ENERGY MYTHS, unlike old soldiers, do not fade away. Instead, they take on new life each time a real energy problem arises. So it is with Fred J. Cook in his July 29 Outlook article claiming that "the numbers" of the recent oil crises "spell out fraud."

Cook's claim flies in the face of the evidence. Indeed, both the departments of Energy and Justice has investigated - and exonerated - the oil industry of the charge that it deliberately hoarded gasoline supplies to create a shortage. Press reports on those investigations were, in fact, available before Cook's article appeared.

Cook, however, is determined to play his own numbers game with a heavy hand.

Let's start with his numbers on oil exports, which he concludes "seem to indicate manipulation of the market." He bases his conclusion on what he calls the "curious fact" that U.S. oil companies exported more oil in the early part of this year than they did during the corresponding periods in 1977 or 1978.

The facts - which are neither curious nor hard to obtain - are:

1. Shipments of Alaskan North Slope crude oil to U.S. refineries in the Caribbean are included in export data, even though products manufactured at those Caribbean refiners are then - barrel for barrel - shipped back to the continental United States. In early 1977, the trans-Alaska pipeline was still under construction, so North Slope crude oil was not going to Caribbean refineries or anywhere else. And in early 1978, less than two-thirds as much North Slope crude oil (700,000 barrels a day then vs. 1.2 million barrels a day now) was flowing through the pipeline.

2. U.S. crude oil sent to Canada in exchange for an equal volume of Canadian crude is also counted as exports. This barrel-for-barrel exchange is the result of a trade agreement with Canada. It allows crude-short U.S. refiners, primarily those near Canadian crude oil producing areas, to import Canadian crude in exchange for an equal amount of crude oil from the United States to Canadian refiners in other areas. The current shortfall of overseas crude oil has increased the volume of such exchanges.

In neither instance is there a net export of oil from the United States. In fact, except for these barrel-for-barrel exchanges, exports of crude oil are prohibited by law. And there has been no real increase in the amount of petroleum products leaving the U.S. (204,000 barrels a day on average in 1978 vs. 206,000 barrels a day in January-February 1979).

These explanations, included in the data on exports readily available from both the Department of Energy and the American Petroleum Institute, could hardly be overlooked by anyone interested in providing an accurate review of oil exports.

The Iranian factor

Cook played equally fast and loose with other numbers.

In an apparent effort to support his "fraud" thesis, he cites figures indicating that oil imports for the first five months of 1979 were 10 percent higher than the comparable period in 1978. (Actually, API statistics show that total gross imports for the first six months of 1979 were just 4.6 percent higher than for the first half of 1978.) These numbers, he claims, prove that the Iranian shortfall was a fabrication.

There was noting fabricated about the revolution in Iran and the subsequent shut-off of Iranian crude oil production and exports. It happened.

In using these import numbers, Cook neglects to point out that U.S. oil companies imported record volumes of oil in the latter part of 1977 to be ready for two possible events: an anticipated large increase in OPEC oil prices at the beginning of 1978, and a U.S. coal strike. Fortunately, the OPEC price increase did not occur in early 1978, though the coal strike did.

Thus, as the U.S. oil companies entered 1978 they had built up above-normal inventories. There was less need, therefore, to import as much oil in the early months of 1978. Instead, the companies drew on their large stocks of both crude and refined products during the first half of 1978.

The Iranian revolution and cutoff of Iranian oil exports in late 1978 resulted in a loss of about 1.5 million to 2 million barrels a day in free world crude oil availability. The United States "share" of that crude shortfall was about 600,000 to 700,000 barrels a day.

As a result, the United States entered 1979 with inventories considerably below the levels of a year earlier. In fact, stocks in the early part of the year were unusually low - given the level of demand at the time. By the end of January 1979, for example, U.S. crude oil stocks were down to 303 million barrels - some 2 million barrels below the Department of Energy's estimated minimum acceptable level for that time of year. A year earlier, crude oil stocks were 340 million barrels.

In the early months of 1979, therefore, there was much more need to import higher volumes of crude oil than there had been in early 1978. It is neither surprising nor strange that imports were higher in first-half 1979 than in first-half 1978. The point is that they were some 600,000 to 700,000 barrels a day less than required in 1979.

What "steep decline"?

Cook continues his "fraud" thesis in citing numbers that show the drop in refinery utilization during the early months of 1979. Interestingly, elsewhere in the article he points out that the lower volume of crude oil stocks at the beginning of 1979 represents what he calls a "potentially short situation." It is precisely because crude oil stocks, in the early months of 1979, were below normal levels - the result of the Iranian crude oil production cutback and cutoff of exports - and because refiners were unable to import sufficient amounts from other countries that refiners could not operate at normal levels.

Crude oil stocks remained below the DOE estimated minimum acceptable level until March 1979. Even then, crude stocks were just 7 million barrels above the minimum level - equivalent to only about half a day's consumption of gasoline. Had the oil companies gone ahead and produced that amount of gasoline, plus other products, they would have delivered just one-half of 1 percent more product than they actually did provide in the first three months of 1979. And they would have done so at the risk of jeopardizing their ability to keep the system filled to avoid gaps and disruptions in the continuous flow process from stocks to consumers.

Cook seeks to sustain his "manipulation" thesis in his comments that Department of Justice lawyers "have been trying to find out why it is, just at the time of supposed shortages, [U.S.] crude oil production went into its steepest decline in seven years." Perhaps the reason the Justice Department has not been able to substantiate that claim is that the "steep decline" just did not happen.

It's no mystery that there is a seasonal drop in crude oil production each year during winter months. In recent years, the normal winter decline has ranged between about 100,000 and 250,000 barrels a day. The severity of weather conditions contributes to this decline: Cold temperatures can cripple machinery and halt shipment of crude oil through gathering lines.

The myth of the "steep decline" apparently started with a news wire story which overlooked this established seasonal trend in crude production and which relied on the amount of crude production for the months of January and February 1979. As a result, the wire story claimed that U.S. production declined by about 550,000 barrels a day between October 1978 and February 1979.

Two weeks ago, DOE issued updated figures for February. These figures show that U.S. crude production in that month was more than 200,000 barrels a day higher than the preliminary estimates. While this admittedly still implies a somewhat greater production decline than normal (about 100,000 barrels a day out of total daily domestic production of nearly 8.6 million barrels), thr DOE figures are not final yet. Final DOE figures will not be released until next spring. In past years, DOE has revised its final figures upward - by 13,000 to 66,000 barrels a day. It's entirely possible, therefore, that the final DOE figures for February 1979 will be close to the normal winter crude production figures published earlier by API.

Government regulations

Cook either is unaware of or chooses to ignore government price and allocation controls on gasoline, as well as other regulations affecting gasoline production, in composing his thesis.

He contends that the "created" gasoline shortage began in late fall when Shell Oil Co. "imposed drastic cuts on the delivery of gasoline to its retailers." The facts are that the only product in short supply then was unleaded gasoline and that government-imposed price regulations required Shell to sell its unleaded gasoline at several cents below the price allowed to other marketers. As a result (and as Shell officials clearly stated at that time), demands on Shell to supply unleaded gasoline increased dramatically - far beyond the company's capacity to meet.

The effects of government regulations were also responsible for many of the supply problems that arose earlier this year when gasoline demand overall reached record levels. The government's allocation system required that refiners set aside 3 percent (later raised to 5 percent) of their gasoline deliveries for use by state governments. Refiners also had to give first priority to certain groups - the Pentagon, public transport, farmers, commercial fishermen and others - delivering to them all the gasoline they needed, even if it was more than they received a year earlier.

The remaining supplies were then allowed to be delivered to wholesalers, jobbers and service stations. Thus, when the oil companies announced they were allocating only 75 percent to 80 percent to service stations, they were actually delivering to all users 95 percent to 98 percent of the volume of gasoline delivered a year earlier.

Cook's thesis that the nation's energy problem is a "fraud" "manipulated" by the U.S. oil companies is, in short, not founded on fact. The fact is that the nation's energy problem is real and serious, Cook's numbers game to the contrary. CAPTION: Illustration, no caption, By Geoffrey Moss for The Washington Post