Environmental reports for the nuclear regulatory commission: Guidelines thwart sound ecological design

The US Nuclear Regulatory Commission requires a detailed description of the ecology associated with every proposed nuclear power station. The usefulness of much of this information is examined. The structure of logic and assumption underlying the requirement that certain information must be presented in applicants' environmental reports is examined. It concludes that the regulation itself makes it impossible to satisfy all of its requirements. It is difficult for investigators to identify species that are to be given special treatment. Though these important species can sometimes be recognized only after completing a study, they must be known beforehand if the requirements of the regulation are to be met. The most difficult are species having critical functions in their ecological systems. Critical has no 1:n correspondence with anything. Therefore, the requirement postulates a prolepsis. It mandates feedback without providing for a loop. It calls for using information before it has been gathered. Another requirement is demonstrating a specific causal link between an organism and a nuclear power plant. This is shown to be logically meaningless, and consequently redundant in practice. Demonstrating the illogic of certain central ecological requirements leads to practical suggestions for improving the regulations. The first is to diminish the demand for useless information. The second is to rely more fully upon professional judgment.