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RADIATION STANDARDS, INCLUDING FALLOUT

Mr. Ramey. You would have other accidents that involved radiation spills, radiation burns, all these other things?
Mr. Parxsr. They are accidents. The only reason for presenting
the criticality experience was that this is the case which is supposed
to be conclusively reported so that one could use it to measure trend.
I intended to use this only to show the trend of accident experience.
AEC reports include these days considerable reference to so-called
radiation incidents which define and elaborate a broader class. We
found no way of picking these up from all sources. They come only
from the licensee sources.
Representative Price. On page 12 you refer to the retrospective
method of operation by the Public Health Service and on the other
hand the prospective target needs of industry. Will you elaborate on

your statement concerning needs for reconciling these differences?

Mr. Parker. Yes, sir. Please recall that this is a personal interpretation or conceivably a misinterpretation of what I think the Pubic Health Service is trying to achieve in this field. I think their
ure is that they would like to have things go along and then step

in from time to time and say, “We examine this case now and our

analysis is thus and so.” This may be good or it may be that you
should not have gonethis far. It is to that possibility that industry is
properly very sensitive. Let us assumethat industry is trying to make
a proper showing in radiation control, then you haveto do this at the
beginning of any time period and not leave oneself subject to being
told after the event that this was not very wise, that you should have
done it some other way.
It is this telling us in advance what we should be shooting for that
I am defining as the prospective target which we need and whichthe
public needs in order to examine our performance against. these

targets.

Representative Pricr. You also touched on certain inconsistencies,
although relatively minor, I think you said, that have appeared in the
transfer from the AEC to the States of certain regulatory responsibility. What are someof these ?
Mr. Parker. I mentioned one already. If I may refer to notes, I
would have a few more. This difference on the time base between
Kansas, Illinois, and New York. These States have three different
time bases for measuring their external exposure. The permissible
concentrations of materials put into unrestricted waters differs in
minor detail between the States of New York, New Jersey, and California. The amount of material exempt from registration differs
over quite a remarkable range between the States of Kansas, Minnesota, and New Jersey.
The definition of radiation area is different in the New York Code
from the recommendations of title 10 Code of Federal Regulations,
section 20. Surprisingly, the alleged definition of the roentgen has
three different appearances as between the codes of Florida, [linois,
and Kansas.
That covers the present differences, and perhaps with the exception

of this rather wide range in exemption from registration, these are

administrative nuisances at the present time.
Representative Price. The committee staff intends to make a study
of the problems involved in terminology. We have been interested
in this area for some time.

PURRCa

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