ORDES
Volume IV
Independent Comments
June 1978
PHASE I
OHIO RIVER BASIN ENERGY STUDY
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ORBES Volume IV
Phase I
June 1978
OHIO RIVER BASIN ENERGY STUDY
INDEPENDENT COMMENTS
Grant Number R804848-01
Prepared for
Office of Research and Development
U.S. Environmental Protection Agency
Washington, D.C. 20460
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Boyd R Kefinan James J. Stu.vi
Project Olfice Project Office
Ocl-ober 19, 1978
Lowell Smith
ORBES Project Officer
U.S. Environmental Protection Agency
R.D.-681
Washington, D.C. 20460
Dear Lowell:
We are pleaded to transmit to you the final volume of the ORBES Phase I report
series: Volume IV, Independent Comments (enclosed). As you know, last April, upon
completion of the review draft of the Phase I integrated summary report (Volume I-A) ,
all members of the Advisory Committee during Phase 1 and all first-year ORBES re-
searchers were invited to send us comments on this draft. At the same Lime we in-
vited comments on other aspects of ORBES Phase I, including other reports. Each
Advisory Committee member and Phase I researcher was given the opportunity to pre-
sent up to ten single-spaced typewritten pages of comments. These unedited remarks,
reproduced directly from the originals, make up Volume IV.
All the comments that we received were reviewed carefully, and a number of the
points made in them were used as the basis for chances in our final version. You
will "loto these changes when comparing the draft Phase I report with the final ver-
sion, which was sent to you last July. Under the stipulations of our Phase I Ex-
perimental Management Plan grant, the summary report is to be submitted by EPA to
Congress.
Again, let us express our pleasure in transmitting to you the last formal docu-
ment of ORBES Phase I.
Sincerely,
Boyd R. Kecnan
mtr Jamos J. Stukcl '
Co-Principal Investigators
Enclosure
cc: Core Team
Management Team
Advisory Committee
345 Advanced Computation Builcimg/1011 West Springfield Avcnuc/Urbana. IL 618017(217) 333-0861. J33-1107
rmMr-MCTj-iTrMMr.^M^if-ir^JCTMggra^
OHIO RIVER DAS!M ENERGY SI
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CONTENTS
Foreword
Comments by Advisory Committee Members
J. P. Apel ........................... 2
Hugh A. Barker and Owen A. Lentz ................ 12
Harold G. Cassidy ....................... 18
James P. Darling ........................ 24
Fred E. Morr .......................... 29
U.S. Environmental Protection Agency, Region V ......... 30
Carl B. Vance ......................... 38
Comments by Phase I Researchers .................. 43
John F. Fitzgerald ....................... 44
Ross J. Martin ......................... 47
K. S. Shrader-Frechette .................... 50
ii
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FOREWORD
The Ohio River Basin Energy Study (ORBES) is a multiuniversity activity
whose objective is to assess potential environmental, social, and economic im-
pacts of proposed power plants and other energy conversion facilities on a
major portion of the Ohio River Basin. The study came about through the ef-
forts of a group of environmentally aware citizens who, in the early 1970s,
became concerned over plans for accelerated power plant development along the
main stem of the Ohio River. Responding to these citizens, in 1975 the Con-
gress directed the U.S. Environmental Protection Agency (EPA) to perform a
specific research project: "This study should be comprehensive in scope, in-
vestigating the impacts from air, water, and solid residues on the natural
environment and residents of the region."
To carry out the congressional mandate, in 1976 EPA awarded a series of
one-year grants to researchers at six state universities located in four Ohio
River Basin states, announcing that these grants represented the first phase
of a proposed three-year project. These institutions were Indiana University,
the University of Kentucky, the University of Louisville, the Ohio State Uni-
versity, Purdue University, and the University of Illinois (both the Urbana-
Champaign and the Chicago Circle campuses). During the first year (1976-77),
the researchers investigated basic high-energy-growth and low-energy-growth
scenarios for future energy development in the study region. The implications
of these scenarios were addressed by three preliminary technology assessment
team efforts as well as by ten special studies in areas requiring more de-
tailed exploration than was possible by the three teams.
Other important participants during the first year were members of the
project Advisory Committee, whose responsibilities include reviewing project
documents and providing counsel and assistance to ORBES researchers. Advisory
Committee members are drawn from both public and private groups affected by or
making decisions on energy facility siting in the project study region. In
the spirit in which ORBES originated, the committee is a major element of the
continuing involvement of the public in the study. During Phase II of ORBES,
which began in November 1977 and is expected to last two years, the commit-
tee's role and composition have been expanded. This expansion parallels the
extension of the study region from major portions of Illinois, Indiana, and
Ohio, and all of Kentucky, to encompass southwestern Pennsylvania and most of
West Virginia.
As co-directors for the ORBES Experimental Management Plan under our own
EPA grant, one of our responsibilities during the first year was to integrate
selected findings into an interim report for submission to Congress. When
appropriate we also consulted non-ORBES findings available from other EPA-
111
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sponsored research and other sources. The interim report concentrated on com-
paring the impacts of the basic low- and high-energy-growth scenarios as pro-
jected for the year 2000. Entitled ORBES Phase I; Interim Findings, it be-
came Volume I-A of the first-year report series. The report also is being
published by EPA in its own edition for wide distribution.
Collected in this volume of the series—Volume IV—are comments on a
draft version of Volume I-A. Each Advisory Committee member and university
researcher was invited to review and submit responses to the draft integrated
report and any other aspect of ORBES. They were asked to pay particular at-
tention to the policy issues listed in the four substantive divisions of the
report: natural resources, developed resources, the biological and ecological
environment, and public health, economics, and society. A number of the
points made by these reviewers were considered in revising the draft report.
Because of these revisions, many of the comments do not apply to the final
version of the integrated report; page references are to the draft version.
The comments are reproduced directly from the responses sent to us.
We are deeply grateful for the help provided by all Phase I researchers
and Advisory Committee members. We would like to extend special thanks to
those individuals who submitted the comments reproduced in this volume.
James J. Stukel and Boyd R. Keenan
University of Illinois
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COMMENTS BY
ADVISORY COMMITTEE MEMBERS
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EvD78-181
May 12, 1978
Columbus
foukhorn
J.P.Apel
COLUMBUS AND JOUIHTO OHIO ELKIRIC COMPANY VICP President Environmental
715 N FHON1 V COLUMUU5 OHIO d3? 15 VlCe rresioenl' cnvironmenwi
Mr. Boyd R. Keenan
Mr. James J. Stukel
ORBES - Project Office
345 Advanced Computation Building
Urbana, Illinois 61801
Re: Comments on ORBES Phase I
Dear Sirs:
These comments have been prepared in response to the Project Office's
invitation to review the ORBES Phase !_: Interim Findings as well as other
Phase I reports. We specifically request that these comments be part of the
documentation of ORBES Phase I and included for publication in Volume IV.
INTRODUCTION
The review of the product of any study must be accomplished in light of the
stated objectives and purposes. The first part of such a review is to deter-
mine if the study contains errors in fact or other deficiencies which challenge
the credibility of the entire effort. Only after determining that there are no
basic flaws in the study is a detailed review of the product warranted. Unfor-
tunately, the review of the reports received for this study indicates errors.
Furthermore, unjustified, unwarranted and unprofessional assumptions, decisions
and conclusions permeate the study to the point that the validity and credibility
of the entire project are challenged. Since the study does not meet nor even
approach its own stated objectives and purposes, the product of this research
study does a disservice to the best interests of both the general public and
the legislators for whom this study is directed.
STUDY REGION
First of all, I must question the scope of the entire ORBES project. It appears
the researchers have taken it upon themselves to conduct a regional assessment
study which is clearly broader than the mandate from Congress which reads as
follows: "The (Senate Appropriations) Committee directs the Environmental
Protection Agency to conduct ... an assessment of the potential environmental,
social, and economic impacts of the proposed concentration of power plants in
the lower Ohio River Basin." The entire ORBES project was initiated when a
local special interest group raised questions concerning the planning and
construction of nine power plants in the lower Ohio River Basin. These nine
plants should have been the focus for the project since they were the only
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Mr. Boyd R. Keenan
Mr. James J. Stukel Page 2
proposed plants in the lower Ohio River Basin. Apparently, the researchers took
it upon themselves to project beyond 1985, a total of 159 additional power plants
and to expand the region to incorporate one side of the middle Ohio River Basin.
Next, there is a fundamental problem in the definition of the study region. The
decision to include the entire southeast portion of Ohio in the study region and
exclude the portions of West Virginia which are just across the river from the
study region is totally indefensible. In effect, this definition says that the
impacts and benefits of a power plant located along the Ohio River in southeast
Ohio somehow magically stop at the Ohio River and do not affect West Virginia and
vice-versa. This is not only indefensible from a physical sense, but also, from
an economic and sociological sense. While the remote counties (in relation to
the Ohio River) of Ohio, Indiana, Illinois and Kentucky may contribute to the
Ohio River runoff and contain appreciable amounts of mineable coal, I believe
that the impact of the West Virginia counties on the ORBES region is as great
or greater than the remote counties, and that their exclusion from the study
area is unjustifiable.
WORK FORCE
In analyzing the impact on the work force, the researchers included the entire
labor force from northern counties of Ohio, Indiana and Illinois on the basis
that workers are auite mobile and may commute across both county and state lines.
They did not, however, consider that workers from West Virginia and western
Pennsylvania are also likely to cross state lines for employment on the other
side of the Ohio River. Such an obvious oversight is unjustified and infers a
lack of knowledge about the fluidity of the labor market. If it is assumed
that workers 200 miles north of the Ohio River will have an effect on the employ-
ment statistics, then it is inane to believe workers that live on the other side
of the river would have no effect.
Further, the "finding" that the high-energy growth scenario would employ three
times as many workers during peak construction as would the low-energy growth
scenario is a function of the researchers time-phasing of power plant construction
and demonstrative of their complete misunderstanding of the subject being studied.
The schedules given for the high-energy scenarios were done with no regard to the
actual experience of the industry. In several cases the scheduled dates are
blatantly impossible because of the regulatory process alone; this does not take
into account such matters as legal delays, siting, etc.
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May 12, 1978
Columbus
Southern
Mr. Boyd R. Keenan
Mr. James J. Stukel PaSe 3
It should be noted that the likelihood of boomtowns developing in the ORBES
region was a subject of controversy even among the researchers themselves.
"Relatively uniform population density" in the ORBES region would make few
locations susceptible to "boomtown conditions". I question the characteri-
zation of the ORBES region as having a uniform population density. The well
developed transportation network in the ORBES region may have more of an
impact in alleviating any "boomtown conditions."
IMPACT ASSESSMENT
The highlight of the researchers self-delusion is contained in the following
statements from the Interim Findings: "The projected lower levels of residuals
from the electric utility sector under the low-energy growth scenarios would be
offset to varying degrees (depending on the pollutant) by increases in residuals
from the industrial combustion of fossil fuels. That is, in order to both main-
tain gross national project and conserve electrical energy under the FTP scenarios,
industries in the region would produce their own power directly through combustion
of coal and natural gas." In other words, the researchers admit that it is
impossible to meet the FTF scenario load-growth without forcing industry to
generate their own power. Furthermore, the power generated by industry is no£
counted as part of the overall electrical energy produced in one case (FTF) and
is in the other (BOM).
The researchers have often reiterated that they were not attempting to predict
what will happen, but rather, they were examining plausible futures. Given the
futures, or scenarios, the researchers would then attempt to assess the various
environmental, social, and economic implications. The 100 percent coal and 100
percent nuclear scenarios are certainly not plausible, the siting configurations
are impossible, and thus, any assessments which follow lack credibility.
The impact assessments are for the most part a classic example of use of unsub-
stantiated value judgments, incorrect data, and misunderstanding of fact. The
following example will establish the point at issue. In one report, in an assess-
ment of the Trimble County Generating Station is a statement which reads as
follows . . . "It is seen that terrain surrounding the stack is, in places at the
same elevation as the stack outlet." Examination of the data presented reveals
that stack height is 800 feet and the height of the surrounding terrain is a
maximum of about 850 feet. Unfortunately, the plant is not being built at sea
level, as apparently assumed by the researchers, but at an elevation of about
500 feet. Thus, the statement that the stack height is the same as the sur-
rounding terrain is wrong, and the conclusions which result, also wrong.
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Southern
Mr. Boyd R. Keenan
Mr. James J. Stukel Page 4
A "major" finding states as follows . . . "If power plants continue to be built
at preferred sites in the region, a dense pattern of these emission sources
along river corridors would result. Because these corridors tend to be aligned
with persistent wind directions, pollutant concentrations would build up as the
air mass moves downwind." The researchers are obviously referring to their
preferred sites which in no way resemble the utility industry's preferred sites.
Thus, the dense patterns of emission sources along river corridors are a direct
result of their primitively applied siting methodology. There are many river
corridors in the ORBES region which do not align with persistent wind directions.
In regards to pollutant concentration build up downwind, let me quote from the
air modeling efforts undertaken by the researchers in Phase I: "Unfortunately,
time did not permit an analysis of the period of time the wind would need to
persist to allow full development of the cascading effect throughout the corridor.
Nor was the meteorological data available to substantiate the persistence time for
a particular case's wind conditions. Thus, the corridor model should be viewed as
hypothetical." When one considers the lack of supportive data necessary for air
quality modeling, errors in the location of existing plants, identical assumptions
regarding all stack parameters, and the errors such as those applied to the stack
height previously mentioned, it is obvious that the researchers "major" finding
rests on a very shakey foundation.
SITING CONFIGURATIONS
Regional and subregional wind corridors may exist, however, the build-up of high
emission sources along these corridors are a direct function of the regional
siting configurations. The siting configurations chosen by the university
researchers are a travesty upon the art and science of power siting and perhaps
the best example of the misuse of data and lack of appreciation of the complexity
of the subject at hand. This is particularly distressing because at the specific
request of the researchers, CSOE provided several copies of a regional siting
survey used to identify sites for actual evaluation and acquisition. In our survey,
procedures were detailed and criteria and data were documented. In examing the
regional siting confugurations, it becomes obvious that either the researchers
did not understand the information or they did not bother to use the information
at all. Most certainly they do not understand current technology and/or utility
power siting practice.
Apparently the researchers did not realize that improper selection of candidate
counties, and illogically designating the type of plant within a county, pre-
determines the results of the impact assessments. Since the regional siting
configurations are the basis for the entire assessments that follow, it is
apparent that tho credibility of the study is destroyed.
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Mr. Boyd R. Keenan
Mr. James J. Stukel ' Page 5
One assumption that perhaps demonstrates the degree of naivety of the researchers
best is the assumption that the availability and accessibility of transmission
lines present no problem in regard to plant siting. This could only be the case
with a group of researchers who have never attempted to site a transmission line,
let alone a power plant. Furthermore, it is obvious that the researchers' own
list of general constraints for siting energy facilities was not adhered to. For
example, looking at air and water quality, the selection of both Franklin County
and Pickaway County, Ohio, for 2000 MWe of coal-fired plants flies in the face of
any logic whatsoever. The problem is then compounded by the selection of counties
such as these for the BOM configurations and then either not using these counties
or drastically reducing the capacity in the FTF configurations. This action has
the effect of forcing the reader to a particular and unwarranted conclusion. The
travesty is then further amplified by the mechanisms used to apportion plants
within the counties. The assumptions used were stated in one report to be as
follows:
"1. If the county was bordered by a river, then the plants were
located along the river at approximately an equal distance
apart,
2. For the counties not bordered by a major river, the plants were
located randomly within the county, and
3. No two plants were given the same site."
These assumptions are complete nonsense and indicative of the researchers pre-
determined conception of what the study would conclude. The selection being
accomplished in this manner clearly magnifies impacts along the rivers and
minimizes impact in the interior counties thus forcing the reader to the now
obvious predetermined conclusions of the researchers.
WATER QUANTITY AND QUALITY
Water quantity and quality are concluded to be potential problems locally during
periods of sustained low-flow conditions. What the research team neglected to
investigate was the possibility of "capturing" water which would ordinarily be
carried from the ORBES region, by utilizing storage reservoirs. Water could be
released from the reservoirs to augment water supplies during sustained periods
of low flow. Furthermore, navigational problems resulting from the widespread
use of irrigation would be more appropriately addressed as a policy issue, rather
than a conclusion. The extent of future irrigation development in the Ohio River
Basin is highly speculative.
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Mr. Boyd R. Keenan
Mr. James J. Stukel Page 6
The water consumption rates were based on an assumption that new generating plants
would be equipped with wet cooling towers and existing plants would be retrofitted.
Recent results from 316(a) studies have shown that many plants can comply with
thermal regulations without going to wet cooling towers. If it can be demonstrated
that more traditional cooling techniques can comply on a case-by-case basis, the
water consumptive losses projected in the ORBES region can be drastically reduced.
The relative impacts of water consumption were assessed for the Ohio River and its
major tributaries and characterized in the undefined terms of light, moderate, or
heavy. I must again reiterate that although the assessments may be correct based
on the methodology of the researchers, the fact that the methodology is totally
invalid makes any assessments meaningless. It is no wonder the impacts on water
consumption are so heavy in the Scioto River, 8000 MWe were located along this
tributary of the Ohio. This is absolutely fantasy.
The Interim Findings state that: ". . .no data are available on non-point sources
that contribute to TSS . . .". However, a conclusion is drawn that if non-point
sources of water pollution are taken into account, significant differences between
the high-growth and low-growth scenarios might be found in the concentrations of
two (TSS and TDS) of the four water pollutants examined. This is an example of a
conclusion arrived at without the benefit of a data base.
GRAPHICS
Figures F-l-5 attempt to show graphically the existing and projected electrical
generating facilities in the ORBES region. To begin with, units and not facilities
are shown. This misrepresentation has been brought to the study group's attention
time and time again. Furthermore, some existing facilities are not depicted while
others are located incorrectly.
LAND USE
I must object to the conclusion that transmission takes significant amounts of land
out of production. Transmission corridors are compatible with agricultural land
use. Productivity may decrease slightly due to compaction but this is temporary
in nature and only the areas around the structure bases are taken out of production.
Furthermore, the relocation of residents during power plant development is very
minimal since thJs criteria is used in determining the site location.
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Mr. Boyd R. Keenan
Mr. James J. Stukel Page 7
GENERAL
There are dozens of land use conflicts which have potentially as great or greater
impacts on agricultural, scenic, and recreational land, e.g., highways. Since the
researchers have chosen to evaluate land use conflicts from power plants in a
vacuum, the conclusion can only mention the conflicts associated with mining and
conversion. The result, therefore, is that the reader is again, led down the path
to the researchers predetermined conclusions.
MINERALS
The researchers concluded that sufficient quantities of limestone would be available
to meet the projected requirements for new flue-gas desulfurization systems. How-
ever, the quality of limestone must also be considered and this information is not
apparent in any of the Phase I research.
A percentage reduction will most likely be required regardless of the sulfur
content of coal. Low sulfur coal is not considered the best available technology
and economic constraints on its use have been imposed in at least one ORBES state.
It is, therefore, highly unlikely that there will be a trend to accelerate
importing increasing amounts of low sulfur coal for new power plants.
The researchers conclude that there is a sufficient amount of coal in the ORBES
region to last several hundred years if coal requirements level off after 2000.
What the researchers did not examine was the usability of this coal. The Clean
Air Act Amendments could restrict the marketability of this coal and thus, much
of this resource may remain undeveloped.
PUBLIC HEALTH
There appears to be no justification within the study for the researchers' con-
clusion that "The high-energy growth option would more than double the expected
number of premature deaths over those expected under the low-energy growth option".
With the exception of nitrogen oxides, the researchers' own results show that no
appreciable difference occurs between the high-growth and low-growth scenarios
regarding air and water pollutants in the year 2000. Furthermore, the assumptions
that people under the high-energy growth option will consume higher calorie foods
and exercise less is unbelievable and does not warrant the above conclusion.
Furthermore, I must disagree with the classification of nuclear accidents as a
first-order impact on public health. The nuclear accident risk level is actually
less than that of most available alternatives in use today. The past nuclear
safety record speaks for itself!
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Columbu/
Southern
Mr. Boyd R. Keenan
Mr. James J. Stukel Page 8
The Interim Findings allude to security risks inherent in the nuclear fuel cycle
of commercial nuclear power. It must be noted that there are at least eight
different ways to produce nuclear weapons grade material. The commercial nuclear
power route is the most expensive, requires the highest level of support technology,
and the broadest base of support industry. To put all weapon proliferation emphasis
on the commercial reactor program is naive. The following analogy will make my
point: If a dike is leaking in at least eight places, and someone comes along,
plugs up the smallest hole, and then announces that the leaking has totally
stopped, he still better know how to swim.
Turning to sabotage, there are many safety systems built into a nuclear facility
and an individual with specialized knowledge may be able to cause a plant to shut
down. However, this must be separated from the incidents which may cause a public
health hazard. The amount of radioactivity release that would threaten public
health must be considered along with the high degree of teamwork which would be
necessary to carry out a sabotage operation. When one considers the relative
costs of other means to create public havoc, the low probability of a successful
sabotage operation cannot be considered seriously as a major social threat.
INDUCED GROWTH
In several instances throughout the Phase I studies, energy facilities are alluded
to being developed to induce growth. Indeed, one is led to believe that power
plants are constructed to allow more residential, commercial, and industrial devel-
opment. This is not the case. Specifically, utilities have a legal responsibility
to supply future needs and that this need must be demonstrated prior to construction.
CAPITAL AVAILABILITY
The technique for estimating the capital availability requirements of the various
scenarios are, at best, confusing. It would be difficult to speculate on what is
included in the general expenses category or how transmission and distribution
costs were determined. However, based on the type of unjustified and speculative
assumptions apparent throughout this study, one can easily imagine similar problems
in this area.
ASSUMPTIONS
Many of the assumptions listed in Appendix F of the Interim Findings are absolute
nonsense and two of the assumptions appear to actually contradict each other.
The first assumption states that the percentage of electrical energy produced in
the ORBES region as compared to the nation as a whole will remain constant. The
third assumption then goes on to say that electrical energy demand in the ORBES
region is not necessarily a direct indication of energy demand in the nation as
a whole.
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fouihem
Mr. Boyd R. Keenan
Mr. James J. Stukel Page 9
The assumption which states that existing government regulations will remain in
effect through the year 2000 may best typify the myopia with regard to the
dynamics inherent in governmental regulations.
Still another assumption, under the BOM scenario, states that the regulation of
strip mining will not be overly restrictive. The researchers were apparently
unaware of existing stringent state regulations in some states and the recently
enacted Federal Surface Mining Control and Reclamation Act of 1977. Further,
many inconsistencies exist when comparing the BOM and FTF scenario assumptions.
The BOM scenarios assume that the role of solar energy and conservation will be
ignored while the FTF scenario does not make these assumptions. Additionally,
the researchers assume that annual energy consumption in the year 2000 will be
31 percent greater for the BOM scenario relative to the FTF scenario and, at the
same time, assume a difference of only 1 million people nationally.
POLICY ISSUES
The policy issues addressed at the end of Chapters 3-6 reveal the true view of the
researchers and can be summed up as follows: If some government control is good,
then more government control must be better, and total government control must be
best. Perhaps cooling technology will serve to illustrate this logic of the
researchers best. USEPA has for all practical purposes mandated the use of
cooling towers rather than once-through cooling to mitigate the thermal effects
on aquatic life; the researchers are concerned that this potentially creates a
water consumption problem; the researchers, therefore, identify this problem and
then propose as their solution—more government control on cooling technology.
The statement of the researchers that "... some believe that the only real
purpose of the procedures (permits and hearings) is to promote and license
energy facilities" again lends little credence to the ORBES project. To
insinuate that public hearings are merely forums to promote energy facilities
does great injustice to the public hearing process and is another example of
the misunderstandings and subjective judgments which so permeate this study.
A careful examination of these policy issues reveal that they are so generic
that they could have been raised by any research group at any time without the
benefit of any research whatsoever. Indeed, it is difficult to see how any
research of the Phase I study logically leads to any of these specific issues.
CONCLUSIONS
In conclusion, I will quote from Page 128 of the Interim Findings; "The
character of this . . . study is so complex that any ultimate management
arrangement by necessity must be an experiment in the sense that its results
10
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May 12, 1978
Coiumbu/
,/butfxw)
Mr. Boyd R. Keenan
Mr. James J. Stukel Page 10
can in no way be predicted at this time." I can only conclude that the experi-
ment was a failure and the patient died.
Finally, it should be pointed out that in any review it is possible to "nitpick"
a report to death. However, this is not what this review has done; neither is
the review all encompassing. This review has provided examples of the basic
errors which so riddle the study that the credibility, objectivity, and usefulness
of the entire product is regretfully destroyed. It should also be made clear
that at the specific request of the researcher this advisor provided both
constructive comments and large quantities of data (including several volumes
of siting material) throughout Phase I, and has now regretfully concluded that
little attempt was made by these same researchers to incorporate the comments
or use the data.
Respectfully yours,
p.
Vice President
Environmental
JPA:DEL:dp
cc - Lowell Smith, USEPA
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Oll'ftW LKNTZ, Executive Manager
EXECUTIVE OFFICE P O BOX IO2 CANTON OHIO 447O1
PHONE 1216) 456-2488
May 15, 1978
Dr. Boyd R. Keenan
and
Dr. James J. Stukel
ORBES Project Office
345 Advanced Computation Building
1011 West Springfield Avenue
Urbana, Illinois 61801
Gentlemen:
Subject: Comments on the ORBES Phase I: Interim Findings, Volume I-A
Throughout the course of the Phase I Ohio River Basin Energy Study, representatives
of electric utilities in the ECAR area were continually appraised of the project
teams' activities, research, and findings. Thus, the following is a consolidation
of comments obtained not only from electric utility advisors, but their staff members
and others not serving directly as advisors.
Our first comment pertains to the format of the report. As indicated, Chapter 1
summarizes potential environmental, social, and economic impacts that might result
from varying levels of electric energy facility developments. It provides a listing
of first-year findings based on your review and interpretation of three university
team reports.1 Chapters 3, 4, 5, and 6 discussed in more detail how the various
segments of our society might be impacted. These chapters each conclude with a
section identified as "Illustrative Policy Issues" listing what we interpret to be
your views as to policy issues that are raised by the ORBES report. We believe these
concluding sections should be deleted from the report. If any of the items under
"Illustrative Policy Issues" can be related to the basic research of the three team
reports, they should be brought forward and presented as findings in Chapter 1.
1We would call attention to the fact that the authors did not limit their summariza-
tion to the three university team reports. On Page V of the Preface the authors
state: "In preparing the report, we have exercised prerogatives as co-directors for
the ORBES Experimental Management Plan under our own EPA grant. When appropriate we
have consulted non-ORBES findings available from other EPA-sponsored research and
from outside sources." Deletion of all such material completed after Phase I from
this interim report which is purported to summarize Phase I activities would be in
order.
12
MCMIII--RS OP EAST CENTRAL AREA RELIABILITY COORDINATION AGREEMENT
Appnlm lii.in I iiwi-i (umpdiiy - Ihr Ciiii.iiiruili Gas £ Electric Company The Cleveland Elcitnt. lllumin.ilini'. Company Columbus and
Southern ninn Hi-line Company Consumers Power Company The Dnyton Power & LiRhl Company The DclfOil Edison Company
Dunucsne I i|-lil Ciiinunny F.jsl Kcrilui.ky Rural Electric Cooperative Indiana A Miclniinn Elc-rtnc. Company Indiana Kentucky Electric
Corporation liiriiaihipnlis Cower <• I u-.nl Company Kentucky Power Company - Kentucky Utilities Company - Louisville Gas and Electric
Company Mnnnni-nhrla Power Company • Northern Indiana Public Service Company Ohio Edison Company • Ohio Power
Company Ohm V.illey dcclnc Corunr.ition Pennsylvania Powi-r Company - The Potomac Ellison Company Pulilic Service
Company ol Inili.inn, Inc Soutlu-rn Indiana Gas and Electric Company The Toledo Cdi«on Company West Perm Power Company
-------
Drs. Keenan and Stukel -2- May 15, 1978
Most of the issues listed (and many other issues not listed) could have been
tabulated without benefit of the three university team reports. Any knowledgeable
person through reading various types of material, technical and/or non-technical,
pertaining to energy development and energy facilities, could have identified the
issues that have been listed and formulated similar questions, such as: What forum
and/or who should address these issues for resolution?
Our request for deletion is not to suppress publication of such policy issues since
these and many others have surfaced and have been well publicized in numerous arenas
and reports. We believe a listing of such generalized issues is outside the scope
of the ORBES report. Illustrative of an unrelated issue is the one raised on Page 54,
"Should rate structures for electricity recognize that increased future demand will
require the construction of significantly more costly power plants than those currently
in use, thereby raising the average per unit cost even when an individual consumer's
demand remains constant?" The philosophy of rate structures has been discussed many,
many times covering unique questions such as raised in the foregoing. Similarly, it
could have been noted that the cost to serve each consumer differs, and this raises
the "issue": "Shouldn't the rate for each consumer be based on his cost of service?"
Issues of this type have been well recognized and have been discarded as being highly
impractical to incorporate in a rate structure. However, returning to our main point,
we see no relationship between this issue and the area of research as covered by the
ORBES studies.
Another example of a vague, generalized "issue" is on Page 53, Chapter 4, "Should
new legislation address the question of safety and safeguards in transporting nuclear
materials?" This is suggestive that there is either no legislation, that present
legislation is inadequate, or that present legislation has not been adequately
enforced. Did the ORBES study provide any basic research or analysis leading to
such conclusions and the need to identify such an issue? If it is a valid conclusion,
then wouldn't it be more appropriate to list the item as a finding in the Summary of
Chapter 1?
Rather than continue with additional examples, we would note that the issues listed
in most cases are so general in nature that they are open to an interpretation that
they would support two diametrically opposite viewpoints. Furthermore, it is not
apparent, inmost cases, as to what is the basic issue and the validity of it as an
issue. It is suggested that the authors review the items under "Illustrative Policy
Issues" to insure that the potential issues published (and if published, be incorporated
under findings as recommended previously) can be directly drawn from factually based
ORBES research. This is an obligation to those who will review the report without a
basis for judging the adequacy of the source. Otherwise, the credibility of the
Phase I effort will be held in doubt by peers who have working knowledge of the
environmental, social, and economic impact of the energy sector.
A description of the two basic scenarios appears in the second paragraph on Page 15.
The postulations or basic assumptions that Gross National Product (GNP) would be or
had to be equal for both the Bureau of Mines and Ford Foundation projections and the
conclusion that a different mixture of goods and services would materialize under one
scenario as compared to the other scenario such that GNP would be equal, are not
supportable by the ORBES studies. This unsupportable theme carries over into other
sections of the report where it is stated on Page 46, "On a national basis little
difference in total employment under the high- and low-energy-growth scenarios
would be expected."
13
-------
Drs. Keenan and Stukel -3- May 15, 1978
The coupling (or correlation) between energy consumption and GNP is well documented
in statistics compiled by governmental agencies in this country and in other
industrial nations. Obviously, the coupling "factor" between GNP and energy
consumption can change—more efficient use of energy to produce the same amount of
goods reduces the coupling factor. On the other hand, more emphasis on use of
energy rather than manpower causes the coupling factor to move in the opposite
direction. We believe the authors should provide more support or rationale as to
why the Nation can expect the same level of economic activity under the two widely
divergent scenarios and as to why other types of services and industries will be
able to develop and sell products to fill the void that would be created if the high-
energy growth scenario is not realized. In the absence of any supporting rationale
reviewers can only conclude the foregoing postulations were arbitrarily decided upon.
Many of the observations or findings of Chapter 1 could be identified as "truisms"
which need little or no supporting data. As an example, refer to the findings
relating to "Potential land-use conflicts exist between coal mining and crop pro-
duction, particularly in Illinois, and between coal mining and forest and recreational
areas in the Appalachian portions of Kentucky and Ohio." It would be just as logical
to say that there is a potential land use conflict between any physical facilities
whether it be a power plant, shopping center, or recreational structure with any piece
of land, whether it be highly desirable farm land or land that is considered to be
marginal in terms of present use.
Such findings as "The high-energy-growth option would more than double the expected
number of premature deaths over those expected under the low-energy-growth option."
on Page 7, is a very vague, generalized statement that is not supported by any analysis
in the ORBES study. Possibly the authors reached this conclusion on the basis that
if it can be statistically proven that "X" number of deaths result for every power
plant, a "Y" number for every ton of coal mined, then doubling the number of power
plants and doubling the amount of coal mined, means twice as many deaths. This seems
inconsistent with some of the study assumptions that GNP and employment will be at
the same level for both high- and low-energy growth. What proof is there that the
postulated growth in other industries and services as noted above to maintain equal
GNP will not also result in premature deaths equal to or greater than those with
the high-energy-growth scenario?
The ORBES study is presumably a result of the directive from Senate Appropriations
Committee to conduct " an assessment of the potential environmental, social, and
economic impacts of the proposed concentration of power plants in the lower Ohio
River Basin." Yet the study seems to present broad energy scenarios including
mobile sources, trucks and automobiles, selectively presented to highlight the adverse
impact. (Page 67) This is another example of deviating from the scope of the study
as defined by the Senate.
Of paramount concern to the utility advisors is the context in which the ORBES air
quality studies are framed and the emphasis on "corridor effects." The subject report
on Page 73, states under "Cascading Effect of Siting Corridors: Subregional Effects,"
the following: "In order to examine the air quality impacts of these siting configura-
tions, a theoretical model (the Air Quality Display Model) was implemented to determine
the level of atmospheric pollutant concentrations if a persistent wind blew along any
of these siting corridors."
14
-------
Drs. Keenan and Stukel -4- May 15, 1978
For the reasons set forth below, we take exception to the methodology employed in
the various ORBES scenarios in projecting regional and statewide air quality impacts:
1. It should be noted that the Air Quality Display Model (AQDM) was one of
the forerunner models developed by Federal EPA to ascertain primarily, annual
SC>2 concentrations, and it was not intended to be used in predicting short-
term pollutant levels, i.e., the 12-hour concentrations stated on Page 74, so
as to depict a "corridor" effect.
2. The Federal EPA'sown Guidance Series, OAQPS No. 1.2-080, "Interim Guide-
line on Air Quality Models," October 1977, Page B-4, recognizes a limitation
of the AQDM where it notes that it is "Useable for urban areas only." Thus,
the application of this model to power plants which are presently located in
many of the predominantly rural areas within the Ohio River Basin and new
plants to be located in similar areas would be of little relevance.
3. The document, "Air Quality Display Model, TRW System Group" PB 189194,
November 1969, Page 2-1, reveals that "...before using the AQDM to estimate
regional air quality, the atmosphere diffusion model should be calibrated
with existing air quality data (various calibration options are provided in
the AQDM.)" The air quality analysis undertaken in ORBES Phase I was predicated
on theoretical modeling exclusively without having calibrated the model used in
the analysis. Since no air quality and meteorological data were incoporated
into this work, the "cascading" hypothesis is suspect, at the minimum, if not
totally invalid.
An overall impression which one can gather in reviewing the ORBES air quality analysis
presented in the interim document is that data and assumptions are loosely supported
from a technical standpoint. In citing a specific example, the ORBES interim document
(Page 74) states that, "...under the cascading effect of a south wind these allowable
ambient concentrations could be exceeded three to six times a year. Another recent
study reports similar results (23)." In this document, wind persistence data were
examined, but no air quality analysis was undertaken to lend support to the theory of
ORBES "corridor" effects. That referenced document (23), compiled by Teknekron, Inc.,
of Berkeley, California, in no way supports this statement.
We fully appreciate that the Phase I effort had to cover a broad scope in a limited
time frame. The project team throughout the Phase I study stressed that the Phase I
effort had to be considered as preliminary in nature—that the objective of the
analysis was to sort out those items and matters that should receive more in-depth
study in Phase II. However, the preliminary nature of Phase I seems to be lost in the
summary report which now conveys a high degree of finality on many subjects. Our
concern for this is evident by the following specific comments.
Page 18—The "...expressed concern over the assumptions implicit in the development of
scenarios, particuarly in areas of health and safety as related to nuclear-fueled
facilities." needs to be isolated from emotional expression. Researchers who expressed
such concern can hardly be regarded as experts in the field of nuclear technology.
This concern would have been meaningful if the researchers who are also experts in the
nuclear field had expressed their views supporting these alleged concerns.
Page 19—The alleged conflict between commitment of land to energy and food in the
ORBES region is indeed highly dramatized. From all Phase I study results, there appears
to be enough land available to adequately meet not only these two needs, but many others.
ORBES region will not encounter any food shortages resulting from insufficient land.
15
-------
Drs. Keenan and Stukel -5- May 15, 1978
Page 24—The land requirement estimates to store scrubber sludge are optimistically
shown to be less than one-half the actual land area (acre feet) currently utilized.
It is further stated that such land use is reversible to the extent that the land
can be returned to its previous use. This again seems not to be the case wherever
scrubber sludge is currently stored.
Page 27~The assumption that evaporative cooling towers would be employed by all
plants—even existing ones—appears to be aimed at obtaining a most adverse impact.
States like Indiana are viewing the issue of projected uses of water resources more
realistically. If once-through cooling would conserve this valuable resource and
reduce its consumptive use, then it is that option and not just an arbitrary assumption
that must be evaluated.
Extensive development of irrigation is a very remote and highly unlikely possibility.
Even if irrigation were to become extensive, it would very likely utilize ground
water and not river water.
Page 33—"...only 50 percent or less of the (uranium) ore in the deposit would be
recoverable." is a highly erroneous statement. In general, over 90 percent of the
ore is recoverable in underground mining.
Page 36—Clean Air Act Amendments of 1977 have provided sufficient legislation to
protect land areas (private as well as public) from adverse effects of electric energy
generating facilities. This should no longer remain a policy issue.
Page 37—The policy issue on the use of local and regional coal has already been
addressed and appropriate measures spelled out in the 1977 Clean Air Act Amendments.
Page 49~Alleged shortage of construction workers is projected in this report. If
this hypothesis is correct, this could be considered a desirable situation for the
United States instead of a severe problem as stated.
Page 58—It is incorrectly stated that states currently are not required to meet
secondary standards within any specified period. In Indiana, for example, Regulation
AFC 14 requires compliance with secondary standards at all times and has been in
effect at least since 1972.
Page 63—It is stated that secondary particulates constitute from one-tenth to
one-third of the mass of total suspended particulates normally found in the ORBES
region. There were, however, no data generated or made available during Phase I to
support this statement and the two ensuing paragraphs. EPA has the Congressional
mandate to protect public health from such pollutants. If the issues indicated in
these two paragraphs are purported to be as harmful, then EPA does not seem to be as
alarmed from these. The issue of alleged plant damage has already been incorporated
by EPA in setting secondary standards established at levels below the harmful threshold.
Page 65—It is erroneously stated that "Sulfur oxide emissions under the high-energy-
growth scenarios in the year 2000 would increase about 7 percent relative to 1972 levels.
Many sections of the ORBES region were nonattainment for sulfur oxides in 1972. However,
all these must and will achieve attainment by 1982 per the Clean Air Act Amendments.
Therefore, compared to 1972 sulfur oxide emission will be reduced substantially long
before the year 2000.
16
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Drs. Keenan and Stukel -6- May 15, 1978
Page 66—The acid rain theory appears to be yet another "what if" hypothesis.
Actual pH measurements of waters in the ORBES region do not support it.
Page 74—The first paragraph clearly indicates that 12-hour persistent winds from
the west-southwest could be expected once in two years, while from the south the
expected frequency would be three to six occurrences per year. The second paragraph
indicates that 1000 micrograms per cubic meter would be expected under either
persistent wind direction. With the wind direction from west-southwest and the
given frequency of occurrence this indicates that the primary 24-hour standard value
would be exceeded once every two years—this does not constitute a violation of air
quality standards, since one exceedance per year is allowed. The hypothetical sulfur
dioxide concentration extremes cannot and will not be allowed under existing National
Ambient Air Quality Standards and State Implementation Plans. Therefore, the entire
discussion that such exceedances could occur appears irrelevant.
Page 92—It is reported that 2400 acre feet would be required to store the flyash and
scrubber sludge from a 1000 MWe plant. Current technology requires 4900 acre feet
to 5800 acre feet just to store the scrubber sludge. No supportive data have been
presented to indicate this vast improvement in land use.
Pages 94 and 95—The discussion on such issues as secondary unregulated pollutants,
secondary standards, "capture" of clean air allotments, and low level radiation emitted
routinely from nuclear-fueled and coal-fired plants appears to be an effort to "create"
issues where there are not any. The Clean Air Act of 1970 has given EPA a clear man-
date to protect public health. The Amendments of 1977 further strengthen the EPA
position. Secondary standards, prevention of significant deterioration, and periodic
revisions to existing standards are the avenues that EPA has been utilizing effectively
to correct not only these hypothetical issues, but also the real ones.
In closing, we must, as in prior comments on the three university team reports, express
dissatisfaction with the limited time frame (a couple of weeks) which has been extended
to us by ORBES in their soliciting constructive inputs regarding the manner in which
utilities might be eventually impacted, and conversely, how the ORBES region might be
affected by electric companies. Along with this, the interim report (while under-
standably "relatively brief"), the findings of which are written in such general terms
and loosely-referenced, leave the reader with no other recourse but to pour through
voluminous support documents in a limited time frame so as to either consent with,
or refute, sundry technical issues often of a controversial nature. A comprehensive
critique of the ORBES Phase I Interim Findings and supporting reports has proven to
be impossible in the time allotted.
Very truly yours,
Hugh A. Barker *
Member-ORBES Phase I Advisory Committee
ci
Owen A. Lentz
Member-ORBES Phase I Advisory Committee
17
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Route 2 Box 251
Hanover, Indiana 47243
May 9, 1978
Dr. James J. Stukel
Dr. Boyd R. Keenan
345 Advanced Communications Building
1011 West Springfield Avenue
Urbana, Illinois 61801
Dear Boyd and Jim;
I received your Volume I-A Draft Interim Findings of the ORBES Study
just as I was leaving for New Haven for a Committee meeting. I looked
forward to reading it and must say it reflects a very great deal of
work.
As a general overall comment, I must say that I am disappointed in the
clear bias towards nuclear energy which is shown overall in the work.
My chief criticism of this overall apparent bias is that nuclear pollu-
tion is cumulative and not biodegradable and that for this reason the
damage it does is irreversible and therefore irreparable. And it seems
to me that this needs to be brought out very clearly in any report on
the subject.
I can understand the need for you to point out on pages iv und v in your
Preface that you were up against the problem of making choices and had to
use your own judgment. This is certainly completely defensible and
could not be any other way. This is one very large gap in the Study
which I find difficult to accept and that is that there is no "scenario"
which relies entirely on the impact of rational, carefully planned and
carefully promoted conservation of energy. It could very well be that
if the facts were gathered it would turn out that conservation would re-
lease so much energy that is now wasted that we could get along to the
year 2000 without building any more power plants.
I think also that you need a section on ethical impact and that means
particularly the ethics of technology assessment. I am trying to write
up such a statement and if I am successful I will send it to you as a
contribution to the project.
I will now make a few comments about the body of the text in the spirit
of your first paragraph on page 1 in which you invite comments on
technical merit and policy implications. I feel sure that you are
going to be deluged with comments.
I think your best statement in Chapter 1 is the very last paragraph on
page 8.
On page 17, the second paragraph, the amount of additional megawatts of
installed capdcity that would be required to meet demand in the year
18
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Dr. James Stukel Page 2
Dr. Boyd Keenan May 9, 1978
2000 is undoubtedly exaggerated. This is why a discussion of conserva-
tion as an acceptable "scenario" is essential. I feel quite sure that
this figure that is given is based on unrealistic projections. The
policy implications of this section would be that plants need to be
built. It seems to me that this is an underlying bias of the entire
report and I am not at all sure that it is justifable. The reason I
say this is that according to the Environmental Action Foundation's
Report "Utility Scoreboard" 1978, the utilities of this region are con-
genital overprojectors, For example, Public Service Indiana, at the
beginning of 1976, projected an increase in demand of 12.9%. By the
end of 9 months the actual increase had been 0.3%. That is to say by
the end of the year it was of the same order of magnitude and the over-
projection was well over 12%. Over the years 1974-75-76, the company
overprojected on the average 11.6% each year. This kind of behavior,
reflecting an inability to learn, is what makes me very nervous about
the whole policy implications of this ORBES Draft Report. This is not
to say that you are to blame but to imply that the input from industry
has been perhaps given more weight than it should be given and to under-
line the need to examine such input with very great care.*
(There are a lot of small things which I could call attention to—mis-
prints, statements which are not quite exact, but still not very bad,
but I will forego this, otherwise this letter would become impossibly
long.)
On page 30 I fail to find in the discussion of mineral resources a proper
discussion of the possibility of using, in place of the lime or lime-
stone FGD systems, those which recover the sulfur from the coal in a
usable form such as solid sulfur or an acid. It seems to me that this
option has been continually underplayed and should be paid much more
attention to. This omission becomes particularly noticeable on page 32
in the second paragraph.
I have the impression that under the section on Electric Utility Capital
beginning on page 45 somewhat more emphasis needs to be placed on the
difficulty of getting money under the very high demands of a high energy
production "scenario". The Ford Foundation Report gave this matter
considerable play.
With respect to labor, I realize that quite probably you were not able
to include in your consideration, work such as that on "Values in the
Electric Power Industry" edited by Kenneth Sayre, University of Notre
Dame Press, 1977. In this book there is an interesting chapter which
points out that the industry carefully planned with respect to conserva-
tion might find itself with an increased number of jobs, for example.
There is also in this book a very interesting essay which questions the
identification of actual need with demand. It is pointed out, for example,
that a utility is not required to provide all the services that a
customer might possibly want, although it is mandated to serve the
public. In connection with this section on labor, is the statement
-------
Dr. James Stukel Page 3
Dr. Boyd Keenan May 9, 1973
in the first chapter, that "Contrary to what is usually assumed,
decreased energy consumption could lead to increased employment and
to a higher standard of living." Unfortunately, of course, you are
writing a publication which when it appears is "fixed" at the same
time the field is one which is developing very fast and for this reason
you will always be behind—and often behind an eight-ball.1
In Chapter 5 there is one omission which I think is important and that
is that you do not seem to discuss what is, admittedly, not conventionally
considered a pollutant, namely moisture. The importance of this moisture
is usually minimized. But one has to ask what is a pollutant and it
must be something that appears in an excessive quantity and does injury.
Consider the proposed plant at Marble Hill. If it were finally built
and operating it would exude something like 50 million tons of moisture
into the atmosphere. This is in a valley which is already quite humid.
The annual average relative humidity at Louisville ranges from 57% to
797,, respectively at noon and midnight. I believe that it is uncon-
scionable to contemplate large releases of moisture into this kind of
an atmosphere.
But the situation is made much worse if one adds in the proposed Wise's
Landing Plant. This is proposed to take up 150 million tons of water
per year from the river at the total maximum peak intake rate. It is
calculated that evaporation from the proposed cooling towers and from
drift loss would be 50 million tons of moisture per year. What is not
mentioned is that in addition 10.5 million tons will be produced from the
combustion of the coal and would be exhausted from the stacks which would
men that this proposed plant would release to the atmosphere 60.5 million
tons of moisture per year and this just across the river and not very
far from the proposed Marble Hill plant. I think that the ORBES group
could do a real service to this area if it would point out and get some
action on considering moisture as a pollutant from power plants.
It seemed to me that the discussion of particulates, pages 62ff, is a
good one considering the space limitations. I suspect that one of your
big problems has been that you had to cut things down and omit a great
deal in order to come out with something that was of reasonable size.
You might have to end up with still shorter statements made up of
categorical statements with references to the data which has been gathered.
I must say that this whole chapter—apart from the omission of considera-
tion of the effects of moisture--is excellently done. It would be good if
we could convince EPA to pay some attention to your findings.
It might seem to you that I was particularly harsh in my strictures with
respect to bias towards nuclear energy, but I would like to give you an
example of why I have this reaction. If you will look on page 94, para-
graph 2, you will find that at the end of that paragraph, it says "In
addition, it is anticipated that those scenarios which emphasize coal
usually would have more severe impact than those which emphasize nuclear
fuel." This is a quite incorrect statement. In the first place, coal
20
-------
Dr. James Stukel Page 4
Dr. Boyd Keenan May 9f
pollution is on the whole biodegradable. Nuclear pollution is not
biodegradable nor is it reversible. Further, and this is the most
important point in connection with this particular quotation, would
you consider that having danger and emissions and watchfulness required
in perpetuity for nuclear waste negligible? This is certainly far more
A?V?S«in
-------
Dr. James Stukel May 9, 1978
Dr. Boyd Keenan Page 5
were to be built, the energy would be sent to Chicago, that is to say,
outside of the ORBES Region. With respect to item 20 on page 143, it
may be of some interest to note that Public Service Indiana has already
talked about increasing the size of the Marble Hill Plant to four units
and has enough land available to go to an energy farm.
On page 144 I found to my amazement that the role of solar energy will
not be taken into account and that energy conservation will not be taken
into account. This I think really should be corrected if you wish to
have this report just not gather dust on library shelves.
Well, Boyd and Jim, I have given you my first impressions of this draft
report. I hope they will be useful. You should not take these as
personal remarks and they arejnot meant in any sense. I feel that this
ORBES report is potentially a tremendously valuable thing for the
people living in this area and therefore I would like to see it develop
its potential more than appears to have occurred so far. I realize,
of course, that you have a terrific pressure on you from all sides--
including Save The Valley, I hope—and have to bring these together.
It is a problem which I do not envy you.
With best regards,
Sincerely yours,
Ha fold G. Cassidy
Professor-At-Large
Hanover College
HGC/db
22
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KW YORK TIMES. FKWAY. MAY 3. 1971
Dll
• rs'
ium» Tallinn
c yesterday
;iatei Stecl'i on-
("hiciro to vice
» 01 the rnmpa-
iiiorlTi. He will
y Hill, who 1m
V'Tonon of the
Hi Hill Is btlng
. Schneider, who
•miciident of the
rks. . . . Olln C
president of the
nr,"K>rotion, has
jf the Penn-DUie
•Dixie Industries,
iy, (nnnerly cot-
hriM tircn elected
nl nnd chief op-
•linn Industries,
irdnics frtncern.
ili ni of the com-
MitKldiiry, has
.t vice president.
n^rly vice r*r»usmes* develop-
i Chemicals divl-
.•e Coinrnny, hu
:ent, chemical In-
R. Cunningham,
f financial plan-
director of mar-
.ji division of the
ration. . . . John
i account officer
ce office of the
/ York office, haj
president of the
e.
?T COST
'AGECANS
i r.iga Dl
«• l>cveraure nf lake Oiilarlo. Ilia Mule Siting
n.iarj inday tiitKli nly mdiTninl-;-,ion |n< |>:m-J u
summary showinjj that cvr.ry now electric
power plant under construction or
planned in the Stole was either being
delayed or deferred because its output
was not needed now or in the near fu-
ture.
Summarizing the situation before on
Av.rrnbly rooimttitf: yesterday, rharlra
A. 7irli[i%ki, thnirrnnn ol the umimission.
d Ilir st:ilp had a "fut" irsrrve of Hec-
trie ropjrily in cunlrnM tn only five
:rnrs !!,•(). ju'.l .ifu-r tihc brownouts mid
lockouts in New York Cily und ju:;t be-
fore the Arab oil embargo.
He told the committee:
"We stand today with electric generat-
ing capacity 20 percent in excess of the
22 percent reserve required by the New
York Power Pool for adequate reliabil-
ity."
In the case of the Sterling plant, pro-
posed by the Kurhcster'Cos nnd Electric
CorpcratH.n nml ihrcc olfit-r upsf.iti? utilt-
lira, th* 1978 knp rangf tmpc.ist showed
•xrprs electric capacity in I'i%. the tar-
get date for completing the pt.mt.
"It seems cbvicus to us," ihe board
M In * unanimous decision, "that these
figures. whic*h are the ut'Iities* own esti-
mates, provide n proper basis for re-ex-
amining our findings of public need."
H rr*rrn by the Siting Dnnrd. wliich
b«rs th<- Formpl title frf the Statn Hoard
on Electric Generation Siting and the
Environment is FUTC to odd to ,nn alrt-ady
heated controversy on building new
power p'anls. involving billion:; of dollars
and toouscnds of jobs.
U also seem1; to support the position
of environmental groups, which have
been opposing new power plants, espe-
ciaJly nncl—ar plants, on several grounds,
including the contention thai they were
not needed.
Nrw York's seven public utilities and
the State Power Authority now produce
encup'h tlectncitv to mri't the fxppi-tcd
peak load of 21,000 mt-RawatLs ihis sum-
rr.pr, about the same lead as l.-ist yp^tr.
But the actual consumption will be G.OOO
^av-'^tts le*s than had been foiecast
in 1973 for this vear.
Reasons Given for Forecast
In addiron. tne exoecled pt*;ik usapc
for 190S. ba<;pd on this yeor';; c*:tim*itc
mefnwatt nuclear plont at S(erlinji in
strad of a conl-fircd plant ot Ginna. 12
m;les Enst of Pnrlicster.
It was expected then that the nnnrovol
would rlmr the way for a bnckloc nf
five other proposed power plants rwnit-
i^e dpc;sion, brt todav's order may delay
consideration of the other cases.
Three proposed plants are near the
decision Btape nccordinp ^n a commi^ion
vno^esmsn. They nrc n nuclrnr olont nt
Jptunsporl. I,. I, proposed l»v (he 1 onr
.Mnnd MflitlnR roinnnnv nnd (ho N«-w
York s»«te Uleitrtc onrt Cm ("itrixirnitnn'
n ron'-fired nhint nt Somerset on l.'*ke
Ont.uio, proposed bv the Ni-'irnra Mo-
tnwk CoroorutiPti. nnrf nnother conl plant
nt Dunkirk nn Lake Frie, also proposed
by Nhgra oMhawk.
Two other 'ilfints, hoth proconed bv
tbe Power Authority, nro in the ho^rln"
state, one n roal-nnd rulibMi-Trcd nli'nt
ul Art'iur Kill nn Stntm M;md and the.
ether n nuclear plant nt Omenion In
Greene Conn'v in Ihc niid-IUulson ValU'v.
Three major power plnnts nre under
((instruction in Hio ;;iril(\ nl] years behind
schedule, At Shorelmm. I,. I.. Lilc'o is
b"Hd:nrr a nurlrnr pl;tnt, ori^in;illy sch^'1-
\iled for 1077, but now set for 10PO'
Ni-«p.ir,i Moltnwk. ;i ntn lc;ir plant rt Nine
Mi'e Point on I ake Onl;iria. drl.ivcd from
1978 urlil ins^. and NiaRara Mnhawk.
nn oil fin-d plnnt nt Oswofirt, delnyed
fruni l!)7fi until I!)79.
-------
TENNESSEE VALLEY AUTHORITY
CHATTANOOGA. TENNESSEE 374OI
May 16, 1978
Mr. Boyd R. Keenan
Mr. James J. Stukel
Project Office
Ohio River Baain Energy Study
345 Advanced Computation Building
1011 West Springfield Avenue
Urbana, Illinois 61801
Gentlemen:
We have reviewed the summary report entitled ORBES Phase I;
Interim Findings sent by your memorandum dated April 20, 1978.
Our comments are enclosed and are based on review of the
summary report and previous review of the individual team
reports. Our concern in reviewing the various Phase I
material was for issues or statements of major or obvious
variation either with our experience and information or
with our perception of the purposes of the ORBES. Therefore,
the comments submitted do not necessarily include all of our
questions or concerns.
Very truly yours,
TENNESSEE VALLEY AUTHORITY
James P. Darling, Director
Division of Power Resource Planning
Enclosure
24
An Equal Opportunity Employe)
-------
The report entitled ORBES Phase I: Interim Findings summarizes in easily
readable form the results of the various studies that have been done to
date in the ORBES. The comments here are based on review of this report
and previous review of the individual team reports. Our primary concerns
with the summary report are really concerns we had with the Phase 1 work
as a whole. They relate to the organizational approach of the ORBES, the
basis and accuracy of the data used to make projections and subsequent
assessment of generic impacts, and the sense of bias that seemed to permeate
some of the research.
Regarding the organizational approach, it seemed to be too much of a dupli-
cation of resources (in terms of money, research personnel, advisory committee
personnel, etc.) to have three study teams with the same basic charge. Granted,
it was theoretically advantageous to have input from universities in different
locales of the ORBES region, but it appears that this input could have been
incorporated without the duplication of effort, introduction of confusion,
and extra work for condensation that resulted from three independent study
teams. The amount of time that was required to produce the summary report
is indicative of the added complexity, and perhaps perplexity also, of the
study approach. Furthermore, it would appear that the advisory committee
could have given much more meaningful input with less material to review.
The organizational concept that is planned for Phase II appears to be a much
more promising one.
The second major concern as noted above relates to the base data used in making
the various projections. Some of the base data used is inconsistent with
25
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-2-
TVA's experience and practice. For example, the land requirements noted
for coal versus nuclear plants (page 23, paragraph two) do not reflect that
increased storage requirements associated with scrubber wastes can actually
result in larger acreage requirements for coal-fired than nuclear generating
facilities. Furthermore, the estimate of waste storage requirements (page
92, paragraph two) for a 1,000 MWe plant of 2,400 acre-feet (80 acres, 30 feet
deep) is smaller by a magnitude of seven than the estimates TVA uses in siting
practice. On the basic requirement of .56 acre-feet required per MWe per
year of operation, we would estimate that 16,800 acre-feet would be needed for
a 1,000 MWe plant for 30 years of operation. From this it would appear that
the ORBES assessment of land use impacts of energy conversion is greatly
underestimated. This discrepancy also creates some concern regarding the
accuracy of the other quantitative estimates in the ORBES which were not as
noticeable or readily checked.
Related to the above problem are repeated references in the summary report
(page 24, paragraph one; page 92, paragraph two; page 96, paragraph five) and
in the earlier reports concerning reclamation and use of scrubber waste and
its storage areas. It is stated that procedures for returning waste storage
areas to productive uses are available, but the actual procedures and their
costs are not discussed at all. Various research is now being conducted in
this area, but we are not aware of any procedures which have yet been proven
either technologically or economically.
Finally, regarding bias, we believe that the credibility of the ORBES project
is lessened by inclusion of the passage from volume II-C on page 18 of the
summary report. Its presence immediately recalls the entire discussion from
26
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-3-
where it came. A discussion with such obvious neglect for the scientific
method and objectivity has no place in a university research document.
Surely, particular technologies can be evaluated and recommendations made,
but all discussion must be objectively made and referenced material should
never be taken from context as it was in some sections of volume II-C. If a
discussion of the disadvantages of nuclear usage is pursued, it must be couched
in an overall objective discussion which includes adequate treatment of the
advantages of nuclear as well as the advantages and disadvantages of coal
usage. Basically, however, we do not believe that the ORBES is the appropriate
forum to advocate or denunciate a particular fuel type.
In progressing with Phase II of the ORBES, it is hoped that the problems noted
above are avoided. Additionally, it appears to us that more time should be
spent in understanding utilities and the context in which they operate. This
is especially true considering the "grass roots" origins of the ORBES project.
It is important to recognize that no matter what the technological mix in the
future (coal or nuclear, low or high growth), the impacts of energy development
will be significant. Utilities are charged with the responsibility of providing
electricity to meet demand, and they must plan to meet future demand. Surely,
conservation is of utmost concern, and utilities are presently promoting Its
role and importance. However, conservation cannot be forced through limiting
supply. In other words, utilities cannot "turn off" electricity in order to
curb demand unless governmental/societal priorities change.
Given this situation, it seems essential that people be informed of the utilities'
situation in fulfilling their responsibility. Electrical energy development
occurs in a complex environment where controls and constraints are increasing,
27
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-4-
along with energy demand. This is not to say that the controJs are unwarranted,
but rather to illustrate that adequate communication between utilities and
the general populace would help people to better understand energy development
and its associated impacts. Perhaps, the ORBES should work toward the
establishment of this communication. Additionally, better understanding of
utility operations by the ORBES research team might clarify some of the
policy issues raised in the summary report.
28
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OHIO RIVER BASIN COMMISSION
Suite 208-20 36 East Fourth Street
Cincinnati, Ohio 45202 513/684-3831 (FTS)
May 10, 1978
Mr. Boyd R. Keenan
Project Office
ORBES
345 Advanced Computation Bldg.
1011 W. Springfield Ave.
Urbana, IL 61801
Dear Mr. Keenan:
The ORBC staff has reviewed the draft report, ORBES Phase I: Interim Findings.
You and Mr. Stukel are to be commended on an admirable job of combining the
findings of so many different researchers. Most of the summary findings are
generally accepted truths and, with a few exceptions, we do not take issue
with them.
The finding that there are potential conflicts between power plant sites and
bottomlands along the Ohio River is not supported by the Commission's recently
completed Ohio Main Stem Study and its adopted plan. These indicate that since
the majority of the bottomlands available are not wetlands or scenic and
recreational areas, there should be no conflict, on a regional basis, between
preservation of such critical areas and industrial development including power
plants. There is, of course, always the possibility of conflict in specific
instances, but this was known before any study.
Those findings which indicate possible problems with water for navigation due to
increases in irrigation and power production are in conflict with the ORBC
regional plan. The best information available to the Commission indicates no
foreseeable problem, even assuming the high energy senario and a reasonable
level of irrigation.
Thank you for the opportunity to comment on this draft.
Sincerely,
?red E. Morr
Chairman
29
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** UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
230 SOUTH DEARBORN ST
5 REGION V
•?* CHICAGO ILLINOIS 60601
MAY
Dr. Boyd K. Keenan
Dr. James J. Stukel
ORBES Project Office
347 Advanced Computation Building
University of Illinois
Urbana, Illinois 61801
Dear Drs. Keenan and Stukel:
In response to your request of April 20, 1978, I am pleased to transmit
the attached comments on the report, ORBES Phase 1: Interim Findings.
Let me preface them by saying that, generally, those who reviewed the
report on behalf of the U.S. Environmental Protection Agency (EPA),
Region V, found it thought-provoking and well-written. The report has
put many important questions before not only this Regional Office and
EPA, but the many people of diverse interests who will be reading it.
We have one significant reservation. The chief concerns of the environ-
mental groups which initiated requests for the study were air quality
and conversion of farmland to other uses. In general, we do not believe
either of these issues has been addressed adequately yet.
The attached comments are organized by chapter and page number. Some
comments may be relevant at several places. I know that some of the
matters which we have raised are being considered in Phase II; however,
the comments are included as a way of reinforcing our interest in the
questions to which they pertain. Several suggestions were made for re-
search on solutions to technical problems that were discussed in the
Phase 1 report. As the detailed investigation of them is beyond the
scope of the report, they have been given to the Regional R&D Represent-
ative for consideration by the EPA Office of Research and Development
in its future program planning.
I know that you and the other members of the core team are already well
into the second phase of the ORBES study, and we will all follow your
work with interest. Jim Phillips and Susan Walker will continue to work
with yoi/? Please feel free to call upon other Region V staff, through
them, LOT additional assistance that you might need.
Sincarely,
m
•/*-
Valdas V. AdamUus
Acting Regional Administrator"
Attachment
30
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ATTACHMENT
Table of Contents should be more detailed; include at least the items that
are used as side headings within chapters.
Chapter 1 (Summary)
This chapter and the rest of the report would be easier to use, and possibly
some questions would be avoided, if summaries of the basic features of the
scenarios were given near the beginning, rather than left for the appendix.
p. 1 The statement that this report "should not at this point be construed
to represent agency policy" is misleading, because such reports are never con-
sidered agency policy, even after final publication.
How much of the projected conversion to urban uses depends on provi-
sion of a certain level of power? If such conversion is assumed to be an
independent variable, what evidence exists for the projection?
p. 2 Is the statement about "regionwide" availability of water accurate
regardless of the number of plants and types of cooling systems that they use?
p. 3 Does the statement about transportation account for rolling stock and
other features besides the total mileage of road, track, etc.?
p. 4 Are the last two assertions applicable to the ORBES region as well as
nationally?
p. 5 Does the statement about labor supply apply to the ORBES region, the
nation, or both?
Area sources and fugitive emissions were substantially lacking from
the emission inventory. Also, changes in emission factors and inventory meth-
odology have taken place. Therefore, the emissions shown appear to reflect
obsolete methodology, and the conclusions drawn could be erroneous.
How is the discrepancy between the levels of particulate removal and
of sulfur oxides removal explained? What level of S02 removal is assumed?
pp. 5-6 If utilities are assumed to be "industries," as they have been re-
ferred to earlier, is the figure for sulfur oxide emissions of 35 percent
from industry correct, even for the FTF 100 percent nuclear scenario? Where
is the rest coming from?
None of these seems to take into account controls on other facilities.
p. 6 Why would concentrations of secondary particulates increase under
the low-growth option (especially 100 percent nuclear)? What difference, if
any, would the mix of fuel sources make?
Neither the material in this chapter nor the later discussions ad-
dress the air quality problem: the impact of the present and projected air
emissions in the local area, the ORBES region, adjacent parts of the same
31
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-2-
States, or other States. We are seriously concerned about the ability to
attain and maintain air quality standards. This is one of the most impor-
tant questions for the study to address. It should also consider the ade-
quacy of existing standards and the need for revisions and/or additional
standards for pollutants like acid sulfates. This comment also applies to
p. 56.
p. 7 What assumptions are made about the efficacy of the 208 (non-point
source control) program?
There should be a statement comparing the expected death rates under
either scenario with current rates.
Population density has previously been stated as low; therefore, what
is the basis of the statement that "boomtown" conditions would be expected in
few locations (regardless of density)?
p. 8 The first statement appears to contradict the last statement on p. 7.
The implication of the next-to-last statement is that the more one
knows about how energy is produced, the less concern one has. This is not
necessarily true.
Although it may be true that no institutional solutions are available
for some problems, is it true that none are available for any? Possibly, the
usefulness of existing solutions has not been tested.
p. 12 How much fuel shifting had actually taken place at the time of the
embargo? The implication is that the Clean Air Act and environmental restric-
tions were entirely responsible; however, the impact of the Clean Air Act had
yet to be felt significantly, and price and other factors may have had more to
do with shifts that had occurred.
The observation that begins "if coal were to be..." is not accurate.
This discussion obscures the fact that the conclusions presented are
those of the utility industry. The arguments of the opponents of energy
facility location in the Ohio River Valley should be given equal attention.
p. 14 If Illinois coal production outside the Basin was taken into account,
should not that in the parts of other ORBES states which are outside the geo-
graphic bounds of the study (e.g., northern Ohio) be considered also?
p. 16 Although methods of power generation other than conventional coal
and nuclear fueled plants may not be in widespread use in the ORBES region
by the year 2000, greater attention should be paid to them in this report.
Thus, for example, there should be more discussion of fluidized bed com-
bustion and other emerging technologies for using coal, and of forms of
power generation like solar 'and hydro.
p. 18 In general, the issues surrounding increased generation of power
by nuclear plants have been insufficiently treated, as compared to those
32
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-3-
which are raised by coal^fired plants, notwithstanding the disclaimer on
this page.
The quotation from the University of Louisville report improperly
emphasizes only one side of the argument. It should be deleted or the
other side should be added with equal emphasis.
Chapter 2 (Impacts on Natural Resources)
p. 21 The rationale underlying the figures for coal extraction and proc-
essing in the two FTP scenarios should be explained.
p. 22 The remainder of the paragraph on subsidence seems to contradict
the first sentence.
p. 24 For purposes of comparison, amounts of land required for disposal
of radwastes should be stated.
p. 27 Do water-removal operations during mining invariably increase the
base flows of streams?
Additional evidence should be given for the conclusions in the first
paragraph under "water use."
In the second water use paragraph, the percentage figure is confus-
ing. Both municipal and industrial use are likely to increase.
p. 27 The assumption that all powerplants, including those presently on
line, will use off-stream cooling may be overstated. Several plants on the
Ohio and its tributaries employ once-through cooling and it is not certain
that they will retrofit; nor is it certain that all new plants will use
closed-cycle cooling.
Chapter 1 implies that irrigation rould become "widespread"; there-
fore, the "role of irrigation" should be accounted for here.
p. 29 The problems that could arise under low-flow conditions are not
limited to navigation, but may include recreation, fishery resources, and
potable water supply.
p. 30 Because many existing plants will be in service until the end of
the period, or close to it, their water consumption should have been taken
into account in calculating impacts.
p. 30 Lime and limestone are reactants with sulfur oxides or sulfates,
not fuel.
The study should not assume that all plants which burn high-sulfur
coal will be using lime or limestone scrubbers after 1985.
p. 33 Is the statement about additional exploration and the reserve base
an accepted fact or an assumption? Would this be likely to be surface
mined, or would underground mining be necessary?
33
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-4-
p. 36 The question of State and local government roles goes beyond just
selection of disposal sites, because they have regulated or attempted to
regulate other matters like transportation of radwastes.
p. 37 The question of water rights and uses is broader than this set of
questions implies. The consideration of water allocation might be expanded
to cover upstream uses. Also, re-use of water (e.g., municipal waste treat-
ment plant effluent for irrigation) might be considered.
Chapter 4 (Impacts on Developed Resources)
pp. 38-39 The environmental effects of barge and train unloading facilities
are ignored; however, they can be locally significant.
p. 39 In the paragraph about transportation of nuclear material, the use
of the phrase "flexibility available for routing trucks" is odd. Transpor-
tation around, rather than through, cities may be required. (Trucking is
flexible only as compared to railroads, but there is no flexibility in be-
ing forced to change routes.)
p. 46 The cost figures for uranium, and the resultant comparison with coal,
are misleading because the costs of enrichment to make uranium a usable fuel
have not been considered. Electric power demand for this purpose is huge.
p. 47 Why is employment in the construction industry higher in the FTP
scenario than in the BOM? This appears to contradict statements on pp.
48-49.
p. 53 An additional question would be: "Should explicit or implied sub-
sidies granted to private users of transportation facilities be modified
or revoked in order to make costs more realistic?"
p. 54 The questions about rates and forecasts do not get at the basic
matter of regulating demand. Also, there should be a question about the
roles of state regulatory agencies and the factors that go into rate-making.
Chapter 5 (Impacts on the Biological and Ecological Environment)
p. 56 The statement about emission rates appears to contradict p. 5.
The criteria for "preferred" sites, as the term is used in this paragraph,
should be explained.
p. 57 The implied conclusion at the end of the first paragraph that re-
placement of old sources by new will result in improvement in air quality
beyond NAAQS requirements may be faulty, in part because fugitive emissions
were not considered.
The second sentence in the last paragraph appears not to be direct-
ly related to the rest of the paragraph. Formation of secondary particu-
lates should be the subject of a separate discussion.
34
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-5-
"PSD" requirements are used on a "local scale" insofar as they may
be applied to individual plants which may be distant from each other, but
the implications and effects of the policy are not just local.
The existence of the "offset policy" should be mentioned.
p. 59 There is no column of net totals for future years; therefore, the
reader cannot understand how much air pollution would be present.
p. 62 It would be more appropriate to define the terms "primary" and
"secondary" particulates here, where they are first used, rather than later.
The fact that these particulates are from point sources should be stated.
p. 63 The reference to "secondary" particulates (constituting 1/10 to
1/3 of the mass) should be to "fine" particulates.
p. 64 There is no citation for the reference to conversion of sulfur in
western coal to sulfur dioxide. EPA Region V Enforcement uses 95 percent
for eastern coal.
The report appears to be based on the questionable assumption that
the current NSPS limitation on S02 emissions will remain. The limitation
is likely to become more stringent.
p. 66 The impact of sulfur oxides on vegetation, etc., has been estab-
lished; therefore, the use of the word "may" is inappropriate.
p. 67 The postulated increases in NOg emissions by the year 2000 range
from 68 to 93 percent. As they would result in violations of ambient
standards- throughout the ORBES area, it is not likely that such increases
would be allowed.
p. 69 Because the inventory does not account for 20 percent of the HC
emissions, the conclusions may be faulty.
p. 72 CO is primarily, but not exclusively, an urban problem; substitu-
tion of the word "local" might be appropriate.
p. 72 The scenarios studied indicate that the SO. emissions will re-
sult in a 7 percent increase or one percent decrease relative to 1972. In
light of the mandate given to EPA by Congress to achieve ambient air quali-
ty standards, and their nonattainment today in the ORBES region, the results
cast doubt on the scenarios used in the study. The numbers of new fossil-
fueled power plants indicated by projected electrical demand cannot be built
in the Ohio River Valley, under present regulations mandated by Congress, if
the standards are not met and maintained.
pp. 73ff The discussion of the "cascading effect" should be expanded and
broadened. At the same time, care should be taken to ensure that models
used to determine this effect are accurate. Although the models are ref-
erenced in the appendix, discussion of methodology would be useful here.
35
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-6-
p. 76 Effluent limitations are established for both industrial and muni-
cipal discharges, and applied regardless of the quality of the receiving
waters. In addition, the phrase "...standards to be set for all major
surface waters..." is too narrow, and is not contained in the Act.
The last two sentences of the first water quality paragraph imply
that issuance of permits is solely a State function. As of May 1, 1978,
30 States administer the program and EPA issues permits in the rest.
p. 82 What is meant by "the nature of the receiving waters" (first
full paragraph, line 4)?
p. 83 Evidence should be given for the statement at the top of the page
that "nearly all phytoplankton...are killed...." This is not necessarily
true.
p. 84 If the statement about organic chlorides is meant to refer to
chlorinated organics, it is wrong.
Although total net BOD levels may decrease with improved treat-
ment, population increases may more than offset the effects of treatment.
p. 85 Additional evidence should be cited for the assertion in the sec-
ond paragraph that production of COD from all sectors except forest prod-
ucts and fisheries will decrease.
p. 86 Some estimates of the contribution of non-point sources to TSS
should be made, because it can be significant.
p. 88 As on p. 84, population growth is likely to more than offset treat-
ment effects; thus, the reductions mentioned here will not occur.
pp. 92-93 The discussion of waste disposal for the nuclear fuel cycle over-
looks evidence of accidental releases and/oi leakage of radioactive wastes.
In addition, it ignores the controversy over both existing and future dis-
posal sites, and the problem of perpetual, as well as complete, confinement.
p. 94 The question about institutional mechanisms implies that existing
mechanisms are inadequate. In addition to consideration of changing insti-
tutional patterns, thought should be given to accommodating existing mech-
anisms to new problems.
p. 95 The rationale for a regional siting mechanism should not be solely
the avoidance of regional-scale impacts. In addition, this question and
the third question appear to be virtually identical.
The 1977 amendments to the Clean Air Act moot the second question.
p. 96 What is meant in the first question by "water quality goals?" How
do they differ from standards?
36
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-7-
p. 97 Public health is a different question from economic and social im-
pacts, and a separate chapter should be devoted to it.
p. 104 The paragraphs on loss-of-coolant accidents and safety in general
are too sketchy. The discussion of the criticisms of the Rasmussen report
(about which EPA had serious reservations, expressed in a letter to the
Atomic Energy Commission on November 27, 1974, signed by the Deputy Assist-
ant Administrator for Radiation Programs, and subsequent correspondence)
is inadequate.
In the last sentence, not only are the long-term effects of waste
disposal uncertain; the questions about methods and siting of waste dis-
posal are unresolved.
p. 107 Is the assumption of a zero occupational disease rate in the coal-
fired cycle reasonable?
p. 108 Some of the energy facilities envisioned in the scenarios, particu-
larly BOM, are quite large. Could not their configurations resemble a
"power park" and thus possibly induce "boomtown" conditions?
P. 112 Additional evidence should be given for the conclusion that urban-
izing, economically diverse, etc., communities "will probably be most recep-
tive to energy facility development...," as opposed to best able to accom-
modate it.
p. 117 There is not necessarily a conflict between local and regional policy
in energy facility decision making, although that might occur.
p. 119 To the second question might be added the clause, "and if so, which
level?"
In the first question, the tradeoffs are not just, as this implies,
between health abuse and employment, but health abuse and the need for energy.
37
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INDIANAPOLIS POWER 8 LIGHT COMPANY
35 MONUMENT CIRCLE P O BOX IS95B
INDIANAPOLIS. INDIANA 46206
CARL B VANCI
FXRCUTIVE VICE PfirSIOI NT Maw 19 1 Q7R
OPERATIONS i ioy 11, i s/ o III?J ((|r; (i(|()(t
Dr. Boyd R. Keenan
and
Dr. James J. Stukel
ORBES Project Office
345 Advance Computation Building
1011 West Srpingfield Avenue
Urbana, Illinois 61801
Subject: Comments on ORBES Phase I
Interim Findings Volume I-A, 1977
Gentlemen:
There is no doubt that the compilation of the widely diverse ORBES
Phase I study is a monumental job. The opportunity to serve on the Advisory
Committee for this group is an honor and a challenge. Having attended, or
been represented, at many of the Core Team meetings, I feel the obligation to
point out some of the areas where it is felt that the study findings deviate
from the work presented at the Core Team meetings. Although there are many
points which can be addressed, I have attempted to address those of a more
general nature rather than a full editorial commentary or critique of the
intergrated summary report.
One of the most striking problems that appears in the summary report is
the negative approach taken on many of the issues where both positive and neg-
ative factors occur. As an illustration of this point, consider the extensive
discussions regarding the problems expected under the high energy growth scenario
with respect to the labor necessary for maintenance of high growth. After reading
such a discussion one is lead to believe that it will pose insurmountable problems
in developing such a labor force. However, the positive side of the same findings
is that many additional jobs will be created and a healthy stimulation of the
economy will occur because of the creation of such demand for labor.
It is disturbing to note the means of presentation of the high and low
growth studies as being options available to the reader. It is strongly recom-
mended that the word "option" be replaced with the more correct word "scenario,"
which was nearly always used in the explanation of the two growth patterns
selected for the study. Neither was presented as an option to be controlled or
otherwise interjected upon the economy, but as boundaries between which the ORBES
researchers felt that the actual growth conditions would occur. The presentation
of such boundary conditions as options is inconsistent with the philosophy of the
scenario development. The handling of the designation of "growth options" versus
"growth scenario" is inconsistent throughout the intergrated summary report and
should be edited to replace "option" with "scenario."
38
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Dr. Boyd R. Keenan
and
Dr. James J. Stukel 2 May 12, 1978
An underlying assumption is the economic analysis of the ORBES Phase I
report that remains unsatisfactorily supported is the assumption that the gross
national product under either the high energy or low energy scenario will remain
the same. It is difficult to imagine that the ORBES region gross national product
will remain the same with both the high and low growth scenarios. The very
factors alluded to in the study regarding the much more extensive demands on
labor and capital to maintain the higher energy growth scenario would lead any
reader to believe that the economy and gross national product of the region would
be greater under the high energy growth scenario. The massive sum projected to be
spent on capital equipment and labor, both operational and construction, must roll
through the regional economy to create substantial multiplying effects, which can
be easily visualized. However, to assume in the low energy growth scenario that
other sectors of the economy will somehow magically increase to produce the same
multiplying stimulus upon the economy does not appear likely or reasonable. In
short, the scenario development on the effects on regional/national employment
under the two energy scenarios does not wring out when testing both scenarios
for the same gross national product. Quickly comparing the employment chart on
page 47 of the report shows apparent inconsistencies in the forced national pro-
duct equality assumption. Household appliances being ranked No. 1 in increased
employment effect appear to be inconsistent with the idea that per capita electric
energy is available for public use. Water and sewer companies are among the bigger
electric users and are ranked No. 2, while a multitude of service and building
sectors are ranked high in the increased employment areas. These same sectors
have traditionally stimulated the greatest electric demand growth, and as such
appear inconsistent with the reduced employment and growth in the electric utility
sector. In further questioning this assumption, I am attaching for the record
the remarks of Mrs. Margaret Bush Wilson, Chairman, National Board of Directors,
National Association for the Advancement of Colored People, given in Houston,
Texas on April 10-12, 1978. This statement directly relates the effect of energy
policy upon the minority employment and is an area wholly unaddressed by the ORBES
study. It appears that some comparison of the high energy versus low energy
scenarios regarding the employment on large minority groups is in order. It is
my considered opinion that the higher energy growth in reality will provide much
better opportunities for employment of such minorities and all other social sectors
of the economy. The indictment of the high energy growth scenario ignores these
effects and rather assumes that the low energy growth scenario will magically
develop other opportunities for employment. The question that arises immediately
is what happened to the unemployed sector of the economy?"
The section entitled "Illustrative Policy Issues" is not a finding and
as such should not be included in an interim findings report. Most are questions
which have faced society for many years and the re-statement of such questions as
ORBES findings are neither correct nor appropriate.
COMMENTS ON INDIVIDUAL REPORT ITEMS
The following comments are not all inclusive, but reflect items which are
questionable regarding the Phae I Interim Findings.
39
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Dr. Boyd R. Keenan
and
Dr. James J. Stukel 3 May 12, 1978
The findings in the "Public Health, Economic, and Social Impact" sections
are rather vague regarding their meaning and tend to mislead the reader. For
example, the findings that "the high energy growth option would more than
double the expected premature deaths when compared to those expected under the
low energy growth option only addresses a portion of the question and recites
an obvious finding. That is, if on the average one person is killed during the
construction of an energy facility then if twice the number of facilities are
built twice the expected premature deaths occur. However, the oversite in the
study is that if jobs and industrial developments occur in other sectors of the
economy under the low energy growth option to maintain the gross national product
these will also result in some premature deaths. No job or work catagory is com-
pletely without risk and the increase in other sectors may well be interpreted as
increasing the expected premature deaths in the other sectors. Likewise, the
comments regarding "most experts agree under normal conditions, the coal fuel
cycle is responsible for more premature deaths than is the nuclear fuel cycle"
is neither profound nor unexpected. The greater employment in coal mining and
transportation facilities obviously leads to greater exposure because of the
greater employment. If more people are out of work, there will likewise be
fewer job related mortalities. To couch the coal fuel cycle as being responsible
for more premature deaths than the nuclear fuel cycle is similar to comparing the
number of premature deaths occurring on the job between the hours of 8 a.m., and
5 p.m., as compared to the number of premature deaths occurring on the job between
the hours of 12 midnight and 8 a.m. Although some validity remains with the argument
that certain jobs inherently contain higher risk than others, intensive investigation
of such items is not apparent. It is my opinion that all deaths are premature, but
many means are being explored by both the government and industry to reduce the
inherent risk in all jobs via corporate safety planning and OSHA regulations.
The statements regarding the reclaimation of land requiring many years for
farmland to be returned to reasonable level of productivity is incorrect. Under
the Surface Mining, Recovery and Control Act any miner is mandated to return land
to within 90% of its original productivity within five years. This appears to be
a requirement of the Act for mining and not merely a goal to be attempted.
Under "Water Use" page 27 a great deal of study has been conducted regarding
the consumptive use of the plants. In actuality what has been termed consumptive
use is the evaporation from the generating system cooling towers installed to
reduce the effect of any heated discharge on the rivers. This evaporation at any
given point may appear to be a loss; however, this water, as with other water
evaporated, is returned to the ground in the form of precipitation and is not
truly consumed. It would be naive to think that none of the evaporation from a
plant along the lower Ohio valley would not be reprecipitated within the ORBES
region. Likewise, some of that evaporated in the upper Ohio might well move into
other water regions as might also be expected to occur into the ORBES regions from
other air movements. Although these effects may not lend themselves to adequate
quantification they may not be omitted as not in reality occurring. It is recom-
mended that "consumptive losses" be changed to evaporative uses. The problems posed
regarding irrigation are not as profound as might be expected.
40
-------
Dr, Boyd R, Keenan
and
Dr, James J, Stukel 4 May 12, 1978
If attempts were made in the development of massive irrigation projects,
it would require substantial quantities of electric energy to move the water
from the rivers to the irrigated land. If enough irrigation is pursued the
river will be lowered, in which case society will be faced with balancing
the distribution of the water resource.
Under the "Coal Designation" on page 31, the statment is made that most
utilities would choose to import low sulfur coal than employ flue gas desul-
furization. Regardless of what most utilities choose the Clean Air Act
Amendments of 1977 leave the utilities with no alternative as far as flue gas
desulfurization.
The section regarding "Regional Employment" on pages 48 thru 53 was
discussed earlier in these remarks. Here again, only the negative aspects of
the increased employment is discussed and the problems of using "scenario" versus
"option" is apparent. The graph on page 51 does not present two distinct options
but represents the boundary conditions identified in the study assumptions by the
ORBES researchers.
With regard to the impact of sulfur dioxide alluded to on page 66, it should
be noted that these negative impacts are only discernable above certain concen-
tration levels, as alluded to in the last sentence of the third paragraph. In
addition, some sulfurate depositions may have beneficial impact in certain areas
where the farmers must periodically treat fields with sulfur bearing compounds
to neutralize the ground.
The discussion regarding sulfur oxides and nitrogen oxide emissions from
power plants on page 68 although mathematically correct, does not reflect the
reality that a shift in emission sources from tall power plant type stacks to
automotive and shorter industrial sources may reflect in the case of the low
energy scenario substantially worse ground level concentrations than would be
expected from the 14% higher total emission which would be emitted from taller
utility sources.
On page 72 and 73 the discussion regarding the corridor effect/sub regional
effect contains several problems. The adequacy of the wind data used in deter-
mining the corridor effects by Tecknekron is subject to significant question. In
addition, the models used to project the concentration were never calibrated or
validated for such extensive distances as the corridor shown. In addition, the
report leaves significant question by quoting 12 hour concentration rather than
24 hour, which are the basis for the ambient air standards.
The discussion of NQX on page 102 is approaching a medical opinion over
which there is considerable controversy. EPA has little unequivocable data
upon which they can rely to such standards. Most of the human studies show
no health effect at low levels of NOg and those that do (VonNieding and Orehek)
have serious deficiencies and have not been replicated. Delving into such
medically related health studies appears to be beyond the scope of the ORBES
charge.
41
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Dr, Boyd R, Keenan
and
Dr. James J, Stukel 5 May 12, 1978
I hope the above suggestions will be of assistance in your revision
of the draft ORBES Phase I Interim Findings. If you have questions regarding
my comments or we may be of assistance, please contact me or Mr. McKnight.
Very truly yours,
INDIANAPOLIS POWER & LIGHT COMPANY
Carl B. Vance w'
Executive Vice-President - Operations
CBV:RAM:lb
42
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COMMENTS BY
PHASE I RESEARCHERS
-------
24 May 1978
INDIANA UNIVERSITY
School of Public and Environmental Affairs
ENVIRONMENTAL SYSTEMS APPLICATION CENTER
III.OOMINR1 ON. INDIANA 47401
TtL. NO. 812 337-9»8J
TO: Boyd Keenan
James J. Stukel
FROM: John F. Fitzgerald
SUBJECT: Comments and suggested changes on Interim Report
p. iii - The first paragraph of the preface states, "Funding for
the project is being provided through grants from the
U. S. Environmental Protection Agency (EPA) to the
Universities involved. The statement should read
"... EPA and the Universities involved." Indiana
University can document many thousands of its own hard
dollars that have been put into the ORBES effort including
and in excess of the required 5% cost sharing provisions
of the contracts. Most of the other Universities can do
the same.
p. iii - The third paragraph of the preface, first sentence should
read, "Concerns of residents living on the shores of the
Ohio River prompted Congress, through Senator Birch Bayh,
to support the project.
Chapter 1, page 2 - Add to "potential land use conflicts" the
continuing conflicts between unwilling property sellers
and the utility-courts bloc under eminent domain i.e.,
the continuing involuntary loss of homesteads and other
property by citizens.
Chapter 1, page 3 - The second item reads, "... there is a suffi-
cient amount of this fuel (coal) in the ORBES region to
supply regional energy conversion facilities for several
hundred years." It is noted that the impact of such
utilization is not mentioned under the Chapter 1 headings,
"Impacts on Developed Resources," or "Impacts on Ecological
and Biological Environment." For continuity of examination
of "several hundred years" of utilization, some sort of •
extrapolation should be made in these additional areas.
44
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Boyd Keenan
James J. Stukel
24 May 1978
Page 2
Chapter 1, page 3 - The discussion on uranium prices should not be
couched with cost of uranium use. These items "price" and
"cost" will probably be separate items of discussion. In
the former only the exchange value of the resource will be
a consideration. When looking at cost, however, other
items not internalized in "price" should be considered.
Price can fluctuate widely for an exchangeable commodity
dependent upon production costs associated with extraction,
transportation, conversion, waste disposal, etc. Cost can
include these items but may additionally include external
costs not necessarily associated with price which typically
reflects only internal costs. External costs should also
be valuated e.g., environmental (aesthetic) degradation,
health care costs, depression of competing money competitors
and subsequent multipliers, etc.
It would be advisable to make these "price" and "cost"
considerations carefully not only with uranium but also
with other energy resources that are considered. External
costs are often the same as social costs and these are the
preeminent issues to be studied in the formulation of public
policy. In fact, the determination and management of social
costs are the only business of public policy makers. When
the final report for the ORBES is written this will be the
focus of the conclusions and policy recommendations to the
Congress and EPA. The study should avoid the tendencies
to place too much analytical effort on identifiable internal
costs that are themselves subject to wide variation in both
short and long time periods.
Chapter 1, page 8 - On local acceptance of power plant construction:
Is acceptance a function of perceived economic benefits or
an absence of an environmental ethic? Can communities be
identified by the exposure to environmental and conservation
education and correlations drawn on acceptability of indus-
trialization? This is an area that deserves more exploration
i.e., does exposure to a different perspective alter the
perceptions and preferences of people in an economics-or-
environment situation? Who should be involved in the public
education process relating to environmental protection and
values? The primary schools? The university? State govern-
ment? Public interest groups? Should this environmental
ethic be promoted at all as opposed to a development ethic?
What kinds of induced stimuli should the population receive
in the energy-environment question? If it is permissible
to induce reactions with commercial commodity marketing,
is it also permissible to do the same for public policy
issues? Is it already being done by the energy companies
or environmentalists?
45
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Boyd Keenan
James J. Stukel
24 May 1978
Page 3
Chapter 2, page 9, third paragraph. - This is redundant; it is already
in the introduction and in Appendix E.
Chapter 2, page 18 - The last two sentences of this page are super-
fluous. Are the authors writing a report or an apology?
Chapter 3, page 36 - Under the land use category in illustrative
policy issues, are all of the points subsets of the fifth
item? "How can individual rights best be balanced against
the use of eminent domain for energy related facilities
to promote the public good?"
Chapter 4, page 45, 1st paragraph, last sentence - The word "entirely"
should be eliminated and the word "possible" should be
placed in front of the word "order." This sentence should
convey the tentative nature of long term economic projections.
Even this tentative statement remains generally true only
if market adjustments do not occur; there is little chance
of that happening.
JFF:dv
cc: J. C. Randolph
46
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University of Illinois at Urbana-Champaign
Engineering Experiment Station 106 Engineering Hall
OFFICE OF THE DIRECTOR JiSm" w?' 6'8m
May 15, 1978
Professor James J. Stukel
Professor Boyd R. Keenan
Ohio River Basin Energy Study
345 Advanced Computation Bldg.
•Jack Desmond and I have reviewed Volume I-A of the Ohio River Basin Energy
Study entitled "Phase I: Interim Findings" dated November 1977. The report was
also distributed and comment solicited from the Urbana participants in Phase I,
Task 2. Since the report has been distributed to Professor James Hartnett of
the Circle campus, I will assume that he and his group will respond directly to
you.
The general reaction is a favorable one acknowledging that the integrating
process was clearly a very difficult one. We were delighted to see much of the
Illinois report in evidence in the current volume. On behalf of the Urbana
group I would like to convey to you two specific concerns raised by individual
members of our research group.
The first is a statement prepared by Professor Wayne Davis who served on
the Urbana task group and dealt primarily with an assessment of impacts upon
air quality. Professor Davis' statement is as follows:
As a contributing researcher to the ORBES report, I find the
basic presentation of the air quality section credible, but with
one major fault. In the detailed discussion of the emissions
arising from the proposed scenarios (which constitutes the major
portion of the section), aggregate data was presented for the
ORBES region as a whole. Though it poses some interesting
insights, particularly when this data is compared to the national
average data, it does not represent the true consequence of
either scenario and its associated siting configuration.
Under either of the proposed scenarios, there will be a congre-
gation of new power generating facilities along the river corridors
in ORBES region. The percentage increase in emissions along these
corridors will be far more significant and assuredly greater than
that for the ORBES taken as a whole. The effect of presenting the
data as given in this report is to average these increases over an
area which includes subregions that are unlikely to be significantly
influenced by the short-range transport phenomena of the primary
pollutants from a nearby source. It will be admitted, however, that
the total region must be affected to some degree by the long-range
transport of secondary pollutants. Thus, it is felt that a similar
analysis for primary pollutants with specific subregions, particularly
the river corridors, would be far more enlightening.
47
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Professor James J. Stukel
Professor Boyd R. Keenan -2- May 15, 1978
It should be stated that the above observation was the major
reason for this researcher's proposing to investigate the cas-
cading effect of the proposed new sources along the river corridors.
It is realized that the models utilized in the discussion of this
effect were rather crude yet they did indicate air quality problems
on the horizon. One important point should be emphasized: the
model (the results of which are discussed in this section of the
ORBES report) included increments in ambient pollution levels
resulting from new power generating facilities only. Time did not
permit an attempt to ascertain the present level of pollution in
the region. Nevertheless, recent developments in the Ohio River
corridor highlight the current situation.
1. Several existing facilities (which are unlikely to be
retired under any scenario in the near future) are in
violation of present standards and are the subject of
current administrative action by the EPA.
2. Already in some areas along the Ohio River either action
is pending or has been taken to severely limit the
emissions from any new source in the area.
The above statements provide one important conclusion: the air
quality along many of these river corridors is already significantly
deteriorated. This leads to one final conclusion by this researcher
that neither of the proposed scenarios can or should be implemented.
It seems to me that Professor Davis makes a very valid point. One of the
significant contributions of our group to the Phase I Study was the identifi-
cation of both the cascading and the corridor affects and while the present
reports touches on subregional impacts, most of the findings are weighted
toward averaging pollution levels for the entire region. Professor Davis1
work provided us with a warning which could be better highlighted. Present
and potential pollution levels, require that the utmost care be used in
siting future power plants to avoid the subregional concentrations which are
likely to occur.
Professor Judith Liebman who assessed impacts upon transportation facilities
in Phase I wishes to submit the following statement:
I disagree strongly with the summary statement on page 3 that
'the transport of coal and of industrial supplies and products
within the ORBES region would not overly stress the existing
regional transportation system.1 It might not overly stress an
efficient transportation system—but the existing system is far
from efficient. I think that, for example, there is very little
additional capacity in the waterways. As for the railroads,
enough lead time to build the necessary hardware would be needed.
Here again, I believe that a valid point is made. The potential problems of
burdening our existing transportation systems have been under emphasized in the
present report.
Now I would like to provide some general reactions to the report. While
the document is clearly labeled as one dealing with interim findings, I see no
48
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Professor James J. Stukel
Professor Boyd R. Keenan -3- May 15, 1978
statement in the document (which we were always careful to include in our own
reports) that the approach of Phase I was one of a mini-technology assessment
which gives great emphasis to breadth of the work rather than its depth.
Phase I was predicated upon the research philosophy of identifying the
boundaries of many problems as a preface to the deeper work which would be
conducted in Phase II.
Within this framework, the summary conclusions assembled in Chapter 1
flow fairly well; that is, one begins to get a bounded view of the kinds of
problems that are likely to exist in the year 2000 under a set of prescribed
alternate futures. Phase I provided a valuable foundation for the work which
must follow.
I have some difficulty with the sections dealing with illustrative policy
issues. They strike me as a series of very broad rhetorical questions. Conse-
quently, I can find no solid ground upon which to argue against or defend the
propositions raised. I have particular difficulty with issues raised which
appear to have no antecedent coverage in either the narrative or the summary
findings. I find it a bit disconcerting without any prior discussion to find
subjects such as the wisdom of the continued use of eminent domain and need
of "protecting" the public interest with regard to the breeder reactor
mentioned for the very first time in the issues section. In addition, I am not
sure what implication one is suppose to draw from these lists of questions. Is
it intended that they be dealt with in more definitive fashion in Phase II?
My own preference would have been to include illustrative policy questions
which followed rather directly from the narrative and preliminary findings.
Irrespective of this expression of concern, I think the Phase I work and
the integrated report which has been assembled provides a most valuable prelude
to the much more intense research which is being conducted in Phase II.
Ross J. Martin
Associate Dean and Director
RJM/ph
cc: W. J. Davis
J. J. Desmond
J. P. Hartnett
J. C. Liebman
J. S. Liebman
49
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UNIVERSITY OF LOUISVILLE
LOUISVILLE, KENTUCKY
40208
COLLEGE OF ARTS AND SCIENCES
DEPARTMENT OF PHILOSOPHY
May 9, 1978
TO: Boyd R. Keenan
James J. Stukel
ORBES Project Office
345 Advanced Computation Building
1011 West Springfield Avenue
Urbana, Illinois
FROM: K. S. Shrader-Frechette
ORBES Phase I Researcher
University of Louisville
RE: Comments on ORBES Phase I Integrated Summary Report
Enclosed are my nine pages of comments, "The Ohio River Basin
Energy Study: Methodological and Ethical Problems," regarding the
ORBES Phase 1^: Interim Findings. I appreciate this opportunity for
Phase I researchers to have their unedited remarks published as Volume IV
of the Phase I Report to be forwarded to EPA.
Since the Interim Findings (pp. 18, 103) indicated that problems
regarding nuclear power and low-level radiation will be treated in
Phase II, I am most interested in seeing further volumes of the ORBES
reports. Key social, ethical, and policy issues still need to be
addressed, and the ORBES team must include health-radiation physicists,
biologists, political scientists, environmental lawyers, and philosophers,
if these questions are to be treated adequately. Best wishes for ORBES
success.
Sincerely,
/.
K. S. Shrader-Frechette
Associate Professor
KS-F:ehw
cc: H. T. Spencer
C. Leuthart
F. Hauck
50
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The Ohio River Basin Energy Study:
Methodological and Ethical Problems
K. S. Shrader-Frechette
Associate Professor
Philosophy of Science
University of Louisville
1.0 Introduction
The purpose of this analysis is to present a methodological critique of the
Ohio River Basin Energy Study, Phase I. Although a great many positive remarks
could be made regarding this multi-volume, multi-university, multi-disciplinary
study, the object of this discussion will be to provide a context for improving
the quality and objectivity of the final technology assessment given in the
ORBES summary. To this end, two key questions will be investigated: (1) Were
all factual or scientific parameters of major relevance to the study taken into
account? (2) Were there any questionable evaluative assumptions implicitly built
into the technology assessment? Question (1) addresses the completeness of the
scientific methodology employed in the study, whereas question (2) focuses on
the objectivity of the ethical and evaluative presuppositions implicit in it.
2.0 ORBES Methodology and the Criterion of Completeness
Completeness is an important criterion for evaluating any technology assess-
ment since policy alternatives, such as those provided by the four energy scenar-
ios of this study, usually involve highly complex tradeoffs. The relative value
of any component in the tradeoff can be skewed if the overall problem is defined
incorrectly or incompletely. Ignoring one of several key parameters could mean
that other factors are given undue weight and that an apparently desirable policy
option is in fact undesirable once all relevant parameters are understood.
In the case of the ORBES Phase I Report, this lack of completeness is
especially evident in Chapter Six of the assessment, "Public Health, Economic,
and Social Impacts."1 There are key omissions of data in each of these three
categories; once these defects are remedied, it is possible to draw conclusions
quite different from those of ORBES Phase I regarding the health, economic, and
social impacts of the various energy scenarios.
With respect to health impact, at least four basic types of data, essential
to evaluation of nuclear technology, were not included: (1) complete information
on the probability of a core melt, as taken from the Rasmussen Report, WASH 1400;
(2) health effects of a core melt as taken from the update of WASH 740, the Brook-
haven Report; (3) The American Physical Society Study on Light-Water Reactors;
and (4) results of tests on the emergency core cooling system (ECCS) for nuclear
reactors. Treatment of (1) is essential since the current ORBES Phase I report
1J. J. Stukel and B. R. Keenan, ORBES Phase I; Interim Findings, Washington, D. C.;
Office of Research and Development, U. S. Environmental Protection Agency,
November, 1977, pp. 97-121.
51
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is misleading regarding accident probabilities. It states that "the Rasmussen
Report predicts that a core melting accident has a probability of about 1 in
20,000 per reactor year."2 While correct, this statistic gives only a year-by-
year probability of a core melt for one reactor. Using the same Rasmussen data,3
it is more meaningful to compute the probability that a core melt will occur in
one of the 60 plants now operating during their 30-year lifetime. Using the
formula for the probability of mathematically independent events, P (a core melt
in at least one of 60 reactors over a 30-year lifetime) = 1-P (no core melt in any
of the 60 reactors over a 30-year lifetime), one obtains P (core melt) =
l-(l-(l/20,000))1800 = 1-.9139 = .086. Thus even if reactors now under construc-
tion and now planned are not built, there is still an 8.6% probability of a core
melt in the 30-year lifetime of one of the reactors now operating. Given this
8.6% probability, the chance of a core melt is approximately 1 in 12. Using the
same mathematical formula and the same Rasmussen probability (1/20,000) per
reactor-year, one obtains the following results. The probability of a core melt
in the 30-year lifetime of 100 plants (assuming 60 now operating and 40 under
construction) is .1393 or 14%. This means that for 100 reactors, the chance of a
core melt is approximately 1 in 7. Similarly, the probability of a core melt in
the 30-year lifetime of 350 plants (assuming 60 now operating, 40 under construc-
tion and 250 being planned) is .4085 or 41%. Thus for 350 reactors there is almost
a 50/50 chance of a core melt some time in the 30-year lifetime of the plants.
Given this more accurate mathematical data regarding core melt probability, it is
misleading for the ORBES Phase I report to provide only single-year, single-reactor
probabilities, and then to conclude that nuclear accidents "have a comparatively
low probability of occurrence."**
A second respect in which the ORBES Phase I report provides incomplete
information regarding the health impact of a nuclear accident is in its omission
of data from the Brookhaven Report, WASH 740. Updated in 1965, the Brookhaven
Report contradicts statements made in the ORBES Phase I findings that a core melt
accident could "cause 110 early fatalities, 300 early illnesses, and property
damage of $3 billion," and "would necessitate decontamination of about 3200 square
miles and relocation of the population over an area of about 250 square miles."5
According to the Brookhaven Report, there would be 45,000 early fatalities, not
110; 100,000 early illnesses, not 300; from $17 billion to $280 billion in property
damages, not $3 billion; and contamination of an area the size of Pennsylvania, not
merely contamination of 250 square miles.°
2Stukel and Keenan, op. cit., p. 104.
3See U. S. Nuclear Regulatory Commission, Reactor Safety Study - An Assessment of
Accident Risks in U_. S^. Commercial Nuclear Power Plants, Report No. WASH-1400
(NUREG-75/014), Government Printing Office, Washington, D. C. (1975).
^Stukel and Keenan, op. cit., p. 97.
5Stukel and Keenan, op. cit., p. 104.
6Brookhaven statistics are given in James Elder, "Nuclear Torts: The Price-Anderson
Act and the Potential for Uncompensated Injury," New England Law Review, 11
(Fall, 1975): 111-135, esp. 127. See also Summary Report of the U. S. Atomic
Energy Commission, "Reactor Safety Study," Atomic Energy Law Journal, 16 (Fall,
1974): 201-202.
52
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ORBES omission of the WASH 740 data is even more significant when one realizes
that the ORBES findings also omitted the American Physical Society report on Light-
Water Reactor Safety. The APS results are consistent with those of the Brookhaven
Report. Moreover the APS study was done at the same time as the Rasmussen Report;
it was performed by a group of the most prestigious nuclear scientists in the world,
while the Rasmussen Report was done by nuclear proponents under AEC contract. The
APS explained why WASH 1400 was able to reduce predicted catastrophic effects of a
nuclear accident, viz., it ignored relevant data treated in WASH 740. Because of
the mathematical errors inherent in the obsolete "fault-tree analysis" of the Ras-
mussen Report, and because of a number of implausible assumptions (e.g., complete
evacuation; downward fuel melt; no incidence of sabotage; no irradiation of special
tissues; downwind radiation lasting only one day; no resource contamination through
land and water, etc.), the APS rejected the Rasmussen Report.7 The independent,
American Physical Society estimates of deaths, cancers and genetic damages arising
from a nuclear accident are as much as 100 times greater than those given in the
Rasmussen Report and cited in the ORBES Phase I findings. It is not clear why the
ORBES Phase I results failed to treat the only reactor safety study done by a non-
advocacy group (the APS) and why it Included the Rasmussen, but not the Brookhaven
findings.
A fourth respect in which the ORBES assessment (of energy-related health im-
pacts) is incomplete is in its failure to cite results of tests of the emergency
core cooling system (ECCS) of nuclear reactors. Disastrous consequences, such as
those cited above, are avoidable only in the event that the ECCS functions properly.
Hence the ECCS is, in one sense, the most essential parameter relevant both to
assessing the numerous studies on light-water reactor safety and to evaluating
the health impact of nuclear plants. In making the assumption that a nuclear
accident has an extremely low probability of occurrence,8 the ORBES Phase I report
erred in not mentioning a second assumption essential to the first, viz., that the
ECCS functions as intended. The ECCS, however, was not mentioned at all; this
omission appears significant for at least three reasons. First, no full-scale
empirical tests of the ECCS have ever taken place.9 Secondly, all Of the small,
scale-model tests (six of six) of the ECCS have failed.10 Third, the full-scale
model tests would be "possibly very destructive" and nuclear proponents are un-
willing to take this risk.11
7Lewis, H.W., ^t ai. "Report to the American Physical Society by the Study Group
on Light-Water Reactor Safety," Reviews of Modern Physics, 47(Summer 1975), Sl-
S124. Study Group on Light-Water Reactor Safety,"Nuclear Reactor Safety - the
APS Submits Its Report," Physics Today, 128(July 1975): 38-43.
8Stukel and Keenan, op. cit., p. 97.
9Sheldon Novick, The Electric War, San Francisco, Sierra, 1976. J. Primack and
F. Von Hippel, "Nuclear Reactor Safety," The Bulletin of_ the Atomic Scientists,
30(0ctober 1974): 7-9. See also M. Bauser, "United States Nuclear Export Policy:
Developing the Peaceful Atom as a Commodity in International Trade," Harvard In-
ternational Law Journal, 18(Spring, 1977): 51.
'Oprimack and Von Hippel, up. £jl_t., pp. 7,9. J.J. Berger, Nuclear Ppwoj; Palo Alto,
Ramparts Press, 1977.
^Nuclear proponents F.H. Schmidt and D. Bodansky (The Energy Controversy; The
Fight Over Nuclear Power, San Francisco, Albion, 1976, pp. 139-42) explain clearly
that high risk is the reason for failure to conduct proper ECCS tests. Novick,
op. cit., p. 192 also quotes industry and government leaders who subscribe to the
same explanation.
53
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In addition to the omissions regarding health impacts, the ORBES Phase I
findings are incomplete in their assessment of the social consequences of energy
development options. At least two important impacts in this area have been neglec-
ted, viz., civil liberties problems arising from the uranium/plutonium fuel cycle,
and possible due process violations resulting from the federal preemption doctrine
as applied to Nuclear Regulatory Commission jurisdiction.
Although the ORBES Phase I assessment of social impacts mentions the possi-
bility of terrorism and sabotage of nuclear installations,12 there is no treatment
of civil liberties violations which might ensue as a result of safeguarding reactors
and fuel against such threats. Although this problem is not quantifiable, it is a
very real legal-political-social "cost" of nuclear generation, and hence must be
included in any cost-benefit analysis of social parameters affected by development
of nuclear energy. Several authors have already pointed out that in Texas and Cali-
fornia, local police forces have kept an eye on people at the request of power com-
pany officials, and that, although the authority was refused, the Virginia Electric
Power Company recently asked the state legislature for police power which would
allow it to arrest people and search their homes.13 Carl Walske, President of the
Atomic Industrial Forum (and hence the top spokesperson for nuclear industry),
thinks we need a new federal police agency solely to deal with problems related to
Plutonium and enriched uranium. The Nuclear Regulatory Commission also contends
that balancing the need for public protection against the necessity for intrusion
of government into personal liberties is "one of the most difficult and delicate
questions confronting the Commission."11*
A second major difficulty with the "social impact" section of the ORBES Phase I
study is its omission of the legal, political, and social consequences relevant to
increased controversy over the federal preemption doctrine. Largely as a result of
several landmark cases, such as Marshall v_. Consumers Power Company, First Iowa Hydro
Electric Cooperative v. Federal Power Commission, In re Consolidated Edison"Company
of New York, Inc., and Northern States Power Company v." Minnesota, the federal govern-
ment has attempted to preempt state regulation of the nuclear power industry.15 The
states, as in the Northern States case, for example, have attempted to control nuclear
plant radiation emissions more stringently than the NRC, and have argued that they
have the right to protect the public health and safety, especially since the NRC is
not doing an adequate job of nuclear power regulation.16 Despite the fact that the
12Stukel and Keenan, op. cit., p. 105.
13Novick, ££. cit., p. 308. See also R.W. Ayres, "Policing Plutonium: The Civil Li-
berties Fallout," Harvard Civil Rights-Civil Liberties Law Review,lO(SprinE 1975),
369-443.
ll+Walske and the NRC position are cited in V. Gilinsky, "The Need For Nuclear Safe-
guards," Atomic Energy Law Journal, 27(Summer 1975), 149-50.
15See J.K. Brydon, "Slaying the Nuclear Giants: Is California's New Nuclear Power
Plant Siting Legislation Shielded Against the Attack of Federal Preemption?"
Pacific Law Journal, 8(July 1977): 741-82; Comptroller General of U.S. to Joint
Committee on Atomic Energy, "Regulating Users of Radioactive Materials," Atomic
Energy Law Journal, 15(Summer 1973): 63-132.
Brydon, ojp. cit., p. 762. K.M. Rhoades, "Environmental Law," Washburn Law Journal,
16(Winter 1977): 521-22. P.A. Parenteau, "Regulation of Nuclear Power plants: A
Constitutional Dilemma For the States," Environmental Law, 6(Spring 1976): 675-728.
See also Berger, op. ci^., pp. 336-38.
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NRC claims jurisdiction over nuclear plants, more than 50 new state laws were passed
in 1976 to regulate this industry. This was a 1/3 increase over the 1975 state laws
passed for this purpose. Moreover in 1976 alone, six states included on their ballots
proposals to provide more stringent safety requirements over use of nuclear power than
that required by the NRC.17 Hence the net effect of continued or increasing reliance
on nuclear energy is likely to be an escalation of the social-political-legal contro-
versies plaguing our cities, states, legislatures, and courtrooms as a result of the
preemption doctrine. Moreover apart from how this issue is resolved legally, there
remains the ethical and public policy issue of how individual citizens can be assured
a voice in siting and licensing decisions. There is no question that the individual
citizen feels he has been disenfranchised,18 and that his discontent is likely to
escalate with the building of more power plants. The sheer bulk of legal cases,19
in addition to the continuing nuclear regulatory controversy, is sufficient reason to
include the social consequences of the preemption conflict within the ORBES "social
impact" assessment.
In addition to its omissions regarding health and social impacts, one of the most
serious deficiencies of the ORBES Phase I report is its incomplete analysis of the eco-
nomic impact of various energy scenarios. The Price-Anderson Act is central to any
discussion of the economics of nuclear power, and yet no mention of this legislation
was made in the ORBES Phase I; Interim Findings report. Since the Price-Anderson Act
limits the liability of the nuclear industry to $560 million in damages for any one
accident,20 although government estimates of losses for a single nuclear incident go
as high as $280 billion (according to the Brookhaven Report, WASH 740), this means
that as much as 99.8% of the damages resulting from a nuclear accident might not be
covered. In other words, up to $279,440,000,000 in losses from a nuclear accident is
in principle uninsurable. Apart from the question of whether the_, Price-Anderson Act
is ethical or legal (a Supreme Court decision on its constitutionality is now pending),21
17Brydon, op_. cit., pp. 741-42. Berger, op., cit., pp. 336-38. A.W. Murphy and
D.B. La Pierre, "Nuclear Moratorium Legislation in the States and the Supremacy
Clause: A Case of Express Preemption," Columbia Law Review, 76(April, 1976):
392-456. See also Novick, pp. 222-239.
18E.D. Muchnicki, "The Proper Role of the Public in Nuclear Power Plant Licensing
Decisions." Atomic Energy Law Journal, 15(Spring, 1973): 38-47. G.C. Coggins,
"The Environmentalist's View of AEC's 'Judicial' Function," Atomic Energy Law
Journal. 15(Fall, 1973): 176-93. Brydon, op_. cit.. p. 767. Novick, op_. cit.,
pp. 222-23. G.B. Karpinski, "Federal Preemption of State Laws Controlling
Nuclear Power," Georgetown Law Journal, 64(July, 1976): 1335-36. R.B. Stewart,
"Paradoxes of Liberty...." Environmental Law, 7(Spring, 1977): 469.
19See, for example, Brydon, op_. cit., pp. 741-82, who reviews many of these cases;
Elder, op. cit., pp. 113-16; Karpinski, op_. cit.. pp. 1323-41; Murphy and
La Pierre, op. cit., pp. 392-456; Mark S. Young, "A Survey of the Governmental
Regulation of Nuclear Power Generation," Marquette Law Review, 59(1976): 836-55.
2°'AEC Staff Study of the Price-Anderson Act, Part I," Atomic Energy Law Journal,
16(Fall, 1974) 220. Robert Lowenstein, "The Price-Anderson Act," Forum,
12(Winter, 1977): 594-604. Joseph Marrone, "The Price-Anderson Act." Forum,
12(Winter, 1977): 605-11. W.S. Caldwell, et^ al., "The...Price-Anderson Act,"
Rutgers-Camden Law Journal, 6(Fall, 1974): 360-386.
21See Berger, op. cit., pp. 145-46. See also Coggins, op. cit., pp. 176-93;
R. Wilson, "Nuclear Liability and The Price-Anderson Act," Forum. 12(Winter, 1977):
612-21; and Robert Drinan, "Nuclear Power and the Role of Congress," Environmental
Affairs. 4(Fall, 1975): 595-627.
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there is no doubt that it has great economic consequences. A nuclear accident would
have a massive impact on the economy of the region and state in which the problematic
plant was located. In fact the Price-Anderson legislation is one of the prime reasons
why so many state legislatures have sought to enact nuclear moratorium legislation.22
Individual citizens and entire states fear the losses they would have to sustain in
the event of such a disaster. Given the magnitude of the risk borne by certain states
and by individuals within a given radius of a nuclear power plant, it is unclear why
the economic impact of the Price-Anderson Act was not included in the ORBES Phase I
assessment.
3.0 ORBES Methodology and Ethical/Evaluative Presuppositions
In addition to the omission of data relevant to the health, social, and economic
impacts of various energy scenarios, the ORBES Phase I results are problematic in a
second respect. While failing to address the ethical aspects of a number of energy
policy decisions, such as that regarding the Price-Anderson Act and whether "it vio-
lates Fifth and Fourteenth Amendment guarantees of protection of property, the ORBES
Phase I study nevertheless employs a number of implicit, highly questionable ethical
assumptions. Although ORBES procedures limit the length of my remarks, I will at-
tempt to address as many as possible of these questionable presuppositions.
One of the most obvious assumptions throughout the report is that any factors
not susceptible to precise quantitative formulation are not important enough to be
included in the assessment. The 22-page summary of the ORBES Phase I findings, for
example, contains exactly six sentences in the section treating "Social and Institu-
tional Factors" relevant to the impact of various energy scenarios.23 It is unclear
why legal, political, sociological, psychological, and ethical impacts are limited
to such a brief evaluation while physical, chemical, and biological impacts receive
a relatively better treatment. Moreover the Task 4 Study of the energy impact on
"Quality of Life" is described as "Subjective Quality of Life" in the ORBES organ-
ization chart.2** This again suggests that social or qualitative parameters are of
little import to the ORBES research; the implicit assumption is that only quantita-
tive, physical-science variables are essential to the ORBES conclusions. This pre-
supposition is especially apparent in the Phase I discussion of the Rasmussen Report
findings regarding the probability of a nuclear accident.25 The study cites the WASH
1400 data and then states that the probability of a catastrophic accident is low.
Nowhere, however, is the qualitative or ethical question, of whether this risk ought
to be taken, evaluated. Likewise the ORBES report "justifies" emissions of low-level
radiation from nuclear power plants by noting that such emissions provide less radi-
ation than that received from flying in an airplane, watching a color TV, etc.26
Again, these ORBES remarks address only quantitative aspects of a problem and fail
to raise important ethical concerns. Some of these ethical questions are whether
one ought to add further to the low-level radiation burden; whether there is an
ethical difference between radiation hazards voluntarily chosen (e.g. by flying in a
plane) and those imposed involuntarily (e.g. because of a nearby power plant); and
22See Brydon, oj^. cit_., pp. 74-82; Klder, op_. c_it., pp. 111-35; Karpinski, op_. cJt.,
pp. 1323-41; Murphy and La Pierre, oj>. cjij^.i pp. 392-456; Parenteau, op. cit.,
pp. 675-728.
23See Stukel and Keenan, op. cit., p. 109.
24See Stukel and Keenan, op. cit., p. 129.
25See Stukel and Keenan, oj>. cit., p. 103-106.
26See Stukel and Keenan, op. cit., p. 103.
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whether economic criteria can ever be said to justify the increased cancer hazard
delivered by even a small amount of low-level radiation.
Failure to address these and other ethical issues, relevant to the ORBES Phase I
study, constitutes a classic instance of what philosophers have termed "the naturalis-
tic fallacy."27 This fallacy is committed whenever one supposes that mathematical or
scientific "facts" can produce ethical directives. Neither mathematical remarks about
the probability of a core melt, nor scientific facts about the pervasiveness of low-
level radiation, constitute sufficient reasons for ethical directives regarding nuclear
power. In order to arrive at such directives, the ORBES assessment needs to encompass
a broader evaluation of ethical, legal, political, and sociological impacts of energy
development. My earlier remarks relevant to the Price-Anderson Act and the doctrine
of federal preemption suggest several important legal and public policy questions which
need to be addressed. Another way to provide a framework bearing on ethical consider-
ations is to include an assessment of the psychological impact of various energy sce-
narios. There is already a vast amount of literature available on the relationship
between environmental properties and psychological well being.28 Holmes, Gunderson,
Dubos, Rivers, Montague, and others have studied the effects of technological change
upon the incidence of depression, impotence, mortality, and other factors related to
mental and physical health. It is precisely this sort of psychological impact, both
which is essential to a complete analysis of all energy scenario "costs'1 and "benefits",
and which is needed in the ORBES research.
A second ethical presupposition, implicit throughout the ORBES research, is that
acceptance of policy decisions regarding construction of more power plants is primarily
dependent upon possible economic benefit to the community.29 Apart from whether econo-
mic parameters are in fact the determining ones, any study based on the presupposition
that such factors are or ought to be the major ones, is itself implicitly employing a
utilitarian ethic. The difficulty with the ORBES presupposition of a utilitarian cal-
culus, viz., "the greatest amount of economic good to the greatest number of people,"
is that such a calculus (and therefore the ORBES research) is insensitive to consider-
ations of equal justice and equal protection under the law. In other words, it is
possible for minority rights to be violated within a utilitarian framework, so long as
such a violation contributes to the economic good of the majority. Both this economic
criterion for energy policy and the Price-Anderson limitation on liability raise a
grave question regarding the adequacy of utilitarian ethics. This question is whether
"all the public or a disproportionate segment thereof shall bear the risks for an ac-
tivity that purportedly benefits everyone."30
27See Albert Einstein, "The Laws of Science and the Laws of Ethics," in H. Feigl and
M. Brodbeck (eds.), Readings in the Philosophy of Science, New York, Appleton-Cen-
tury-Crofts, 1953. p. 779.
28See for example, H.H. Iltis, O.L. Loucks, and P. Andrews, "Criteria for an Optimum
Human Environment," in R.T. Roelofs, J.N. Crowley, and D.L. Hardesty (eds.), En-
vironment and Society, Englewood Cliffs, Prentice-Hall, 1974, pp. 88ff; and P.O.
Pahner,"A Psychological Perspective of the Nuclear Energy Controversy," Vienna,
International Institute for Applied Systems Analysis, RM-76-67, August, 1976.
29See Stukel and Keenan, op_. cit., p. 8, where this assumption is made explicitly.
JOJ.C. Bodie, "The Irradiated Plaintiff: Tort Recovery Outside Price-Anderson,"
Environmental Law, 6(Spring, 1976): 896.
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8
As a number of authors have pointed out, to the extent that energy-policy deci-
sion-making is utilitarian, its policies share the major weaknesses of this ethical
theory. Some of these deficiencies include a general insensitivity to considerations
of equity; a disregard for future generations; a tendency to equate desires with need;
and an assessment only of quantifiable goods and bads.31 The utilitarian presupposition
of ORBES that power plant acceptance is a function of economic benefit to the community,
has a potential for two consequences of questionable ethical character. First, it might
cause noneconomic benefits, e.g., aesthetic and health-related goods, to receive no
consideration at all. Secondly, it might cause overall maximization of economic bene-
fits even though economic inequities or hardships are visited upon a given minority
within a community. Because it sanctions the maximization of economic good, rather
than equity, this ORBES presupposition (and the utilitarian ethic underlying it) are
at odds with any ethical scheme based on a theory of equal rights.
Several other presuppositions in the ORBES study are questionable, not because of
their underlying ethical frameworks but because they purport to be scientific while
being purely evaluative. There are at least three such presuppositions, stated without
any substantiation, that need to be investigated further. These are the statements
(1) that there exist sufficient supplies of uranium for all nuclear plants to be built
up to the year 2000;32 (2) that the probability of release of radioactive wastes into
the atmosphere is low;3i and (3) that coal-fired plants have a worse impact on land
quality than do nuclear plants.3** In the interests of objectivity, each of these eval-
uative statements should be either substantiated or retracted. There are several rea-
sons suggesting that the latter is the more desirable option. (1) above is question-
able because a number of nuclear advocates, including Alvin Weinberg, maintain that
there is not enough uranium to last more than ten years from the present.35 In the
face of an acknowledged shortage of uranium which has been admitted by ERDA, the U.S.
Geological Survey, and the utilities, statement (1) above seems questionable. Also
doubtful is statement (2), regarding the low probability of accidental release of ra-
dioactive wastes. This thesis is not documented or substantiated in ORBES Phase I:
Interim Findings and there are several facts suggesting it is inaccurate. First, as
is admitted in the ORBES report, there are "no permanent storage sites for high-level
wastes" and "the long-term effects of high-level waste disposal are quite uncertain."36
3lSee Alasdair Maclntyre,"Utilitarianism and Cost-Benefit Analysis: An Essay on the Rel-
evance of Moral Philosophy to Bureaucratic Theory," in K.M. Sayre (ed.), Values in
the Electric Power Industry, Notre Dame, Univ. of Notre Dame Press, 1977, pp. 217-37;
Sayre and Goodpaster,"An Ethical Analysis of Power Company Decision-Making," in Sayre
op. cit., pp. 238-88.
3zStukel and Keenan, o£. cit., pp. 31, 142.
33Stukel and Keenan, op. cit., p. 93.
3l*Stukel aid Keenan, op. cit., p. 94.
35Alvin Weinberg,"The Short Term Nuclear Option," Report of the Cornell Workshops on
the Major Issues of a National Energy Research and Development Program, 1973, Ch. Ill,
p. 183. Acting Federal Energy Administration (FEA) Deputy John Hill, testifying be-
fore Joint Committee on Atomic Energy, Bureau of National Affairs, May 8, 1975.
Mason Willrich, Global Politics of Nuclear Energy. New York, Praeger, 1971, pp. 70,
73, 78. Schmidt and Bodansky, op. cit., p. 34. See also C.C. Howard,"Uranium Sales
Contracts," Rocky Mountain Mineral Law Institute. 22(1976):389-403; and P.L. Joskow,
"Commercial Impossibility, The Uranium Market, and the Westinghouse Case," Journal
of Legal Studies, 6(January 1977):119-76. See also F. Von Hippel and R.H. Williams,
"Energy Waste and Nuclear Power Growth," Bulletin of the Atomic Scientists, (December
1976), p. 54.
36Stukel and Keenan, op. cit., p. 104.
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Given these two unknowns, it is unclear on what basis (2) above can be asserted.
Moreover hundreds of thousands of gallons of high-level radioactive waste,
temporarily stored in several areas of the country, have already leaked and
contaminated the areas surrounding the storage sites.37
ORBES statement (3) above, that coal-fired plants have a worse impact on land
quality than do nuclear plants,38 is also problematic. As mentioned previously,
this remark was not substantiated, nor is it clear what criteria might be employed
to assess its correctness or incorrectness. At a minimum, the basis of this claim
must be made explicit. Such an evaluation would have to include, for example, a
comparison of long-term effects of both types of plant on land quality and costs
of decommissioning the nuclear plant and decontaminating land area around it. In
the absence of such quantitative and comparative studies, statement (3) merely begs
the question.
A.O Conclusion
While space limitations of ORBES procedures have precluded an in-depth analysis
of the topics outlined above, these remarks may be helpful in two respects. First,
they may enable the ORBES team to correct misleading aspects of the current Phase I
report. More importantly, they suggest a number of areas which ORBES research so
far has not touched and which ought to be accomplished in the future. Some of these
areas include legal, ethical, political and psychological impacts of various
scenarios.
37Novick, op. cit., pp. 178-79, and E. Nathanson, "International Management of
Radioactive Wastes," Environmental Affairs, 5(Spring, 1976): 365.
38Stukel and Keenan, op. cit., p. 94.
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