It's reasonable (though misguided) to look at occurrences that appear to call a supposed 1-in-20,000-year claim into question and challenge the claim of "X level of safety". It does not then become "completely valid" to make up entirely different figures out of whole cloth. You can claim (incorrectly in this case) that history proves a claim to be inaccurate... you cannot use that claimed error to justify calling this nonsense "valid".
It isn't valid to throw up your hands at a lack of data for 3rd generation designs and just make one up (pretending to be charitable). It isn't valid to count meltdowns and any reactor you can find (including the bulk that cannot in any way be labeled as "nuclear catastrophes"
, but then only count reactor-years for the ~400 commercial power reactors as a comparison. It isn't valid to ignore decades of improvements in design and regulatory oversight and pretend that the earliest experimental reactors' failures tell us something about failure rates for current designs.
He doesn't even try to explain (nor does Shrader-Frechette) how it is that reactor accident rates fell so dramatically as the number of reactors in service climbed so rapidly? Almost all of the incidents that they're counting occurred in the 50s-60s... yet what percentage of the reactor-years have occurred since then?
A few points re: the "black swan" piece:
* - Nine of the reactors on that list were Russian nautical units - nothing like commercial power reactors. Even if it were reasonable to simply divide reactor-years by incidents (it isn't)... naval reactors aren't included in the reactor-year denominator.
This alone shows how ridiculous her claims are (because they rely on the same faulty "a reactor is a reactor is a reactor" risk assessment). Nine (really more like 10-12) Russian naval reactor meltdowns... yet zero meltdowns in USN naval reactors (a couple hundred of them over many thousands of reactor-years of use). I don't think the British, French, Indian or Chinese navies have had a meltdown in their nuclear subs either.
Obviously, design, experience, operator expertise, etc. do play a role in accident frequency.
* - At least six other units on the list were early experimental or weapon-producing reactors.
* - I'll be charitable and assume that Shrader-Frechette has really poor grammar skills and is not being intentionally dishonest. Her claim that all of these events resulted "in radiation releases, death, and injury" is simply incorrect.
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