vere ete ee 324 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 guage