of insufficient balance in this part of the investigation.

Reliance on Books and Magazines

The staff report relies to a considerable extent upon excerpts from a book authored by E. Rolph without establishing the author's qualifications. Ms. Rolph did not testify in this investigation. The undue reliance upon this secondary source, without first establishing a primary source for its support and without establishing its reliability, is a further example of insufficient balance in this part of the investigation.

In my view, the Rolph book does not express a comprehensive, accurate, and balanced knowledge of the NRC and of the nuclear industry.

CONCLUDING STATEMENT

The rather extensive criticism of NRC in the Commission report, and as implied in this supplementary statement, should not obscure the central issue that primary responsibility for nuclear safety lies with the utility, shared to a large extent with the equipment suppliers and the architect engineers. This also reflects my view of the responsibilities for the TMI-2 accident.

However, these criticisms of both the industry and the NRC should not obscure the fact that in 480 reactor years of commercial nuclear power operation in the United States, there has still been no identifiable effect upon the physical health of the public, and that this record has been achieved by the industry and NRC -- the parties that have been criticized -- and under the system that has been criticized.

It must be emphasized that nothing learned from this investigation suggests that the nuclear power option should be curtailed or abandoned as a result of the TMI-2 accident.

Thomas H. Pigford

October 25, 1979

A note on Thomas Pigford: Pigford spent 2 years in Oak Ridge in the early 1950's. He was the brother-in-law of my father'slong time neighbor and Oak Ridger newspaper editor Dick Smyser. He was involved in the ANP project. Pigford described memories of his Oak Ridge days, including some observations on the ANP project in a UC Berkley oral history.