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June 19, 1997

Jon Palfreman
c/o Frontline
125 Western Avenue
Boston, MA 02134

Dear Mr. Palfreman:

We have received your letter of May 12 replying to the Nuclear Control Institute's rebuttal of your April 22 "Frontline" program, "Nuclear Reaction." Most of your responses miss the point or are exercises in equivocation.

Your suggestion that we did not watch "Nuclear Reaction" before issuing our response is amusing. The NCI rebuttal was based on a careful screening of the program. You even contend that many of the statements we attribute to you were never made in the program. Our rebuttal paraphrased several claims made in "Nuclear Reaction," drawing together themes from various parts of the program. Direct quotations are indicated by quotation marks. Here, we will cite page numbers from the broadcast transcript to refer to points made in "Nuclear Reaction."

Regarding public attitudes, the thesis of your program is that public attitudes toward nuclear power in the United States are irrational -- that is, based on emotion rather than "facts." The environmental devastation of the U.S. military nuclear program is highly relevant, because many of the same contractors -- including Westinghouse and General Electric -- developed both the U.S. military and civilian nuclear programs, as well as played a major role in nuclear power development overseas, especially in France, Germany and Japan. Their track record at weapons complex sites speaks for itself, and gives credence to many public fears about nuclear power.

You claim that "Nuclear Reaction" did not mention Japanese public attitudes toward nuclear power. Where, then, are the "parts of Asia" where "nuclear power is accepted, even popular?" (Richard Rhodes, transcript, p. 14) More important, the claim in your May 12 letter that "Japan has mismanaged their nuclear program (from a public relations point of view)" is a remarkable oversimplification. The serious accidents at the Monju fast breeder reactor and Tokai reprocessing plants represent much more than "public relations" problems---as do the deliberate acts by Japan's Power Reactor and Nuclear Fuel Development Corporation (PNC) to cover up and destroy evidence of these and other serious safety problems at Japanese nuclear facilities.

The statement in your May 12 letter that a containment breach in case of a meltdown is possible but highly unlikely is a significant modification of claims made in on-camera interviews in "Nuclear Reaction." Host Richard Rhodes stated that "[e]ven if an accident occurred, the argument goes, the radioactive material would be confined inside the plant." (transcript, p. 10) Al Reynolds then claimed that "...even if...some of the fuel melted, that fuel cannot get out of the containment into the environment." (ibid) Neil Todreas then claimed that in the worst accident he could imagine, no more than five fatalities would result, and those would all be plant personnel. No one in "the general public" would die. (ibid) These statements in Frontline's "Nuclear Reaction" suggested that the viability of containment buildings in serious, even worst-case, accidents is absolute and unqualified---and such statements are therefore highly misleading.

As to the health consequences of Chernobyl, the fatalities that occurred from acute radiation sickness following the 1986 accident represent only a tiny fraction of the total number of fatalities that are anticipated to occur. According to the proceedings of the 1996 joint EC/IAEA/WHO conference on the consequences of Chernobyl, it is estimated that radiation exposure from Chernobyl will cause an additional 2200 cancer deaths among the 200,000 "liquidators" (cleanup and recovery workers) and an additional 6700 fatal cancers among evacuees and residents of highly contaminated areas. Based on projections of the United Nations Scientific Committee on the Effects of Ionizing Radiation (UNSCEAR), the total number of excess cancers worldwide that may be expected is in the range of 30,000 - 60,000. These estimates, of course, are based on a linear dose-response for ionizing radiation, which you apparently do not accept. However, as you are no doubt aware, your skepticism is not shared by any of the national and international scientific committees that set radiation protection standards, such as the International Commission on Radiological Protection (ICRP), but only by nuclear industry-funded groups. Moreover, the data you present in your letter is obsolete. The ongoing epidemiological study of atomic bomb survivors has now directly observed a statistically significant excess cancer mortality for doses as low as 5 rem, and it is expected that as more deaths occur in the future, statistically significant increases will be observable at lower doses.

Further, your contention that natural gas poses a much greater radiological hazard than nuclear power is not supported by the results of UNSCEAR, which estimated that the radiological dose commitment from natural gas is 100 times lower than from the nuclear fuel cycle per kilowatt-hour of electricity generated.

We certainly agree with you that natural sources of radiation exposure can pose significant health risks and should be thoroughly identified and mitigated. However, this in no way implies that man-made sources are of no consequence. The aggregate health and environmental impacts of nuclear power generation, including not only exposures from routine operation but those that may result from accidents, as well as the long-term waste disposal risks, are real and quantifiable. Ultimately, it should be the decision of the affected public whether these risks are justified by the purported benefits of nuclear power. Attempts by industry to belittle the significance of low-level exposure by espousing scientifically unsupportable notions of "thresholds" or "hormesis" effects work against the objective of providing the public with accurate information that will enable them to make these decisions wisely.

Regarding nuclear waste, you claim that "[a]t no stage did we say that reprocessing would eliminate a need for a repository or stocking center." Not in so many words, no, but consider this strong suggestion to that effect during the program's contrast of French and U.S. approaches to nuclear waste.

[French] research showed that what bothered people most was the idea of a permanent geological site, like Yucca mountain, where waste would be abandoned. People felt much safer with the concept of an underground laboratory, where waste is not only carefully monitored, but where research goes forward on how to transmute it to a safer form. [Richard Rhodes, transcript, p. 21; emphasis in original]

Hank Jenkins-Smith then contrasted this French approach with "a place that's primarily a disposal facility where we permanently cork it up." (transcript, p. 22) Richard Rhodes then claimed that "U.S. policy makers don't want a laboratory. They want a graveyard. They're determined that Yucca mountain will open sometime after 2010." (ibid) This section clearly implies that the need for a geological repository would be obviated by some type of advanced laboratory where "this dreadful stuff might actually be turned into something useful." (Hank Jenkins-Smith, transcript, p. 22) In point of fact, reprocessing does not eliminate the need for a final burial ground for nuclear waste and spent fuel. You neglected to inform your viewers that eventually nuclear fuel made with recycled plutonium will have to be buried because after as few as one or two recyclings it is too heavily contaminated with even-numbered plutonium isotopes to be used in light-water reactors (LWRs) as fuel.

The claim in your May 22 letter that "reprocessing...greatly reduces the amount of plutonium" is false on its face. In fact, reprocessing is the chemical separation of plutonium from uranium and fission products in spent nuclear fuel. Rather than reducing the amount of plutonium, reprocessing merely puts plutonium into a separated (and thus weapon-usable) form.

Perhaps you meant to say that the use of plutonium in mixed-oxide (MOX) fuel would "get rid of" plutonium. This claim is also false, ignoring the fact that 1) only a small portion of the plutonium in MOX fuel is fissioned, and 2) as a result of neutron capture, new plutonium is created during the irradiation of MOX fuel. In the case of an LWR loaded with one-third core of MOX fuel, the irradiated MOX fuel contains virtually the same amount of plutonium that it did when loaded into the reactor. In fact, a recent Russian analysis concluded that an LWR loaded with a 30 percent MOX core would discharge spent fuel containing 25 percent more plutonium than was contained in the fresh fuel. Nor can this plutonium be recycled again and again in LWRs, to the point of total elimination. As indicated above, according to an OECD study of plutonium physics, plutonium is unusable in LWR fuel after a few reactor cycles. It can therefore never be totally eliminated by use of MOX fuel in LWRs.

Therefore, it is inaccurate to say that "NCI prefers to bury plutonium, which in principle can be dug up and used, rather than consume it in reactors." It is not an issue of preference; plutonium must be buried eventually, even if it is first "recycled" one or more times in the form of MOX fuel. The large amount of plutonium remaining in spent MOX fuel can be "dug up and used" to make nuclear weapons just as readily as spent low enriched uranium fuel. The point is largely academic, because the "plutonium mine" scenario is specious: the major industrial operation required to recover plutonium from a spent-fuel repository for use in nuclear weapons would likely cost as much or more than simply producing new plutonium in a reactor.

The reference in your May 12 letter to the Integral Fast Reactor (IFR) suggests that this breeder could solve the plutonium and actinide problems. In fact, Congress killed the IFR program in 1994 because the reactor design lacked realistic promise as a solution to either the nuclear waste or warhead-plutonium disposition problems (according to studies by the National Academy of Sciences and Office of Technology Assessment), and, as a "fast reactor" originally designed to breed more plutonium than it consumed, was inconsistent with U.S. non-proliferation policy.

The points in your May 12 letter regarding the economics of nuclear power are baffling. We did not claim in our rebuttal that cost was "a moral issue." We simply point out the reality of the future electricity market in the United States: for the foreseeable future, nuclear power is not a competitive alternative. Unless the federal government is willing to provide billions of dollars in Federal subsidies (maybe in the form of a large program to use warhead-plutonium MOX fuel in commercial reactors), this will remain true for the foreseeable future. But in our view, a Federal subsidy program to get nuclear power plants to use uneconomical and dangerous plutonium fuel can only hurt the industry's chances of survival.

You are correct that NCI does not oppose nuclear power using a once-through, low enriched uranium fuel cycle. However, the numerous inaccuracies in "Nuclear Reaction" served only to muddy the waters of the important debate about the future of nuclear power. As a public-interest "watchdog" group, our mission is to provide accurate information on nuclear issues to the public. We were therefore repelled by "Nuclear Reaction" and compelled to respond.


Paul Leventhal

Steven Dolley
Research Director

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