ML20050B791
| ML20050B791 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/02/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| NUDOCS 8204070418 | |
| Download: ML20050B791 (95) | |
Text
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L LOUISIANA POWER AND LIGHT COMPANY L
L (Waterford Steam Electric Station,
).
DOCKET NO. 50-382 Unit 3L L
l cAn. April-2, 1982 pAggs: 2032 thru 2121 AC: New Orleans, Louisiana 4
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y UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
ATOMIC SAFETY AND LICENSING BOARD
(
4 e
5 In the Matter of:
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h
)
A 6
LOUISIANA POWER AND LIGHT COMPANY
)
Docket No. 50-382 e
)
E 7
(Waterford Steam Electric Station,
)
{
Unit 3)
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8 d
d 9
Room 223, East Courtroom i
Court of Appeals Building h
10 600 Camp Street g
New Orleans, Louisiana j
11 D
- Friday, d
12 April 2, 1982 a"
13 The above--entitled matter came on for further l
14 hearing, pursuant to adjournment, at 9:00 a.m.
2 15 BEFORE:
j 16 SHELDON J.
WOLFE, Chairman d
Administrative Judge ti 17 Atomic Safety ar.d Licensing Board U.
S.
Nuclear Regulatory Commission
{
18 Washington, D.
C.
20555 E
19 DR. HARRY FOREMAN k
Administrative Judge 20 Box 395, MAYO University of Minnesota 21 Minneapolis, Minnesota 55455 22 DR. WALTER H.
JORDAN J
Administrative Judge 23 881 West Outer Drive Oak Ridge, Tennessee 37830 w
i ALDERSON REPORTING COMPANY,INC.
i 2033
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APPEARANCES:
.gs On behalf of the Applicant, Louisiana Power &
'% y Light Company:
s SHAW, PITTMAN, POTTS and TROWBRIDGE
^
ERNEST L.
- BLAKE, JR.,
Esq.
,),(y JAMES B.
HAMLIN, Esq.
1800 M Street, N.
W.
5 j
Washington, D.
C.
20036 8
6 E
8 On behalf of the Regulat'ory Staff:
I E
8 EERWIN TURK, Esq.
GEARY S.
MIZUNO, Esq.
N SUZANNE BLACK 9
g Office of the Executive Legal Director 10 U.
S.
Nuclear Regulatory Commission j
Washington, D.
C.
20555
=
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On behalf of the Joint Intervenors:
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,g-LYMAN L.
- JONES, JR.,
Esq.
P.
O.
Box 9216 E
14 Metairie, Louisiana 70005 w
2 15
-and-16 LUKE FONTANA, Esq.
834 Esplanade Avenue b
17 New Orleans, Louisiana
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ALDERSON REPORTING COMPANY, INC.
2034 1
E E'E T_ E E T,S
'b' VOIR BOARD 2
WITNESSES DIRECT DIRE CROSS REDIRECT RECROSS EXAM.
3 DR. VELMA CAMPBELL (Resumed)
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4
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5 By Mr. Blake 2039 5
8 6
By Mr. Turk 2080 m
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By Mr. Jones 2102 s
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By Mr. Blake 2110 d
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By Mr. Turk 2112 i
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2 9:00 a.m.
3 JUDGE WOLFE:
All right.
The hearing is now I
4 in session.
o 5
I would advise the parties that last night b
j 6
after close of the hearing the Board conferred and I R
7 saw Mr. Jones accompanying Dr. Johnson through the lobby 3l 8
downstairs and I advised Dr. Johnson, becaune we were d
9 9
concerned that during the course of his testimony he z
O 10
- said, "I have these documents and I can furnish them or E
11 I will furnish them.
I don't remember names, but I'll a
p 12 furnish them."
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13 I was concerned that this might lead h
14 Dr. Johnson to believe that he should send these 15 documents en masse to the Board and these would not be g
16 in evidence.
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I7 We thought this would not be proper, so I
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18 advised Mr. Jones in Dr. Johnson's presence that no, we I9 g
did not want to receive those documents that he had n
20 referred to in stating that he could or would send the 2I copies to us.
22
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Howsoever, the Board, again conferring, is 23 :
interested in receiving the titles or captions of various jh 24 documents that Dr. Johnson referred to but indicated he 25 didn't recollect the title and/or copies of the documents ALDERSON REPORTING COMPANY, INC.
l 2036 l
1-2 1 !
themselves.
l kr) l I think these were but few in number.
As 2
3 a matter of fact, Judge Foreman will now take over and k) 4 advise what the documents are.
I'll just turn it over 5I to Judge Foreman.
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3 6
JUDGE FOREMAN:
Repeating briefly, we would R
7 like the articles and references; if possible, copies, n
j 8
and if that is not feasible, abstracts if possible.
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9 The types of documents that I would like are zcg 10 types of documents to which we spoke at the end of the E
h 11 session yesterday, I am asking very specifically for S
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I2 studies relating to synergism between ionizing radiation
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13 and chemical carcinogens in which
- a. range of doses of l
14 ionizing radiation were used in an attempt to determine
$j 15 dose effects, dose rate effects or combinations of those.
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16 And further --
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II MR. JONES:
Your Honor, excuse me for 18 interrupting, but I want to be sure that I understand P"
19 precisely what the last portion of the proposition is.
8 i
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I have gotten it so far that the Board is 21 interested in studies relating to synergism or potential qk synergism between carcinogens and a range of ionizing 23l radiation.
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JUDGE FOREMAN:
Range of doses.
2, '
MR. JONES:
Range of doses, okay.
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ALDERSON REPORTING COMPANY,INC.
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l JUDGE FOREMAN:
If it would help you, what I I
h>N 2
am looking for is information that deals with means for NJ 3
extrapolation of dose effects or dose rate effects.
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4l Then further, and this may be more difficult, v
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in which there were such studies by "such studies," let U
3 6I me repeat, studies looking at synergism or potential 7
synergism between chemical carcinogens and ionizing s
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radiation in which the doses were varied and at which d
some doses that were studied in which there was d
9 dose Ng 10 no evidence of synergism, and information of the dose Ej 11 levels at which that occurred.
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12 I don't know whether there are studies or E
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13 not, but I would appreciate it if any of the parties had l
14 any such information, to provide it to us.
5 2
15 JUDGE WOLFE:
And we would request that g
16 copies be sent to the Board and to all other parties, w
d 17 accompanied by a letter from whoever is writing the 5
18 letter, identifying what is enclosed or identifying the A
19 title if there are no copies available.
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20 We have not decided, not having seen the 21 documents or the identification of the documents, what
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22 action we will take with respect to those documents; but U
23,
for now we request that this be done, and if you could 24 provide those to us within ten days, that would be 25 appreciated.
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ALDERSON REPORTING COMPANY, INC.
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Mr. Jones, I believe you have Dr. Campbell
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MR. JONES:
That is correct, Your Honor.
At h
4 this time I would recall Dr. Velma Campbell to the 5
stand.
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JUDGE WOLFE:
The witness has been sworn.
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2, Doctor, you remain under oath.
And her written direct I
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testimony has already been incorporated into the record as i
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if read.
5 MR. JONES:
That is correct, Your Honor.
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JUDGE WOLFE:
There were, as I remember, Rg 7
certain corrections or amendments that were made to the s
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written testimony.
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9 All right.
I think you had turned the witness i
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11 MR. JONES:
Yes.
That's also correct, Your 3
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- Honor, w a j-13 JUDGE WOLFE:
All right.
Mr. Blake, cross-a l
14 examination.
C 15 Whereupon, 8
g 16 VELMA CAMPBELL M
d 17 called as a witness by Counsel for the Joint Intervenors, 3L 3
18 having first been duly sworn by the Chairman, was examined I
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and testified further as follows:
n 20 CROSS-EXAMINATION 2I BY MR. BLAKE:
22
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4 Good morning, Dr. Campbell.
23 :
A Good morning.
24 g
Dr. Campbell, in your testimony,in the first 25 :
couple of pages of your testimony, you've outlined your I
ALDERSON REPORTING COMPANY, INC.
2040 background and education.
To insure, however, that I under-
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stand, let me ask you quickly some questions.
Do you 2l hold any degrees in epidemiology?
3
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4 or biostatistics?
e 5
An A.
No, sir.
M 6
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4 Occupational health?
8 8
A Degrees?
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G Yes.
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No.
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Environmental health?
c5 12 A.
No.
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Toxicology?
E 14 A.
No.
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15 4
Have you had courses in biostatistics?
16 A.
No.
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Epidemiology?
18 A'
Yes.
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Where?
20 1
Michigan State University and then as part 21 of the medical school training -- and then in, let's see, 22 1981 through the LSU Family Practice Residency.
23!
4 I didn't understand the last.
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24 A.
Through the LSU Family Practice Residency in i
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the spring of 1981.
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Describe that to me, the course in bio-
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'w) 2 A
No, epidemiology.
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Excuse me.
4 What did that amount to?
Describe it to 5
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A That was a three-month period of directed 7
8 readings under the tutelage of Dr. William Williams and j
his role is both Professor of Internal Medicine in LSU 9
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l jj Hospital of New Orleans.
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Do you receite credits of some sort for Z
this course?
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14 A
Yes.
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15 And credits toward what?
J 16 A
Completion of a residency and board certi-ow g
17 fication in Family Practice.
And --
I'm sorry.
Go ahead.
I didn't mean i
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I was just going to add, you know, this is 21 the sort of thing that in general is required of a j f")
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24 G
Do you now hold board certification in Family 25 Practice?
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A Yes, sir.
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When did you obtain your board certification?
2 A.
July
'81.
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4 Do you hold any other board certification?
4 No, sir.
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4 Have you published any articles other than the 6
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f7 two which are identified in your testimony?
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A No, sir.
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Do you consider yourself to be expert in
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10 epidemiology studies?
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11 A
That depends on how you mean it.
However you would --
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.I consider myself qualified as a rrofessional.
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14 in the field of Family Medicine, with a special interest ab 5
15 in clinical and occupational aspects of primary care, to 16 adequately reinterpret and apply the published products 3
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17 of research centers, which means I have to understand the 18 principles and application of epidemiology.
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Have you ever done any laboratory research n
20 on cancer?
21 A
On cancer specifically?
22 G
Yes.
23,
A No.
24 G
Have you done any research into the causes 25,
of cancer?
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A Personally --
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4 Yes.
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A No.
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Do you have with you, Dr. Campbell, a copy g
5 of the study which you published in the " Journal of Family 9
3 6
Practice - Occupational and Environmental Disease in R
7 Family Practice"?
A j
8 A
No, I don't.
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4 Would you describe that as a epidemiology Ey 10 study?
8 II A
No, not precisely.
That's a survey of n
I 12 pfacticing family physicians in the state of Louisiana
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I4 the Academy of Family Pract' ice regardining their personal Y
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9 15 experience with the numbers of cases which they see of y
16 occupational and environmental disease in the state.
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I7 That, of cours e, reflects the physician's 18 subjective perceptions of his practice and not th'e actual E
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numbers of cases which would be, of course, an epidemiology 20 study.
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Did it take, Dr. Campbell, any particular ex-22 pertise in your mind to have conducted this survey which 23 ' you did through the questionnaires and then compiled it and
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reported it?
I 25 l A
Yes.
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What was the nature of that expertise?
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Several areas.
The knowledge of human dis-V 2
ease as it presents itself in the practic, setting rather 3
than in.the laboratory setting; in other words, what patients are likely to come in complaining of.
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They come in and complain that their 9
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abdomen hurts.
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4 So you have to have some special expertise in c
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to which physicians whose primary role is that will be able
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designing questions so that people can read them, under-U g
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be made of numbers and what cannot.
For instance, in inter-7 w
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E that this reflects the subjectiva experience of physicians j9 3"
in their practice.
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4 Do you happen to have with you a copy of gb
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2 the questionnaire which you sent out?
3 A
No, I do not.
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Your report of this work didn't include the g
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questions involved?
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Correct.
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Did you say it also required in your mind d
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expertise in statistics or in numbers in order to do the zo 10 compilation?
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Oh, the compilations wereorelatively simple.
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12 I n anaged them with a Casseo calculator.
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What was the nature of the last expertise 14 that you referred to which was necessary for this?
M 15 A
The understanding of -- more in the nature d
16 of practical applications of numbers.
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For instance, to take a statement such as 5
y I3 occurred in this study, that a certain percentage of family 5
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practitioners perceived that they were treating patients t
5 20 l who complained of occupational disease more than once a I
week, and for instance, try and translate that into 2
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numbers of occupational disease occurrences in the state 23 '
would be difficult.
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ourselves perform and our colleagues in the research
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G Dr. Campbell, as I understand --
Did I give 8
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A Yes, sir.
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9 active members of a particular organization; is that zo 10 correct?
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Yes, sir.
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How many of them are there?
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Well, at the time in 1980 there were 325 on m
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Three hundred and twenty-five?
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Active members.
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What percentage is 325 of the total membership?
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18 A
I wouldn't know.
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in Louisiana belong to this organization?
2I A
That would be very difficult to say.
If they 22 don't register, there's no way of counting them.
23 '
G How would you characterize the difference
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I may be wrong, how would you characterize the difference pu) 2 between those who belong to the organization and those who 3
do not?
Impossible to say?
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About $250 a year.
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4 Do you regard'it as unimportant in arriving 8
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at conclusions which I believe your study purports to R
7 regarding Louisiana generally that you do not know what 3
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8 percentage of the physicians that you sampled are within 5
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9 family practice, nor the percentage of physicians in the
!g 10 organization which you sampled are active members?
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I don't believe that either I don't 3
f 12 understand what you're asking or you haven't asked what
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13 you want to, because what you just asked me was in a m
5 14 questionnaire done on a survey of the Louisicna Academy of r
15 Family Physicians, did it matter to me that I didn't know y
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If you're asking me whether my study purports n
20 whether this particular article purports to to represent 21 represent a conclusive numerical study of the amount of occupational and environmental disease in the entirety of 23 i primary care in Louisiana, this study did not and does not 24
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purport or assert that.
25 :
What the study suggests in the closing comments I
ALDERSON REPORTING COMPANY, INC.
2048 3-4 1
is that occupational and environmental illness may represent l
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such as myself; and, therefore, should be given increased k) 4 emphasis in the ongoing research and educational programs s
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4 Does your study here limit its conclusion to R
7 some subset of ' f amily practitioners in Louisiar.a?
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looking at the comment section that you referred to to io G
10 stand for the proposition that these illnesses are a j
11 significant part of family practice in Louisiana.
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12 Now I want to go back to my questions.
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do not know how many physicians in the organization are h
14 active members of the total membership of the organization;
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If you're asking me how many members of the E
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Family Practice Academy actually practice family practice, 1
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21 There are a number of inactive, being either 22
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retired or otherwise occupied, members of the Academy, but 23 '
who for various reasons maintain their membership.
24 The number of people in the organization who i
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ALDERSON REPORTING COMPANY. INC.
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2049 is found on the firs
- page.
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That's t..
number,325 to which you referred 3
to earlier?
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Righz.
The' inactive people who do not g
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family practice, I do not know the number of.
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0 Nor do you know 'what percent these-325 3
8 8
represent of f amily prac,ti cioners in Louisiana?
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9 A
No, I do not know that.
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Nor do you know why a person would join the j
11 organization, as opposed to one who might not, since you U
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12 don' t know about those who.,do not?
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In general, membership in a professional o
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What I'm. testing, Dr. Campbell, is your a
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16 sampling technique.
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Are you confident now that you did a study 5
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18 which involved proper s'ampling techniques --
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A Yes, sir.
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-- or was it just. mare generally intended?
2I A
Within the goals and objectives of the study, 22 our sampling techniques were very carefully designed to 23 -
attempt as best any researcher can to answer the questions 24 that we set out to ask.
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Did y'ou'make any corrections in your study ALDERSON REPORTING COMPANY, INC.
I 2050 D-6 i
for those who reported from your questionnaire and those l
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who did oee2 3
A I'm sorry, who did what?
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G Did you attempt to make any corrections for a
5i those who reported back to you, responded to the I
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questionnaire, from those who did not?
R 7
A The percentages which are reflected in the a
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first table are clearly indicated as percentage of dd 9
respondents, not percentage of the total surveyed.
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Is there any bias in questionnaire studies, 5
j 11 Dr. Campbell, occasioned merely by the fact that some U
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Is 13 that a facet --
m 14 A.
In general that's a facet of study design, n
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How did you correct for that or involve that us g
17 facet in your study?
x 18 A.
There are several attempts -- several ways to P
g" 19 attempt to level out that factor to which you refer.
20 In general, you try and understand your 21 study population as best you can and direct a questionnaire 22 which will not be so -- which will be specific and relevant 23l enough that the people being asked the questions will be 24
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interested in answu;ing them.
25 In other words, if you send a questionnaire l
l ALDERSON REPORTING COMPANY,INC.
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that's very long and complex and requires extensive special 1
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knowledge of the subject, even though you are not 3
necessarily interested in that special knowledge of the
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4 subject, what you'll get back is a response from. people e
5 who are critically and vitally interested in the subjec*
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6 area, and you will receive a bias.
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7 On the other hand, if you do as we'did and A
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try to design a relatively simple, easy to respond to d
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questionnaire, which -- because our goal was to get from 5
10 these physicians an estimate of their experience, we 11 received in response to our questionnaire a percent of the Dj:
12 total studied, 59 percent responded, f >. S
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16 practicing physicians who tend to put questionnaires in s
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the circular file under the desk on a pretty regular basis.
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ALDERSON REPORTING COMPANY,INC.
j 2052 01 BY MR. BLAKE:
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So your bias correction to account for
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p pl who responded from people who did not to your question-3 nairo was built into the format of your questions?
is 4
that what you're saying?
5 E
I A.
N 6
Into the overall design.
That is to say, we o
7 attempted to design a questionnaire which we -- in such a
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8 way that it would elicit the most response.
N G
Did you do anything when you got the question-9
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10 naires back to take this fact'into account?
Did you do z
11 anything in compiling the informa, tion which you received D
d 12 either based geographically or based on the particular
?.
13 types of practice, or --
S 14 A
one of the --
If you mean did we analyze w
2 15 whether or not we had a particular geographic basis, for 16 instance S.?
d 17 G
Did you analyze at all for the 18 A
Where the responses came from?
5 19 G
That's correct.
R 20 A
Okay.
21 G
Out of the total sampling which you attempted 22 to do.
23 '
A Sure.
24 One of the things we did, and which was 25 [ included -- I was kind of proud of the artwork myself --
i ALDERSON REPORTING COMPANY. INC.
2053 1
but the Journal apparently didn't have room for it in their
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2 publication.
They sent it back to me.
3 One of the things which I did do was a map (F';
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4 of Louisiana, because of the concern that maybe the answers e
5 wore coming only from university-based practices or some-5 3
6 thing of this sort, and the response So we basically R
7 made a map of the addresses of the physicians who s
j 8
responded.
d 9
And the responses were spread quite uniformly 10 throughout the state, north and south, east and west, urban 5
j 11 and small town.
Oj 12 O
Did you check for the types of practice which'
( )
13 these family practitioners had, in terms of those that you 14 heard from and those which you did not?
E 15 A
Well, for the respondents one of the questions d
16 in the survey was whether or not they considered themselves s
,d 17 to be practicing industrial medicine full time, which, of I
x 18 course, would incline them to see occupational diseases E
19 g
with some frequency.
n 20 And there were only five physicians out of the l
l 21 total response who indicated that they were in fact 22 industrial physicians rather than family practitioners.
23l a
Did you distinguish between disease and i
24
(
occupationally incurred problems?
25 i
A The questionnaire was directed towards disease i
l l
l J
ALDERSON REPORTING COMPANY. INC.
2054 perception rather than on hagiology.
In other words, i
I
-3 whether or not either in the mind of the physician or the g')
g mplaint of the patient, the disease was identified as an 3
occupational disease.
4 Now, th s is quite different, of course, m
5 3
from, say, taking all of the low back pain patients in a 3
7 specific physician's practice and doing a case-by-case study to see whether in fact those diseases were originating 8
N from some occupational causation.
9 z
h 10 4
Turn for a moment, Dr. Campbell, to what you z
referred to as the first table in this study.
J.s there ij D
d 12 any other. table in it, other than Table 17 3
13 A
The other one was the map.
3 E
14 G
~ The other table was the map?
w b
k 15 A
Yes.
T 16 The Journal asked that all tables be numbered, D
A 17 regardless of whether there was a table number two.
=
5 18 G
Let me ask why the numbers in the column --
=
19 the right-hand column don't add up to 100.
8n 20 A
one is a percentage, and the other is the 21 actual numbers.
It's helpful, I've found, in trying to 22 read this type of -- or any other type of --
23 4
Excuse me.
You misunderstand.
24 l I'm looking only at the percent column.
(
25l A
Right.
i l
1 ALDERSON REPORTING COMPANY. INC.
9
l b055
-4 G
And if I cdd --
1 I
A You said what's the meaning of --
<l) 2 G
And if I add those numbers in that column, why do they not add up to 1007 g_D A
I don't know.
What do they add up to?
O We ll, why don't you add'them for me?
I l
g ll A
I don't have a calculator.
G Well, let's add them by -'
49 plus 9 is 8
aj what?
9 i
A You say, I'm beginning to be a little bit z
j jy annoyed, and I don't believe that I am appearing here as an accepted witness in the area of family practitioner 12 3
, ) @
13 t
attest to the commonly held professional opinions of d
E 14 myself and my colleagues in order to be subjected to some U
k 15 questioning regarding my fourth grade educational level of arithmetic.
T 16 Dd g7 G
Dr. Campbell, as I understood it, you said b
18 that you couldn ' t add those up because you didn' t have a E
19 calculator.
en 20 Then I said, "Well, let's go ahead and add 21 them up."
22 What is 49 plus --
Are the numbers in that 23!
column 49, 9,
29, 8 and 11?
f, 24 A
Again, Mr. Blake, I fail to see any relevance 25 ;
between this particular exercise and whether or not the ALDERSON REPORTING COMPANY. INC.
i 205G
-5 physicians, including myself, have'a professional opinion I
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regarding whether or not we have cancer in Louisiana, and s,/
whether or not we have chemical pollution in Louisiana.
g"]
MR. BLAKE:
I move to strike the answer, and v
I would like an answer to my question.
h MR. JONES:
Your Honor, if it please the 3
0 Board, at this time I would raise an objection as to the 7
materiality and relevance of this line of questioning.
I 8
j realize that counsel have tried to accommodate one 9
i h
10 an ther by allowing a reasonably wide latitude in cross-z j
jj examination.
<u But I fail to see how in any substantial d
12 3
respect this line of questioning contributes to the Board's U,(d} 5 13 E
14 understanding of Dr. Campbell's tastimony as it appears in w
the record.
2 15 16 That's the basis for my objection.
~
DW g
j7 JUDGE WOLFE:
Well, there's an outstanding "x
5 18 motion to strike.
=
5 19 Now, where does your objection come in, Mr.
8n i
20 Jones?
Do you object to the motion to strike, or do you 21 object to this line of questioning?
22 MR. JONES:
I object to the line of questioning,
23,
Your Honor.
24 JUDGE WOLFE:
I will handle first things l
25 first.
I ALDERSON REPORTING COMPANY. INC.
t 1
l 2057 The motion to strike is granted.
Doctor, when you're asked a question, it is
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ti) 2' not for you to question the relevancy of the attorney that's
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- l asking you the question.
Just answer the question.
c, Mr. Jones, if he sees fit and questions the K
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relevancy, I'll rule on that.
But as a witness you're here e
j to testify. Unless there's an objection and the Board 2
7 sus a ns y u must answer the question and answer it 8
4 directly.
m 9
i Now, back'to you, Mr. Blake.
There is now an z
E objection to this line of questioning as being irrelevant.
11 p
12 Perhaps you can tell us where you're going, what the 1
13 Purpose --
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MR. BLAKE; Let me first say that I only have E
14 ab!
15 ne or two more questions in this area.
Dr. Campbell has a
[.
16 published just a couple of publications.
I would not have D
A g-j7 regarded her as expert, quite frankly, in statistics or b
18 epidemiology or -- well, in those areas based on what I've
=
had before me.
19 8n 20 But when she said that she did regard herself 21 as qualified in these areas, I felt that I needed to go ~in 22 and explore it.
23,
And the only:: document that I have before me 24 which allows me to understand the techniques which'she has 25 ; used is this one report which she has published.
Now, I'm i
ALDERSON REPORTING COMPANY, INC.
2058
-7 1
exploring how she got to the bottom line and drew her con-l
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clusions, based on the only table that's in the document.
V 3
JUDGE WOLFE:
Then this is --
You're
('T 4
questioning her qualifications then; is that correct?
9 e
5 MR. BLAKE:
That's correct.
5 3
6 JUDGE WOLFE:
All right.
May I suggest a R
7 shortened time, though, that you in this instance give j
8 the Doctor what these numbers add up to and let's get on dd 9
with.it rather than asking her to make the calculation.
dg 10 If you have that calculation, ask her to E
g 11 accept it and let's proceed.
u
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12 Objection overruled, Mr. Jones.
3 13 BY MR. BLAKE:
14 g
Dr. Campbell, do the numbers -- are the l
t 2
15 numbers in that table 49, 9,
29, 8 and ll?
s i
l f
16 A
Yes.
W i
I b.
17 g
And have you had an opportunity ~to add up 5
18 those numbers?
l 5
l9 g
A No.
M 20 l
21 c1P 22 23!
($k
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ALDERSON REPORTING COMPANY,INC.
2059 5-1 1
MR. JONES:
Your Honor, if I might, I would g
2 suggest that if Mr. Blake has a sum he wants to suggest, we 3
might arrive at a stipulation.
4 MR. BLAKE:
I have just added them up and gotten 106.
Would you concur?
a h
3 6
MR. JONES:
I'll stipulate to that, Your Honor, a
7 THE WITNESS:
I didn't understand what just X
j 8
happened.
d d
9 5,
MR. BLAKE:
Your Counsel stipulated that the g
10 percentages in that column added up to 106, rather than 11 to 100.
D y
12 THE WITNESS:
Okayr 5
13 BY MR. BLAKE:
(
l 14 4
Is there an explanation for that, Doctor?
A.
The mast logical explanation would be tilat 15 16 ri someone made an error.
us II 4
Turn to your testimony, Dr. Campbell, and IO the portions of it which refer to the SEER Report.
i That's Question No. 9 and its answer.
,g 20 A.
Yes, I have that.
21 4
Dr. Campbell, did you look at the SEER Report 2
itself and get these figures out of the SEER Report and 23 :
then write them in this testimony?
I A.
Yes, sir.
g You believe them to be accurate?
I ALDERSON REPORTING COMPANY. INC.
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Yes, sir, to the best of my ability.
y h
2 g
Do you have a copy of the SEER Raport with you 3
uhat you used, or an abstract at least?
h 4
A The copy that I have with me is the copy e
5 which was distributed by Counsel.
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I think that will be fine for our purposes.
R 8,
7 I think it will include the right pages.
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8 MR. JONES:
Your Honor, I would request that d
d 9
if Counsel intends to go in some depth into the data 10 contained in the SEER Report that he identify either by j
11 page number or by table each reference, so that we don't 3
l 12 spend an inordinate amount of time looking through the
/
13 documents to find the right pages.
l 14 JUDGE WOLFE:
All right, Mr. Blake?
m 9
15 MR. BLAKE:
Yes.
=
g' 16 JUDGE WOLFE:
All right.
as MR. BLAKE: Sure.
l I7 l BY MR. BLAKE:
18 g
Looking at Do you have page numbers on h' I9 g
your copy of the SEER Report?
n 20 A
On some of them.
21 g
Looking in the lower left-hand corner at the 22 page numbers, do you find Page 32?
23 A
Uh-huh.
24 g
Looking at the figure for New Orleans breast 25l cancer, 16. 7.,
l l
ALDERSON REPORTING COMPANY, INC.
2061 9-3 A
Yes.
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2 4
Do you know what the national average is?
3 A
For this period of time, it is stated in
,g' }
4 this document as 15.1.
e 5
4 So that the breast. cancer in New Orleans --
f r
s 6
and this is the mortality rate table, correct?
I E
7 A
Correct, all races, both sexes.
j 8
G Pardon me?
d d
9 A
Excuse me.
It's the mortality rate for all 10 races and both sexes.
3l 11 G
Now looking at -- so the mortality rate in u
g 12 New Orleans is very high compared to the national average?
)
13 A
It is higher than the national average.
l 14 0
Higher than.
15 Looking at Page 14 in th e same document.
j 16 A
The SEER Report?
w d
17 G
Yes, please.
Actually, Doctor, my 14 is M
18 cut off on the document I have.
E 19 g
A I've got one that says 14, " Age Adjusted n
20 Incident Rates"?
21 4
No, my doesn't reflect the title in the copy 22 I have in front of me.
23 '
This is incidence rate for breast cancer or 24 for various cancers?
25 i
A That's wha't my Page 14 says, " Incident Rate ALDERSON REPORTING COMPANY, INC.
2062 5-4 i
Per Hundred Thousand, All Races, Both Sexes."
th 2
4 What is the incidence rate for breast cancer 3
in New Orleans?
.{
4 A.
Forty-three point five.
e 5
G And the national averages?
U 6l A.
Forty-six point seven.
R 7
4 So that with respect to breast cancer, the 3
j 8
mortality rate in the New Orleans area is 16.7 compared do 9
with the national average of 15.1, and the incidence rate N
10 is 43.5 compared to the national average of 46.7.
11 Do you have an explanation as to why the 3
gi 12 mortality rate would be higher by some amount than the 5
13 national average, but the incidence rate is low by some l
14 amount, when you look at the other figures here I take it U
15 you'd agree, than the national average?
gl 16 A.
The discrepancies between incident rate and us
(
17 mortality rate are always hard to pin down, because there 5
3 18 are a 1c t of f actors that go into answering the question E
I9 g
of once a person has acquired a disease, why they end up n
20 dying of it.
21 Many factors go into contributing to mortality
{u 22 So it would be impossible for me to comment as to any 23 '
specific reason why those rates might be different.
24 g
If I were to do the same thing with respect 5
to colon cancer as it exists in these figures, or with ALDERSON REPORTING COMPANY, INC.
206D 5-5 1
respect to rectum cancer, would it be likely that your r~')
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or impossible to know?
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4 A
To compare mortality and incidence?
- Yes, a
5 that's always difficult.
Ae 6l 0
The 16.7 figure which we focused on on Page 32,
R 7
in your testimony in answer to Question No. 9 you've 3
j 8
referred to the 16.7 figure.
You referred to it, I believe d
o[
9 as New Orleans having the highest rate.
Is that correct?
z h
10 A
Yes.
Do you mean it's correct does my 11 testimony say that?
D g
12 g
Yes.
13 (s
A Yes.
u l
14 g
And is that correct from a review of the 5
y 15 table now?
m j
16 A
From a review of this table, it appears that w
h 17 j connecticut has us beat.
=
I 5
18 G,
so you would correct your testimony to say 19 j
that in fact New Orleans does not have the highest?
20 A
New Orleans in fact appears to have the 21 second highest.
r'3 t,/
g Do you know whether or not there are any 23 !
other misreadings from the statistics reflected in your 24 testimony?
25 A
I reviewed these rather closely prior to l
1 l
ALDERSON REPORTING COMPANY, INC.
i 2064 5-6 I
submitting the testimony, and to the best of my knowledge,
,-m (j
2 that's the only one-I missed.
3 4
In the bibliography of studies which you have r{o,/
4 referred to with your testimony, did you include in that 5
bibliography any reference to a paper by DeRouen and e
h j
6 JeRouen entitled, " Relationships Between Cancer Mortality R
7 and Louisiana Drinking Water Source and Other Possible A
8 8
Causative Agents"?
d C
9 A
In the bibliography for which now?
I'm Eg 10 sorry, I'm not clear which bibliography you mean.
11 4
The second study which you did.
One of them u
f I2 was the questionnaire and the second study.
A3
({J g 13 A.
In the literature review for the Mayor?
- Yes, l
14 DeRouen and DeRouen I have read.
15 g
Did you include a reference to that in that E
I0 write-up of important studies?
us II A.
I don' t seem to have a copy of that document I0 with me.
There were more than 60 references in that.
19 8
No, I.do not see the DeRouen Report in here.
n 20 g
But you are familiar with that report?
l 21 A.
I have read it, yes.
G Is it dated about the 1977 time frame; does 23 l that sound about right?
A.
Seems about right,
'76,
'77.
4 Does that same study which you did or i
I
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l ALDERSON REPORTING COMPANY, INC.
aoss I 5-7 1
compilation of the literature refer to a study done for 3
({ )
2 the Environmental Protection Agency by the Epidemiology 3
Subcommittee of the Safe Drinking Water Committee, National 4
Academy of Sciences?
g 5
MR. JONES:
Your Honor, I would request that 8
3 6
Counsel identify the study further by author and title.
R R
7 MR. BLAKE:
This study is P.B.
- 292875, Aj 8
entitled, " Epidemiological Studies of Cancer Frequency d
c; 9
and Certain Organic Constituents of Drinking Water."
10 It would be of recent literature published 8
11 and unpublished, U.S.
National Research Council, Washington, m
Y 'I2 D.C.
prepared for Environmental Protection Agency, dated 6
^ ~*
Q )g 13 September 1978.
l 14 It was prepared for the EPA Office of 15 Drinking Water Criteria and Standards Division by the d
Ib Epidemiology Subcommittee of the Safe Drinking Water s
h II Committee Board on Toxicology and Environmental Health x
IO Hazards, Assembly of Life Sciences, National Research 19 8
Council, National Academy of Sciences, Washington, D.C.
n THE WITNESS:
No, sir, I don't believe I I
have that one here.
22 23 ;
25,
I i
ALDERSON REPORTING COMPANY,INC.
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-1 BY MR. BLAKE:
bm j
jgh g
Have you ever heard of that report, Dr. Camp-2 bell?
3 I
A Not by that title.
4 g
Have you put any page numbers --
Can I o
5 b
refer t pages in y ur testimony?
Have you numbered them 8
6 yourself or not?
7 8
A No, but I'm generally familiar.
n 9
The Gottlieb study which you referred to in z
h 10 your testimony at the bottom of the sixth page of the testi-Zj 11 many, the-deathccertificate ahalisis D
d 12 A
The study on lung cancer?
z A
13 4
Yes.
7U8 E
A
' Okay.
y,4 E
15 a
sy death certificate analysis.
16 A
Uh-huh, I'm with you.
17 g
Are you aware --
Is it your opinion that 18 death certificate analyses are highly informative?
=
19 A
Certainly they're highly informative.
20 g
And are there limitations on the conclusions l
21 which can be drawn from death certificate analyses?
(]
22 A
Yes.
v 23 O
And are you aware whether or not that Gottlieb 24 study in fact explicitly states that the data is obviously 25 f limited?
~
i l
ALDERSON REPORTING COMPANY. INC.
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A 12 I
The particular study in question does include j
grs a brief discussion of the limitations of death certifi-6) u a e studies, being basically that they are limited.
They 3
gs identify diagnosis at the time of death, and therefore, are
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7 appropriate for further study.
b 8
They're limited because, in general, death n
N certificates do not include, for instance, a lifetime 9
)i 10 ccupational history, lifetime residential history, and a
E 5
11 many times other co-existent disease processes at the same D
d 12 time.
z 13 4
Do you know, for example, with those limita-3 g
j4 tions which are inherent in such a study -- whether or not U!
15 it was possible in this study to provide any control for S.-
16 cigarette smoking?
2 6
17 !
I would refer you to page 1136.
s l
18 '
A Well, in general, without leafing through and 19 spending the Court's time to find the specific page, in 8n 20 general, in death certificates one thing which we in 21 practice frequently find is that it doesn't ask about 22 cigarettes.
It doesn't ask about occupation.
It doesn't g
23 ask about other types of both lifestyle and environmental 1
24 exposures.
25,'
Therefore, they are utilized to identify I.
i ALDERSON REPORTING COMPANY. INC.
I 2068 general categories of either disease or populations for further and more specific study.
G W uld you agree with me that in fact this 3
I study did not have any control for cigarette smoking?
4 Actually where I'm looking is on page 1136, the bottom 5
a d
right-hand corner of that page.
g 6
m A
Correct.
7 8
g The paragraph that begins, "Although death N
certificate studies are a quick" 9
2 h
10 A
Ri.ght.
Along with detailed variety and z
jy duration of employment, residential history and information D
d 12 on. cigarette smoking, so that causal inferences in E
keeping with my earlier statement are not to be drawn 13 S
E 14 from death certificate analyses.
w b
k 15 They generally are utilized in.the profession 5
J 16 to raise concern'for further study.
N d
17 4
The specific --
The statement there was 18 causal inferences on specific factors as a result of not
=
19 having information which --
8n 20 A
Cert ~ainly, that is the limitation of death G1 certificate --
I')
22 4
can't be made from this study; is that 23 '
the statement?
24 A-That causal -- uh-huh.
25,
causal inferences cannot be made.
r I
ALDERSON REPORTING COMPANY. INC.
206D j
G Referring to the colon and rectum study, which k) 2 is' referred to in your testimony on the seventh page --
3 in that study, and I would refer you to page 125 is it
()
4 a fair conclusion of this study that the study does not o
5 show causality, but it strengthens the credibility of a b
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drinking water risk?
i 6
E 7
A That's the statement, yes.
K 8
G That d
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A That's the conclusion the authors draw, Yg 10 right.
Ej 11 4
That's a fair conclusion?
y 12 A
Certainly, uh-huh.
m g
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20"/0 BY MR. BLAKE:
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bme3 G
Referring to the pancreatic cancer mortality
'h,J 2
which you refer to in your testimony, is this study also a 3
death certificate analysis?
4 b
e 5
a G
And, theref re, subject t the same limitations 8
6 e
7 the other Gottlieb study which we referred to earlier, as n
control for cigarettes or alcohol or limitations on 8
M N
lifestyles, certain life --
9 i
h 10 A
Not quite.
This particular death certificate z
jj study was performed in a slightly different fashion from D
d 12 the others, in that pairs of death certificates were E
^s $
matched for age, race, sex, year of death, parish of
'{D?E 13 E
14 residence and cccupation.
w b
k 15 Now -- and this particular type of analysis 16 permits slightly more specificity for factors, such as
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g 17 occupation, residence.
It continues to contain the long-E 18 term limitation in a sense, but a death certificate, even
=
5 when you match it with a pair, doesn't start with the
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19 20 person's place of birth and work through all their 21 residences for their whole life, for instance.
22 But it does permit more specific analysis of 23,
the data than the type of study done on the lung cancer.
24 4
Let me refer you to'page 259 in this 25; study, the final paragraph in the study.
Would you read ALDERSON REPORTING COMPANY. INC.
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A "The limitations of death certificate data c
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4 d(
work and residential histories, and no information on risk 0
factors, such as smoking and alcohol consumption."
]
6 G
On the fourth page of your testimony, Dr.
7 f
Campbell, in the first paragraph of your response to 8
Mj Question No.
9, you talk about laboratory experiments in 9
i which some agents are isolated from one another.
z jj Have you done --
I guess I asked you D
earlier today if you have done any studies of cancer, and d
12 Z
y ur answer was no.
13
,,UB A
That's correct.
E 14 ab!
15 g
Let me ask you whether or not you've done any S
3 16 laboratory experiments in which you've isolated one agent Dw g-j7 from another?
u I!
18 A
My particular expertise is in the area of E
19 applied science rather than laboratory science.
And so as R
20 an expert in those areas, I'm simply drawing on references 21 to which this type of work is referred.
22 G
Are you aware of any study where background 23 i radiation was isolated -- any experimental -- laboratory 24 experiments?
g 25 ;
A It's --
I don't k n e-- how I should respond to i
ALDERSON REPORTING COMPANY, INC.
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-3
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g I don't know that we established that you
((/~~3 couldn't use the term.
I think we're established that you
_/
4 were not an expert and didn't profess to be an expert in 6
the radiation areas, g
6 e
A That's true.
But it was also suggested that 7
my preparation in medicine was not sufficient to qualify 8
8 N
N me to make any statement about radiation at all.
9 z
h 10 Are y u aware of any study in which background z
radiation has been isolated -- any laboratory experiments?
jj D
d 12 From my understanding of the word " background,
A E
()
it would seem to be that it would be difficult to isolate 13 E
14 background anything from anything.
w b!
15 G
Difficult, if not impossible?
16 A
I wouldn't be able to say about impossible.
O g
37 4
Okay.
5 18 Referring to that same page in your testimony --
=
5 j
19 A
Although I should modify that and I am 8"
i 1
20 aware of at least one local research laboratory in which 21 they make a strong attempt to isolate to the best degree f
22 possible from background influences, their experiments.
this being one of the 23,
And I would assume 24 best in the South -- that he is trying to isolate and 25l you know, " isolation" is a funny word.
" Identification" l
l ALDERSON REPORTING COMPANY. INC.
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is good.
-4 l
But I have toured those facilities, and they
)
2 have carcinogenesis testing facilities there in which an 3
attempt is made to isolate the environment in which they j^g 4
uy do their testing from virtually every factor.
o 5
U 8
6' He might be able to tell you whether or not e
7 it's possible to isolate background radiation.
j 8
G This is at Oschner?-
a N
9 A
No, this would be Dr. Lasiter's laboratory, i
h 10 the Center for Bloorganic Studies at ~UNO 5:
it the University of New Orleans.
a d
12 G
- But to your knowledge, natural background 3a (gj 13 radiation can't be isolated?
/u E
14 A
'I don't have knowledge to that effect, if it W
2 15 can or can't.
I wouldn't know.
j 16 G
The third paragraph of your answer to Question w
~
b 17 i 9
Are you familiar with the primary repair mechanism 18 within cells of the human body?
=
19 A
The primary repair mechanism?
g n
20 G
Are you familiar with a repair process within 21 the cells of the human body?
Are you familiar --
)
22 A
Human cells are constantly repairing them-23 selves.
24 G
And what you've referred to here as the 25 '
immune system, is that distinguishable -- and maybe it can i
i l
1 ALDERSON REPORTING COMPANY, INC.
I 2074 be looked at as a secondary repair process from the repair g')3 pr oss which takes place in individual cells?
2 A
That's difficult to answer.
You know, bio-3
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4 logic repair systems start with the molecular and probably y
the atomic levels and increase in ever-widening circles e
5 E
f complexity.
j 6
7 So to take one piece of the process and dis-E 8
tingiush it, you can -- it's much the same as asking me a
N to distinguish a heart from a body and a myocardial 9
1:
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15 G
Were you --
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16 you were not addressing yourself to the cellular level Y
17 here when you w ere talking about the immunicy system.
E 18 A
Well, that's my point.
The immune system 19 consists of cells and processes.
And it's a system.
R 20 It's not a little box.
21 0,
Sa the repair may be looked at as taking place 22 at the cellular level?
It may be looked on as taking 23 place as a result of the interaction of other systems 24 within the body?
25l It may be looked on at various levels?
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THE REPORTER:
Mr. Blake, I'm sorry, but I y
4 can't hear you.
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U MR. BLAKE:
You may take a look -- isolate on 8
6 e
7 an individual cell and look for repair which you've said 8
8 takes place constantly in cells, or you may look overall n
9 at how the human body functions and its immunities.
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The answer is yes.
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6 A
Let me answer it this way.
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professional understanding of the literature of the d
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literature which is commonly available to practitioners z
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11 stage process occ;urring over time, both on a cellular Ievel D
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14 length to determine all the processes at each of those 15 stages and what impact each process might have on the E
I0 other.
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I7 In my testimony I am referring to the general
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18 concept which is becoming widely accepted that this E
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multi-stage process is one which may involve limitations n
20 and limitations which may be overcome.
2I MR. BLAKE:
I have no more questions.
Thank 22 you, Dr. Campbell.
I 23 l THE WITNESS:
Thank you.
JUDGE WOLFE:
Mr. Turk.
May we take a five-minute recess?
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2077 8-2 j
JUDGE WOLFE:
We'll take a ten-minute recess.
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A (Recess taken.)
2 3
MR. FONTANA:
Judge Wolfe, as executive b
attorney for Save our Wetlends, I might have something.
4 g
5 that might help me',in my preparatica on this feed-and-bleed a
6 and on your order, and I've sent you a mailogram today R
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also requesting something.
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8 I feel like I should bring it to the dd 9
Commission's attention.
i 10 I received an anonymous phone call.
The 3l 11 anonymous phone call stated that the main feedwater system D
j 12 that goes to both generators fell approximately a foot (4 5
)
13 and a half sometime in January, supposedly, of 82; and l
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20 this main water feed 33 Fr 21 I have to tell you it was anonymous.
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would not give me his name. ~He would:not give me his 23 phone number, and I tried desperately'to get it.
24 JUDGE WOLFE:
Well, I would assume that the D
Staff and/or Applicant in a timely manner would bring this
2078 8-3 1
to the Board's attention and certainly to the technical
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2 staff's attention.
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I personally am unaware of any such Ct 4
circumstance.
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6, MR. BLAKE:
This is news to me, what R
7 Mr. Fontana has just said, and I know nothing about the
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MR. FONTANA:
This is the main feedwater h
10 system that goes to both generators.
That's the way he
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12 MR. BLAKE:
I know nothing at all about it 13
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dropping a' level of one foot for some months now; but m
6 I4 quite frankly,
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I approaching a testing phase, it doesn't surprise me that the levels are increasing or decreasing in various systems h
out there as they test these components out.
m 18 Of course, we are still months and months 19 from even fuel loading.
20 MR. TURK:
I am not aware of any incident like 21 this.
I will certainly talk with the technical staff and 22 with the resident inspector and see if there is any truth 23l to it, or if so, what the significance is.
24 May I just see if I understand what the 25 j
communication was to Mr. Fontana?
I l
l ALDERSON REPORTING COMPANY, INC.
2079 8-4 1
Was it that the hardware fell or the water 2
level fell?
3 MR. FONTANA:
He said that the main feedwater 4
system that goes to both generators fell because of its s
5 own weight, without any water in it.
It fell approximately i
3 6l a fod; and a half and came to rest on a beam.
R 7
He thinks it happened sometime, approximately, A
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the last two weeks in January of 1982.
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Y MR. TURK:
I'11 look into it, bg 10 JUDGE WOLFE:
All right.
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11 MR. FONTANA:
I'd appreciate it if you would.
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12 Thank you.
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13 MR. BLAKE:
I will check further, but lest
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14 this go with anybody leaving with any concern, I am informed 15 by a manager of Louisiana Power & Light Company, who in my j
16 opinion ought to be in a position to know about such a w
h I7 development, that there is no basis here for a statement a
5 18 that the main feedwater system, including the two 8
generators, fell a foot.
n 20 JUDGE WOLFE:
Yes.
Well, we would appreciate 21 receiving notification from the Applicant and Staff in a 22 timely manner whether there is any factual foundation to 23 '
this whatsoever.
All right, Mr. Turk.
25 '
//
L ALDERSON REPORTING COMPANY. INC.
2080 8-5 1
CROSS-EXAMINATION
)
2 ! BY MR. TURK:
a 3
g Dr. Campbell, I won' t have too many questions V
4 for you today.
o 5
I do want to turn'to your written testimony, h
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however, and on the fifth page of that testimony, which is R
d 7
your continuation of your response to Question 9, the 3
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second paragraph on that page has a statement which d
q 9
indicates that, "The people who live along the lower 5g 10 Mississippi River in southeast Louisiana have rates of f
11 cancer which are significantly higher than the national D
y 12 average."
(d2 5~) 5 13 Do you see that statement?
m l
14 A
Yes.
15 g
When you prepared this testimony, was it your E
16 intention to refer here to the national average for the A
entire. country, or are you referring to the data in the z
18 SEER Report?
19 g
What was your intention?
You'll notice that 0
the rest of the paragraph has to do with statistics that 21 are drawn from the SEER Program.
22 S
A The primary basis for this testimony was 23 the SEER Report from '73 to
'77.
So I believe it would be 24 fair to say that the preceding statement was based on that 25 ;
document.
t ALDERSON REPORTING COMPANY. INC.
2081 8-6
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G And I believe we established last week when we N) 2 were talking that the SEER Report represents data for 3
eleven different registries, rather than for the entire r
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4 country; do you recall that discussion?
p o
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The SEER Report is taken from data from tumor 5
h 6
registries, yes, in various places in the country.
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From eleven registries in various places A
8 8
around the country; is that correct?
d d
9 A
That's correct.
10 G
So would it be correct, also, that throughout j
11 this paragraph where you compare New Orleans rates for D
12 cancer incidence and mortality, and you compare them to
(.
13 what -you refer to as "the rest of the nation," " nationwide,
14
" highest in the nation'," and similarly in the next 15 paragraph you use the words " nationwide," " highest in the x
d 16 United States," throughout these two paragraphs you are A
.h I7 referring to the SEER data; is that correct?
5 18 f
A That's correct.
E I9 g
G And you recognize, don' t you, that the SEER n
20 data has to do with the areas which reported through the II SEER Program, rather than with the nation as a whole?
[
A I have some problem in the degree to which 23 I that distinction is useful.
There are ways in which it's 24 useful.and ways in which it's not.
t 25f G
Can you answer the question, though?
Is it I
i ALDERSON REPORTING COMPANY. INC.
1 2080 8-7 not true --
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A That's what I'm --
2 3
g Is it not true that the composite figures if )
which are represented in the SEER Report as an average for 4
e 5
the registries represents in fact the data from those N
8 6
registries rather than broader data from across the United e
Rg 7
Stales as a whole?
3 j
8 A
(No response.)
d d
9 G
If you don't understand the question, I can bg 10 help you.
I can make it a little more simple.
El 11 A
Let me see if I understand and if I don't 3
12 answer it, try again, en
(. j) 13 The data.from the SEER Report is not is 14 taken from tumor registries in various geographical areas, C
15 select geographic areas of the United States, and as such, g
16 do not represent what you might consider to be, say, a w
17 census or a house-by-house a.ccounting of cancer cases.
18 On the other hand, to suggest that this means E
19 g
that absolutely no inferences of national significance can n
20 be drawn from that data, I believe, would be a mistake and 21 would not be consistent with the goals of the SEER Program
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22 itself.
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BY MR. TURK:
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Is it your belief that while the data reflect 3
only the data collected from these 11 registries, you (O
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4 would go further and say that inferences can be 5
drawn from those data?
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Yes, I would believe so.
R d
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But the data themselves -- the comparisons s
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you're making here, only go to the 11 registries which dd 9
reported --
10 A
The comparisons which I make are inferences 11 drawn from the SEER Report, and they do not, in fact, repre- -
D y
12
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sent a house-by-house nose count of the nation's popula-
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13 tion in the sense of -- you know -- to say with absolute u
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15 population in the United States, one would have to go y
16 house-to-house and count noses.
A l
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18 from which reasonable inferences may be drawn.
E I9 3
G Doctor, what I'm trying to establish is n
20 that wherever you draw a comparison in these two para-21 graphs between data for New Orleans and data for the rest p
22 i
of the United States or nationwide, or the nation as a I
23 '
whole, you're really referring to the specific data tabulated in the SEER Report; is that not correct?
A Yes.
I'm drawing inferences based on data
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ALDERSON REPORTING COMPANY,INC.
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2084 c2 in the SEER Report?
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g Doctor, please.
I know that you'd like to p(e]
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explain your answer, but, first, let's see if we can get 3
yes's or no's.
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MR. JONES:
Your Honor, I'm going to object 5
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to that.
I think the witness is entitled to make a full 8
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7 and complete explanation where it is appropriate and rele-8 vant to the question.
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9 I would take exception to Mr. Turk's direction i
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yes and no answers.
D d
12 JUDGE WOLFE:
I thought in that circumstance 3
l 13 the witness did say yes, and then proceeded to explain, E
14 Mr. Turk.
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If so, I stand corrected.
I must j
16 have been distracted by the explanation and not heard W
G 17 i the answer.
18 JUDGE WOLFE:
But I would think that for an E
19 orderly procedure, if possible -- if the question is R
20 subject to a yes or no answer, say yes or no, or "maybe."
21 But, in any event, give us the simple answer.
1
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22 And then if you feel it necessary, why, you may explain l
23 your answer.
24 All right.
25 MR. JONES: Thank you.
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ALDERSON REPORTING COMPANY,INC.
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I 2085
-3 BY MR. TURK:
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G I don't want to belabor the point.
But is, 2
in fa t,
your answer, yes, that the data which you use 3
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here to compare to New Orleans is the data which was 4
tabulated from the 11 registries reporting through the SEER g
5 4
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Program?
o A
Is that the basis for my comparison?
7 G
Are those the data whichcare referred to 8
N here and upon which you rely?
9 i
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Yes.
E 5
11 You stated earlier today in your cross-
<D d
12 examination testimony that you believe that the data in the E
I 13 SEER Report are accurate; is that correct?
E 14 A
It's correct that I believe so.
I don't wb k
15 remember the previous question.
But it is correct that I J
16 believe so.
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17 4
Do you recall last week when we were speaking, 5
18 I showed you a letter --
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19 A
Yes, sir.
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from a person at the National Cancer 21!
Insitute to a person with the Charity Hospital, New c f 22 Orleans.
23 A
Yes, I remember that.
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24 G
And do you recall that in that letter, there y
25; was reference to " data inconsistencies"?
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Yes, sir.
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Do you know of your own knowledge whether
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the data on which you rely in these two paragraphs in 3
4 resp nse to Question 9 are subject to any data incon-()
sistencies?
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-5 A
Yes, sir, I do know.
8 6
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0 You do know?
8 A
Whether or not these data a:2 subject to in-d d
9 consistencies.
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10 G
And what would your response be then to E
11 whether or not they are subject to data inconsistencies?
d 12 A
My response would be that resulting from Ec 13 introduction of this letter into testimony last week,
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14 obviously not only for the sake of my own testimony, but 2
15 also for the sake of the considerable amount of research j
16 conducted in and on the state in which the SEER Report W
p 17 takes part, I made inquiries specifically of Ms. Jacqueline 18 Clarkson, who is at present the Director of the Tumor
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19 Registry of Louisiana, as to whether or not she had any g
n 20 knowledge or explanation for this letter of inquiry from 21 the NCI.
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SEER Report; that the years which remained in question Ig were 1978 and 1979, which tapes, incidentally, had recently 9
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9 i
The nature of the inconsistencies which con-10 oz!
11 cerned the' National Cancer Institute, according, you under-d d
12 stand, to Ms. Clarkson represented a concern that cancer Z
{[)d rates in Louisiana were being underestimated in the SEER 13 E
14 Report as a result of the failure of all of the data 15 tapes to be received by the National Cancer Institute.
3 16 As I said, it was Ms. Clarkson's opinion as A
g-j7 Director of the Tumor Registry at the present time, that i"
E 18 the data for the years included in the report on which my EN 19 testimony is based, had eventually all been received, re-8 i
n 20 viewed and accepted by the National Cancer Institute as 21 acceptable for its standards of publication.
pl 22 G
This person, Jacqueline Clarkson, she's the l
23,
current Director of the Tumor Registry; is that correct?
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24 A
Correct.
25 g
And do you know how long she has been i
I i
ALDERSON REPORTING COMPANY, INC.
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I Q
A.
Approximately four months.
G So that her statement to you, as you've repre-sented it, will be based in turn upon someone else's statements to her?
A.
Presuming, as I was, that she was a responsible t e
person, I would assume that she -- and, in fact, she told 7
3 me --
g 8
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Doctor, let's please try to answer the 9
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10 question.
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A.
Ukay.
Her statements to me were based on inquiries wh2.ch she made of the NCI regarding their 6
12 z
13 problems with the Tumor Registry of which.she is now d
Director.
E 14 U
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J 16 (Document handed to witness.)
a rA g-37 4
Doctor, I've now handed you a copy of the 18 letter to which we referred last week.
And I ask you to
=
note in the first paragraph whether or not the following j9 k
20 statement is found:
"The current contract will be extended 21 in time without funds through September 30, 1980, to allow 22 for resolution of data inconsistencies for cases diagnosed r
23,
January 1, 1974 through December 31, 1978."
24 Do you see that statement contained in the 25 letter?
ALDERSON REPORTING COMPANY, INC.
l 2089
',7 A'
Yes.
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G And do you see that the date of this letter is June 6, 1980?
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A Yes.
4
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4 Apart from Jacqueline Clarkson's representa-e 5
5 tion 8
6 to you of her conversation with some person at the e
7 National Cancer Institute, do you have any reason to quarrel with the statement in this letter that there were 8
8 n
N Jaca inconsistencies for cases diagnosed from January 1, 9
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10 1974 through December 31, 1978?
E g
MR. JONES:
Your Honor, if it please the jj d
12 Court 3
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THE WITNESS:
I don't understand the 13 5
m 14 question.
Ux 2
15 MR. JONES:
I want to make a motion to 16 object to this line of questioning as irrelevant and aW d
17 immaterial.
I would also move to strike any references 18 to questions or responses by the witness dealing with
=
19 the letter of June 6, 1980.
8n 20 My reason for making this motion at this 21 time is that the only thing that we have before us is a 22 vague representation of data inconsistencies.
l 23,
And I think if counsel inte'nds to conduct a l
24 line of questioning on that basis, that he should have a l
25l more substantial basis for questioning the validity of i
1 ALDERSON REPORTING COMPANY, INC.
I 2090
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the data.
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As the witness has stated, she spoke to the 2
urrent head of the Tumor Registry.
The current head of 3
the Tumor Registry had checked with the National Cancer 0.)
4 Institute and had been advised by the National Cancer g
5 R
Institute that the data which were published in the SEER 8
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8 acceptability.
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JUDGE WOLFE:
Mr. Turk.
gcb 2
MR. TURK:
I believe that there is a question 3
as to whether or not the testimony of the witness which O'
4 cites various statistics for cancer incidence ac.d/or 5
mortality, is reliable.
a U
6 The witness' relies upon the SEER Report.
I 7
have shown her a copy tf a letter, which I believe is sl 8
self-authenticating, pursuant to the Federal Rules of d
d 9
Evidence, as a document which bears the hallmarks of a 10 letter which, to my mind, is clearly authentic.
!!!l 11 In the event there's any need for further D
j 12 authenticatio,. we can provide that at a later date.
There
, h b 13 v 5 was no time to obtain certificates of authentication.
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14 JUDGE WOLFER Mr. Jones' objection, I think, 15 is directed.to the words in the letter, " data incon-a d
16 sistencies," isn't that correct?
I d
f II MR. JONES:
That's precisely the point, 18 Your Honor.
I am sure there's an original or file copy 19 og the letter somewhere -
20 JUDGE WOLFE:
That's not self-explanatory.
21 However, I'm not persuaded one way or the U
other at this point on this matter.
23 We have a witness relying on double hearsay, 24 so to speak, and we have a. letter which is not conclusive 25 on its face.
2092 10-2 i
Therefore, whatever weight I give to any of I
b) 2 this is liable to be quite small.
3 So I am going to overrule the objection.
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4 would think if the parties think this is important, they o
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this.
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But inasmuch as its weight one way or the s
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other, and I suggest that it will be quite small at this d
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point in my mind, I'm going to overrule the objection.
10 please answer.
E 11 THE WITNESS:
Would you repeat the question, D
y 12 please?
Q ) g@
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And I can assume what the u
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The question was, apart from your conversation w
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Jacquviline'Clarkson, do you have any reason -- strike that.
E 19 g
Do you have any basis for being certain that a
20 the data to which you refer 'in your response to Question 9 21
(
are not affected by so-called data inconsistencies?
22 A
(No response.)
I 23 '
g More simply stated, are you 100 percent 24 cartain that the data which you cite in your response to Question 9 are absolutely accurate?
ALDERSON REPORTING COMPANY, INC.
2003 10-3 i
A I don't know of any statement, except the fact C) 2 that I'm here in front of you to which I'd be willing to 3
attest within 100 percent absolute certainty.
A
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So your answer would be no?
o 5
A I think that's an impossible question to b
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answer, and I'm finding myself very hard put to give -- it's R
7 my impression one is supposed to answer honestly, and I j
8 find it hard to answer an honest yes or no to that do 9
question.
10 Perhaps there's some other phrasing.
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l 12 sense that data inconsistencies are rather like background I
13 radiation.
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l 14 and so it's hard to -- I'd be lying to you if I stated that U
15 any and all data don't contain inconsistencies.
d 16 G
What groups, other than the National Cancer w
h I7 Institute, to your knowledge, are concerned about and a
5 18 involved with the problem of cancer in the United' States?
E l9 g
A There are a variety of organizations concerned n
20 both with cancer as a whole and specific cancers as they 21 occur.
22 The American Cancer Society is one such widely 23 :
respected organization.
I 24 The -- and there are various research 5l institutes throughout the country.
I I
ALDERSON REPORTING COMPANY. INC.
l 2004
.10-4 j
G Have you ever seen the yearly publications I
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put out by the American Cancer Society which are entitled, j
3
" Cancer Facts and Figures"?
cm i) 4 A
Yes.
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4 I have in my hand my only copy of what is b
6 titled, "American Cancer Society, 1981, Cancer Facts and R
d 7
Figures," and I would now approach the witness and show X
8 8
her this pamphlet.
do 9
(Document handed to witness.)
icg 10 0
I would ask you, first, whether you have ever 5
g 11 seen this particular year's edition of the " Cancer Facts D
y 12 and Figures" pamphlet?
-L 13 A
Yes, I am familiar with this particular year.
! ' 14 4
Would you please turn to the third page --
15 excuse me, Page 4,
and could you read the paragraph which j
16 I have circled.
I d
17 Please read it into the microphone, please.
m 5
18 MR. JONES:
Your Honor, I'm going to object 19 g
to this line of questioning.
The document, I believe, n
20 speaks for itself, although it~might be subject to an 21 l
objection relative to its hearsay content.
22 If Counsel wants to read the statement for 23 the record and then proceed with his questioning, subject 24 to my verification of its contents, I would be willing to 1
25[
stipulate to the words.
i l
t ALDERSON REPORTING COMPANY, INC.
2005
- 10-5 i
I don't see what the purpose of this is.
2 MR. TURK:
The witness has represented that 3
there is a higher cancer incidence in morbidity and O
4 morta11tv, r he11 eve in touisiana, eased eeen infermation e
5 which she states is contained in the SEER Report.
6 There is to my mind some question of the 6
7 reliability of those comparisons, and I had asked the 2
j 8
witness whether she knows of other organizations involved dd 9
with the cancer problem.
10 She has identified the American Cancer Society 3l 11 and has stated it is a widely-respected organization.
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12 I now place in front of her a publication 13 from that organization and believe it's very relevant to l
14 know whether the American Cancer Society supports the n
15 witness' statement as to the cancer incidence rate in d
16 Louisiana.
w l
17
, JUDGE WOLFE:
Just what is your objection, 18 Mr. Jones, to the witness reading the wording of this E
19 report into the record?
20 Is that your objection?
You would rather 21 have Mr. Turk read it into the record?
22 MR. JONES:
That's correct, Your $onor.
If 23 Counse1 wants to read it and ask questions, that's fine.
i 24 MR. TURK:
I would be happy to do that to 25 f remove the objection.
ALDERSON REPORTING COMPANY. INC.
2096 10-6 1
JUDGE WOLFE:
Let's get on with it.
2 BY MR. TURK:
3 0
Doctor, I am going t'o read a statement from rn.
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4 this pamphlet and ask you whether or not I,
first of all, 5l am correctly restating what is contained here.
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6 "Beginning with the 1979 edition of ' Facts and j
R 7
Figures,' SEER incidence information has been used.
The K
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latest available information for this 1981 edition is d
9 from the years 1973 1977.
Each time a new database is
$g 10 introduced to estimate incidence there may be sharp changes E
II in figures due to the more accurate data."
3 y
12 Does that statement appear on Page 4 of the Ihb
'd5 13 1 1981 " Facts and Figures" pamphlet?
m l
14 A.
Yes.
}
15 MR. JONES:
Your Honor, I'm going to object x
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to any questions based on the statement read by Counsel l
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I7 l because I think he's taken one sentence out of context.
5 IO' If he would read the remaining sentence and l
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8 the next full paragraph as it appears, however, I would 20 withdraw the objection, but I think that it's important for 2I i
the Board to understand the complete context of the t
statement.
23,
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MR. TURK:
After I conclude my cross-1r/~)
examination, Mr. Jones is entitled to redirect.If he feels, bm /
2 f 11 wing my exami ation, there is some impropriety, he 3
i i
T~J3 may proceed to develop what further information he wishes w
4 to introduce.
5 E
JUDGE WOLFE:
I think since you are reading 6
o from the document, you had best read what Mr. Jones indi-7 8
cates should be read, so we can have a flow here of n
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9 i
h 10 Go ahead.
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p 11 u
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The sentence which follows the one which I z
,( )h 13 have read reads as follows:
"They do not indicate a vo E
g4 cancer epidemic or new cure."
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15 The next paragraph reads:
"Since comparisons 5
16 of figures from different data bases are not valid, one M
d 17 can compare the 1978 facts and figures only with the E
5 18 previous editions, and the 1979 facts and figures only 1
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19 with later editions."
8n 20 MR. JONES:
Thank you.
21 BY MR. TURK:
M 22 4
Doctor, I would now turn to page 10 of this i
23!
pamphlet, and ask you whether you see on this page a f
24 table which is entitled " Cancer Deaths 1981, Estimated 25 ;
Cancer Deaths for All Sites plus Major Sites by States l
ALDERSON REPORTING COMPANY, INC.
I 2008 1981."
g'l Is that the table which appears on this "j
2 Page?
3 53 A
Yes, ie is.
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And do you see there is a vertical listing of o
Mh6 different states and the District of Columbia and Puerto Rico.
And next to each of those different geographic 7
8 areas, there is a set of numbers.
Do you see that?
N A
Yes.
9 i
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Do you see under the column "All Sites" z
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sites --
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Do you see that under this column, " Death f
16 Rate per 100,000 Population," next to Louisiana the w
6 17 figure 184 appears?'
18 A
Correct.
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And do you see at the bottom of the page next 8n 20 to the line which reads
" United States," in that 21 same column, do you see that the figure 180 appears?
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22 A
Correct.
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g Are you aware of any information which would i
f 24 lead you to conclude that the American Cancer Society's 2f ;
estimate of 1981 deaths for Louisiana, as compared to the l
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nation, is inaccurate?
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A No.
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Doctor, I wou d now show you a pamphlet en-
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titled "American Cancer Society Cancer Facts and Figures 4
and ask,you whether you have seen this particular e
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g pamphlet previously.
a A
Yes, I have.
7 G
Do you see on page four of this pamphlet the 8
nj following statement Let me read it to you, if I 9
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16 The latest available information for this 1982 Edition is DW 17 from the years 1973 - 1978.
Each time a new data base x
18 is introduced to estimate incidence, there may be sharp 5
19 changes in figures due to the more accurate data.
They do l
20 not indicate a cancer epidemic or new cure.
Since com-t 21 parisons of figures from different data bases are not
[J) 22 valid, one can compare the 1978 Facts and Figures only 23,
with the previous editions, and the 1979 Facts and f
24 Figures only with later editions."
25l Is that a correct representation of what I
ALDERSON REPORTING COMPANY, INC.
I 2100 1-4 appears in this part of page four?
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A Yes, it is.
4 I
w ask you to look at page nine, and do you 3
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see a table on this page entitled " Cancer Deaths - 1982, 4
Estimated Cancer Deaths for All Sites plus Major Sites by o
5 A
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. State - 1982"?
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A Yes, I see that table.
7 8
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10 Facts and Figures pamphlet?
!E A
Yes.
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It sets out a vertical listing of t he states 3
13 and territories in the United States',- and next to those 3
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2 15 cancer estimated deaths?
.-,16 A
Yes.
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Do you see next to the column for --
Excuse 18 me.
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l 22 A
Yes, I do.
U 23 :
g And do you see at.the bottom of this page, 24 next to the entry for the United States, the figure 176 25[
appears?
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Yes, I see that.
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Do you have any information which would lead you to conclude that the American Cancer Society's esti-J mate of cancer deaths for Louisiana and the nation as a whole for 1982 is inaccurate?
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A N o ', I have no information to suggest that.
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MR. TURK:
I have no further questions.
SE 2
JUDGE WOLFE:
Redirect, Mr. Jones?
3 MR. JONES:
Thank you, Your Honor.
CT LJ 4
REDIRECT EXAMINATION e
5
' BY MR. JONES:
A" 6
4 Dr. Campbell, in the tables which have just R
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been displayed to you from the American Cancer Society a
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about which NRC Staff Counsel -- which NRC Staff Counsel d
9 has asked you to recognize, do there appear to be certain zog 10 distinctions with respect to the database used for reporting 11 Louisiana cancer death rate per hundred thousand population?
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12 A
I'm afraid I don't understand.
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Well, let me ask you this question.
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g 16 A
Thd tables which appear in the American w
h 37 Cancer Society's annual reports on cancer mortality refer x
18 to mortality on a statewide basis, and thi's has certain P"
19 8
limitations.
n 20 g
Would you tell us what those limitations are, 21 please?
(j 22 s
A Certainly.
'For instance, in the areas 23 l addressed in my testimony I was very careful to state that 24
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Louisiana, and this was one reason, because this is the ALDERSON REPORTING COMPANY,INC.
2103 12-2 1
I area of concern in this hearing.
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Waterford 3 is not going to be in Shreveport, 3
and presumably the population of northwestern Louisiana does
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Therefore, the most recent parish-by-parish b
3 6
data which I could find was contained in the SEER Report R
7 1973 to 1977.
A j
8 The limitations in interpreting data for a dd 9
state as a whole are that that data do not permit the 10 identification of local cancer incidences and local cancer E
11 rates on a parish-by-parish or city-by-city basis.
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14 of the state which have relatively low rates.
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What are the specific parishes which are d
16 included in the data for the New Orleans area as reported W
II in the. SEER Report?
II A
Because the SEER Report was based on the 19 g
Louisiana Tumor Registry and that was sited in New Orleans, O
the parishes in the New Orleans area, Metropolitan New l
21 Orleans, Jef fe rson, St. Bernard, Placquemaine, St. Charles, 1
22 St. John the Baptist, would be -- and I must. qualify here 23 l the most likely parishes to be involved.
l 24 The reason I qualify that is because I don't 25 '
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2104 12-3 1
of the cases reported to the tumor registry; but the logical n
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assumption, as pointed out by Mr. Turk, is that the data 3
would be heavily weighted in favor of the local geographic 4
area.
o 5
g Dr. Campbell, would you take a moment to refer k
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to Page 1 of the extract of the SEER Report.
R 7
A Yes.
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4 And in the lower right-hand side there appears d
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a chart designated " Participant," " Entry Year," and 5
10
" Reporting Area."
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11 A.
Yes.
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And would you advise for New Orleans, Louisiana,.
I 13 metropolitan area what appears as the reporting area?
14 A.
The reporting areas are. listed as Jefferson, 15 orleans and St. Bernard Parishes.
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Dr. Campbell, other than the data expressed A
h 17 in the. SEER Report, are you aware of any other database 18 which is drawn -- I'm sorry, strike that.
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the question.
n 20 Are you aware of any other reports dealing 21 with cancer incidence and mortality,otha.r than the SEER 22 Report, drawn from a statistical base, utilizing metropolitan 23 '
New Orleans as the source of its figures?
24 A.
I don't believe so.
In fact, the -- well, 25 l never mind.
i ALDERSON REPORTING COMPANY, INC.
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G Do you accept the statement contained in the J
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American Cancer Society's annual report that comparisons 3
based on figures with different databases cannot be
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5 A.
As a genoral statement, I would agree with j
6 that.
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2106 BY MR. JONES:
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Dr. Campbell, do you find that the br 2
data presented in the SEER Report dealing with elevated 3
cancer incidences and mortalities in metropolitan New 4
Orleans to accurately depict the present situation?
e 5
E A
In my pinion, they do.
3 6,
f7 G
bo the figures contained in the SEER Report in y ur view indicate a population which is at sub-8 n
9 stantially greater cancer risk than either the United i
h 10 States average or the average of all other units reporting 3
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in the SEER program?
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12 A
For some sites for some cancer sites, 3
Mb 13 yes.
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Is there anything significant in your view a
2 15 about the particular cancer sites which are of concern --
f 16 Strike that.
Let me rephrase the question.
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17 Is there anything significant, in your view, w
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R 20 A
I don't think I understand what you're 21 asking me.
There are many ways for things to be 22 significant, and I don't quite know which one you're 23 asking me for.
24 Well, let me ask this question, Dr. Campben.
25 ;
Do the elevated cancer rates for metropolitan i
ALDERSON REPORTING COMPANY. INC.
2107 3-2 New Orleans, as they appear before you in the SEER data, l
indicate to you a population which is at special risk or
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Yes, I think that statement could be made.
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And what w uld be the basis -
- Strike e
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that.
8 6l What would be the factual basis to support 7
3 that view, Dr. Campbell?
8 a
N A
The basis on which I support that view, which 9
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d 12 National Cancer Institute, as well as subsequent, more
}k 13 specific studies to which I also refer in my testimony.
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What is the basis for your assignment of W
2 15 evidentiary weight to the specific studies which you have 5
1 16 cited in your direct testimony?
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The basis for.my reference to these documents M
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n 20 would give -- of consideration that I would give to docu-21 ments in the preparation of recommendations to eitner.a 22 patient or group of patients.
23,
And that is, that the data, to the best 24 knowledge of the peer review and quality assurance pro-25,
cesses which make up the link between research and applied f
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ALDERSON REPORTING COMPANY. INC.
i 2108 science, have been satisfied and the data have been, there-
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medical and other applied science communities, to form the 3
basis 4
for our judgments and recommendations and assessment f various conditions in which we find ourselves, and 5
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about which we have to make these recommendations and 8
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13 consideration and that of my colleagues.
l 14 Therefore, I utilized them in my testimony.
2 15 g
What, Dr. Campbell, in your view are the f
16 principal causes of cancer risk to persons residing in the its
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17 metropolitan New Orleans area?
18 A.
As the body has already heard, there are a e
19 number of risk factors which go into an estimate of cancer g
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20 risk either for an individual or for a population.
Those 21 factors include lifestyle, factors of occupation and 22 environmental exposures, age, race, sex and ethnic origin.
23,
Q Do you find, Dr. Campbell, that there is 24 that environmental factors are a substantial contributing 25 cause to existing metropolitan New Orleans cancer rates?
ALDERSON REPORTING COMPANY, INC.
I 2100
'L3-4 MR. BLAKE:
Objection, unless' counsel can
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1 tie it to cross-examination.
I think it's outside the scope of any 3
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cross.
(Bench ~ conference. }
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MR. JONES:
Your Honor, my recollectioncof Sc.]
2 Mr. Blake's cross-examination this morning was that among 3
other things, he asked Dr. Campbell several questions
,--(,)
4 relating to her use in her study on health and environment, y
5 human health and environment in New Orleans, of the 9
6 several studies of Dr. Gottlieb and her colleagues, R
7 including the one specifically entitled, " Cancer and a
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Drinking Water in Louisiana, Colon and Rectum," and that d
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he further asked about her familiarity with several iog 10 other studies.
11 I think that this is a relevant response to D
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Why?
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14 MR. JONES:
I think it explains her basis a
15 for the use of those particular authorities.and I think j
16 it provides a summary of that view.
A h
II JUDGE WOLFE:
I'll sustain the objection.
I t
z IO no connection with the cross-examination.
see n
I9 MR. JONES:
I have no further questions, g
Ol Your Honor.
21 JUDGE WOLFE:
Anything further?
N MR. BLAKE:
I have one area on recross.
3l RECROSS-EXAMINATION BY MR. BLAKE:
l 25 i G
Dr. Campbell, in the course now of the i
ALDERSON REPORTING COMPANY, INC.
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2111 14-2 1
cross-examination and on redirect, you have distinguished g
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between statistical bases for a metropolitan area like 3
New Orleans, rather than statewide statistics, and as I pv 4
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statistics; is that correct?
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8 A.
For the purposes of this body, that does seem d
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to be the case.
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10 0,
Well, let me refer you to your testimony on II the seventh page, which is in that long Answer 9, the U
N 12 short paragraph ct the bottom of the page says, "The
/-Q h's 13 differences between Louisiana and the rest of the United -
14 States in such things as dietary patterns or cigarette a
15 smoking do not account.for such a largo difference in cancer l
d 16 risk."
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Is the basis for that statement statistical
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18 studies?
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No, sir.
The basis for that statement is 20l probably third order hearsay, to be really straight.
I 21 It's based on my hearing of a report which
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23 j
" Jobs, Cancer and the Air We Breathe," prepared by the Legislative Council for the State of Louisiana, in which 25 the statement was made that his survey of several -- of I
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considerations, do in fact account for very large g-4 proportions of not only New Orleans and Louisiana cancer e
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explain away apparent differences in the data.
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And your recollection was that he was talking 10 about the State of Louisiana generally?
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11 A
That's my recollection.
r bl 12 MR. B LAKE :
Thank you.
No more.
b fy 3 13 MR. TURK:
I have just one very brief line u
14 of inquiry and then I'll conclude.
15 RECROSS-EXAMINATION g
16 BY MR. TURK:
w 17 4
I ask you this because you agreed with E
18 Mr. Jones that comparisons between different databases n"
I9 g
cannot be made validly.
n 20 I will now show you again the 1981 and 1982 21 American Cancer Society pamphlets entitled, " Cancer Facts 22 and Figures."
23 l Maybe I,can do it without even referring to 24 a document.
25l Do you know whether the American Cancer I
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2113
&4-4 Society relied on the SEER Report data in putting out l
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A.
Yes.
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G They did rely on the SEER data?
g 5
A.
Yes.
a 6
MR. TURK:
I have nothing further.
R 7
JUDGE WOLFE:
Any re-redirect, Mr. Jones?
Aj 8
MR. JONES:
No, Your Honor.
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9 J.UDGE WOLFE:
Board questions.
Ng 10 BOARD EXAMINATION 5
j 11 BY JUDGE FOREMAN:
D 12 Am I correct, Dr. Campbell, in believing
)
13 that the -- in fact, I think you just said.this, that the 14 American Cancer Society information is based upon the g
15 SEER data?
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16 A.
Yes, sir.
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4 And the SEER data are data primarily from 16 the metropolitan New Orleans tumor registry?
E 19 A.
The information which refers to Louisiana 20 would be primarily from that source.
21 G
So tha't the data in the American Cancer D
22 j
Society are primarily the New Orleans metropolitan data 23 :
or overwhelmingly influenced by that data?
24 A
I d& ' t know if one could say overwhelmingly, but it's definitely influenced.
Overwhelmingly is an l
ALDERSON REPORTING COMPANY. INC.
2114 14-5 unusual word to use in that j
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2 Well, I'11 withdraw it.
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5 area?
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6 A
Yes, I believe so.
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4 Okay.
I'm going to read you a paragraph from a
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the SEER Report with the idea that you would comment on dd 9
this with respect to your drawing inferences from the i
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11 JUDGE WOLFE:
Do you have a copy of the D
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'h 13 THE WITNESS:
Yes.
14 BY JUDGE FOREMAN-2 15 G
Now, would you look on the first page, the j
16 portion of the report entitled, " Description of the us 6
17 l Program"?
18 A
Yes, sir.
E 19 g
Then look at the right-hand column, 20
" Participants."
21 A
Yes, sir.
22 G
Now I'm going to read you a description of 23 i the participants.
24
" Participants in the SEER Program were selected 25f on the basis of their ability to operate and maintain a l
l ALDERSON REPORTING COMPANY, INC.
I 2115 i
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unique population subgroups that each of them offer.
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participants were selected with forethought to subgroups
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within the defined vogu1ations which were egidemioloeice117 e
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of the United States population."
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Should I repeat my query of you, then?
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Please.
N 10 G
Would you comment on the basis of the informa-E j
11 tion, of drawing inferences f rom the SEER data f or the D
g 12 nation as a whole.
9 (Jg 13 A.
Yes, I believe I can offer comment on that.
a l
14 The use of the SEER data, not only by myself, n
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18 either a statewide or nationwide basis is done so with E
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20 laid out in ttus description of the participants.
21 Such inferences are not lightly drawn.
They 22 are drawn with the knowledge that all of us have that our 23 data is at best in all of the areas which we are addressing 24 here incomplete with respect to the degree that we would 1
25 like as professionals.
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this data, providing that the acknowledgement is made of 3
the special characteristics and limitations of the data.
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JUDGE FOREMAN:
Thank you.
That's all the e
5 questions I have.
5 3
6 BOARD EXAMINATION Rg 7
BY JUDGE JORDAN:
A 8
8 Inasmuch as the American Cancer Institute dd 9
data does seem to have been drawn largely from the SEER 10 data, what is the explanation for the fact that apparently E
j 11 the American Cancer Institute data for all sites does not D
j 12 show a large increase for Louisiana, whereas the SEER h'a,13 data did?
l 14 Do you have an explanation for that?
2 15 A
I can try.
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2117 5-1 THE WITNESS:
The answer to that question --
bm (7N r my attempt to answer it har a couple of pirts.
The 2
D SEER Report, per se, which is eferred to in my testimony 3
is a finite document, beginning and ending '73 through 7Nb 4
'77.
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e Secondly, the --
And although the NCI Pro-3 e
f7 ject continues, the local participation in that project, 8
as has been pointed out, ceased.
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With respect to the American Cancer Society's 9
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E 19 BY JUDGE JO RDAN :
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I see.
You feel that the American Cancer 21 Institute was trying to include the entire state, not 22 just New Orleans?
23 A
Yes, although they state that they base a lot l
24 of their estimates they base their estimates, at least 25 '
in part, on NCI.
I have no evidence that that's the only i
ALDERSON REPORTING COMPANY, INC.
2119 source of their information.
JUDGE WOLFE:
Cross on Board questions, Mr.
2 Blake?
3
['T MR. BLAKE:
None.
y) 4 JUDGE WOLFE:
Mr. Turk?
e 5
5 MR. TURK:
(No desponse.)
8 6
7 MR. JONES:
One' moment, please, Your Honor, if I could have about 30 seconds.
8 a
9 (Pause.)
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10 MR. JONES:
Your Honor, at this time we E
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12 JUDGE WOLFE:
Well, Mr. Turk, do you have 3
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E 14 MR. TURK:
I was checking the American Cancer w
2 15 Society documents to see if they might provide a response Y
j 16 to Judge Jordan's question.
I have not been able to find c
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4 18 JUDGE WOLFE:
Mr. Jones?
E 19 MR. JONES:
I'm sorry, Your Honor, f thought R
20 the ball was in my court all this time.
21 JUDGE WOLFE:
It is now.
22 MR. JONES:
We have no questions, and we 23,
would move the Board that the witness be excused permanentl:(.
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24 JUDGE WOLFE:
The witness is excused 25 permanently.
ALDERSON REPORTING COMPANY,INC.
3 2119
- 5-3 (The witness was excused.)
C3 JUDGE WOLFE:
Are there any other matters to be taken care of at this time, or discussed?
I would ask --
It's my understanding that 4
with regard to written direct tesimonies on emergency 5
h planning, that these written testimonies 4
6 I think that e
7 we have discussed in one or the other of our conference 8
calls -- are to be submitted on or by April 20th.
Is that right?
9 i
h 10 MR. BLAKE:
Yes.
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JUDGE WOLFE:
All right.
4 11 D
d 12 Are there any other matters to discuss?
z MR. BLAKE:
Only that I should note for (i{}
13 3
j4 the record that we have checked further at the site this w
2 15 morning to confirm with regard to this report on the 16 dropping of the main feedwater and still are unable to Ds g
17 confirm any substance to such a report.
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18 I do not think, Judge Wolfe, that you'll hear 19 anything more from me on the subject, in view of this R
l 20 confirmation, unless there is something to it.
And I I
21 would like the Beard's leave to take that position.
22 JUDGE WOLFE:
We will wait to hear then from 23 Staff with regard to this alleged incident at the 24 plant.
25l All right.
We will recess until May 3rd I
i ALDERSON REPORTING COMPANY. INC.
2120 at 9:00 a.m.
in this courtroom.
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2 We will then proceed with Applicant and Staff's rebuttal on Contention 8/9.
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4 We will then proceed with direct testimony e
5 and cross-examination on thecemergency planning issue, M
6 through May 14th.
7 Also, in that period if the Board denies j
8 Appli' cant's motion for reconsideration, we will therein a
dd 9
hear testimonies on the feed-and-bleed capability.
Direct i
h 10 written testimonies on the emergency planning issue, as E:
7 it well as on the feed-and-bleed capability -- if we deny D
d 12 Applicant's motion for reconsideration -- are to be 3
f 13 filed on or before April 20.
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E 14 MR. BLAKE:
Judge Wolfe, I hope that the Board t
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15 would allow counsel to consult with respect to the 5
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16 sequence in which we take up these matters rather than w
g 17 necessarily 8/9 first, to the extent we have witness E
18 availability problems, for example.
19 JUDGE WOLFE:
Certainly.
n 20 I was just pointing out the subject matters, f
21 not necessarily the schedule.
I would trust that counsel 22 would get together and timely advise me in writing what 23,
the scheduling will be.
24 All right.
We will then recess until 25 ;
May 3rd.
i ALDERSON REPORTING COMPANY, INC.
2121 (Whereupon, at 11:40 a.m.
the hearing was I
5-5
,/f; T adjourned, to reconvene on Monday, May 3, 1982, at 9:00 2
V a.
m.
in the same place.)
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ALDERSON REPORTING COMPANY, INC.
NUC 3AR REGULATORE COMMISSIC!r is is to certifT that the attached proceedings before t:he Atomic Safety and Licensing Board
.a the matter of:
Cate of Proceeding:
April 2, 1982 Docket Number:
50-382 oL DC& Cf Proceeding:
New Orleans, Louisiana were held. as hereim appears,. and that this, ir the original transcript thereof for the fi.La of the Commission Mary L.
Bagby Official Reporter (Typed)
. O_
' Official Reporter (Signature)
O
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