ML19308A540

Deposition of Re Alexander (NRC) on 790813 in Bethesda,Md.Pp 1-70.Resume Encl

ML19308A540
Person / Time
Site:	Crane
Issue date:	08/13/1979
From:	Ryan Alexander, Pearson E NRC OFFICE OF STANDARDS DEVELOPMENT, PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE
To:
References
TASK-TF, TASK-TMR NUDOCS 7910310244
Download: ML19308A540 (73)

Text

{{#Wiki_filter:... \\ o o s-Transcript of Proceedings o o 0 0 g y UN1 FED STATES OF AMERICA o U O PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAlm g n 0 o o o DEPOSITION OF: ROBERT E. ALEXANDER 0 o o .o if ik il il il if il il O o d) it il 1) o o o Bethesda, Maryland o d August 13, 1979 0 l o o if o o o o Acme Reporting Company ODicial Reporter: 0 1411 K Sm N.W. O w n.nsan. a c. :::ces d GO2) 623-4888 4 9 o 7 010 310 2_.4 4-j ,/

r ge=2 1 UNITED STATES OF AI: ERICA 2 PRESIDENT'S C0f01ISSION CN THE ACCIDENT AT THREE MILE ISLAND 3 4 5 6 DEPOSITION OF: ROBERT E. ALE:G.NDER 7 8 9 10 Room 210 11 5650 Nicholson Lane Bethesda,.:'.arylhnd 12 August 13, 1979 13 2:17 o' clock p.m. 14 15 16 APPEARANCES: 1; On Behalf of the Commission: 18 ERIC PEARSON, ESQ. Associate Chief Counsel 19 2100 M Street, N.F. Washington, D.C. 20037 On Behalf of NRC: 21 PAT DIXCN, ESQ. l [ 22 Office of General Counsel 1717 H Street, M.U. 23 Washington, D.C. 24 L 25 l Acme Reporting Company m,. 4... _j

4 ph 2 1 TABLE OF CONTENTS 2 WIT'1ESS : DIRECT CROSS REDIRECT RECROSS 3 Robert E. Alexander 3 4 5 6 E, X_ ** _ B,I T,S, 7 EXHIBIT NO: MARKED FOR IDENTIFICATION: 8 1 9 2 10 3 32 11 4 44 12 13 14 15 16 17 IS 19 20 ~ l 21 22 l n 24 25 Acme Reporting Company

ph-1 3 1 _P_ _R.O _C.E_ '.E _D _I _N_ _G _S 2 .MR. PEARSON: Okay, on the record. Let's begin 3 . ith the. cath. w 4 Whereupon, 5 ROBERT E. ALEXANDER 6 having been first duly sworn was called as a witnessLin 7 this case and was examined and testified as follows: 8 DIRECT EXAMINATION 9 BY MR. PEARSON: to G Have you ever had a deposition taken before? 11 A Yes, I believe I have. 12 G Okay, I would just like to make you aware that 13 the testimony you give is of the same force and effect as 14 it would be if you were in a court of law. Consequently, 15 if any questions are unclear or in any way inccmplete, just 16 stop me and I'll explain or paraphrase or rephrase or what-17 ever is necessary. Is A Okay. 19 G Mow let's start with your name and your current 20 job title. 21 1 Robert E. Alexander, Chief, Occupational Health 22 i Standards Branch, Office of Standards Development, Nuclear 23 Regulatory Ccmmission. 24, G Could you tell us quickly what your educational 25 background is? i I I I i l Acme Reporting Company

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,s ,j'. .ph-2 4 1 A I have a Bachelor's Degree from Howard Payne 2 College in Texas, and I've done graduate work since then. 3 G And~what is your Bachelor's Degree in? 4 A Mathematics. 5 G And your graduate work? 6 A Mathematics and physics. 7 4 And where did you go to school for your graduate 8 work? Ti*ca s Cbra's Bae lln WtvNij 4 ~/ klL A 9 A ? ~ :r'l ray.: 00110;:. 10 0 Sr p12ce. When did you get your graduate degree? 11 A -Ia 19 54.- I hu r no jiody,ie dye 12 G And since 1954 have you taken any further courses 13 or educational training of some sort? 14 A Yes, I've taken some courses in mathematics and 15 physics. 16 0 Under the auspices of the NRC? 17 A No. 18 4 Who taught those courses and where were they? 19 A They were at Texas Christian University and UCLA. 20 4 Okay. Have you taken any courses since you've 21 been with NRC that they have sponsored? 22 A I've taken a few very short courses in management i 23 development type. Nothing longer than three days. 24 G Since your graduation from college could you just l 25 characterize for us quickly your employment history? i Acme Reporting Company j ,ll u.........

ph3 5 1 1 A Yes, I became employed in health physics work 2 immediately at Convair, Ft. Worth. I went from there to -- 3 I was an operational health physicist at Convair. I went 4 from there to Atomics, International, in 1958. 5 I was a consultant for the United Nations in Indo-nesia and Greece in 1961 and 1962, and then back to AtomicqsH 6 7 International until -- where I was Supervisor of the Safety 8 Program until 1968, when I came with NASA Headquarters. Gnien ~ ru fs / 9 I was Chief of the Ecricgical Health Branch there 10 until 1972, when I came with the AEC. 11 G When you came with the AEC in what capacity did 12 you ceme? What was your position at that point? 13 A I was a staff member of the Occupational Health 14 Standards Branch. 15 G And when did you assume your present position? 16 A I don' t remember the exact date, but it was in II 1974. 18 G Okay. I have a document here which you have just 19 given me, entitled, " Robert E. Alexander". bould you iden-l 3 tify the document for us, please? 21 A Yes, that's a brief resume of mine. It covers the 5 l same material I just spoke of. U G Okay, is this document accurate to the present i-24 time? l A Yes. Acme Reporting C o m p an'; i n a.. 4...

1 ph4 6 I MR. PEARSON: Okay, this will be Deposition Exhibit 2 Number 1. 1 (The items referred to were marked 3 f'or identification as ExhibiE 1 and, 4 Exhibit 2.) 5 BY MR. PEARSON: 6 0 Would you characteri=e for us, please, what your ~ present employment responsibilities are? 8 A Yes, my responsibilities are the supervision of 9 the Occupational Health Standards Branch, which, at the pre-10 sent time, has ten members total. 11 Our job is to ensure that workers in NRC-licensed activities [re adequately protected from the hazards of 12 13 nuclear radiation. To accomplish this purpose, we develop 14 regulati6ns, regulatory guides and topical reports. 15 S Okay, of the ten members of your staff ara. you 16 referring to ten professional members? 17 A No, one is a secretary; that includes a secretar". 18 G And the other nine, including yourself, arh prof-19 essionals? 20 A Yes. 21 4 Could you characterize'what the particular jobs 22 of the professionals are? U A They are all engaged in approxinately the same 24 type of activity. It begins with the identification of a 25 problem in radiological health protection, occupational l Acme Reporting Company l a w........

a h5 7 1 radiological health protection, the development of a workable s 2 and effective solution and then the coordination of this 3 solution with the other offices in NRC and the public and, Mittfd 4 finally, the issuance of the regulatior guide or nz: r;; 5 report. 6 G Well, do the people, the other professionals in 7 this branch, have other job titles? Or are they simply 8 assistants to yourself? 9 A No, we refer to them either as health physicists or 10 senior health physicists. 11 0 So all of them would be in that category? 12 A Yes. 13 0 Health physicists or senior health physicists. ~ I4 A Yes. 13 g Okay. Do you have any ml.nimal education or exper-16 ience requirements for the profettionals within your branch? 17 A No. Most of them either have a PhD or a Master's 18 degree, and since applicants for new positions normally have 19 either a Master's degree or a PhD, I think it might be 20 rare for us to employ someone less than that level these 21 days. ~ ~ 5 But as far as a minimum criterion is concerned for 23 the branch, none has been officially established. 24 4 Would it-be possible for you to provide us with 25 some statements of professional qualifications of the other Acme Reporting Company =c a,.n m...

-,' ph6 8 I professionals in your office? 2 A Most certainly. 3 Okay, fine. 4 A You mean now? Right now? 5 G No, not right now, but at some later time. 6 A , Y I-=... - C " "" k' 7 G Ok ay. Let's speak, if we can, for a moment, co n-carning the types of regulations that your branch works on a 9 or generates. How does your regulatory work correlate with s that of Mr. Parsont's branch? 10 Pr. 11 A MrT'Parsont's branch is a fairly new branch, and we haven't had a great deal of time to gain experience in the 12 inter-working relationships. X-- primarily, I think, w e 13 dependi+h-on his branch for epidemiological work, and work-

• 14 and radio-biology work.

15 So whenever a problen in those two areas arises, 16 we tend to turn to him. t; 18 G Mm-hmm. What kinds of regulations do you write? A The regulations we work'on are primarily 10 CFR 19 Part 19 and Part 20. These regulations pertain to the pro-20 tection of workers. Not altogether to protection of workers, 21 but most of the regulations that we have, the Commission z 33 has, that are intended to protect workers are found in those two regulations. 24 G Are there other places where the -- l g5 I l Acme Reporting Company

ph7 9 1 A Yes. 2 G Where would they be? 3 A Yes, in Part 34, regulations pertaining to radio-4 graphy safety appear. Also in Parts 30 and 40, 50 and 70, 5 regulations applicable to worker protection appear. And oc-6 casionally we do work on a rule change in one of the other 7 parts. 3 But primarily our' work is in Part 19 and Part 20. G Do you work on regulations that actually establish 9 permissible radiation levels -- to A Yes. 31 4 -- that workers are allowed to receive? 12 A Yes, thats our job. 13 ~ 4 So your office determines what those radiation 9 levels should be in the regulations? 15 A Well, in my branch we develop and then coordinate 16 with the other offices the level -- the radiation doce lim-17 its that should be recommended to the Commission for a final 18 determination. 19 C With which other offices do you coordinate these 20 recommendations? 3 l A We coordinate with the Nuclear Materials Safety and 22 Safeguards Office, the Nuclear Reactor Regulation Office, 23 l the Office of State P cgrams, the Office of Inspection and g Enforcement, the Office of Research and the Executive -- no, 3 Acme Reporting Company

ph8. l' ) i 1 that's E-L-3 -- 2 VOICE: 0-E-L-D. 3 THE WITNESS: Office of -- 4 VOICE: Executive Legal Director? 5 THE WITNESS: The Executive Legal Director. I 6 believe that's it. 7 BY MR. PEARSON: 8 G Okay. How would you go about considering a rule-9 making proposal or package? What steps would you take? to A Oh, there's a long answer to that question; I'll A. 11 be as brief as I can. What you're asking for is +he-descrip-12 tion or synopsis of the rule-making process. When a probism 13 in occupational health protection that can be solved or 14 helped with a rule change is brought to our attention, we 15 first prepare a value impact statement. 16 It's a preliminary value impact statement, in which 1-we scope the problem and attach to a task initiation forn 13 which is distributed to the other offices to get their con-19 currence that this is a problen that should be addressed in the Office of Standards Development. 3 21 Once the concurrence is' obtained, a' task : leader is 3 appointedf'and given full responsibility for carrying the 23 task through to completion, whether it be preparation of a 24 topical report or the issuance of a regulatory guide er an ej actual rule change. Acme Reporting Company

ph9 11 1 The task leader develops a solution, develops alter-2 native solutions, prepares the necessary documents, which 3 might be a Federal Register notice for a rule change or a 4 regulatory guide would be the guide itsel.#. or a report would 5 be the report itself, prepares the associated documents, the 6 final value impact statement. j 7 the case of a rule change, a Commission paper, 8 which is an executive summary for the Commission. The appro-9 priate letters to the carmittees, the four committees on 10 Capitol Hill. 11 A -- I can't remember exactly what we call it right 12 now, but what it is is a news release that's used by the 13 Office of Public Affairs to announce this item. And for the 14 effective or final publication, an analysis of the public 15 comments. 16 This is all pulled together in one package, and 17 the first time is published for ccmment. After the public 18 ccmments come in, the task leader analyzes those, prepares 19 an analysis which shows our reasons for either accepting or 20 rejecting each comment, and changes the guide or the proposed 21 rule in accordance with public~ comment, and then goes back l 22 to all of the offices here within the staff to negotiate l 23 their concurrence. 24 And then we go forward to the Commission for a 25 final vote as to whether or not the regulations shall become Acme Reporting Company

) ph10 12 i i I a law. l G Is that the first time it gets to the Commission? 2 3 A No, I'm sorry if I didn' t make that clear. Before the rule it's published in the Federal Register for comment, 4 5 changes do go to the Commission. The guides and reports do 6 not. They are issued over the authority of the office 7 8 director for Standards Development, Mr. Minogf The rule changes, however, do go to the Commission before they're 9 published in the Federal Register, unless they're of a minor-- 10 11 very minor. clarifying nature, in which case the E:cecutive 12 Director for operations has the authority to publish them. 13 When the Commission gets the rule-making reccamen-14 dations from the staff for the first time, what does it do? 15 A Well, that varies. If they agree with us fully they simply write the 2 ecutive. Director for Operations a 16 17 letter, memorandum, authorizing the publication in the Fed-18 eral Register. If they have questions that they want resolved 19 20 before their final vote or determination, a memo to that 21 effect will ccme, and we have to' develop an additional paper ~ 22 to resolve these questions. 3 or they may simply decline our recommendation. They may choose an alternative other than the alternative 24 25 we recommended, in which case we have to rewrite the Federal Acme Reporting Compony

phil 13 1 Register notice. 2 In one case I recall -- this wasn't the Nuclear Regulatory Comission -- but I think it's apropos to your 3 It was the Atomic Energy Commission, but the Nucleair 4 question. Regulatory Commission could do the same thing. 5 one rule change that was recomended to the Commis-s sion, the Commission contracted with some additional scientif-> 7 ic personnel outside the NRC staff, changed the regulation a based on recomendations from those scientists significant-9 ly, and then published it as an effective rule. 10 So there's quite a variety of things that can 11 happen once we make our recomendation to the Commission. 12 13 Q. Can the Commission, at that point, simply deter-mine tha't the staf f recommendation is wrong and indicate 14 there should be no more rule-making consideration for this 15 matter? 16 A. Yes. 17 And that would then constitute a denial of the IS 0 petition which may have started the rule-making proceedings 29 l [ in the first instance? l go A. Yes, if it was a petition. But that -- in that 21 case it would be a denial. Another possibility that has 22 23 happened to us that I didn't mention was simply to do 24 nothing. The Comission isn' t constrained to act. And I 25 Acme Reporting Company ~........

phl2 14 have one rule change that's been before them for about three I years that they've never acted on. 2 3 4 What rule change is that? That's the rule change on -- to protect the embryo 4 A or 4arthe fetus from radiation. 5 You have no word as to why they haven't acted on 6 4 7 that package? No, the memorandum that we have from the Commission 8 A simply states that the Commission has taken this rule change 9 10 under advisement, and we haven' t heard from them since. Is it the Commission's task, at that point, to 11 G determine whether to go forward or to determine whether the 12 regulation in the recommended form should be published in la the Federal Register? 14 Is that the two options the Commission has? 15 I don't believe I understand what you mean by A 16 "go forward". 17 4 Go forward into the Federal Register. gg Oh, to be published in the Federal Register; yes. A 19 I The Commission's determination is whether or not to authort co or to ise the publication of the rule. change for cccment, 21 authorize its publication in effective form. 4 Would the Commission, at that point, ever order 1 f 23 hearings? 24 25 Acme Reporting Company

ph13 15 What kind of hearings would they order, and under 1 4 what circumstances, if you can answer that? 2 I'm not the best one to ask that question to, be-3 A 4 cause in my experience, since 1972 here, in the Occupational We are Health Standards Branch, we've never held a hearing. 5 right now in the process of holding the first one that I 8 will have been directly involved in. 7 That is to be a joint hearing with EPA and OSHA 8 on the subject of the adequacy of occupational dose limits 9 that are now being used in this country. And the Commission-- 10 11 in this case, the Commission did direct us to arrange for this hearing. 12 13 4 Is this in response to the NRDC petition? o't

• Chat's how the whole thing arose,' was the staff's A

14 A response to the MRDC petition, which was submitted some time 15 16 ago to the NRC. 4 Normally, then, after the Commission would give 17 its okay to place a particular recommendation into the Fed-is eral Register, the remaining steps would be to secure the 19 public comments, to analyze them and then to announce in co the Federal Register the promulgated version of the regula-21 tions. 3 A Yes. 23 G Would the Commission get a second icok at the 24 regulation after the comments are in and analyzed? oJ5 l Acme Reporting Company t .au,.2 4...

\\ phl4 16 ) i 1 A We normally include in the first Commission paper-- 2 by "first Commission paper" I mean the paper which requests 3 authority to publish the proposed rule for comment. 4 We have a statement which says that if no substan-5 tive comments are received we will go ahead and publish the 6 rule in effective form without coming back to them. So at the time that that statement is present'J 7 in the staff paper, 8 at the time the Commission votes on a proposed rule, they 9 might very well be voting on an effective rule. 10 Sc they take it very seriously. And that state-11 ment, normally, is there. In my experience [ don't remem-12 ber any case where we ever failed to get substantive comment, 13 so we've always, in my experience, gone back to the Commis-14 sion with an effective rule, explaining to them how we 15 handled the public ccmments. 16 g Rule-making begins, I take it, either by a peti-17 tion from an outside party, or by seme initiative within 18 the NRC; is that accurate? l 19 A I think we've had reques ts for rule-making, I'm 20 sure we have, which did not constitute a petition. We've 21 had what might be called suggestions from people outside 1 5 the NRC that we have examined and have, at times, accepted t l 23 the suggestions and gone ahead then on our own initiative to t 1 24 start a task. 25 G To your experience, has your branch ever initiated Acnue Reporting Company

ph15 17 I rule-making proceedings without some suggestion or petition 2 from outside persons? ~ 3 A. Yes, most of them. 4 G How many, on an estimated number, have you initia-5 ted? How many rule-making proceedings? 6 A. Well, that would be difficult to say. I could go 7 back through our records, but we carry at all times on the 8 order of eight to 12 rule-making tasks. We finalize anywhere 9 from two to six per year, and I'd say t. hat certainly 75 per-10 cent of those are -- the idea for the trsk was initiated 11 within my branch. 12 O What kinds of factors prompt you to initiate a rule-13 macing package? 14 A. There are several. If we feel that an area of 15 occupational radiation protection needs strengthening in 16 some way. For example, health physics measurement accuracy 17 is scmething we're placing a great deal of emphasis on. 18 Making the occupational AIARA concept inspectable 19 and enforcible is something we're placing emphasis on. And 20 when we identify a problem of this nature, and as scon as ~ 21 cur schedule will permit, we do initiate a rule change to 22 effect.an improvement. 23 C Would it be fair to say that your in-house analysis 24 of the regalations in place are often the basis upon which I 25 new ule-making procedures are begun? Acme Reporting Company

I ph16 18 1 JL Well, I wouldn't put it exactly that way, because 2 it's an analysis of the existing rules in comparison with 3 health physics practices and the effects of the application 4 of these in the workplace combined, which lead us to the 5 initiation of a task. 6 0 Once you've decided to proceed with the particular 7 rule-making package, for example, with respect to a permis-8 sible radiation level, what kinds of factors do you consid-9 er in making the proposals you make or in reaching the de-10 cisions that you reach? 11 A Basically, we consider two types of risk, and then 12 other considerations spring from taase two basic ones. We 13 consider, first, the risk to the individual, and compare 14 that risk as best we understand it with risks that are ac-15 cepted in other, safer industries. 16 But we also -- the second, we also take a hard 17 look at a second type of risk, which is the risk to the 18 worker population. In other words, we look at both the 19 individual dose and the collective dose -j j 20 e collective dose being the total dose to an ? 21 entire worker population. JDur -- both considerations bear r heavily on the selection of a numerical dose limit. The 23 objective is to have the individual risk as low as we can 24 get it, without raising the collective risk. 15 Unfortunately, the only way to reduce the overall Acme Reporting Company

phl7 19 I risk, whether it be to the Individual or to the population, 2 is to reduce the radiation levels in the workplace, or to 3 reduce in some manner the amount of time that a person has 4 to be exposed to the.m levels, or a ccmbination of both. 5 That's the only way you can actually reduce the 6 amount of radiant energy absorbed by human tissue, and that 7 is the only way you can reduce the risk. 8 Now at a certain level that becomes extremely expen- - 9 sive, to the point where -- you can reach a point where it 10 becomes so expensive that it would appear imprudent to con-11 tinue the operation. 12 What we have tried to do in our analysis of the 13 dose limit question is to determine at what point the collec-tive dose" would be -- would rise considerably above what it 14 15 is now with the dose limits we're using. 16 And it's very difficult to determine, but from 17 data that we've received, primarily frem the industry, since 18 they are the only ones who have these answers, it would 19 appear that the -- though the individual dose limit could be 20 reduced to somewhere on the order of two and a half rems 21 per year, and below that then the collective dose starts 22 going up rather dramatically. 23 C. Mm-hmm. t 1 24 A. For example, three analyses we have from the indus-25 try of what would happen if the Cc= mission were to grant the l l Acme Reporting Company .,e,,

ph18 20 1 NRDC petition and reduce the present dose limit by a factor 2 of ten, one analysis indicates tha.t the collective dose at 3 that particular plant would go up by a factor of 4.5 or 4 450 percent. 5 Another one indicates a 90 percent, as I recall, 6 increase. And the third one indicates a 20 percent increase. 7 We don't know whether the 20 percent or the 90 percent or the 8 450 percent number is right. 9 But what we do know is that whatever the number is, 10 it would be very costly if these dose limits were reduced, 11 and if the result were an increased risk rather than a de-12 creased risk, then all of that expenditure would not only 13 be wasted, but it would be invested as it were in radiation-14 induced cancers. 15 We're not very anxious to do that. 16 0 Well, when you indicate that a particular regula-17 tory switch may be costly, what role do costs play in your 18 final decision-making? 19 ,1 At the present time, and I hope it continues that of 20 way, we are not using a dollars-per-man-rem criterijt in occu- / pational health protection,. ,The way our Appendix I to Part 21 22 50 does for reactor effluent controls, and-if you're familiar 23 with that one, the criterion is S1000 per man-rem, and if a 24 particular effluent clean-up system would result in a cost 25 of less than S1000 per man-rem, it is required. Acme Reporting Company ">L" *"a..

poh19 21 1 If the cost is more than $1000 per man ram, it's 0* 2 not required. J6r -- we do not use such a criterig in occu-3 pational health protection at the NRC for four what I consid-j 4 er to be very good reasons. ) 5 I hope we never do. I don't know'.whether you want 6 to get into -- 7 G Briefly. 8 A -- those or not. All right, I'll be as brief as 9 I can. First, to use the dollars-per-man-rem criterion, in-or 10 extricably associates your thinking ef the thinking of the j 11 NRC or the government,with the value of a human life. 12 For example, $1000 per man rem-means approximately 13 $10 c'111on to save a human life. A hundred dollars per 14 man-rem means $1 million; $50 per man-rem, S500,000. Most 15 of us would prefer to avoid associating dollars with the 16 prevention of fatal cancers. 17 The second problem has to do with hazard pay. We 18 think that once the government establishes an occupational 19 dollars-per-man-rem value associating so many dollars with a an./ - 20 one rem, that the labor unions will demand hazard pay appre-i o< r k, 21 ps'aLul. f 22 So many extra dollars for so many rems received. 23 When that happens, the worker tends to be less ccoperative i 4 about saving his dose, and mest -- many of them want the j 25 dose, in order to get the money. Acme Reporting Company

ph20 22 1 The second disadvantage here is that empicyers 2 tend to substitute pay for safety measures, when the pay is 3 cheaper than the safety measures. Okay, that's the second 4 reason. 5 Ghe'-- let's see, the third reason is that over the volun N +M/ 6 past 30 years or so employers have accepted that you can A 7 almost say that they do so historically new certain safety 8 features, which, if th:-i eccept th :0 voluntarily; and if 9 they were subjected to any reasonable dollars-per-man-rem criterion (and, incidentally, I think the criterion would be 10 somewherebetweenS50 ands 100perman-rem) 11 12 But even if it wcce $1000 per man ran, many.of thesesafetymeasurescouldn'tbejustified,(thatareal-13 wou// 14 ready being provided And so you have the federal govern-A Nt taking official action to reduce the degree of safety 15 16 provided in the workplace. 17 The fourth reason, which is the most important, is 18 that in making a determination on a dollars-per-man-rem d 19 basiqp as to whether or not to provide a safety feature, you 20 have to first calculate the cost. 21 Well that can be done in a fairly straightforward 22 manner that most people would accept. But then you have to 23 calculate the number of man-rens that will be saved in 1 l 24 order to get the ratio of dollars per man-rem. 05 0, Mm-hmm. Acme Reporting Company ,2u,.. 4...

ph21 23 y th 1 A And then some trial calculations we've done in 2 my branch, we've determined that you can very readily make 3 assumptions in the calculation of the number of man-rems 4 to be saved which can make that answer ccme out any way you 5 want it. 6 So even if we had a regulation like that, it woul'd 7 have virtually no effect on the licunsegs, because they 8 could make their analyses -- they could decide beforehand 9 whether or not they wanted to provide the safety measure,, 10 and then make their analysis come out that way. 11 We don't think that's any way to regulate an 12 industry. So we're against it. 13 G So you said the NRC is moving away from that con-14 cept? ~ i 15 A Well, I said the staff is. I can't really speak 16 for the NRC. I'm hoping that they won' t force that dcwn 17 our throats. 18 Would you like for me to explain what we are mov-19 ing toward? 3) G Yes. 21 A I don't want to leave a' vacuum here. 5 G That was the next question. 23 A That's the next question. Okay, we feel that the 24 occupational ALARA concept is the answer. We feel that what 25 the Cc= mission needs to do is to establish teeth in the i Acme Reporting Company l . w...u 4...

ph22 24 1 occupational ALAPA concept, to make the concept both inspect-es able and enforc[ble through regulation changes that we have 2 3 before them right now. [ ight 4 We feel that the criteria to be used 5 be described as the best state of the art criteria. That 6 is, fer e.c cfety = instead of lookihg at dollars we would 7 look at safety measures. 8 And these that have been successful -- already been 9 and are being successfully used by licensees, we would ac-10 cept that as crima facie evidence that they're cost-effect-Geo,, 11 ive, or else they wouldn't -- probably wouldn't be using 4t', 12 but we're not making them use them. 13 We only make them meet the dose limits, at< -- now 14 we're talking about maintaining levels lower than th; d::c-15 /the regulatory dose limits. 16 G ALARA only applies to making levels lower than 17 what -- 18 A,

yes, 19 0

-- are the established levels within the regula-20 tion? 21 A. Yes. 22 4 Okay. 23 A. So that we want to require in the regulations that 24 licensees develcp their own occupational ALARA programs, and i,, n,es t w r s 25 we want to incorpocate those programs into their license { so A Acme Reporting Company

ph23 25 1 they become like individualized regulations for that'partic-2 ular licensee, based on his situationy7 [/ndtousethiUcriteriainourevaluationof 3 a the 4 program best state of the art-technology in occupational 5 radiation protection. 6 G In this scheme, would you have minimum standards 7 for ALARA programs, for facilities? And if a plant didn't 8 move far enough in that direction it would not be licensed? 9 A Yes, we would do that through the regulatory guide 10 procedure. Now that doesn't mean that a license reviewer 11 would be close-minded. If we had listed a best state of the 12 art technique in our regulatory guide for a given type lic-13 ensee, and then he could come forward with an alternative 14 measure that he felt in his particular case was just as gcod 15 or bettar, then I'm certain our reviewers would accept it. 16 4 Did you take into account the financial solvency 17 or strength of the particular utility in determining what 18 would be an ALARA level for that utility? 19 A I really don't know; I have no basis for answering 2 that question. 21 G Let me ask you, back-tracking for a minute, you Z indicated that you are considering both the individual dose Il and the collective dose to the worker pcpulation. When an 24 individual dose limit is promulgated by the NRC, is the 25 NRC, by that act, stating that it believes that exposure of Acme Reporting Company

ph24 26 4 1 an individual to this amount of radiation will cause no 2 adverse health effects? 3 A No. 4 g Okay,what is the NRC. stating to the world when it 5 passes an individual dose limitation? 6 A I can't speak for the NRC, but I think I can answer 7 that question as a representative of the NRC staff, and in 8 answering that question I'll be telling you the sort of 9 words and ideas that we would be presenting to the Commis-10 sion in trying to influence their decision or help them with I their decision. 1 -th We accept as a poligt what is called / " linear,, 12 13 non-threshold dose effect curve", which states that there is 14 no cut-off point below which there is no hazard. Or, stated 15 another way, that there is some hazard all the way down to 16 zero dose, and that the probability of experiencing an ef-17 fact is reduced as the dose goes down, but the probability 18 doesn't become zero until the dose becomes zero. i 19 ? So, ideally, you would like to see a zero dose. I 20 A Yes, but of course that would detract from the 21 usefulness of nuclear materials and reactors. 22 G Right -- 23 A So what we try to do is select a point somewhere 24 on this curve which would -- which, if received year in and 3 year out by a worker, would create for that worker a risk l l Acme Reporting Company

27 ph25 I similar to the risk accepted in the saf er industries in the 2 United States, such as manufacturing. 3 Now this attempt suffers somewhat frcm the fact 4 that radiation-induced cancer and genetic effects are not 5 directly comparable with accidental death. For one thing, 6 in industry the accidental deaths occur to people much youn-h e ~G mip,1 exp,, r,.e - 7 ger than the radiation-induced cancers. 8 Because of the latent effect, it can be 20 years 9 or more for cancer to appear at the advanced stage, whereas to these accidental deaths tend to occur to youngar people, to 11 younger men. 12 So the number of years of life lost is much greater 13 in industry than it is for the radiation-induced cancers. That's no't true of other industrial diseases, but we simply 14 15 don't have the data for other industrial diseases on which 16 to make.our comparison. 17 So we're almost limited by circumstance to making 18 our comparison with accidental deaths, and that's what we 19 do, 20 G How ccmplete is the data on accidental deaths? 21 1 Those data are very complete. 22 G Is there -- can you quantify, as a number, the l 23 risk that enployees in the manufacturing industries have for 24 an accidental death, which is then the number to which the 25 radiation standards that you promulgate are comoared? Do vou l 1 l Acme Reporting Company . m. u......

4 ph26 28 1 follow my question't 2 A. Yes. I don't believe I can recall those numbers. 3 I have them at my desk. I do recall the number for mining 4 and quarrying, which is I believe the most dangerous, most 5 hazardous -- one of the most hazerdous. 6 There are some -- there are a few that are more t4 e so, but that is one of the most hazardous, and I recall data 8 indicate that about six people out of 100 who work at that 9 sort of thing will lose their lives on the job due to an 10 accident. 11 0 Six people out of 100. I would imagine on the 12 manufacturing side you get quite a bit of -- 13 A. I think it's almost a factor of ten lower than 14 that, but I'm sorry I can't remember the Itumbers. 15 G But I would think that on the manufacturing side 16 of the balance sheet you get quite a bit of.different con-17 flicting data as to the risks that different industrial ac-18 tivities prenant to workers. 19 Hos, do you take that data and combine it, for com-20 parison purposes? 21 A. Well, we don' t do it qtif.te that analytically. We will takegtablef such as those published oy the National 22 23 Safety Council, where they list by occupation the accidental 24 death rate. 25 They usually do that, I believe, per 100,000 people. Acme Reporting Company 1

ph27 29 1 0 Mm-hmm. 2 A Now for radiation, the risk factor is approximate-3 ly ten to the minus four, which means that 10,000 people -- mtf 4 if 10,000 people receive one rem each, that one df them der 5 likely to die of radiation-induced cancer. 6 So that's a f airly low risk. If you multiply that

. 6, 7

by five, get up to five rems per year, and then by 50, for A (2 9 ) 8 a 50-year life span, you get to a much larger nenber. It A 9 turns out that the number of re=s that a person can receive 10 under those conditions is 250 rems in a lifetime. 11 Most of us consider that to be too much radiation. 12 We wouldn't want to receive that much. We wouldn't want 13 anybody to receive that much. The amount of radiation that 14 people are actually receiving l'ifetime is about 1/10 of that. 15 So that the limits, where they're set right now, 16 seem to be working, creating a safe occupation, except for 17 a very few people. New what we're concerned about ir that 18 very few people, as more and more of these power plants come 19 on line, they start growing to a larger nenber of people. 20 And I think we're going to have to very carefully 21 watch that situation as time goes by. Right new, even at m the reactor power plants, the average dose per year is 23 only about 7/10 of a rem, so that the average worker is very 24 well protected, in ecmparison with other industries. i 25 There are a few people that are getting -- by Acme Reporting Company

n ph2g 30 1 "few" I mean several hundred, who *u= L _. 31.iw are getting i 2 much more than 7/10; it's closer to five rems per year. 3 And even a few that get more than that, under our 4 dose-averaging formula -- 5 g You mean this will just occur statistically? 6 A Yes.

1. 1 cnd ph 7

4 okay.

1. 2 ph 8

A. So I believe I've given you a fairly complete answer of our analysis of the dose limit question. Of course, d 9 to it's been the policy of the NRC and its predecessor, the 11 AEC, to comply with the guidance of the Federal Radiation 12 council, whose authority now resides with the EPA. 13 The EPA is currently reviewing occupational health 14 protection standards, and will issue new guidance in the 15 future. And I feel it's very safe to say that the NRC will 16 almost undoubtedly follow that guidance, when it is issued. 17 We contribute to their deliberations. 18 G In what way? 19 A. They have formed an Interagency Committee, Advisory 20 Committee, to work with them and advise them in the develop-21 ment of their guidance. I am the representative for the 22 NRC, and have been t,a ever since this review started sev-a/ nf 23 eral years ago* I've been to all the meetings. A 24 G Ckay. Then you have a goed sense of what they're l 25 coming out with and when they will ccme out with it? l f f Acme Reporting Company ?m aa aa

I ch29 31 1 A_ I have a yes to the first question; no to the 2 second. 3 4 Okay. What about the sense that you have with respect to what they're going to come out with? 4 5 A Well, would you like for me to review that very 6 briefly? 7 4 No, we can get that from another source. 8 A Okay. 9 G But I would just like it for general information. to Do you think the standards that they're going to come out 11 with are going to be roughly analogous to the ones in 12 place now by the URC, or will they constitute a major shift 13 from the present standards? 14 A ~ I think in the case of -- let me divide my answer 15 into two parts: one dealing with external radiation protec-16 tion and the other dealing with protection from airborne 17 radioactivity, which would be a source of internal exposure. Is In the case of external exposure, the guidance that they are leaning toward right now in the EPA would not 19 33 be a dramatic change in present practices. In the case of 21 internal dose protection, ar several radio-nuclides, th ir = guidance would result in standards for concentrations of radioactive material in air that are much lower than we z3 24 are presently using. 25 G Do you have any documents or memorandtt or criteria Acme Reporting Company

ph30 32 I that describe essentially what you've describ,ed for me thus 2 far with respect to hcw -- what factors are considered when 3 you are promulgating standards ? 4 A Yes, I believe almost every statement I've made 5 is referred to in the SECY 78-415. 6 0 Okay, would it be possible for us to get a copy 7 of that? 8 A Yes, I have it immediately. 9 MR. PEARSON: Okay, great, let's identify that as to Number 3 for the deposition, SECY 78-415. 11 (The item referred to was marked for 12 identification as Deposition Exhibit 13 3,) ~ 14 MR. DIXON: What was Number 27 15 MR. PEARSON: That was the statements of the pro-16 fessional qualifications of the persons within your branch, 17 in Mr. Alexander's branch. 18 THE WITNESS: Incidentally, did you want a general 19 statement or a statement for each individual? l l 00 MR. PEARSON: I'd like a statement for each indiv-21 idual, if possible. 22 THE WITNESS: Okay. l 23 BY MR. PEARSON: 24 4 You indicated before that you take both individual 25 and collective doses into account. Acme Reporting Compony i

ph31 33 I A Yes. 2 g Is that because you are not absolutely -- well, 3 let me see if I can phrase this right to see if I understand 4 it completely. As I understand it, you would believe that 3 the individual dose limits that vou promulgate represent a 6 reasonable occupational risk for employees of commercial I energy production facilities, nuclear reactors. 8 'But you realize that the greater nunber of people 9 that are exposed, even.to this reasonable risk, would result to in a greater number of cancers in the population.

And, 11 hence, for that reason, you also consider the collective 12 dose, the number of employees that would -be exposed, as part 13 of your decision-making.

~ 14 A I believe I may have led you astray just a little 15 bit, if I'm guessing correctly, based on what you just said. 16 You see, the main consideration for the collective dose is 17 as follows: the individual dose limits can be met by a lic-18 ensee without doing anything to reduce the risk, merely by 19 bringing in extra workers he can comply with the individual 20 dose limits. 21 I see. 22 A To the extent that 114'4 *: done, the risk isn't 23 reduced at all, and may ever. be increased as we discussed 24 before, by large factors. So the only way to limit the 25 risk is to limit the collective dose, and then, wi Eh the Acme Reporting Company m a,........

4 ph32 34 1 collective dose objective or limits, you can't meet those by 2 bringing in additional people. 3 The only way you can meet those is by reducing the 4 dose rates or reducing the working times or both, that is 5 reducing the risk. 6 4 All right, now, if -- would there be situations 7 when your collective dose rate would allow an increase in a the individual dose rate? 9 A No. 10 4 No. 11 A No, the individual dose rates are fixed, and not 12 subject to being raised. 13 4 So the collective dose rate is, as I understand it, 14 then, placed in the regulations in order to ensure that some 15 change is made to limit the amount of radiation you -- 16 A well.. 17 G --for people is limited. 18 1 There are no collective dose limits in the NRC 19 regulations. 00 4 Well, then, I'm confused. 21 A I said that we considered the collective dose in 22 establishing our recommendations for individual dose limits. 23 4 Okay. i ) 24 A And while there are individual dose limits in the l 25 regulations, no mention is made of.the collective dose Acme Reporting Company . m....... o

ph33 35 1 limit. 2 B So then how -- you've indicated the possibility 3 that a utility could simply run in more and more employees. 4 A Yes. 5 'G Is there anything in the regulations to prohibit 6 that? 7 A None, no. 8 g Do you consider that a shortcoming? 9 A Yes. 10 g Is there anything being done within the NRC to 11 change that particular regulatory posture? 12 1 Yes. We will submit very soon a recommendation to 13 the Commission on the concept of occupational ALARA, a rule e< change to make occupational ALARA inspect ~ ble and enforc/ble. 14 a 15 That's the rule change I mentioned to you, which 16 would require individual occupational AL RA programs. We 17 will issue, for each type of facility, if the Commission is g c along with us, a regulatory guide, which talks about 19 the appropriate content for these ALARA programs. 20 One of the things that will be recommended in 21 these guides is the establishment of collective dose objec-22 tives. 23 Now these collective dose -- now this is not a 24 particularly strong move en our part; this is our first 25 venture in the area of any sort of collective dose limits. Acme Reporting Company i

6 .ph34 36 1 We would simply be telling our licensees, "You should, as 2 an annual procedure, establish collective dose objectives 14w 3 in your plant and try to meet itr, and to the e' "ent that -t Ma 4 you don't meet it, our inspectors will be talking to you 5 abcat why, and what can be done to -- why you didn' t meet -{}sU this * .6 kt and what could be done to meet it next year." 7 But th;; dose objectives would not be in the 8 regulations 'and th:f -iculf not -- they also would not be / 9 in the license, so that a licensee who f ailed to meet his 10 objective could not be cited by the NRC. 11 G Oh, is there any move afoot to place collective 12 dose limitations within the regulations, or in some more 13 enforcible form? ~ 14 A Well, I have personally advocated that, but I 15 haven't been able to develop any appreciable support, ho, 16 other than just those efforts on my part, I can't say that 1; there is any general movement by the staff in that direction. 18 4 Okay. Let me just make sure I have one point 19 clear. When the existing individual dose rates that are .) contained in the regulations were considered, when other y 21 dose rates have been considered, have collective dose limi-r tations been part of that decision-making process? 23 Has that been -- 24 1 Do you mean when Part 20 was first written? 25 G Yes. i i Aa:me Reporting Company e=

ph35 37 1 1 My impression is that back in the fifties, when 2 those dose limits were first established, that much less 3 consideration was given to collective dose te that prob 4ena 4 and that the risk to the individual was the primary consid-5 eration at that time. 6 Later on, in more modern times, the dose -- the old 7 dose limits have been evaluated, in terms of their effect 8 on the collective dose. 9 G I see. And are the old limitations still in force, 10 however? 11 A They are -- it depends on how far back you go. m 12 They haven't been changed since I believe 1959. The, external 13 dose limits for the whole body are really three rems per 14 quarter. 15 New I'm talking now for the ICRP and the NCRP. 16 Their recommendations are three rems per quarter, with a 17 lifetime limit of five years for -- pardon me, five rems 13 for every year beyond the age of 18. 19 G Okay. But that's basically an individual dose; 3) you didn't take into account collective -- you said -- 21 A I think collective dose played very little -- had ZI very little to do with the establishment of these -- 23 G Mm-h=m. 24 A -- of those limits. 25 G How would one, if you can answer this in some way 1 Acme Reporting Company ) ,an........

ph36 38 1 that a layman could understand it, how would one reconsider 2 an individual dose level in terms of the collective dose 3 implications that it would have? 4 A I had reference to that a moment ago, and in my 5 opinion the way that should be done is that the individual 6 dose limit should be made as low as you can get it, without 7 increasing the collective dose. 8 4 And how does one make that determination? How do 9 you know when the cut-off point will be that the collective 10 dose would increase? 11 A Unfortunately, we're limited to data from our -th e ia Tw fwt 12 licensees. They are the only ones that have ir. We can't A 13 sit here and come up with those data. They are the only csfin He e 14 ones who can tell us when the dose would start going up and A 15 how much it would go up if we lowered the dose limits. 16 The information that they've provided for us so 17 far indicates to me that the collective dose wouldn' t star: 18 going up appreciably until the individual limit got below 19 two and a half rems per year. 20 But it goes up very f ast, very rapidly as you get 21 to smaller dose limits. S 4 Let's switch the subject for a minute. When you 3 are fashioning dose limitation regulations or other regu-24 1ations, what is your interrelationship with the Occupation-25 al Safety and Health Administration, if any? 1 Acme Reporting Company ,na, a..

ph37 39 -1 A We have some contact with them. They have, in 2 their regulations for the radioactive sources that they 3 regulate, tended to use Part 20, with very few modifications, l 4 in their r~;ulatic=. 5 And we make an attempt, whenever a major change to 6 Part 20 is coming along, to coordinate with them. And, in 7 addition to that, we participate with them on various commit-8 tees that affect radiation protection, such as the Advisory 9 Committee to the EPA. 10 4 Do you have any standard procedures for involving 11 other agencies in your rule-making process? 12 A We really don't, other than inviting them to com-13 ment at the same time the public is invited to comment. Un-14 les s, for a particular reason, there is a particularly impor-15 tant or sensitive area where we feel, on an ad_ hoc basis, 16 that special coordination is indicated. 17 G Okay. What kind of work has the NRC done over the is past, say, ten years with respect to studying the health 19 effects of ioni::ing radiation? 20 A I believe there are only two ways to do that. One 21 is epidemiological study of human experience, and the other 1r 22 is the radiation of animals. I believe that -- now, let's A 23 see, your question -- you want to go back ten years, which 24 is scmewhat past the beginning of the NRC. l 25 I don' t suppose you'd consider changing your Acme Reporting Company l

ph38 40 I question to include the NRC only, because if you want to 2 know about the AEC's work, I'm certainly not the best quali-3 fied to f: it. per>n 1kr asNr 4 And if you go back ten years you're going to be work 5 including about six years of AEC. 4 6 G Okay, let's go back to the beginning of the NRC. 7 A Okay. 8 4 See how you feel there. 9 (Laughter) 10 A That I'm much more comfortable with. We haven't 11 funded any epidemiological work, as yet, although probably 12 from talking to Dr. Parsont you found out that we are begin-13 ning to get into that. 14 As far as animal studies are concernedr-the ;r.ly 15 -- there may be animal studies that I don' t know about, but 16 the only two animal studies that I know of that our Research 17 Office has funded are one study to investigate the effects 18 of what are referred to as " hot particles". 19 These are very, very tiny particles that are in-20 tensely radioactive that can be deposited in the lungs, and 21 the effects are not as well understood as for other types i I 22 of radiation. 23 We have funded a study of hot particle effects at l l l 24 the Loveless Foundation. 1 l 25 4 Is that study new complete? Acme Reporting Company

[ .ph39 41 1 A No, it's still in progress. 2 G And when was it funded, roughly? What year or 3 month, if you know? 4 A. I '.,elieve -- I 'culd -- I'm not sure, I.hink 5 around 1975 was when the work started. The only other one 6 involving radiation of animals that I know of is one being ~ done for me at the University of Rochester, to study the 8 effects of uranium principally en the bone and kidney, due 9 to exposu:' to t02 T2. (A 0 / 2 10 G And what is that? 11 A Well, when uranium hexafluoride, which is a ga.%. l 12 gaseous form of uranium used in the enrichment process, when 13 it becomes airborne it hydrolizes almost immediately to a . came..f 4 of ' 14 chemical feemelv referred to as CO2 F2, it is a highly sol-15 uble form of uranium. ok 16 And its behavior, metabolism in the body isn't i i I 1-as well understood as other compounds. +.nd I've been un-18 comfortable with that, because we have a regulatory guide l 19 on bioassay for uranium in which we had to simply state that 20 this guide does not include consideration of UO2-F2. M# #- t t \\ = 21 so we instigated these animal studies to try to get l 22 seme answers, so that when we revise that guide we can give reccmmendations for bicassay for UC2-22. 62 O F. 23 z t l 24 G Do you see a need -- 25 A. That's bicassay,3-Ii-0-A-S-S-A-Y, that 's one word. Acme Reporting Company

(' ph40 42 1 G Do you see a need for further investigation by 2 the NRC with respcct to the health effects of ionizing 3 radiation? 4 A Yes, I think that there ar: -- that other questions will arise in addition to the one I just described for ##,6, 5 6 -UC-;,Z}, questions that, unfortunately, I can' t sit here and 7 predict right now. 8 And I also believe that a certain amount of epi-9 demiology should be done. I am very skeptical that any 10 definitive results will be available to us for the very low 11 doses that apparently many people insist be investigated in 12 these epidemiological studies, because even at th 2c5; l 13 p:::imistler using the most pessimistic risk factors the 14 incidence of radiation-induced cancer is so near or so small i 15 compared with the incidence due to other causes that I don't ) 16 think they'll be able to see any difference, even if it's 17 there. 18 I would think that the epidemiological studiec 19 should be restricted to people who are getting very signifi-20 cant occupational radiation exposures, exposures near the 21 dose limits. 22 I think if they were followed very carefully, and 3 if the risk factors we're using are not sufficiently conser-24 vative, that would be discovered. 25 4 So is it your view that studying the much lower Acme Reporting Company

ph41 43 1 exposure levels is not a worthwhile task, because you prob-2 ably wouldn't have reliable study results anyway; is that 3 what you're saying? 4 A That's what I'm saying. I'm not at expert in that 5 area,. so I doubt if my testimony there would account for 6 much in most people's minds. 7 G No, but your impressions are certainly much more 8 knowledgeable than ours. Okay. 9 1 What I'm saying is that if the results from the to studies of people who receive these very low levels of 11 radiation, if certain statisticians ccm: en in and say, "We en u 12 don't see any", I think they usur_11y refer to them as "entr-a erurs 13 cancers","the number of entra cancers is not statistically ~ 14 significant", I don' t think that a statement like that from 15 those epidemiologists will satisfy anybody's curiosity as to 16 whether or not those low levels cause cancer. 17 G Mm-hmm. 18 A And we'll be essentially at that time where we are 19 right now, wondering whether those low levels cause cancer 3) or not. Do you foresee any time in the future when studies-! 21 G 5 A No. 3 G -- could be at all effective? l 24 A No. l M 4 In addition to working with regulations that Acme Reporting Company .ua,........ I

~ ph42 44 1 establish dose limitations, what other kinds of regulations 2 do you work with? 3 -A Well, the dose limitations are a -- the limitation 4 work is really a small part of the -- what should I do? 5 Give you some examples of regulations and some examples of 6 the regulatory guides? 7 4 Well, let me just see if -- ll> & 8 A ~ could give you a littic collection of it-ms 9 that we have been working on and are working on for inclu-10 sion in your record. 11 O Okay, let's do that; that would be helpful. 12 A Okay, I have that available in my desk right now. 13 MR. PEARSON: Okay, we will make that Identified 14 Exhibit Number 4, how shall I describe it? A synopsis of 15 types of regulations with which you are now concerned. 16 THE WITNESS: Types of work. 17 MR. PEARSON: Types of work? 18 THE WITNESS: Yes, that's what you asked me. l 19 You said other than --we have guides and the topical reports 20 that we're working on. 21 MR. PEARSON: Okay. 22 (The item referred to was Tr '.ed for 23 identification as Depositica Exhi-24 bit 4.) 25 i Acme Reporting Company .aoa,.2......

ph43 45 i I BY MR. PEARSON: 2 G Let me see if I have this clear in my own mind. 3 You would work On, for example, scme regulations that would 4 establish radiation limits or doses that would be permissible 5 and would you also, then, put in place regulations with 6 respect to the operation of a commercial reactor or a ccm-7 mercial energy-generating facility to assure that those dose. 8 limitations would not be exceeded? 9 Would you work on regulations of that sort? 10 A Probably not. Historically, the way we have worked 11 is to establish, in Part 20, the basic standards for radia-12 tion 5 otection, and then to establish in the other parts, 13 such as Part 50 for reactors, any requirements of a systems or facil5.ty nature that are necessary to comply with Part 20. 14 }w + A < /A der 15 Normally, my branch does not get invcived. A 16 G In the Part 50? 17 A In the Part 50 type work. 18 G Which branch gets involved with that? 19 1 Well, that involves, as I understand it, several 20 different branches. We have, in our own office here, three I al branches that are engineering-type branches that I believe 22 get involved in setting that sort of standard. 23 And then ie the reactor licensing office, NRR, 24 eey-get; involved very deeply in the review of the various Lvhen 25 systems,and tcre the licensee comes forward and says, "We Acme Reporting Company .aen .a..a...

46 ph44 th ' Wlg,,,, s m,4 -Urn Tr& tvit le 1 want,d/ to comply with : cycter. Lhet dcc this", those people A 2 have to review it and decide whether or not they can believe 3 the licensee. 4 G Oh, I see. But even in Part 20, for example, 5 there will be some regulations with regard to placing 6 warning signs and -- 7 A Yes. 8 G -- restricting areas of that sort. 9 A

Yes, to G

Would you be involved in those regulations? 11 A Ch, yes. 12 G How would you make a determination of that sort 13 with respect to restricting areas; is there any criteria 14 that you follow? Or is it more a common sense judgment? e/ 15 A No, the restricth,wea is very carefully defined 16 in Part 20. That is the area inside of which the licensed = 17 activity is to take place. And-17e have it very carefully 18 defined, and we have a graduated scale of requirements that 19 must be set by the licensee inside that restricted area, 20 depending on 'the degree of hazard. 4 21 If there's very little hazard, fraining may be the f l 22 only requirement, for example, a small amount of graining. i 23 The / raining is to be commensurate with the hazard. 24 4 Mm-hmm. 25 A If there's a little more hazard we require posting Acme Reporting Company

2e2,

.2......

~ .ph45 47 1 of radiation areas inside the restricted area. If the haz-i ard is a little greater we require the use of a dos 4 meter to 2 3 measure the dose. Then adding on routine surveys, using radiation-4 5 detection equipment, air sampling, bicassays, alarm systems, 6 on and on and on, depending on how much hazard is present inside the restricted area. ~ 8 G And this decision would be made on a case-by-case 9 basis for each f acility? apii,..e > 10 A Yes, ther are required to describe what they're going to do and how they're going to comply with what we 11 12 call our performance requirements in Part 20; how they're 13 going to do that. ~ 14 And we do issue regulatory guides to tell them one way of complying. If they'll do it this way they're 15 16 quaranteed acceptance. But they don't have to do it exactly 1~ that way; they can describe another way -- 13 I see. 19 A -- which we will review. 20 4 The restricted area, you said, is the area in 21 which the licensed activity takes place. 5 A Yes. Z3 4 Would that generally be the area of the site over 24 which the utility has control? 25 A Yes. Acme Reporting Company

ph46 48 1 4 Would the unrestricted area,- then, generally be 2 the area in the vicinity of the plant which would be occu-3 pled, perhaps, by the public? C/s c 4 A Yes. The unrestricted area is, for example, that %~~ 5 fence around the plant, the unrestricted area is all the / 6 area outside o th44rr-Senee; the restricted area is every-7 thing inside the fence. 8 4 Okay, now in Part 20 there are different dose 9 limitations for exposures within the restricted area than 10 for exposures within the unrestricted area. What's the 11 rationale for having different exposures in those two areas? 12 A The principal rationale is degree of control. 13 Within a restricted area, we specify what's to be therein, 14 how things are to be done, how things are to be controlled. 15 And we feel that the levels that have been recommended as 16 being comparable with other -- we've gone over this -- with 17 other industrial risks can be allowed, with that degree of 18 control. 19 Outside the restricted area we have no real con-m trol. The only thing we can do is to limit the effluents 21 that are released, and the radiation levels at the boundary 22 of the restricted area. 23 The second reason is that -- 24 4 Let me stop you for a second. You're saying that 25 it's the state of the art, then, that inside you control up Acme Reporting Company

i ph47 49 I to the level that you possibly can, and outside you can con-2 trol it more so, so the limitations would be'less; is that 3 accurate? 4 A No, that's not what I meant to convey. I meant 5 to convey that it': - we think it's safe to allow the high-6 er limits on the inside, because we can prescribe the safety 7 measures that are to be taken to make sure it doesn't go 8 even higher. 9 0 okay. 10 A Whereas outside the plant, in people's homes and 11 so forth, we can't prescribe any safety measures. We don't i 12 even require them to wear dospmeters or anything like that. 13 The control isn't there. 14 So to compensate for that lack of control we im-15 pose safety measures on the licensee, so that he cannot is create outside that fence the same dose levels that he can 17 create inside the fence, where he does have the control that 18 we've prescribed. 19 4 Okay, you confused me at the very end there. It's 20 like a safety factor. There's less control in the unres-l 21 tricted area -- l 22 A Then you have the safety factor -- 23 4 -- then you'd lower it. And so even if there were 24 scme mistakes made, the levels of exposure in the unrestric-25 ted area would not exceed the occupational restricted area Acme Reporting Company

50 'ph48 1 levels; is that a fair characterization of what you're say-ing? 3 A I'm not sure I followed you. 4 0 Okay, let me try again. 5 g yem not sure what it -- 6 4 Okay. The unrestricted area has a lower dose lim-7 itation because you don' t have any control over that area; 8 correct? 9 A 'Much less co..;ol. 10 G So 2 cu can' t measure what the exact day-to-day 11 exposure to that area will be. 12 A Yes. 13 0 But it would be your thinking that by setting the 14 level low, that even if there were some exposures in excess 15 of the low unrestricted level, that exposure would not reach 16 any unsafe degree. 17 Is that -- I'm trying to characterize what you 18 are saying. Is that not right? 19 A I suppose that's about right. 20 4 Is it wrong in any way? 21 A Well, I'm not sure. 3 (Laughter) 23 Let me follcw up on that a little bit more. The l l 24 second reason for restricting the degree of ha ard in 4h 25 unrestricted areas more is that it's populated with very Acme Reporting Company 2n,........

ch49 51 I young people and very sick people. 2 And still a third reason is that the exposures 3 inside the plant are accepted voluntarily, whereas in the 4 public they're involuntary. 5 G Okay, I'd like to address the question of voluntary G exposures. Does the NRC have a policy concerning voluntary 7 exposures at all? 8 A You mean exposures above the limits? For example, 9 in an emergency? 10 G Yes. 11 A No. We've never established anything like that. 12 4 Does the NRC have any prchibitions that it imposes 13 upon operators of utilities with respect to even voluntary 14 exposure $1? 15 A Yes. 16 G What are they? = 17 A iiall, Giu --- we have our dose limits in Part 20, is and even if a worker volunteers to accept a larger exposure 19 for some reason, it would still be a violation of the regu-20 lations. 21 4 Okay, that's a flat, across-the-board rule without 22 exception? 23 A YeS-l I 24 4 And that would apply even during the time of an 25 emergency? I Acme Reporting Company .. =,........ i

'l ph50 52 1 A Yes. 2 G Okay. Do the regulations require notice to per-3 sons working in a utility as to what dose they would receive 4 or could expect to receive at a particular job or on a par- ~ 5 ticular day? 6 A Well not on a particular job or during a particular 7 day, but we do require M '6e - a couple of things. We a require for any exposure report that is submitted to us that 9 a copy be given to the involved workers. 10 So that would include any sort of an over-exposure. 11 G m-hmm. a m,t at 12 A And we require that if a worker requests his dose, a 13 that the licensee give it to him. 14 G If the worker requests it, that the licensee give 10 it to him? 16 A Yes. 17 G Why is that? I'm unclear on that point. i is A Well, we don' t require that the licensee autcmat-19 ically notify the worker of his dosa, but if the worker a n p.- t-29 requests -i-6, he gets it. 21 G Oh, okay, right. I misunderstood what you said. l 22 [ What requirements do you have of utilities with respect to 23 keeping track of the amount of dose that workers have? 24 A We require that th<ay measure the dose, if it's 25, expected that the dose wi11 exceed 25 percent of our dose Acme Reporting Company

ph51 53 1 limit. 2 G For a particular day, you mean, or -- 3 L No, for a quarter,for a calendar quarter. For 4 any dose, then, that is measured, using a personal dosimeter, 5 well, or a survey instrument, for that matter, in whatever 6 way it's measured, we require that the records of that expos-7 ure be maintained on a form that we prescribe, although we 8 allow them to use their own form as long as exactly the same 9 information is present. 10 G Mm-hmm. 11 A And those records.have to be kept until the commis-12 sion authorizes their disposal. 13 0 Do you have any particular measurement techniques 14 that must be followed? 15 A No. No, the way the regulations are written now, 16 some examples of types of dosimeters are mentioned, but not 17 prescribed. Now we do have one program going right now to 18 improve the dose-measuring situation. 19 We have some evidence that some dosimetry processors 20 do not perform with an acceptable degree of accuracy, and 21 we right now have a program going to correct that problem. 22 G Is the type of monitoring of doses that you re-23 quire, monitoring of whola-body doses, as compared to i 24 internal doses? i 25 A Well, that's right. We require whole-body dose Acme Reporting Company

}, '

• ph52 54

/as< 6 M <- 1 -measurements, and measurements of the extremities in the 4 / 2 regulations. As far as internal dose is concerned; from 3 radioactive materials that arei taken into the body, we go 4 about that in two ways. 5 The primary way is limiting the concentration of 6 radioactive material in air. We have a table of values in 7 Part 20, and require that the concentrations to which the 8 workers are exposed be maintained below those concentra-9 tions. 10 And we require an over-exposure report at any time 11 they are exceeded. But we also, in addition to that, on a 12 highly-individualized basis, require bicassays. A bicas: y, khattermisusedtorefertothemeasurementofradioac-13 \\ 14 tive material in excreta, or the direct measurement of 15 radioactive material in the body by using a detector placed 16 over the body. l 17 G M.m-hmm. i 18 A Those requirements are placed in individual licen-19 ses,' rathcr the t: jing we haven't been able to make up 20 sufficiently generalized language for the regulations. It 21 virtually has to be done on an inm 'idual basis. 22 We have issued several regulatory guides on the 23 subject of bicassay, and we have others in progress. 24 G When you are talking about fashioning individual 25 license conditions -- 1 i Acme Reporting Company

.ph53 55 1 A Yes. 2 0 -- would you place in an individual license a 3 condition, for example, that would indicate that there has 4 to be a certain number of first-aid kits placed at certain 5 locations? 6 Would that be part of the regulatory process in 7 implementing 10 CFR 207 p,, t e f r> y 8 A No, 10 CFR 20 is restricted to radiation -dese con-9 siderations. 10 0 Right. So this would be 10 CFR 50, I assume. 11 A Well, I don' t think that that :culd b something like that wouldf(d be in the NRC regulations at 12 13 all, since the Commission's responsibility is restricted to 14 radiation protection. 15 The type of device you're talking about there-would 16 be more likely to be found in OSEA regulations. 17 G Okay, and OSHA regulations would apply to the is working place? 19 A Yes. 3) G So am I correct, then, in thinking that the NRC 21 would have no regulations in place for respirators, for t2 example? rQu/4h 23 A Respirators we do, because rcdicacti /c

tcrialc-A 24 4'

' ' r -' - b - .you can protect a worker, using a respir-25 ator, from radioactive materials in air, and so we do Acme Reporting Company ,a w.......

~ ] ph54 56 I regulate the use of respirators very closely. o G What are your regulations there? 3 A Rather extensive. We have a paragraph in 20.103, 4 that tells the licensees that they must, if they are going 5 to take any credit for the use of a respirator fr 6 G Mm-hmm. [ [ note that distinction, if they want to use I A 8 a respirator but take no credit for it, in other words to 9 go ahead and report it to us as an over-exposure if somebody to is exposed to a greater concentration than in Appendix B of 11 Part 20, that's fine, they can go ahead and use the respir-12 ators all they want to. I3 Out if Mey =re going te t:%: crcj credit fer thcr. 14 for protection of the person, then they have to establish 15 L c respirator prcgram as described in Regulatory Guide 8.15. ( -And they are""r"estricted to using respirators that 16 II are certified by NIOSH. So we regulate respirator use very 18 closely. 19 G So is there also training that has to be done for 20 use of respirators? 21 A Training is included; yes. 22 G And that's part of the-- 23 A Required training is described in the guide, and 4Av 24 testing, individual testing of the effectiveness. 25 G But whether or not to use this entire program Acme Reporting Company l . m, n......

57 P.h55 1 is at the option of the utility? i< 2 A That's at the option. 3 4 And assuming that one exercises the option, and 4 decides to have this, what kind of credit does it get? 5 A ,Thz. ; _: - let me introduce the term " protection j 6 factor". The protection factor offered by a respirator is j rainnlide-7 the factor of difference between the concentration inside 8 the mask and outside the mask. 9 For example, a protection factor of 100 means that to the concentration inside the mask is only one percent of the 11 concentration outside the mask. 12 Q. Okay. 13 A So they're required to measure the concentration 14 outside the mask, and then they can use this protection fac-15 tar to determine the concentration inside the mask. And if 16 they followed our program in every respect, as described 17 in Reg Guide 8.15, they can use that protection factor in IS determinining the concentration to which the worker was 19 exposed. 20 New e have the protection factors measured for 21 us thrcugh contract to Los Alamos Scientific Laboratory. 22 4 I see. Now, are there other items, besides respir-23 ators, to which this protection factor option exists? 24 perhaps clothing, protective clothing? 25 A no, I d:n' t - I believe that's the only instance l 1 I I Acme Reporting Company l I i an,....u..

[, ph56 58 4 1 in which we use that concept. 2 G Okay. Now it seems that a respirator would be a 3 means by which to limit the dose, okay? 4 A The internal dose; yes. 5 0 The internal dose that somebody gets. 6 A Yes. 7 G But having a First Aid Center would not be a limi-8 tation on a dose, but that would, rather, be some sort of 9 recovery for a person who has been exposed. Are you drawing to the line, then, to say that the NRC would have regulations 11 with respect to items that would limit the dose, but would 12 not have regulations with respect to items that would enable 13 someone to receive fast medical attention or recover from ~ 14 a dose already received? 15 Is that the line you're drawing? 16 A I'm drawing a line of authority, but not necess'ar-1; ily a line of interest. Scr err.plc, cven--though I'~ not 18 -Gure - ? t might-hcip c5 tharc -- I' net curc :c ha"e --

r 19 to begin with, we have authority only over the licensees; 2

not the workers. 21 We have no authority over the wcrkers themselves. 5 I a worker receives an over-exposure and is possibly poten-23 tially injured, I'm not sure we have any authority over the 24 licensee as to what he shall do abcut that, unless that t 25 happens to appear as a condition of his license. i Acme Reporting Company n a,.a.a...

ph57 59 1 g Mm-hmm. A. But we certainly have a lot of interest, and we-ad 3 .h ve -- our Inspection Enforcement Office has physicians A 4 under contract who will be taken to the site to assist the 0 physicians at the site, in the care and treatment of the 6 over-exposed individual. 7 4 Is it fair to say that the NRC licensing process 8 would not require a utility to have physicians on site? 9 A. I can't be certain, but I've never heard of such 10 a condition. 11 Q. How about -- 12 A. I don' t believe there is one. I can't be certain. 13 4 Does the NRC have any rules with respect to the 14 availability of potassium iodide for worker use on site? 15 A. No, the rcgulaLiccA the regulatory guides are 16 silent on that point right now. That is a question under 17 evaluation. 18 G When did evaluation of that question begin? 19 A. I can first remember that being discussed as long 20 ago as 1974. 21 G In earnest, at that point? 22 A. The discussions at that point were whether or not j 23 to establish a research program to determine the side 24 effects. I believe it was decided against, on the basis 25 that' enough about the side effects is probably already known Acme Reporting Company

ph58 - 60 1 to enable a decision. 2 And also about that same time, or not long after 3 that, the NCRP made a recommendation about the use of pot-4 ass.ium iodide, so it appeared that a research program wasn't 5 really necessary,' but it was more a matter of decision-6 making ased on information that was already available. 7' O What's the status of this issue now within the 3 NRC? 9 A The Nuclear Reactor Regulation Office is right now to evaluating the use of potassium iodide and is preparing a 11 report for the Commission which, I presume, although I'm :.St 12 sure, would make a recommendation to them as to what should 13 be done. noC 14 I do think that that study 4.c draf t I : : fidn't-A

• ' included worker protection in 15 4--',4-A-

16 its scope. I believe it was dealing with the use of potas-17 sium iodide in connection with a nuclear accident as far j 18 as the public is concerned. 19 4 Mm-hmm, okay. Let's change our focus for a bit, I 20 now. I'd like to ask you a couple questions about your per-21 sonal involvement with the accident at Three Mile Island. l 22 1 That won' t take long. 23 g I didn't think it would. When did you first hear 24 about the problem, and what was your response to the first l 25 information you had? Acme Reporting Company

ph59 61 I 1 A I first heard about it -- I don't remember the i. 2 date, but here at work. Somebody had heard about the prob-3 lem at Three Mile Island, and came to me and told me in my b6 4 office that there was a problem there, that the extent of A 5 it wasn' t known at that time. 6 4 Did you or your office take any actions or. contact 7 any persons or have any discussions with respect to the acci-8 dent -- 9 A When you say "my office" do ydu mean my branch? 10 4 That's correct; your branch. 11 A Well, I didn't. And I really don't know whether 12 any members of my branch did or not. It was a situation 13 in which we had no direct responsibility or authority. Our ~ 14 function from the beginning was one of support, as needed by 15 the other offices with direct responsibility and authority, 16 suc1 as the NRR and the Inspection and Enforcement Office. 17 And we did, as the days went by, provide a limited 18 amount of support to -- primarily to the inspectors, in the 19 Office of Inspection and Enforcement. 20 4 To those personnel from I and E on'the site? 21 A Both on-site and primarily over at the I and E 22 building, the East-West Building, at their control center, 23 emergency control center. I had two people who were 24 essentially put on loan to them, to man the control center i .25 at night. Acme Reporting Company . ~ ..t

I',.

• ' ph60 62

1. 2 and; 1 0

I see. 2 3 4 5 4 6 t 7 8 '9 j 10 r 5 11 } 12 13 14 15 16 17 18 L 19 20 21 = 1 23 24 4L 25 i e i Acme Reporting Company .=. =. n~: n.:.. -.

ED,JRabg-1 coo. Alexcndor 63 51110 Isl. /13/69 Tape 3 1 A I believe they each worked about two weeks over 2 there and then -- 3 4 When did they first go to the Center? 4 A Well, I have a record of all that. I can't remember., 5 It must have been several days after the accident first i 6 occurred on the order -- probably on the order of a week before we were called on to help. s G Were you surprised that you were not called on to 9 help prior to that? to A That I wasn't called on? No, -! don ' t -I don't 11 think that that surprised me. Things went just about as I t2 expected that they would. I thought that they would probably i 13 need a limited amount of help from my branch and we were able ) i 14 to provide it. 15 0 Who did you send from your branch? 16 A The two men who went over to East West to help were t-Dr. Alan Brodsky and Dr. Harry Pettingill. The only other 18 person in my branch I believe that was of direct help to I &E 1 was my expert on respirators whose name is Jerry Caplin, j 19 3) C-A-P-L-I-N. He did quite a bit of work for them and also 21 brought to bear the expertise of the respirator laboratory at v.- LosAlairos/s'cientificlaboratory. 22 23 G How did he bring that expertise to bear? A Well, we actually arrnnged for visits to Three Mile 24 Island by Mr. Alan Hack the i: -- who heads up the respirator 25 Acme Reporting Company m > u....

[.bg-2 04 t-laboratory for us at Los Alamos. 2 When did you arrange for that visit? 3 A I didn't do it personally, and I really have no 4 knowledge of the arrangements. 5 0 Is it your sense that that didn't occur until at 6 least a week after the beginning of the accident? 7 A I think so. He visited there twice and ee Orp;;t =- a we expect probably to send him there again n; the as the 9 recovery operation gets into full swing. to G What type of support did your branch, including 11 those two gentlemen you mentioned, give? Whatexactlydidyod 12 do or what were you called upon to do? ^ 13 A I don't know very much about it. They didn't -- they 14 were essentially placed on loan there. Their assignments is didn't cert through me so that all I know i: - about their 16 work is just casual references to it that they05& made -to as t-when they came back from being on loan to I and E. I think is that -- it's my impression that they were there M to 19 offer health physics assistance as various questions arose y) during the night. I think that they did health physics evalu-21 ations of potential releases of radioactive material and j 22 things lih: thrt of that nature for the people in the control 23 center on the Three Mile Island incident. 24 4 Since Three Mile -- well, first of all, dcas that l 25 fairly well characterize the activities of you and your branch Acme Reporting Compcny ~ " ~ ~

G5 bg-3 1 A Yes. 2 0 -- with respect to the whole accident? Are thera l 3 any other events or meetings or discussions? 4 A Yes. Sometime after the accident, perhaps six 5 weeks,. along in there, Brodsky and Pettingill were again 6 requested to work for an extended period of time on the j 7 order of two weeks each and - over there at East West. It J 8 is my understanding that what they did was to assist I and E 9 people in the review of tapes, of taped interviews that were to taken during -- virtually during the progress of the 11 accident or perhaps immediately thereafter. 12 I'm not sure exactly -- I never did understand 13 exactly what Pettingill and Brodsky were doing with respect 14 to those tapes, but apparently they were simply doing things 15 like explaining to the person who was transcribing the tapes 16 what a technical term that had just been used was in order to 1-get an accurate transcription. 18 0 What tapes were these? Do you know? 19 A Well, they were tapes in the possession of the 20 office of Inspection and Enforcement so I presume they were 21 tapes of interviews between I and E people and employees and r others at Three Mile Island. 23 a I see. So they were actually tapes that were 24 generated at Three Mile Island itself -- n A Yes. Acme Reporting Company um,........

60 [, bg-4 4 i G -- rather than, for example, tapes of telephone 2 conversations into the Incident Response Center or scmething 3 of that sort., 4 A c-it's si - I'm not sure but f--- it's my under- / 5 standing tnat they were the former. 6 G Okay, fine. Since.the TMI involvement, has your office or your branch become involvol in any studies or 8 analyses of the event? A Yes. I believe Dr. Brodsky was asked to evaluate 9 the seriousness of a skin contamination incident that occurred. to e. tt 0 would that be a person whose extremities were 12 exposed while taking a sample or something? 13 A I believe so. 14 S

• What is the status of that analysis or examination?

15 A Well, he completed that some time ago and 16 transmitted it to the appropriate people in I and E. 1-G Has your branch undertaken any studies or 18 commissioned any studies because of the TMI incident? /Vbttfi4-19 A Not yet. We have_rscomme.nded that a new reg report go be developed which would offer guidance to our licensees with respect to the use of respirators and preparntion for the use 21 22 of respirators under emergency conditions. 23 0 Do you expect to make any further suggestions as to studies or modifications of procedures due to TMI? 24 25 A Yes. I believe that the involvement of my branch Acme Reporting Company I' L .u,,..4...

bg-5 c.7 1 in the TMI incident i: hasn't even yet begun. The reason 2 for that is that th: the real recovery operation hasn' t 3 started yet. That's when the occupational exposure will 1 4 occur. i 5 How are you gearing up for that? 6 A Well, I've appointed one man to establish the necessary contacts with the health physicists -- both I and E a health physicists and utility health physicists at Three Mile 9 . Island -- to establish contacts with them and to start to collecting dose data so we can follow the accumulation of the g . :11 collectddc dose at-Three Mile Island. I have asked th: that ,12 everybody be on the Icekout for conditions during the recovery 13 that could have been mitigated if things had been built . /14 differently or installed differently or treated differently 2 15 so that W -- in case anything like this happens again the i 16 exposure to the workers during recovery can be minimized. t-These, of course, are issues amenable to correction 13 through a standards effort, through standards setting. 19 G Through regulation development. Is that what you 3 mean? 21 A Yes, or guides. I 22 a Do you expect that your involvement will take any 23 course beycnd what you have just described, your involvement 24 in the post-TMI story, as it were? = A cP"f5 unless scuething unanticipated ccmes up that y;, Acme Reporting Company 22a,........

[, bg-6 4 I is really outside of our present responsibility where our 2 assistance would be needed, that would be the only way I can 3 imagine that we would get involved any more deeply than I've 4 just indicated. 5 4 Will you be getting involved, either directly or 6 indirectly, with ar,y studies that are now under way with 7 respect to exposures to ionizing radiation? 8 A I don't know of what studies you might be referring C 9 to. -If they h::: - if any studies of exposure to workers o 10 are conducted there, I'm sure my branch wuld be involved in I 0 11 the review, probably not in the management or conduct of the 12 studies.. 13 0 Your branch is not initiating any studies as of -- 14 A

• No.

15 g Okay. Is there any topic or information that we 16 haven't covered that you would like to mention before we 17 conclude, any point either about the event or any point you 18 would like to make with respect to the material we have 19 . covered, anything of that sort?. 20 A I would like to understand b'etter how all of the 21 basic information we covered today before we got to TMI 22 relates to your purposes. 23 4 Okay. I'11 be glad to exclain that but there's no l 24 need to put that on the record I assume. 1 25 A I see. l Acme Rep ortir-; G mpany l m, a..~

bg-7 CO 1 G Anything else? Anything of your testimony that 2 you would,like to supplemest on the record? I gather the 3 answer is no. 4 A No. 5 0 okay, fine. We vill conclude.the deposition. 6 (Whereupon, at 3:58 p.m., the deposition was 7 v concluded.) 8 9 10 - 11 12 13 14 15 16 17 18 19 O ' 21 22 23 24 25 l Acme Reporting Company l

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70 1 2 ~ CRT*7':- ~ ~ C T'" ~ ? ' G*** 2T 3 - ~ ~ ~ - - - 4 5 CCCKET NUM3ER: 6 , CASE TI*LE: DEPOSITION OF ROBERT E. ALEXANDER 7 "c A R

• N G D A T E :

August 13, 1979 3 LOCATION: Bethesda, Maryland 9 to I hereby certify that the proceedings and evidence 11 herein are contained fully and accurately in the notes 12 taken by me at the hearing in the abcve case befcre the 13 PRESIDENT'S COI@iISSION ON THE ACCIDENT AT THREE fiILE ISLAND 14 and that this is a true and correct transcript cf the is sa=e. 16 17 13 Cate: August 14, 1979 19 / .4 r.

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) 20 [; Y )_ v - l / 21 Official Reper er Acme Repcrting Cc=pa.y, Inc. 22l 1411 K Street, N.W. 22l Washing cn, D.C. 20005 l l i 24 i fj[D)I9'M/$g D * *lft 0 d[%l $ Kilu a l ' 25 ; gg \\ s l Acme Reporting Company l I saa sae <eee l l

'-~ y~ ? U DJp, Y.4% .4 A :g e 5^{ L L(g. $I-Robert E. Alexander Robert E. Alexander began his work in health physics at Convair - Fort Worth imediately following gra~duatibn from Howard Payne College, BA, Mathematics, in 1954. After three years as a reactor health physicist, he joined Atomics International as Lead Engineer, Health Physics Services. Later, he was appointed Responsible Engineer for the Radioactive Materials Disposal Facility. During 1961 and 1962 he served.as advisor in radiation protection to the governments of Indonesia and Greece, under the au. apices of the International Atomic Energy Agency. Returning to Atomics International, he was appointed Responsible Engineer for the safety analysis report, SNAP-10A Reactor Flight Test, and later became Radiation Engineering Supervisor. Sub-sequently, health physics, industrial hygiene, and industrial safety were added to his responsibility. In 1968 he joined NASA Headquarters and served as Chief of the Radiological Health Branch until coming to the AEC (NRC) in 1972. He i's presently Chief of the NRC Occupational Health Standards Branch. He is a past President of the Health Physics Society (HPS) Southern California Chapter, past Secretary-Treasurer of the HPS Baltinore-Washington Chapter, and was the Chairman of the HPS Public Relations Comittee for four years. He organized the Atomic Energy Infornation Service, a cooperative activity of the HPS, ANS, AIF, and AEC, and served as its Executive Director for three years. He also organi::ed the Speakers Bureau for the Los Angeles Section of the ANS. He is certified by the American Board of Health Physics. i g e e 9, =emag i e J m

,0 = p 1 CERTIFICATE I certify that I have read this transcript and corrected any errors in the transcription that I have been able to identify, except for unimportant punctuation errors. 2-l, /f2/ / Date: / ROBERT E. ALEXANDER 4 e e 4 e -ea}}