ASSESSMENT OF TOTAL RISK

Owing to the many quite different types of risks incurred in the operation of an energy system, we considered it undesirable to force them into the terms of some arbitrary measure to obtain a sum. Instead (where possible), comparisons were made on the basis of individual, similar risks. Since the facts are frequently insufficient for clear-cut quantitative analysis, estimates of cost and benefit may become highly speculative. This is especially true if sociological data are in question, but as explained later in this chapter, it is also a frustrating problem even in dealing with the chemical and toxicological aspects of atmospheric pollution. The evaluation of total damage, based on all contributing factors, must therefore be a matter of judgment.

Additional judgment must be brought to bear on decisions about “acceptable levels of risk.” In this case, the assessment of cost may have to be considered and should include the consequences of being wrong. Society may (or may not) prefer a larger risk that can be estimated with confidence to one estimated to be smaller, but with great uncertainty.

REGULATION

The federal government attempts to protect public health and the quality of the environment through the Environmental Protection Agency (EPA), the Nuclear Regulatory Commission (NRC), the Occupational Safety and Health Administration (OSHA), and other agencies, based on such acts of Congress and subsequent amendments as the Clean Air Act of 1970 and the Clean Water Act of 1972 (as amended), the Nuclear Regulatory Commission Act of 1975, the Federal Mines Safety and Health Act of 1977, the Surface Mining Control and Regulation Act of 1977, the Energy Supply and Environmental Coordination Act of 1974, and the Resource Conservation and Energy Act of 1976. Some 20 congressional committees deal with this field and compete with one another in producing legislation.3 At a conservative estimate, close to 90 units of the federal government, most of which function independently of one another, set or enforce standards.4

While there is no doubt about the need for regulation, its explosive growth and resulting complexity is bewildering and, on occasion, too costly or perhaps even self-defeating. An example of the complexity may be drawn from the electric utilities industry, where the regulation of risk, though not the only consideration of national policy, is a major factor in determining the 8- to 10-yr lead times for construction of fossil-fueled plants, and the 10- to 12-yr lead times for nuclear power plants.5 It has



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