APPENDIX I

NUCLEAR POWER
QUESTIONS AND ANSWERS

          The proponents of nuclear power conduct a well-financed campaign (largely paid for by us taxpayers) which relies heavily on a barrage of statements that minimize the hazard of nuclear electricity generation and extol its wonders. Citizen action groups need accurate, honest information to rebut such statements. Because so many of the questions concerning the value and safety of nuclear power recur over and over again, we have summarized the "questions and answers" and offer them here for ready reference.

Setting Permissible Doses of Radiation

1. How much radiation do AEC standards allow Americans to receive as a result of peaceful uses of the atom?

   Answer: The maximum allowable whole-body dosage at the perimeter of a nuclear installation is 500 millirads to any individual. The average dose allowable for the U.S. population is 170 millirads per year. In fact, part of the justification for the average allowable dose being 170 millirads per year is that it was considered that this limit would prevent any individual from receiving over 500 millirads per year. (Millirads are equivalent to millirems.)

2. Is the allowable or permissible dose of radiation truly safe?

   Answer: Numerous atomic energy proponents repeatedly make the claim that the "permissible" dose is a safe dose and they imply that no one will be injured at this "permissible" dose. However, there is not a shred of evidence that supports this claim of safety.

3. What would the effects be for exposure at the "permissible" dose?

   Answer: The two major effects of concern are an increased death rate from cancer plus leukemia and an increase in genetic mutations.

         Cancer + leukemia: For an individual steadily receiving 500 millirads per year, the chance of dying from cancer or leukemia is increased by 30 percent.

         For a population averaging 170 millirads per year steadily, there will be a 10 percent increase in death rate from cancer plus leukemia. If this average were reached for the entire USA, there ultimately would be 32,000 extra deaths from cancer plus leukemia annually.

         Genetic Risk: The genetic mutation rate would be increased by 5 to 50 percent for a population averaging 170 millirads per year. Ultimately this would translate into a 5 to 50 percent increase in death rates due to genetically-determined diseases. At the time such genetic deaths will be occurring, our population is expected to be 300 million persons. This means we can then expect between 150,000 and 1,500,000 extra deaths each year.

4. How can a dose which leads to such high death rates be considered "permissible"?

   Answer: There is no justification whatever for such "permissible" doses, which can lead to public health disaster. So far as can be ascertained, the justification is simply that the development of atomic energy is not too seriously inconvenienced by such allowable doses. No health justification would appear possible.

5. Are these "permissible" doses already being received by the U.S. population as a result of nuclear energy developments?

   Answer: Definitely not. It is fortunate that we recognize the serious health hazard of such allowable doses. We have, therefore, the opportunity to reconsider the wisdom of rash proliferation of nuclear electricity plants and other nuclear energy programs before an irreversible public health calamity has occurred.

6. Is there scientific controversy concerning the hazard associated with "permissible" doses of radiation?

   Answer: The real controversy is political, not scientific. If the sound public health principles agreed to by such bodies as the International Commission on Radiological Protection and the National Committee on Radiation Protection are applied, it is not possible to reach conclusions significantly different from those listed above (Question 3). Scientists do differ from one another, concerning the precise magnitude of the hazard, in a minor way. But all, applying sound public health principles, would agree the hazard is large.

         The electric utility industry has been misled by the AEC and the JCAE into believing that a "permissible" dose of radiation is "safe."

7. Is the hazard of radiation exposure now recognized as greater than it was thought to be when the AEC standards were put into force?

   Answer: The hazard of developing cancer is now recognized to be about twenty times greater than it was thought to be when the AEC standards were set. This is the result of a totally unsound public health approach which has characterized every aspect of standard-setting.

         The genetic hazard is also now recognized to be far greater than was thought to be the case when the standards were set. In this case new medical information concerning the genetic basis of many major diseases is the reason why the hazard is now recognized to be much more severe than previously thought.

8. What is meant by unsound public health practices in setting radiation standards?

   Answer: Evidence based upon experimental animal studies, available for 25 years, would have led to the serious expectation of cancer plus leukemia that we now realize we are facing with the "permissible" radiation doses. In the case of atomic energy, we have failed utterly to apply sound public health principles.

         Obviously we shouldn't have made the error of demanding the human corpse at all. If such grossly unsound public health practices were extended to all poisons in the environment, we would indeed face a sorry plight as a species.

9. When the FRC, ICRP, or NCRP (standard-recommending bodies) sets a standard for public exposure, do they mean to suggest that such exposures are safe?

   Answer: Absolutely not. These various bodies have never stated, nor implied, that such exposure is safe. This implication is a misuse of the standards by AEC, JCAE, and the electric utility industry. The net effect of such misuse of standards is deception of the public.

         What the standard-recommending bodies hoped was that the benefits of the atomic technology might offset the cancer, leukemia and genetic hazards.

10. Can it be demonstrated that such a body as the International Commission on Radiological Protection did not mean that anyone should construe their suggested limits to be safe?

    Answer: It most certainly can be demonstrated. The following is a direct quote from ICRP Publication 9 (1965).

          "Because of the need for guidance in this regard, the Commission (ICRP) in its 1958 Recommendations suggested a provisional limit of 5 rems (5,000 millirems) per generation for the genetic dose to the whole population, from all sources additional to natural background radiation and to medical exposures. The Commission believes that this level provides reasonable latitude for the expansion of atomic energy programs in the foreseeable future. It should be emphasized that the limit may not in fact represent a proper balance between possible harm and probable benefit, because of the uncertainty in assessing the risks and the benefits that would justify the exposure."

          So, the ICRP admitted forthrightly it didn't know the risks.

          And the ICRP admitted forthrightly it didn't know the benefits. In the face of both uncertainties, they (ICRP) went ahead to "provide reasonable latitude for the expansion of atomic energy programs." Most people, including the electric utility people, were led to believe the standards were "safe," when the ICRP in fact said no such thing.

          Standards arrived at in this manner can in no way be regarded as safe with respect to damage either to humans of this or future generations. Instead, such standards mean a moral judgment has been made that a certain number of human lives lost is acceptable for the good of the atomic industry. The entire standard-setting procedure is probably illegal and unconstitutional involving, as it does, the moral judgment to sacrifice the lives of humans explicitly.

11. Is the entire concept of "safe" or "permissible" radiation exposures subject to challenge?

    Answer: Most certainly. Standards, as they have been set up to the present time, have nothing to do with the protection of the public health. They represent a set of numbers drawn out of thin air, for the convenience of a particular technology. The public and (in the case of atomic energy) the electric utility industry are misled into believing that the words "standards" or "allowable" or "permissible" mean "safe." This is simply false.

12. Would it ever be possible to set truly safe standards, for radiation exposure?

    Answer: There is only one set of circumstances under which truly safe standards could be set. That would be if we knew that some amount of radiation was free of such harmful effects as cancer, leukemia, or genetic damage.

          It can be stated unequivocally, and without fear of contradiction, that no amount of radiation has ever been proved to be safe. As a result, it can be stated unequivocally that there does not exist any standard which implies a safe amount of radiation.

13. Does this mean that all codified "standards" represent trading human lives for some supposed benefit of technology?

    Answer: Unfortunately, yes. Worse yet, there has never been an effort made to demonstrate that the supposed benefits accrue to those who suffer the hazard. Nor has society even been permitted to participate in such an important decision.

Natural Radiation

14. Aren't we exposed to radiation naturally?

    Answer: Yes.

15. Is there any harm from natural radiation?

    Answer: Every responsible body (ICRP, NCRP, FRC) has explicitly stated that since we cannot prove that any radiation is safe. we must figure that harm in the form of cancer, leukemia, and genetic deaths is occurring from all sources of ionizing radiation in direct proportion to the amount of radiation received.

          Since this is the basic underlying assumption for all responsible scientists, all of them would necessarily estimate that natural radiation, like man-made radiation, will produce its proportionate share of cancer, leukemias, and genetic deaths.

16. There are areas in the world (Kerala, India and Brazil) where "natural" radiation is many times higher than in most other regions. What do these areas show with respect to cancer or leukemia induction by such natural sources of radiation?

    Answer: No adequate studies have ever been carried through in these regions to learn about the cancer and leukemia production by the high natural radiation. Such studies would be difficult, for they require careful control observations and large numbers of subjects.

          For some strange reason the absence of studies is commonly equated, by atomic energy promoters, with an absence of harmful effect of the radiation.

17. What did we do in assessing the cancer plus leukemia hazard for atomic energy?

    Answer: The standard-setting bodies refused to accept the experimental animal evidence, a grave public health blunder on their part. Instead, they demanded seeing human cancer and leukemia before they would consider human cancers and leukemia to be caused by radiation.

18. Do we have the human evidence now concerning cancer?

    Answer: Unfortunately, yes. When the standards were set, the humans exposed to radiation (the Japanese A-Bomb survivors and 14,000 medically irradiated British subjects) had not been observed long enough for the radiation-produced cancers to develop. The result, the cancer hazard of radiation was estimated approximately twenty times too low. The new evidence showing the twenty-fold higher hazard became available just through the passage of enough time.

19. It has been stated that even if the cancer and leukemia production by radiation is as serious as has been estimated, the average person will suffer only a shortening of life measured in weeks or months. Should we worry about such a "minor" effect on life expectancy?

    Answer: The correct answer to this question is to point out that this approach, considering average life expectancy, is truly immoral. What should really be considered is the shortening in life expectancy for those who suffer the cancer or leukemia from the radiation they receive. Many of these individuals lose 5, 10, 15, 20, or 25 years from their life expectancy as a result of the early death from cancer or leukemia. It is small comfort to these individuals or their families that their loss of life expectancy is made falsely to look insignificant by being averaged in with the life expectancy for those fortunate enough to escape the radiation-induced cancers or leukemias.

          This can be illustrated by consideration of a specific situation. If a group of ten-year olds were to be irradiated, we know that a certain number of them will die of cancer or leukemia, the number who die increasing with each increase in radiation dosage. For those who do die of radiation-induced leukemia or cancer, the deaths start, after a latency period, some five years after the radiation, and new deaths are added annually for many years thereafter. Since the group of 10-year olds are representative of the population-at-large, their life expectancy without radiation should be some 50 to 60 years. But for those whose leukemias and cancers develop between the 5th and 10th year after radiation exposure, there has been a loss of 40 to 50 years of life, a matter of grave seriousness to them and their families.

          It is difficult to understand the logic of those who treat this problem by averaging the radiation victims in with those who escape the effect. By their logic the crime of murder is not a serious matter in the civilian population After all, if we average in all those who are not murdered, the average" loss in life expectancy for society is trivial.

20. How much harm is natural radiation causing?

    Answer: Since at sea level we get approximately 100 millirads per year from natural radiation, we can calculate the harm very simply by direct proportion.

    For cancer + leukemia

          We estimated (see text) that exposure to 170 millirads would cause 32,000 extra cancer plus leukemia deaths per year.

          Therefore, natural radiation is right now causing 100/170 x 32,000 = about 18,800 cancer plus leukemia deaths each year. (Actually, since some of our population lives at a higher altitude and hence gets more than 100 millirads per year, the true number of cancer plus leukemia deaths must be higher than 18,800.)

    For genetic injury

          We estimated (see text) that for 200-million people 170 millirads would lead to between 100,000 and 1,000,000 genetically caused deaths per year. Therefore for natural radiation, we calculate 100/170 x (100,000 to 1,000,000) = 58,800 to 588,000 extra genetic deaths are being experienced each year as a result of natural radiation.

21. Is it really correct to refer to such deaths as "are being caused"? Have these deaths actually been observed?

    Answer: Adherence to responsible public health principles leads one to make the statement that these death are occurring. These are the numbers arrived at by applying the ground-rule assumptions that all responsible scientists and radiation study groups agree to follow, for public health purposes. If one denies these calculations, one is directly and overtly denying the sound principles of public health.

          These deaths have not been observed as the specific ones caused by radiation. The radiation-induced cancer cases look just like other cancer cases. It is not relevant to ask whether the cases have been observed. It would be folly to consider such deaths as not occurring.

22. Would it be possible to set up scientific studies to observe deaths from natural radiation by direct observation?

    Answer: It would represent a monumental scientific study to make the direct observations, but it could be accomplished with Herculean effort. Unfortunately, technology promoters, especially atomic energy promoters, seem falsely to equate "no adequate studies done" with "no effect occurring."

The Linear Theory-
Damage Is Directly Proportional To The Dose

23. What is the linear theory of relationship of radiation dose to effects, such as cancer, leukemia, and genetic injury?

    Answer: All responsible bodies involved in considering radiation hazards have agreed to use the linear theory to estimate the number of deaths caused for each amount of radiation. The linear theory holds that if one unit of radiation produces one case of cancer, two units of radiation will produce two cases, ten units will produce 10 cases of cancer, etc. In other words, the linear theory states that the damage is directly proportional to the dose right down to the lowest doses. Thus, it is obvious that if the linear theory is used, there simply cannot exist such a thing as a "safe." dose of radiation.

24. But do all scientists agree with the linear theory?

    Answer: There is virtually nothing in the world upon which all scientists agree. But the question is not relevant. What is relevant is that every responsible scientific body and every responsible scientist involved in public health considerations of radiation injury have all agreed to use the linear theory for estimating cancer, leukemia, and genetic deaths until and unless someone proves otherwise. If someone claims to abide by responsible public health ground rules, which include using linear theory, and then says that some dose of radiation is safe, he is guilty of public health irresponsibility.

25. Is there direct experimental evidence on animals or humans to support the linear theory of radiation injury?

    Answer: There most certainly is abundant evidence both for experimental animals and for humans—providing extensive support for linear theory in the production of leukemia, cancer, and genetic injury. And as new evidence is published, the experimental support for the linear theory becomes overwhelmingly strong. Listed below are major new reports supporting the linear theory with extensive scientific evidence for cancer and leukemia production by radiation.

    1. Production of breast tumors in rats by x-rays and gamma rays.
       (C.J. Shellabarger, V.P. Bond, E.P. Cronkite, G.E. Aponte, p. 161 in "Radiation-Induced Cancer," A Symposium of the International Atomic Energy Agency, Vienna, 1969.)
       
    2. Production of bone cancer in mice by radium.
       (M.P. Finkel, B.O. Biskis, P.B. Jinkins, p. 369, ibid)
       
    3. Production of lymph cancer in mice by gamma rays.
       (A.C. Upton and coworkers, p. 425, ibid)
       
    4. Production of cancer and leukemia in children irradiated by x-rays while in utero.
       (A. Stewart and G.W. Kneale, Lancet, p. 1185, June 6, 1970)
       
    5. Production of Leukemia in Japanese Survivors of the Atomic Bombing of Hiroshima and Nagasaki.
       (S. Jablon and J.L. Belsky—Presented at the Tenth International Cancer Congress, Houston, Texas, May, 1970)
       
    6. Production of Thyroid Tumors in Children irradiated with x-rays.
       (L.H. Hempelmann, Science 188, 160:159-163, 1968)
       
    7. In the field of genetic injury, even the most optimistic data for genetic mutations, for slow delivery of radiation, shows linearity between dose and effect.
       (W.L. Russell, Nucleonics 23, No. 1, 53-62, 1965)
26. Does the AEC agree to abide by sound public health principles?

    Answer: The AEC presents a remarkable paradox, caused undoubtedly by its dual role as promoter of nuclear energy and as its own regulator. The AEC claims to accept the guidance of the ICRP, NCRP, and FRC concerning radiation injury. All of these bodies use the linear theory as a fundamental ground rule of sound public health evaluation of radiation hazard.

          The AEC is constantly adhering to two hopelessly inconsistent statements. For purposes of suggesting its public health responsibility, AEC accepts these ground rules. At one and the same time AEC suggests that 170 millirads of exposure is "safe." These two statements are absolutely irreconcilable. The reason why the AEC finds itself in such a difficult position is that if it really accepts sound public health principles, it will be led to estimating tens of thousands of extra cancers and leukemias per year for radiation doses which it considers "permissible." The public impact of this is horrible for the AEC to contemplate, so it is locked into an impossible and hopeless quandary.

          The only escape for the AEC would be to admit the truth to the public—namely, that its "permissible" radiation dose is really not at all safe. It is conceivable that the public may wish to accept a large number of extra cancer and leukemia deaths in exchange for atomic energy programs. Sooner or later the AEC will be forced to stop hiding this massive inconsistency in its position.

27. But isn't it true that atomic energy programs, such as nuclear electricity generation, will deliver radiation slowly and that this might offer some protection?

    Answer: No acceptable evidence exists that slow delivery of the radiation will afford any protection against cancer or leukemia. Therefore, all responsible bodies (ICRP, NCRP, FRC) agreed to use the sound public health principle that no protection will be assumed for slow delivery of the radiation until and unless such protection is proved beyond doubt. Hence, only the total dose of radiation can be considered to matter. For anyone to claim atomic energy program "allowable" doses to be safe because of slow delivery of radiation is to violate the agreed upon fundamental public health ground rules. And this represents public health irresponsibility.

          In addition, no acceptable experimental animal data indicates that cancer or leukemia will be lessened if radiation is delivered slowly. What experiments have been done simply show that radiation spread over a long period of time may, in some cases, produce less cancer than when the whole dose is given early in life. All this really proves is that young animals are more susceptible to radiation-induced cancer than old animals. Young humans are more sensitive than older humans, too.

28. What is the net effect of the combined statements concerning linear dose versus response and the absence of proved protection from slow delivery of radiation—with respect to cancer and leukemia hazard?

    Answer: As a result of these public health ground rules, all responsible bodies say that you must expect injury in direct proportion to the dose of radiation received. They all agree that, for public health prediction and action purposes with respect to atomic energy development, no amount of radiation is safe.

29. Is it not true that the Russell mouse genetic studies show good evidence that slow delivery of radiation produces one-third as many mutations as fast delivery of radiation?

    Answer: At very high total doses of radiation the Russell studies do show one-third as many genetic mutations for slow delivery of radiation compared with fast delivery. For low total doses there is likely to be very little difference between slow and fast delivery of radiation. Since atomic energy programs will generally involve slow delivery of radiation, it is appropriate to explore the genetic consequences of radiation for slow delivery of radiation. This is the most optimistic possibility.

          If we use the most optimistic Russell mouse genetic data, and even if we give full credit for slow delivery of radiation, we reach the conclusion that 100,000 extra genetic deaths per year would occur for the allowable average exposure of 170 millirads to the population. This can hardly be construed as an "optimistic" outlook, or a "safe" dose of radiation.

30. Is it valid to transfer the Russell mouse genetic results directly to man?

    Answer: Of course not. Even the most optimistic outlook, based upon direct transfer of the most favorable mouse results, leads to the gloomy outlook for 100,000 extra genetic deaths per year for "allowable" radiation doses.

          However, Russell himself proved that the mouse is fifteen times as sensitive to radiation-induced mutations as is the fruit fly (Drosophila). Man may, in turn, be much more sensitive than mouse. We simply don't know. If man is more sensitive than mouse, then the anticipated 100,000 extra genetic deaths per year will rise in proportion. How many times 100,000? No one knows.

          Furthermore, Russell's own data show that some mouse genes are easier to mutate than others through ionizing radiation. If the critical genes in the human should turn out to be more readily mutated by radiation, then the 100,000 extra genetic deaths per year could rise appreciably.

Disparity of Estimates on Radiation Risks

31. Is it true that the risk of radiation induction of cancer plus leukemia was seriously underestimated by standard-recommending bodies such as ICRP?

    Answer: Unfortunately, it is true. By refusing to use the long available experimental animal data, bodies such as ICRP committed a cardinal error that led to a gross underestimate of the cancer hazard from radiation. The ICRP used human data (from Japan and Britain) for the early period after irradiation, before the bulk of the radiation cancers had arisen. As a result, in ICRP Publications 8 and 9 (Pergamon Press) the ICRP estimated one extra cancer for each leukemia produced by radiation. We now know the true number is much closer to twenty extra cancers for each leukemia caused by radiation.

32. Has the ICRP recognized its error in estimation of the cancer hazard from radiation?

    Answer: It certainly has. In a more recent (1969) publication, ICRP 14, the correct numbers are provided by a Task Force of the International Commission. It is extremely simple to show how these newly published numbers give such a greatly increased hazard of cancer from radiation.

          By actually counting extra cancer and leukemia deaths in the 14,000 British subjects treated for arthritis by x-rays, Court-Brown and Doll (quoted in ICRP 14) have shown 5.3 extra cancers for each leukemia produced by radiation.

          Next, the ICRP Task Force pointed out two corrections that are absolutely essential to arrive at the real cancer hazard from radiation.

          (1) Only 40 percent of the bone marrow was irradiated in these 14,000 British subjects. (The leukemias arise primarily in the bone marrow.)

          (2) The organs developing the extra cancers from radiation received approximately 7 percent as high a dose as the spinal marrow. Obviously, to compare cancer and leukemia one must correct the data so they are based upon the same radiation dose. The arithmetic is exceedingly simple.

          First, We must correct the leukemia estimate for the fact that only 40 percent of the marrow was irradiated.

          Thus, to correct to total body irradiation, there would be 100/40 x 1 = 2.5 leukemias for every 1 case observed.

          Second, we must correct the cancer estimate for the fact that the dose to the various organs developing extra cancer was 7 percent of that received by the spinal bone marrow. So, 5.3 x 100/7 = 76 extra cancers for 5.3 observed, after correcting to the same total body radiation dose. Finally, to get the true ratio of radiation-induced cancers to radiation-induced leukemias, we simply take 76/2.5 = 30. So these data, properly corrected by the factors presented in ICRP 14 lead to 30 extra cancers for each leukemia produced by radiation. This means that the earlier estimate (ICRP 8 and 9) had underestimated the cancer hazard by 30-fold just a few years ago.

          Some observers feel that the factor of 7 percent for dose correction (presented by Dolphin and Eve and quoted in ICRP 14) may result in an over-correction. Even if the extremely rash assumption is made that Dolphin and Eve were off by 100 percent, that is, the dose correction should be 14 percent instead of 7 percent, we would be led to estimate that extra cancers produced by radiation are fifteen times as frequent as is leukemia.

          Incidentally, the ICRP 14 analysis doesn't take into account the fact that some organs weren't appreciably irradiated in the 14,000 British subjects. Therefore, for true whole body radiation, such organs will also develop cancers. Therefore, the 15 to 30 cancers for each leukemia is a minimum estimate of the hazard of cancer from radiation.

33. The Gofman-Tamplin estimate of genetic deaths from exposure to "allowable" doses of radiation is 150,000 to 1,500,000 extra deaths per year for a population of 300-million people. How could the standard-recommending bodies have possibly chosen 170 millirads as an average population allowable dose to be acceptable in view of such estimates of genetic hazard?

    Answer: The erroneous thinking of the standard-recommending bodies was even worse on the genetic question than it was on the cancer plus leukemia question. Over a decade ago, these men thought they knew the kinds of genetic injury that would cause deaths. They were focusing on such uncommon single-gene diseases as hemophilia, galactosemia, phenylketonuria, and other rare diseases. Altogether these rare single-gene diseases add up to about one percent of all causes of death.

          Since the standards were set, it has been discovered that most of the major killing diseases of humans have a genetic component, but it appears that more than one gene is involved. Such diseases are, therefore, called multi-gene diseases. Coronary heart disease, which kills more than twice as many Americans per year as all forms of cancer put together, is one such multi-gene disease. Diabetes mellitus, rheumatoid arthritis, and schizophrenia are other examples of multi-gene diseases. As a result of these discoveries concerning multi-gene basis for major diseases of our society, the real genetic hazard problem extends to between 50 and 100 percent of all causes of death, contrasted with one percent that was considered genetic when the standards were set.

          Thus, the radiation standards were set with an underestimation of the genetic hazard by 50 to 100 times as a result of this error alone. It must be acknowledged that new knowledge of the past decade has led us to realize how erroneous the estimate of genetic hazard was when the radiation standards were set. But this is precisely a major point to understand. At any point in time, our medical and biological knowledge is fragmentary. And this means that standard-recommending bodies should lean far over to the conservative side, if they are to do even a minimum job in the field of public health protection.

34. AEC spokesmen say the evidence for cancer plus leukemia comes from high doses of radiation, whereas the standards for peaceful uses of atomic energy are for much lower total doses. Doesn't this alter the hazard estimates?

    Answer: Not one iota. It has been pointed out in earlier questions and answers that every responsible body (ICRP, NCRP, FRC) has stated clearly and repeatedly that the linear proportionality must be used for public health purposes. Therefore, whatever is observed for high doses (say, 100 rads) will be expected to occur in proportion at low doses (say, 5 rads). Thus, if 100 rads produces 200 cancers, it follows that 5 rads will produce 5/100 x 200, or 10 cancers. That's what the ground rules say, ground rules everyone accepts for hazard estimates. There is simply no way to escape this. AEC cannot continue to claim it will behave responsibly and accept sound public health ground rules and then turn around and use gibberish concerning high dose and low dose in attempts to obscure the real hazard.

          Moreover, the statements that all the cancer-leukemia evidence comes from high doses of radiation are simply false. There are experimental animal and human data for low total doses, very damning data indeed. For example, Dr. Alice Stewart's data show that about one rad, a very small dose, delivered to the unborn child in the first 13 weeks of pregnancy will double the potential number of cancers and leukemias during the first 10 years of childhood.

35. Over the years since 1945 a large number of workers within and outside the AEC have been exposed to ionizing radiation. Can we get direct evidence for the effect of radiation in producing cancer and leukemia from the records kept on such workers?

    Answer: Unfortunately there has been inadequate record keeping concerning the fate of workers so exposed. Indeed, only recently has the AEC introduced a procedure to insure that radiation exposure records will be maintained for periods of time long enough to be useful in this regard.

36. AEC spokesmen say the 170 millirad standard for average population exposure is the "improper" standard. They say that 500 millirad (or 500 millirem) at the perimeter of the nuclear reactor is the appropriate standard to use. Further, they state that if this standard is used, it is impossible for the population average dose to ever come near the 170 millirem figure as a result of nuclear electricity generation. What is the response to these claims by AEC?

    Answer: In a simple statement, the AEC claims are irrelevant and simply fail to address the hazard issue at all. The AEC has picked out the least important part of the radiation hazard problem and dwells upon it. In this way the AEC takes note of only the very tip of the iceberg. They have thereby neglected all the important sources of radiation associated with nuclear power generation.

          The perimeter dose of a nuclear power reactor operating perfectly is so small a part of the problem that it is hardly worth discussing at all. Therefore, we must examine the real problems of nuclear electricity generation.

          (1) All authorities recognize food chain accumulation of a variety of radionuclides to be a major problem associated with the release of radioactivity into the biosphere. Even if the releases at the perimeter of a reactor were at the AEC "permissible" value, radionuclides that can go through the forage to cow to milk to human pathway can result in enormous multiplication of radiation dose in humans. Thus, contaminated milk can be consumed hundreds of miles away from a nuclear reactor with the result that people drinking such milk will get far higher doses than one would get by breathing contaminated air right at the reactor fence.

          (2) The fresh water-to-fish pathway can concentrate radioactivity easily 1000-fold or more. Cesium-137 is an illustration of this. Thus, even though a water effluent at the release point may make the water drinkable with delivery of 500 millirems, the fish grown in such water, 1000 times as radioactive, can not be eaten in any quantity without grossly exceeding "tolerance" levels.

          The AEC standards do not give proper attention to these food chain pathways, although the AEC is beginning to correct this error in new licenses, but not adequately.

          (3) The AEC claim concerning population exposures from nuclear electricity generation neglects all of the following important sources of exposure:

    1. Accidental releases at the reactor. No one knows the risk of such accidental release for any of the currently planned reactors, since all of them are experimental reactors, large in comparison with those for which operating experience exists.
       
    2. Accidental releases during transport of spent fuel rods from the reactors.
       
    3. Releases and accidental releases at the fuel reprocessing plants. The one commercial reprocessing plant (West Valley, New York) has a very unfavorable operating experience. (see text)
       
    4. Releases and environmental contamination from low level and intermediate level waste releases and waste burial in the environment.
       
    5. Releases and environmental contamination from storage, burial, or final other disposal of the astronomically high level wastes left after fuel reprocessing. The handling of such wastes is still in the research and development stage, and the economics of such handling remain conjectural.
       
    6. AEC Commissioners themselves are on record saying they cannot be sure that the fuel rods in the reactors will not be leakier than expected from design specifications. Therefore, assurances of releases even under routine operation of new, untried reactors are, at best, conjectural.
       
    7. Accidental releases through sabotage at any step in the entire fuel and waste cycles are not even discussed by the AEC.

Safety Factor in Reactors

37. Don't some AEC and utility officials claim the reactors "safe"?

    Answer: They do claim this. No one alive has any reliable estimate of the risk of major accidents in nuclear electricity generation simply because there is no valid operating experience for the current generation of large power reactors. Claims based on the handful of small power reactors are simply indefensible. Most reactor experts readily admit this. (see text)

38. If we don't have enough operating experience, what is the justification for placing the new, untried larger nuclear electricity reactors near major population centers?

    Answer: There is no justification. A serious moral question is posed here. All AEC and electric utility officials should be asked to answer this moral question.

39. If the AEC is so confident that nuclear electricity generation can go forward with trivial exposure to the population, why doesn't AEC itself argue for lower permissible doses and end all the arguments?

    Answer: This intelligent question has been asked by countless people at symposia, lectures, and in articles. They have yet to receive an intelligent answer from AEC spokesmen. It is, of course, obvious that if the AEC really believed the exposures would be as low as they hope they will be, AEC would assuredly jump at the opportunity to eliminate public concern by lowering the permissible doses. The only rational conclusion the public can draw is that neither AEC nor the electric utility industry has any confidence in these optimistic predictions.

40. The AEC spokesmen repeatedly assure that the releases of radioactivity will be one percent of the permissible AEC limits. Can the public count on this assurance?

    Answer: If anyone really knew what the releases are going to be from the new, large, experimental nuclear plants, the problem would be very different indeed. But no one knows what the releases are going to be, either initially or after various time periods of operation. The best evidence on this can be found in the recent Hearings of the Joint Committee on Atomic Energy (Environmental Effects of Electric Power Production, Part I). When Commissioners Ramey, Thompson and Johnson were asked why such a large "cushion" was required in the form of high permissible standards when the releases were going to be so low, all three men answered truthfully that they simply didn't know what the releases were going to be for the new plants, and, therefore, the high allowable doses were required as a "cushion".

          Obviously, anyone predicting radioactivity releases for new, experimental nuclear power plants is engaging in sheer speculation. It is unfortunate that the public is serving as guinea pigs in this gigantic, speculative experiment.

41. Are there additional reasons for concern over the burgeoning nuclear electricity industry?

    Answer: The speculative character of the estimates concerning routine releases is only one reason for reservations concerning the construction of such plants. There are more compelling reasons.

          (1) The entire nuclear electricity industry, including the electric utility industry, had been misled into thinking that a dose of 170 millirads had a wide margin of safety built in. We now know there was not only no margin of safety, but we know further that the cancer risk is some 20 times larger than thought when standards were set, and the genetic risk is some 50 to 100 times larger than thought when the standards were set.

          Any time that an engineering development goes forward with the false illusion that a 100 or 1000-fold margin of safety exists compared with the real hazard, that entire engineering development can not be trusted in any way.

          The appropriate first step is to stop construction of any further nuclear power plants. Then it is essential to educate the nuclear manufacturing industry and the electric utility industry concerning the true magnitude of radiation hazards. Once they realize the true magnitude of the hazard and they rethink their engineering in terms of the realities they face, reasonable discussions concerning nuclear plants can be held. Not before.

          (2) On January 28, 1970, then Secretary of HEW, Robert Finch, ordered a complete review of all aspects of radiation standards. This review is only now getting underway, and it is estimated that it will take two years. The review is being conducted largely by atomic energy proponents, so that there is no doubt that the conclusions will be subjected to severe scrutiny by the ever-larger informed scientific and lay community. The radiation standards controversy may last well beyond the two years of the formal review, since there may be severe challenges to a review conducted primarily by atomic energy supported scientists.

          No one knows, out of all this, what the new standards for allowable radiation exposure will be. Thus, if new nuclear power plants continue to be constructed under the obviously unacceptable present standards, it may be that such plants will be unable to meet the new standards. This may represent a colossal economic blunder for the electric utility industry, a blunder they would undoubtedly pass on to the electricity consumer in the form of rate increases. It would seem far wiser to have a moratorium on new nuclear plant construction until all aspects of the radiation hazards controversy are settled.

          (3) In spite of numerous irresponsible assurances to the contrary, no one knows the risk of a catastrophic accident for the large, experimental nuclear power plants now being planned for and built near major population centers. There simply is no relevant experience upon which to draw. Dr. Walter Jordan, a nuclear expert, and a member of the AEC Atomic Safety and Licensing Board, has spelled this out in no uncertain terms in his article, entitled `Nuclear Power, Benefits versus Risks', which is published in Physics Today, May 1970. In that article Dr. Jordan admits we have no idea of the odds of a major accident because we have no experience. It is not reasonable to have the population of American cities become the guinea pigs for such experience.

Price-Anderson Act—
Insurance Against Personal and Property
Damage from Nuclear Accident

42. Is it true that the American public does not stand to recover from damages suffered as a result of nuclear power accidents and damage to property?

    Answer: Sadly, but unfortunately, this is true. Historically, we know that neither the electric utility industry nor the private insurance industry was willing to gamble money on the liability that might be incurred in a major nuclear power accident. An AEC report (WASH-740) itself indicated that for the earlier, much smaller, nuclear power installations, an accident could result in 7-billion dollars in property losses. Because of this, the nuclear electricity industry was at a standstill. The promotional Joint Committee on Atomic Energy pushed through Congress a notorious piece of legislation, the Price-Anderson Act, which, in effect, absolved the electric utility industry of real liability for major accidents. This Act, at the same time, removed any hope for the citizen to recover more than a nominal part of damages suffered. Thus, the Price-Anderson Act decreed that, no matter how severe the damages, the maximum to be paid out for a single nuclear power disaster is 560-million dollars. Simple arithmetic shows that for an accident causing 7 billion dollars of damage the citizen, at most, could hope to recover seven cents on each dollar lost.

43. Why should the electric utility industry be freed of liability for damage its nuclear plants cause, when other industries have to stand behind their activities fully?

    Answer: The only answer possible is that this represents a shocking disfranchisement of American citizens, perpetrated by those who wish to promote atomic energy at any price to the public. Certainly the repeal of the Price-Anderson Act is an early item of the highest priority for citizens concerned about their lives and property.

44. If the Price-Anderson Act is repealed, would the electric utility industry be willing to go ahead with nuclear electricity generation?

    Answer: There have already been a number of statements by utility officials that they would not go ahead with nuclear power plants if they had to bear the financial liability for the consequences of major accidents. And we also know that the private insurance industry refuses to insure the full liability for major accidents. Thus, the ill-considered nuclear electricity industry would undoubtedly come to a standstill if it had to be financially responsible, as all other industries must be.

45. If nuclear electric power plants can not be insured for the full amount of damages they can produce in a major accident, why does the AEC, a governmental agency, allow such plants to be licensed at all?

    Answer: If we had a rational society, it would be unthinkable for a governmental agency, such as AEC, to grant a license for building nuclear power plants that cannot be insured for the real damage they can wreak upon the public. But the Congress has acted very unwisely in giving a promotional agency, AEC, the power to license the wares it sells. Obviously there is an extreme conflict of interest here. The AEC, favoring its promotional role, goes ahead to license nuclear plants that are uninsurable.

46. Can't the individuals in the public recover damage, from nuclear power plant accidents through their personal homeowners' policies?

    Answer: Not a chance. The private insurance industry, with a notable reputation for making money, realized the hazards of the advent of the nuclear electricity industry. They, therefore, moved swiftly to protect themselves, not the public. Thus, most homeowners' policies now have a nuclear exclusion clause absolving the insurance company of liability for home damage caused by nuclear accidents or radioactivity.

          While the insurance companies are to be commended for their financial wisdom in protecting themselves against the nuclear electricity industry, it is sad that the public is almost totally unaware that this action has left them in a position to lose catastrophically. Every citizen should be informed about his loss of rights to recover for property damage.

47. Is there any reasonable compromise on this issue of safety and insurance against nuclear power plant accidents?

    Answer: Yes, there is one excellent compromise. Stop licensing any nuclear power plants until the insurance industry can be convinced to provide full coverage for losses sustained from nuclear power plant accidents. Either the nuclear power plants are safe enough to be fully covered by insurance, or they are too unsafe to be licensed at all. There is no middle ground.

48. It is said that the reason why private insurance companies refuse to cover the full liability of nuclear power plants is that they have no "actuarial" experience with such accidents upon which to base insurance rates. Is is this true?

    Answer: Absolutely correct. The private insurance companies are far too shrewd to accept the optimistic, but totally unsupported, reassurances concerning safety emanating out of the Atomic Energy Commission. The insurance industry, having no relevant experience, refuses to risk dollars. But the American public, also not having the relevant experience, are being forced to risk their lives m a gigantic experiment.

"Clean" Nuclear Plants vs.
"Dirty" Fossil Fueled Plants

49. Isn't it true that fossil-fueled plants also create a health hazard? Would it be wise to stop nuclear electricity plants and accept the hazard of poisonous emissions from the dirty, fossil-fueled plants?

    Answer: Dirty, fossil-fueled power plants are a national disgrace. Every citizen should be adamantly against being poisoned by them as he should be against being poisoned by deadly radioactive emissions.

          The real truth is that this question is phrased poorly, representing a phrasing that is carefully sponsored by the public relations branch of the nuclear power industry. The nuclear power industry wants the public to think that the choice is between dirty fossil-fueled plants and nuclear power plants. This is simply ridiculous. The technology to stop the poisonous emissions from outmoded fossil-fueled plants is far developed, and could be installed in the near future, if the demand for this were insistent. It is up to the public to declare its outrage against such poisonous emissions.

          We could have eliminated the poisonous emissions from old fashioned fossil-fueled plants long ago. But all the research and development funds that should have gone in this direction were siphoned off into atomic energy. This has been a grave error. There is no doubt that we can and should have clean power from fossil-fueled plants. We will have if we insist upon it. Public pressure is the effective tool to achieve this.

50. Are there even more attractive alternatives than fossil fuel or nuclear power?

    Answer: There are two parts to the answer. The first and most important task is to introduce some reason in the dialogue concerning electric power requirements. The electric utility industry stampedes the public into nuclear power with the threat of brownouts and blackouts and at the same time spends an advertising fortune to stimulate the use of more electricity.

          Mr. Charles F. Luce, Chairman of New York's Consolidated Edison Company, as recently quoted (Time Magazine p. 40, December 28, 1970) takes an eminently sensible position:

          ". . . But last week he told a startled Manhattan audience: `The wisdom of three years ago is the idiocy of today.' Instead of trying to increase consumption (of electric power), he now wants to decrease it.

          "Luce is regarded as one of the most socially responsible leaders in the utility business . . . (Conservationists) argue that power generation also generates pollution—and now Luce has publicly agreed with them. . . ."

          Mr. Luce is certainly to be commended for raising "the serious question of whether we ought to be promoting any use of electricity."

          The second part of the question of alternatives is equally important. Here again Mr. Luce has made a worthy suggestion: "As a long term solution, Luce last week suggested a new federal excise tax of `perhaps 1%' on electric bills to speed new ways of generating power compatible with the environment." Here Mr. Luce has come to grips with the heart of the problem, which is to press forward with methods for electricity generation compatible with the environment.

          Numerous attractive opportunities abound, including solar power, geothermal power, clean fossil-fueled power, increased efficiency of power plants, and fusion power. If some of our elegant scientific talent were stimulated to develop these sensible approaches, we would undoubtedly hasten an early ecologically-sound solution for electric power generation.

          The first step is to break the stranglehold on energy research and development dollars that has been held by the super-promotional, narrow-visioned Joint Committee on Atomic Energy.

Scientific Objectivity and Radiation Damage

51. The Chairman of the AEC, Dr. Glenn Seaborg, is a highly respected scientist. Can't we rely on him to take an objective view of radiation hazards?

    Answer: Dr. Seaborg is indeed a highly respected, capable scientist. Yet in recent speeches he has taken a position diametrically opposed to all sound public health principles in assessing radiation hazards. In effect, he has ridiculed sound public health practices in the following statement from his November 19, 1970 talk entitled "Power, People, and the Press." Let us quote Dr. Seaborg directly:

          "Unfortunately, much of the alarm being generated today is based upon speculation that has its roots only in manipulating statistics—in large linear extrapolations. These make the assumption that if X number of people are killed by a certain high level of radiation, known numbers of other deaths can be deduced at each decreasing level. But as a prominent radiation expert recently pointed out, such extrapolations can become ridiculous, and especially upon reaching certain low levels. They are, in effect, saying that if 1000 people die in a 100-mile an hour hurricane, 100 people will die in a 10-mile an hour breeze.

          "Though I admit this analogy is not a scientifically accurate comparison with radiation effects, such ridicule seems justified because there is much evidence of biological repair mechanisms that counteract the effects of low levels of radiation. . . ." (Glenn T. Seaborg)

          Dr. Seaborg has, in this unfortunate speech, chosen to ridicule the sound public health principles adhered to by all responsible scientists concerned about radiation hazard and he has chosen to ridicule the sound principles adhered to by all responsible standard-recommending bodies, including ICRP, NCRP, and FRC.

          The public should now address individual letters to Chairman Seaborg and ask him to produce one iota of evidence that is convincing of any biological repair mechanism that will protect against cancer and leukemia from low levels of radiation. If he has such evidence, it has been thoroughly hidden from the scientific community.

52. Why does Chairman Seaborg of AEC try so hard to ridicule the hazard of radiation?

    Answer: He does not like to admit that he made a mistake. None of us do. He and other atomic energy officials began an intense promotional campaign of promises about the wonders of nuclear electricity several years ago before the extremely serious hazard of radiation was appreciated. It is one of the most difficult problems any human must face to admit past errors and to face unpleasant realities.

          Undoubtedly, the public would admire Dr. Seaborg's courage if he faced up to the issue squarely and said he realized now that the hazards of atomic energy programs are far greater than he previously thought. Everyone makes mistakes, and the public admires men who can forthrightly acknowledge mistakes. This is especially true when the mistakes were based upon erroneous knowledge of the past.

53. Isn't the problem of defensiveness a serious problem of technology in general with respect to environmental problems?

    Answer: Absolutely. Until recently, technology was given a green light to develop hardware as rapidly as possible. Today we recognize that such technology can produce an unbearable environmental burden. Nuclear power may represent one of the best examples of this. How can we expect men whose professional lives, jobs, and fortunes depend upon a particular technology to view the abolition of their technology with equanimity? If they weren't defensive, they wouldn't be human. Job security and professional life work are very important to people.

54. Is it being suggested that society foot the bill for ill-advised technological ventures?

    Answer: Representatives of our government pushed atomic energy upon industry. Many scientists and engineers were urged to prepare for careers in this field. Now with a greater awareness of our environmental crisis, all of us must share to some extent in the burden of a change in direction. Just as we must make accommodations (with tax money) for loss of jobs and careers in other fields, so must we assume some of the responsibility for tiding the Atomic Energy Commission over the setback that will occur when the building of nuclear power plants is postponed, until we know how to make them safe.

Why So Much Fuss Over Such a Little
Radiation from Nuclear Plants?

55. Nuclear power advocates commonly state that the radiation one might receive by living in the near vicinity of a typical operating plant site for an entire year is equivalent to about what one would receive on a single round trip, coast-to-coast airplane flight. If the radiation is so low, why is there any concern about nuclear power?

    Answer: Nuclear power advocates almost step over one another in their hurry to claim how little radiation one will get from nuclear power generation. This should be greeted with, "Bravo!" Since nuclear power advocates claim it is ridiculous to think any significant radiation will be delivered, the nuclear power advocates should be the vanguard in the fight to lower the allowable radiation doses to the public. So far, when such optimists are asked why they aren't fighting to lower the allowable doses, they are speechless. Just as soon as their actions begin to match their words, credibility might be assigned to them.

56. Isn't it true that medical exposure to x-rays is providing more radiation dosage to the public than nuclear power at present (1970)?

    Answer: Yes. This points up two necessities:

          (a) Every effort should be made to reduce the exposure in the course of medical diagnosis. This can be done and is being done. Dr. Karl Z. Morgan has courageously campaigned for reduction in x-ray exposure from medical and dental use of x-rays.

          (b) We should be very happy to have discovered the serious hazard of radiation before the nuclear power industry has led to a prospect for irreversible pollution of the environment. It is very hopeful that we can stop the nuclear power stampede before it has done irreversible damage, rather than later.

57. In a speech on May 21, 1970, the late Commissioner Theos Thompson stated the following:

          "Radiation is understood much better than almost any other of the possible effects caused by man or his environment. It is strange that we who believe that atomic energy is an improvement in our environmental situation find ourselves attacked on the environmental basis, when we know full well that when the final choice is made, nuclear power will prevail because the alternatives to nuclear power will have much worse effects on human health!"

           What is the answer to such comments?

    Answer: It is because we know now how hazardous radiation is that we should reject a stampede to nuclear electricity which is certain to increase radiation hazard. It makes no sense to plunge headlong into a technology where we know the hazard is large.

          As to the hazard of alternatives, we most certainly should not accept dirty fossil-fueled power plants instead of nuclear plants. But it is only the limited vision of nuclear power advocates that results in their failure to appreciate that environmentally-sound alternatives can be and must be made available.

          This is an excellent illustration of how a parochial interest leads to a limited vision concerning possibilities for alternatives. There are very few reasons for believing any rational society will make "final" choices in favor of nuclear fission power.

58. In that same speech, the late Commissioner Thompson stated:

          "If a state agency arbitrarily lowers the levels which are permissible in the state until they are barely above normal levels, they run some risk that at some time they will either have to require shutdown of this plant, or else find some graceful way to back off from their own regulation."

          What are the implications of this statement?

    Answer: Commissioner Thompson was, in effect, saying that no one really knows how much radioactivity would be emitted by the new plants. Therefore, he was warning states against restricting releases of radioactivity.

          Of course, his comments are correct. What he is saying is that the promises of the nuclear electricity industry concerning how little radioactivity they are going to release are simply empty, untrustworthy promises. In effect, it is fine for nuclear electricity advocates to promise low releases of radioactivity to the environment, but it would be unfortunate if regulations were enforced to make them adhere to their optimistic promises.

59. In a speech (January 23, 1970) AEC Commissioner Larson stated the following:

          "During the 27-year period (of nuclear power development) there has not been a single nuclear reactor accident in which a member of the public has been injured in any way whatever. This safety record is unequalled in any other industry in this country. This experience covers the operation of 435 nuclear reactors."

          What is the answer to this claim?

    Answer: First of all the nuclear reactors of this period were almost all tiny compared with the giant plants now being built, so the "27 years" of experience is hardly meaningful. Second, no one really knows how much total radioactivity was released by all these plants, since very few of them were independently monitored. Third, and most important, the claimed safety is only by definition. The way the Atomic Energy Commission operates is to deny all the extra deaths due to radiation. Having denied the deaths, they then claim safety. How is it that they "deny" the deaths? Very simply. Radioactivity has been released from many of these nuclear power reactors. First, the AEC calls an amount of radiation that can produce cancer by the term "safe". Having done this, they deny culpability for any deaths caused in people who have received this falsely "safe" dose. So, many people can be killed by such "safe" doses of radiation and the AEC simply denies the deaths by saying, "How can these people have been hurt by radiation—they received no more than our `safe' dose?"

          Thus, suppose the U.S. population were to receive an average exposure of 170 millirads per year and were to build up to 32,000 extra cancer plus leukemia deaths each year due to the radiation. Commissioner Larson would, by his reasoning, still say nuclear radiation had caused no deaths, simply because he would define the 170 millirads as the "safe" dose, and he would therefore dismiss the extra 32,000 deaths each year as non-existent.

Is Nuclear Power the Only Answer
to Future Needs?

60. AEC Chairman Seaborg stated (April 22, 1970) the following:

          "It has long been recognized that nuclear energy's full promise for providing a virtually unlimited energy source for future generations could be realized only through the development and application of the breeder reactors."

          Is this statement correct?

    Answer: This statement of AEC Chairman Seaborg is a classic illustration of the parochial absence of vision that characterizes nuclear power advocates. Numerous responsible scientists have indicated that solar power, geothermal power, and fusion power have excellent promise to provide unlimited power with minimal environmental deterioration. The limited vision of AEC Commissioners prevents them from seeing these possibilities, as they continue to focus upon nuclear fission power.

          One might add that with the plutonium hazard introduced along with the breeder reactor, it is problematical as to whether future generations would get to enjoy the "unlimited energy source."

61. In that same speech, AEC Chairman Seaborg said:

          ". . . it is the utility (industry) which has the basic responsibility to make sure that the plant is designed, constructed, and operated to meet requirements for safety, reliability, and economics."

          Is it true that the electric utility industry carries these responsibilities, and that AEC is not responsible?

    Answer: Sadly enough, this is true. And the consequences are horrible to contemplate. The electric utility industry has been misled by the AEC into thinking the "allowable" doses of radiation have a wide margin of safety in them, when indeed we know there is no margin of safety. So the utilities have gone ahead with all their engineering with this false illusion of safety. While Dr. Seaborg is right that the utility industry will be the patsy for the deaths that will be produced, the real losers will be the unfortunate citizens who develop the radiation-induced cancers and leukemias.

Environmental Considerations with
Nuclear Power Plants

62. Chairman Seaborg continued:

          "But when we hear members of the scientific community express the view that despoilation of the environment might make life untenable on this planet by the year 2000, we can but wonder if they know something we don't know."

          Is it really true that no one has told the AEC the true facts concerning radiation hazard?

    Answer: It is regrettably true that members of the scientific community do know something the AEC does not know. The difficulty does not arise because the AEC hasn't been told about radiation hazards. The difficulty arises because the AEC refuses absolutely to listen to anything concerning radiation hazards.

63. Another statement the AEC Chairman made in that speech:

          "In our efforts to bring about increased public understanding, I see one need as central and pervasive. That is the need to create a heightened awareness of the need for energy, of the extent to which it is essential to our welfare today, and of our increasing dependence on it in the future, particularly with respect to protecting the environment. . . ."

          Is this really what is needed?

    Answer: At a time when all those concerned with the environmental crisis have come to recognize the pollutional aspects of energy consumption and the wisdom of questioning increases in energy consumption, the AEC is 180 degrees out of phase and is, in effect, arguing in favor of more of the same approach that brought on the environmental crisis in the first place.

64. In a speech (March 26, 1970) Commissioner Larson said:

          "Far from being one of the curses of the nuclear age, as many well-meaning laymen believe, the nuclear waste disposal problem is, in fact, one of the smaller such tasks in our modern high consumption society."

          Is it really true that nuclear waste disposal is no problem?

    Answer: Apparently so for the AEC. But a committee report of the National Academy of Sciences was severely critical of AEC waste disposal practices—practices which could lead to serious fouling of the environment. Indeed the report was so critical of AEC waste disposal practices that the AEC suppressed it for over three years (see text).

          News accounts of AEC laxity in waste disposal practices appear repeatedly. The AEC is not yet convinced that the earth is finite in its capacity to serve as a sewer. Probably, this is why Commissioner Larson feels that the legacy of radioactive garbage is perfectly appropriate for us to visit upon future generations.

Informing the Public on Nuclear Power

65. In a speech (April 4, 1970) AEC Commissioner Ramey stated the following:

          "Despite our efforts to inform and listen to the public however, we have been charged with failure to inform the public or to consider the public's views in the setting, by rule, of radiation-emission standards for nuclear power plants. . . ."

          What is the answer to Commissioner Ramey's statements?

    Answer: There can be no doubt that the AEC has spent millions of dollars to "inform" the public. The only difficulty is that all the "information" represents a Madison Avenue huckster message, replete with fairytales about "clean, cheap, safe nuclear power." It is impossible to find any evidence that would indicate effort by the AEC to present to the public a balanced set of information concerning the radiation hazards question.

          With respect to the public's point of view being heard, the record of AEC Atomic Safety and Licensing Board Hearings can only be regarded as a national disgrace. The real issue before such Boards should be:

          (1) The validity of the primary radiation standards,

          (2) The moral question of going ahead with nuclear power plants when safety cannot be assured. Neither of these questions has been admissible. The public has been limited to proving that the design specifications for the particular reactor do not meet the established standards. If it is the established standards that are really in question, it is the public's right to question these standards. The failure to allow this is the essence of the answer to Mr. Ramey's plaint. Indeed, the AEC deserves more severe criticism than it has received for its manifest failure to listen to the proper questions raised by the public,—a public acting appropriately to protect life and property.

66. In that same speech, Commissioner Ramey went on to say:

          "Members of the public whose interests are affected can intervene in these hearings, and can call witnesses and cross-examine in order to try to satisfy themselves as to the safety of the proposed plant."

          Is it true that the public has all these opportunities?

    Answer: In principle, the public has these opportunities. In practice, the public is deprived of the opportunity in such a way as to mock our democratic society. First, it has been estimated that a successful intervention would require $100,000 to $200,000. Why should the public be forced to provide such funds to raise appropriate questions? Why should taxpayer dollars be utilized by the AEC to prevent the public from being adequately represented and heard? Second, the rules concerning what questions can be raised in such hearings make it impossible to raise any of the pertinent issues about which the public is properly concerned. These really pertinent issues are listed in the previous question.

67. Later in the same address Commissioner Ramey stated:

          "Discharges of radioactive materials from nuclear power plants operating to date have generally been only a few percent of the AEC limits."

          Is this true?

    Answer: Commissioner Ramey's statement is an illustration of the one-sided, distorted picture presented by nuclear power advocates. It is true that many plants, under routine conditions, have operated at a few percent of AEC limits. But why does Commissioner Ramey not add to his statement that the Dresden Plant had a period of over a year at about 30 percent of AEC limits and the Humboldt Plant, for a long period, operated at between 55 and 60 percent of AEC limits?

          Why does Commissioner Ramey not discuss the appalling state of affairs at the West Valley Fuel Reprocessing Plant, where citizens groups had to go out to measure and prove that the releases were far above "a few percent of AEC limits"? Why does Commissioner Ramey not mention that once the citizens groups discovered the sad state of affairs at this plant, their findings were confirmed by the Bureau of Radiological Health? It is the omissions by men like Commissioner Ramey that lead to the loss of credibility of the AEC.

Who Are the Critics of Nuclear Power?

68. Commissioner Ramey further stated:

          "There are a lot of people going around the country spreading `scare talk' about nuclear power. Some of these people whom I have called the stirrer-uppers, like Larry Bogart, apparently make their living by creating controversy without regard to fact. Others are scientists who haven't done their homework or who insist on broadcasting their theories without first subjecting them to the review of their peers."

          Is there any validity to Commissioner Ramey's remarks?

    Answer: None. Society has far more to fear from the proponents of nuclear power who resort to the type of slander evident in Mr. Ramey's remarks. Gofman and Tamplin offered to test the sincerity of those who claim they want a review of the evidence by peers. They did this on January 28, 1970 by offering to debate the radiation hazards question with the AEC before a jury of the most eminent scientific peers. This offer is in the Hearings of the Joint Committee on Atomic Energy in print. (Environmental Effects of Producing Electric Power, Part 1). The AEC has steadfastly refused to participate in consideration of the evidence before a jury of eminent peers.

          Mr. Ramey must be fully aware of this offer. If he is not aware of it, then he, as a Commissioner, is the one "who hasn't done his homework" by failing to know what is in those hearings. Moreover, he was present at those hearings.

          What can the public think of the AEC, having itself declined to accept a review before peers, subsequently criticizing others for failing to subject their findings to a similar review? Can it be that the AEC, and not its critics, fear the review of the evidence. The record is quite clear for all to examine.

69. In a speech (February 9, 1970), Commissioner Ramey charged:

          "Gofman and Tamplin and others are . . . violating one of the cardinal principles of scientific endeavor by not subjecting their conclusions to the normal review of their scientific peers. Instead they are trying their cases in the press and other public forums. We used to call such characters `opera stars'."

          What is the answer to this charge?

    Answer: It should be expected of public officials at the high level of AEC Commissioner not to voice such totally irresponsible statements. Unfortunately for the AEC, they destroy the credibility of the AEC, not the credibility of Gofman and Tamplin.

          The record on this matter is clear. The Gofman-Tamplin findings were presented before a highly respected scientific forum, a Symposium on Nuclear Science before the Institute for Electrical and Electronic Engineering at San Francisco, October 29, 1969. It would be difficult to imagine a more appropriate forum. Let us quote from the published Transactions of that Symposium[1] (a highly respectable Scientific publication) why that presentation was requested by the distinguished Program Committee of that scientific society:

    "Up until the last few decades, man's ability to pollute his environment was relatively slight. In recent years however, the combined population and technological "explosions" have magnified this hazard to awesome proportions. The engineering community has a major responsibility and role in understanding and controlling this situation before it is too late. The Plenary Session was most effective in presenting these problems through the presentation of five invited papers:

    1. "Pollutants and Natural Minor Constituents of the Upper Atmosphere"—Dr. E.A. Martell, National Center for Atmospheric Research, Laboratory of Atmospheric Sciences, Denver, Colorado
       
    2. "The Chemical Invasion of the Oceans by Man"—Dr. Edward D. Goldberg, Scripps Institution of Oceanography, La Jolla, California
       
    3. "Stable Isotope Measurement of Sulfur Pollutants"—Mr. Bernard Manowitz, Brookhaven National Laboratory Upton, Long Island, New York
       
    4. "Low Dose Radiation, Chromosomes, and Cancer"—Dr. John W. Gofman, Associate Director, Biomedical Division, Lawrence Radiation Laboratory, University of California, Livermore, California
       
    5. "Fast Breeder Reactors—Status and Prospects"—Mr. P.M. Murphy, Manager of Advance Engineering, Breeder Reactor Development Operation, General Electric Company, Sunnyvale, California

    Unfortunately for those who did not attend the Symposium, it is only possible to include the last two of these excellent papers in this issue of the Transactions.

          Gofman and Tamplin pleaded for the AEC to join them in a review before peers, and Commissioner Ramey knows this full well. He knows, too, that Gofman and Tamplin have published their findings in several scientific journals, with thorough review by "peers." Commissioner Ramey knows that his statement concerning "trying their case in the press and other public forums" is fatuous and as valid as a three-dollar bill.

70. In that same speech Commissioner Ramey continued:

          ". . . We have made less (progress) with our non-scientific antagonists—the `rag tag' stirrer-uppers such as Larry Bogart and others who use high school debating techniques which are sometimes surprisingly effective. They seem most vulnerable when asked what alternatives they might suggest to meet the increased needs for electric power. Some, like Bogart at the Senate appropriations hearings last fall, talk about some far-out alternatives such as MHD (magneto hydrodynamics) or harnessing the Gulf Stream, or using solar energy or even tidal power. One finds also a certain softness by them in relation to coal and fossil sources, and some obtuseness as to the air pollution problems of these competitive sources. I believe the ridiculous position of these fellows could be made more evident."

          How shall we view these remarks of Commissioner Ramey?

    Answer: Mr. Ramey speaks for himself with respect to his disdain for the lay public and the excellent questions they raise concerning alternatives for electric power production. Indeed, distinguished scientists and engineers are giving extremely serious consideration to the very alternatives Mr. Ramey ridicules. While Mr. Ramey scoffs at the prospects for clean power from coal and other fossil fuels, Dr. Philip Abelson, Editor of the Journal, Science, writes that a high national priority is the research and engineering to derive clean power from coal.[2] (Science, 1970.)

          While Mr. Ramey scoffs at processes such as Magneto-hydrodynamics for increasing the yield of electrical energy per unit of fuel utilized, responsible scientists such as Dr. Arthur Squires (Science, 1970) point up the importance of processes of this sort.[3]

          While Mr. Ramey scoffs at the far out aspects of solar power, highly regarded scientists point to the importance of a thorough evaluation of solar power. (Solar Energy—Resource of the Future by Peter E. Glaser, Ph.D., Chief of Engineering Sciences, Arthur D. Little, Inc., Acorn Park, Cambridge, Massachusetts 02140. For the National Energy Study, U.S. Dept. of Interior.)

71. In that same speech Commissioner Ramey said:

          "I am afraid we are headed for a rather turbulent period. What does this mean, then, in terms of public relations and understanding? Obviously we are going to have to do much better in communicating with the public. We will have to show through our words, and more importantly by our actions that we indeed are performing a useful function in a responsible way with the public interest foremost in our minds."

          What should one say about this statement of Commissioner Ramey?

    Answer: It is a wonderful statement. Commissioner Ramey is confirming what the public already knows, namely, that the AEC has done a terribly poor job of convincing anyone that they are performing a useful function in a responsible way with the public interest foremost.

          As a suggestion to Commissioner Ramey and his colleagues for their self-help, improvement programs, one might suggest one simple ingredient, candor.

72. Commissioner Ramey further stated:

          "Nuclear power is a fact of life and I am convinced the public will reach a point in time that they will not only embrace nuclear power—they will clamor for it. So through this interim period we must retain our patience and our good humor and do the best possible job in planning and building plants properly, running them right and helping the public understand this new source of energy."

          How are these statements to be viewed?

    Answer: There are many "facts of life" the public never seems to clamor for. Among them are poliomyelitis, tuberculosis and cancer. Commissioner Ramey may find nuclear power as another "fact of life" that may be added to this list.

          As for the statement about "helping the public understand this new source of energy," this would be an extremely welcome contribution on the part of the Atomic Energy Commission. A good place to start would be an honest presentation of the hazards of nuclear power, an answer to the question of the morality of going ahead with nuclear power installation when safety cannot be assured, and a cessation of a one-sided propaganda campaign about "the wonders of the atom."

73. In a speech by AEC Chairman Seaborg, the following is stated (May 5, 1969):

          ". . . a recent resurgence of anti-nuclear articles designed to alarm the public about the growth of nuclear power when it should be enlightened about it. Many of these articles use the effective propaganda technique known as `stacking the deck'—the technique of taking all the detrimental, isolated facts and information about a subject, misinterpreting other factual material, adding numerous statements—taken out of context—by authorities in the field, and placing all this material in a story that gives a completely one-sided viewpoint. Specifically, every fact and statement in such a story may be true, while the article as a whole, and the conclusion it draws, may be invalid and misleading. Such dishonesty is made more harmful by the fact that these articles are written as exposes and crusades in the public interest."

          What can one say about these remarks of Chairman Seaborg?

    Answer: There are two important conclusions to draw from Chairman Seaborg's remarks.

          (1) It is easy to understand Chairman Scaborg's dismay that people look at all the facts and come up with the "one-sided view" that they don't want nuclear power.

          (2) With respect to his statement that "the article as a whole, and the conclusion it draws, may be invalid and misleading," one can only conclude that he must be referring to the numerous press releases of the U.S. Atomic Energy Commission. There are no better examples of this anywhere.

74. In the early phases of the radiation hazards controversy the nuclear power proponents denied the seriousness of the radiation hazard associated with "permissible" doses. When too many scientists began to agree that the hazard estimates were correct, the nuclear power proponents stopped the denial approach, and shifted to the claim that the standards don't mean anything since nuclear power programs would never deliver the "permissible" dose to the public.
    
          How should the concerned public view this change in position by nuclear power proponents?

    Answer: The answer is simple. If the nuclear power proponents are so sure the public will never be given the "permissible" doses, they (the nuclear proponents) should be in the forefront of the effort to reduce the "permissible" doses.

          In a country which operates under law, one thing, and one thing alone, can guarantee that exposure to a poison will not occur, and that is to make it illegal for it to occur. It makes no sense whatever to permit something realized to be disastrous.

          The concerned public must insist, again and again and again, that the nuclear power proponents demonstrate the sincerity of their belief that the "permissible" dose won't be reached by the only sound approach—and that approach is to abolish the permissibility.

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1. I.E.E.E. Transactions on Nuclear Science, February 1970, volume NS-17, No. 1. Part 1.
   
   
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2. Abelson Philip H. "Scarcity of Energy," Science, Vol. 169, No. 3952 Sept 25, 1970. (See Chapter 9)
   
   
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3. Squires, Arthur M. "Clean Power From Coal" Science, vol. 169, 821-828, Aug. 28, 1970. (See Chapter 9)