ML20004E794
| ML20004E794 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/03/1981 |
| From: | Cunningham J FOX, FARR & CUNNINGHAM, NEWBERRY TOWNSHIP TMI STEERING COMMITTEE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8106150268 | |
| Download: ML20004E794 (5) | |
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! UNITED STATES OF AME.::CA '
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NUCLEAR REGUL.L. TORY COMMISSION C
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD V l
In the matter of: :
- w METROPOLITAN EDISON COMPANY : Docket No. 50-2 r '> ' 4
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et al. : ,N.tOA
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TThree Mile Island Nuclear : Restart S' g {"
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5: JUN 121981
- NEWBERRY TOWNSHIP TMI STEERING COMMITTEE ' 4 " u.a. mcun nautecat d' PETITION TO RECONSIDER THE ADMISSIBILITY scuisscN .
OF THE TESTIMONY OF RAYMOND L. GOLDSTEEN, M AND NOW ccznes your Intervenor, Newberry Township . YIl 6t'e sng Committee, by and through its counsel Jordan D. Cunningh am ,
Esquire, and files this Petition to Reconsider and in support of this Petition, which seeks the admission of Mr. Goldsteen's testimony based on a longitudinal' study of the psychological effects of the Three Mile Accident conducted in Newberry Township, Pennsylvania, between October 1979 and November 1980, Intervenor files the following:
- 1. In the field of psychometrics it is well accepted that a pure test cannot be devised, that is, a test that has no items connection or bias. See Harper, " Local Independence in Test Psychometrical", Volume 37, March 1972. With respect to the objections raised by the Board that items dealing with (1) i perceived threat to physical health, (2) perceived threat to -
1 physical health of children and (3) demoralization contaminted l l
the trust items of the study:
i (A) All but one trust item preceded these other items in the questionnaires so that item contamination could not have !
occured to any significent degree within the study.
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(S) There is only T.oderate ccrrelatien between trust n
[ and demoralization, perceived threat to physical health, and i
lperceivedthreat-tophysicalhealthofchildren.
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! On the basis of this information it is suggested that item I
l contamination is not a plausible theory to explain high levels of I
mistrust evidenced in the study of Newberry Township, Pennsylvanic.
- 2. The criticism contained ir. the Order of the Board of May 1, 1981, concerning the validity of the demoralization scale is unfounded. ihe scale used in the study is a standardized mental health measure which has been tested for reliability and validity in many populations by experts in the field of mental health research and has been found to be acceptable.
The specific objection to the measure raised by the Board is that it creates demoralization where none might exist indicates a i
l thoroughly incorrect understanding of the way in which the test 1
t was scored and interpreted. Single items scored in the study j were not compared to a mid point above which demoralization is indicated and below which demoralization is not indicated.
Rather, all items of the study were scored and summed to obtain ai single demoralization score for each respondent which score is
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~ then compared to a score typical of the mental health patient population in that area. It is this comparison upon which l
conclusions regarding demoralization in a population are based.
See Dohrenwend, Shrant, Ecri, and Mendelsohn, " Measures of Non-Specific Psychological Distress and Other Dimensions of i Psychopathology in the General Population" . Archives on General Psychiatry 1980, Volume 37, pgs. 1229 and 1236. It should also be noted that the same demoralization measure was accepted P,
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P by the President Commission on the Accident at Three Mile Island as an indicator of psychological distress folle.ing the accident.
l: 3. The cricitism contained in the Order of the Board of Mav i 1, 1981, that the health items concerning cancer birth defects are biased is also unfounded in fact. The Order states that "there is a perception and there is a premise that getting cancer ;
i because of the accident exists and there is no opportunity in the j i
poll to address whether that premise is correct or not". The same point was emphasized and set forth concerning the genetic i
effect items contained within the study. To the , contrary, !
I however, these items do not assume a direct relationship between l i
the Three Mile Accident and such health effects as cancer and birth defects. Rather, they assume the commonly held and scientifically substantiated belief that there is a direct lin~k between over exposure to radiation and such health effects and they measure whether or not the respondents perceived the event I to have exposed him to levels of radiation sufficient to cause ;
such effect.
l l 4. In conclusion, the Board has not used a professional st~andard in evaluating the testimony ytesented and it is respect-fully submitted that the objections raised by the Board have no l merit by e ientific standards.
l WHEREFORE, it is respectfully requested that the Board re-evaluate its Order of May 1, 1981, and admit so evidence into l
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the Record of this proceeding, the rebuttal testimony cf Raymond
! L. Goldsteen, M.A. (Newberry Exhibit "1").
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- Respectfully submitted, ,
FOX, " RR & " NNINGHAM i
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frdan D./ nyingham
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:' :
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METROPOLITAN EDISON COMPANY, : Docket No. 50-259 et al. :
TThree Mile Island Nuclear : Restart Station, Unit No. 1) :
CERTIFICATE OF SERVICE i
I hereby certify that a copy of the foregoing Newberry ;
i Township TMI Steering Committee's Petition to Reconsider the l l I i Admissibility of the Testimony of Raymond L. Goldsteen, M.A. was mailed First Class, postage prepaid, this 3rd day of June, 1981, to the following:
Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Chief, Docketing Service Section Ivan W. Smith, Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission s, Washington, D. C. 20555 3 \' 'l s-i l
Dr. Walter H. Jordan jv7 37~.,. C ., y 881 West Outer Drive /, .
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,3 \ i Oakridge, Tenn. 37830 !, ;
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Dr. Linda W. Little q; .._
5000 Hermitage Drive . .; - 4[;7j
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ti-ti C George F. Trowbridge, Esq. ~~
SEAW, PITTMAN, POTTS & TROWBRIDGE 1800 ;1. Street, N.W.
Washington, D.C. 20036 James A. Tourtellotte Office of Executive Legal Director U. .S. Nuclear Regulatory Commission I W ni gton D. C. 555
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