ML19338B820
| ML19338B820 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/13/1979 |
| From: | Parsont M NRC OFFICE OF STANDARDS DEVELOPMENT, PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7910310257 | |
| Download: ML19338B820 (77) | |
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Transcript of Proceedings 0
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0 UNITED STATES OF AMERICA o
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PRESIDENT'S COMMISSION ON THE ACCIDENT AT U
THREE MILE ISLAND O
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0 DEPOSITION OF:
MICHAEL PARSONT o
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August 13, 1979 0
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Acme Reporting Company o
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1411 K Street. N.W.
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0 (202) 528-4838 1
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UNITED STATES OF AMERICA PRESIDENT'S COMMISSION ON THE ACCIDENT AT 2
THREE MILE ISLAND 3
4 5
6 DEPOSITION OF:
MICHAEL PARSONT 7
8 9
10 11 Roct 218 5650 Nicholson Lane Bethesda, Maryland-12 13 August 13, 1979 10:25 o' clock a.m.
14 15 APPEARANCE 16 On Behalf of the Commission:
17 ERIC PEARSON, ESO.
2100 M Street, N.W.
Is Washington, D.C.
20037 19 On Behalf of MRC:
3)
PAT DIXON, JR.,
ESO.
Office of General Counsel 21 1717 H Street, N.W.
Washington, D.C.
22 23 24 25 Acme Reporting Company 22C t 6294999
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1 EEEEE UITNESS:
DIRECT CROSS REDIRECT RECROSS 2
3 Dr. Michael S. Parsont 3
4 5
6 7
8 EXHIBITS:
IDENTIFIED 9
1 5
2-12 75 10 11 12 13 14 15 16 17 18 19 m
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MR. PEARSON:
This is the deposition of Dr. Michael 2
3 A. Parsont of the Nuclear Regulatory Commission.
Dr. Parsont, 4
have you ever had a deposition taken before?
5 DR. PARSONT:
Yes, I have.
6 MR. PEARSON:
Okay, then you are aware that the 7
testimony you give today has the same force and effect as a
the testimony that you would give in a court of law?
9 We should swear in the witness.
10 Whereupon, 11 DR. MICHAEL A.
PARSONT 12 having been first duly sworn, was called as a witness herein 13 and was examined and testified as follows:
14 EXAMINATION 15 BY MR. PEARSON:
16 G
Because you are testifying under oath, please try i;
to be as precise as you possibly can in your answering.
Is And if there's any questions that I ask that are not clear, 19 make sure that you stop me quickly, and I'll clarify them.
20 Would you tell us your whole name and address for 1
21 the record, please?
A My ndme ir Michael A. Parsont.
Do you want my 22 work address -- in the Office of Standards Development of 23 Nuclear Regulatory Commission, address Washington, D. C.
24 20555.
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1 G
And what position do you occupy with the NRC?
2 A
I am Chief of the Radiological Health Standards 3
Branch.
4 4
How long have you been with NRC?
5 A
Since 1972.
6 S
Can you briefly characterize for us the jobs and 7
the responsibilities you~have had between 1972 and the pre-8 sent?
9 A
Yes.
From 1972 until 1976, I was in the Radio-10 logical Assessment Branch of the Office of Nuclear Reactor 11 Regulation.
I did health analyses of applications for 12 nuclear power plant licenses.
In addition, I did special 13 studies in radiobiology.
I performed consultation services 14 with other offices and staff members, gave testimony at is licensing hearings, and performed under the title of radio-16 biologist.
1 Since that time, I have a in the Office of 18 Standards Development of NRC, first as a radiobiologist, 19 also evaluating the health effects of ionizing radiation, and 20 since November of 1978, have been Chief of the Radiological 21 Health Standards Branch.
22 0
When did you first transfer to the office of Stan-23 dards Development?
24 A
In October ot 1978.
25 4
October of 1978?
Could you characterize again Acme Reporting Company
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briefly your educational' background?
2 A
Yes.
I have a Masters degree in Radiology, and 3
a Ph.
D.
in Radiation Biology, from Colorado State University.
4 I have a Bachelor of Science Degree in Environmental Sani-5 tation -- Public Health, from UCLA, and I have done addi-6 tional graduate work in sanitation engineering, genetics, and 7
endocrinology at the University of California, Berkeley.
8 G
Have you taken any courses or graduate work of 9
sorts sponsored by the NRC, or since you've been with the 10 organization?
Y
/.
11 A
Yes, yes, I've taken 4 st:tistic cour:0, a-nn-ke-V 12 of -- ::15, at least one computer programming course, and 13 a number of management courses.
14 0
I have here a document entitled, " Professional 15 Qualifications of Dr. Michael A. Parsont."
Could you tell 16 us what this document is, very quickly?
1:
A It's just a brief resume of my work experience, is both within NRC and prior to coming to NRC.
19 0
Is this document accurate to the present time?
20 A
Yes.
21 G
Okay, I'll mark this Deposition. Exhibit Number 1.
22 (The document referred to was 23 marked for identification as 24 Exhibit Number 1.)
25 A
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1 BY MR. PEAPSON:
2 O
Would you tell us your current responsibilities in a
your position as Chief of the Radiological Health Standards 4
Branch?
5 A
I am responsible for the determination of health 6
effects from NRC-licensed facilities, both medical and 7
from power product on facilities.
I am Project Manager for 8
a radiation epidemiology study currently being conduc-9 ted.
to a
This is a particular study?
11 A
Yes.
Yes, it's a study that has been mandated 12 by the Congress.
I'm responsible for developing radiological 13 health standards and guides, and for the evaluation and.
14 assessment of radiobiological health impacts, on the public 15 and on workers, from both proposed and licensed NRC activi-16 ties.
I also act as an advisor and coordinator within the i;
NRC, and I participate in both national and international is meetings and groups in thu areas of radiological health 19 effects.
20 0
If you have responsibility with respect to develop-21 ing radiological health standards for workers, how do your 22 responsibilities vary from those of Mr. Alexander?
23 A
Basically, my branch develops the health effects 24 results from exposure, and it really doesn't make much 25 difference whether the people are industrially oriented or in Acme Reporting Company i
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1 the general population' It applies to both.
So, whereas 2
Mr. Alexander's branch actually gets into the industrial 3
community, and writes regulations and guides with respt:t to 4
how workers operate within those facilities -- the materials 5
that my branch develop relate to the effects of the expo-6 sures, and Mr. Alexander can then apply those --
7 4
I see.
3 A
-- or the group, the Office of Standards Develop-9 ment, applies those in the regulations.
10 0
I see, so you determine what exposures may or 11 may not be acceptable, and then his group would implement 12 procedures to assure that exposures not exceeding the re-13 commended levels would not occur.
Is that fair to say?
14 A
We don't use the term, acceptable -- permissible.
15 O
Permissible?
16 A
Right, because what may be a permissible expo-17 sure to the Commission may not be acceptable to the person is or population.
19 Okay.
Would it be fair to say, then, that -yes -M[__
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, determine what exposures are permissible, and Mr. Alexander's 21 group then determines procedures to assure that exposures 22 beyond the permissible levels will not occur?
l 23 A
Yes, that's a fairly accurate description.
I 24 4
Okay.
I'd like to direct our attelaion just for 25 a minute to the actual branch within which you work.
Would Acme Reporting Company
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you tell us how many employees it has, professional and 2
clerical, and what their responsibilities are?
3 A
Yes.
We have six professionals, other than myself, 4
and one secretary.
The back' ground of the professional 5
people range from radiobiology and epidemiology, to health 6
physics and nuclear engineering.
We have two health physi-7 cists who are primarily responsible for writing regulations 8
for the medical side of the house, and the other four are 9
primarily responsible for the general radiological health to effects, populations, and considerations.
11 0
When you refer to the medical side of the house --
12 A
Yes.
13 0
-- what do you mean?
14 A
This relates to the use of radiopharmaceuticals --
15 safety of radiopharmaceuticals and medical devices using 16 radiopharmaceuticals.
17 G
Okay.
You said there are seven professionals 18 and one secretary for your particular branch?
19 A
Yes, that's correct.
20 0
Okay.
Is your entire branch located here in this 21 facility?
22 A
It is, yes.
s O
Are there any other branches within NRC that do 24 comparable wor.N to the work that your branch does?
l 25_
A Generally, the branches within Office of Standards I
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1 Development are support-type branches.
If regulations and 2
guides are necessary, generally, other offices request that 3
the Office of Standards Development write those guides.
So 4
there.are individuals within NRC in other offices who have 5
similar responsibilities, let's say, from the standpoint of 6
training in radiobiology, or of training in the medical 7
area.
8 For example, in NMSS -- and I can't remember what 9
that stands for -- Nuclear Materials, and Systems Safe-10 guards, or something like that, I can' t remember what that 11 is -- that is the office with primary responsibility for the 12 medical area.
13 If, let's say, a petition comes in to them, and 14
-- requesting a rule change or a new regulation, then that 15 is transmitted over here, and we write that rule.
We put it 16 together for them.
In the Office of Research, there is a 1;
radiobiologist, also in Nuclear Reactor Regulation, there's le a Isw.sbiologist.
Both of these individuals are capable of 19 calculating health effects.
So there is expertise of a 20 similar nature to what we have in this branch, also represen-21 ted in other offices in the NRC.
22 4
Would it be fair to say that any regulation that 23 the NRC would promulgate, relating to radiation levels, 24 permissible levels for the public or for workers, would 25 generate from this office?
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A I may have been a little misleading before.
The 2
permissible levels are part of 10 CFR, Part 20.
They're 3
stated there.
If we were to attempt to change those, then 4
we'd have to go through a rulemaking procedure, and at that 5
rulemaking procedure, let's say, there's a hearing -- then 6
the evidence would l~a presented on both sides, and recommen-7 dations of the staff and intervenors and whomever would be 8
presented, and then the recommendations, or the levels, 9
would be changed.
10 We can't do that directly here.
We can recommend 11 that certain levcis be changed, and recommend the extent to 12 which those levels are changed, or should be changed.
But 13 it's really the Commission that makes the change --
14 0
Okay.
15 A
-- and not this office.
16 0
Would this office begin any rulemaking proceeding 17 that would finally result in a change of this sort?
18 A
In response to a petition, we would make recom-19 mendations on the petition -- make recommendations to the 20 Commission, as to whether a hearing -- whether we would re-21 commend a hearing or not. 'The Commission can then indepen-22 dently decide whether or not to hold a hearing, and at that 23 hearing we can recommend -- so in that sense, we initiate it.
24 G
Could you initiate a rulemaking procedure on your 25 own initiative, without the receipt of a petition from an Acme Reporting Company I
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outside party?
2 A
Yes.
Yes, I'm sure we could.
If we find that there 3
is sufficient evidence of research and so forth on the out-4 side, that would indicate that our standards needed change 5
-- the regulations needed to be changed, we could.
6 G
Has that ever occurred?
7 A
Not in my area.
I'm not sure whether -- I'm not 8
familiar whether it has.
I don't know.
9 G
Okay.
Do you have any requirements for either 10 education or experience, for those persons who work with 11 you within this branch?
Are there minimum requirements that 12 they must meet in order to be employed in their respective 13 capacities?
14 A
Each position has its own description, and the 15 requirements of education and experiential are part of that 16 description.
And then candidates are interviewed against 17 the criteria set in the description.
18 G
Could those requirements be made available to us?
19 A
Sure, copies of the position descriptions.
00 0
All right, and could you also make available to 21 us the statement of professional qualifications for each 22 of the professional persons who work with you in this branch?
23 Could that be made available to usi I
24 A
Yeah, they would have to be written up, because 25 generally these are written up when we go to give testimony, Acme Reporting Compony m
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so I imagine that we could have the branch members write 2
them up.
3 G
Okay, it shouldn't take too long, just something --
4 A
Okay.
5 0
-- very brief, for our purposes.
I'd like to talk 6
for a minute about how the procedure of promulgating regu-7 1ations is actually undertaken.
The initiating event, we've 3
already decided, would be either a decision by the NRC 9
itself to commence a rulemaking, with respect to the per-10 missible radiation levels, or the receipt of a petition.
11 Once that initial event occurs, what is the very 12 next thing that happens in the rulemaking procedure?
13 A
I'm not sure I can give you a really accurate an-14 swer to that.
I'll just give you what my impression is.
15 Generally, the petitions don't come directly to this office.
16 They come into another office within NRC, or they go to 17 the Commission directly,'and they come down then.
Is The assignment -- that is, to say the Assistant 19 Director and then down to the Branch Chief that's going to 20 handle this, is then made, and written responses to the 21 petition are put together.
22 G
What would the response say?
23 A
There has to be a technical evaluation.
In other 24 words, if it's a technical point, based on scientific --
l 25 or some data, then people within the organization make an Acme Reporting Compony an u.a..
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analysis of those data, and the arguments, and come up with, l
2 let's say, a branch position.
The material usually is not 3
restricted to treatment by just one branch.
Usually, there 4
will be other organizations within NRC involved.
If NRR 5
has a piece of it, then that portion of the petition -- any 6
specific questions that are asked, that NRR can answer, 7
are sent over there for their input, and then when all of the 8
input is gathered, the position paper is written and cir-9 culated for concurrence, both throughout the other offices 10 and through the Executive Director.
11 Finally, that paper goes up to the Commission 12 for their decision as to whether or not there should be a 13 hearing, or it may be that the recommendation is to deny 14 the petition, and the Commission can say, we'll go along 15 with this or not, as they see fit.
16 0
Okay.
If a petition would come in -- say, let's 17 change tho. levels in 10 CFR Part 20 to this or that -- in 18 analyzing whether that petition should or should not-go to the Commission with a recommendation for a hearing, or a 2t recommendation simply to deny it or whatever, would the mem-21 bers of the NRC go beyond the data presented in the eeti-22 tion?
23 A
Ch, yes.
Oh, yes.
We use whatever data that we r
1 24 can to make the decision.
25 0
Would that be data on hand, or would you also seek i
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new data?
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We attempt to get all of the current data we can 3
to make a decision.
It'a just not good policy to take it 4
on a few -- you know, make decisions on a few limited pieces 5
of information.
Evan if the information upon'which the 6
petition is based, is not solid -- on solid scientific 7
grounds, we do -- generally, in my understanding, we do a a
terrific job of going in there and picking out the infor-9 mation in the scientific literature upon which to make a de-10 cision.
11 G
How long does it take generally, if there is such 12 an assessment, between the receipt of the petition and the 13 time that the offices within NRC would review it and sub-14 mit it to the Commission for the initial decision?
15 A
A long time, usually.
Generally a number of years.
16 O
A number of years?
17 A
Yes, unless there is some really hot potato.
For
.D 18 instance, the N3B'C submitted a petition in 1975 or '76.
19 We' re still acting on that -- very, very bad.
It doesn't 20 look good, and it's not good.
21 G
What do you mean, it's not good?
r A
In other words, yeah -- the impressien is created l
23 that we're not actively pursuing the response to the peti-24 tion.
I would say that for a petition on substantive 25 matters to be processed and completed by the staff -- that is, Acme Reporting Company 2025 629 4988
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the technical review, if it takes a year, that's fast.
2 There are certain things'in the medical area that we can 3
knock off petitions very rapidly.
Sometimes -- well, I know 4
there's a fellow in my branch who has responded to a peti-5 tion and the final decision was made, and so forth, and the 6
regulations changed, within a matter of a couple months.
7 But that's an unusual circumstance.
8 G
Well, why does'it take so long?
9 A
Generally, the problems are not simple ones, and to there's a great deal of controversy involved, so one has to 11 be very careful to do the best job possible to gather all 12 the data and write up all the material properly.
And then 13 there's a -- just the process of getting concurrence, 14 office concurrences, among all the offices and all of the 15 cone.ents included -- and also just the process -- the peti-16 tion comes in, it's received, it has to be announced in the 17 Federal Register, there have to be comments on it, and a 18 whole series of things that do take time, in themselves, 19 outside of the technical considerations, and they go to the 1
20 Commission.
21 The Commission takes some time making decisions l
22 in these areas, and so it's not just -- it's not all the 23 fanit of the technical people, but there's a good portion l
24 of that time is involved in the technical evaluation.
25 G
After the Commission gets hold of a petition, do Acme Reporting Company m, u.....
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they either recommend that it be denied, or do they recom-2 mend that there will be r hearing, or do they have a third 3
or fourth option in there too?
4 A
I don't know.
The options I know is that they 5
can take the staff recommendation.
I know the Commission 6
has the option of either recommending that a hearing be 7
held, or recommending that no hearing is necessary.
8 0
When you say, take the staff recommendation, do 9
you mean simply confirm the recommendation, and it then be-10 comes a regulation?
11 A
ch, no -- well, if -- that I don' t know, quite 12 frankly.
I don't know the answer to that.
13 0
During the period when the staff is censidering 14 the petition, or the rulemaking procedure, at any rate, a'nd 15 prior to the submission of the staff recommendations to the 16 Commission, there are, as you've indicated, some opportunity 17 for public comment, is that accurate?
IS A
Yes.
19 i
Okay, are there public hearings held during that 20 span of time, as a matter of course, do you know?
21 A
No, I don't.
22 0
Okay.
After the-Commission has decided on -- con-23 cerning a petition, to have a hearing, is tha hearing al-24 ways an adjudicatory hearing, with witnesses, cross-examina-l 25 tion, judges, testimony under oath?
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A No, I don't believe there are judges.
I believe 2
it's befere a panel of the commission.
3 0
Is there testimony under oa.n, for example?
4 A
Yes.
5 0
And there's cross-examination of witnesses?
6 A
h-% =,
7 0
And how does the result of the hearing play into 8
the final decision-making, with respect to the regulation?
9 A
I don't kncw.
10 0
You don't know if the result of the hearing man-11 dates that that becomes the regulat.on, or whether that 12 simply --
la A
The decision is made by the Board, and I don't 14 know how that fits into becoming a final rule.
15 4
Okay.
Do you have a sense for how long it takes 16 between a commission recommendation for further proceedings --
1; a hearing or whatever, and the time that a proposal actually 18 takes the form of a regulation and becomes effective?
19 A
No, I don't.
20 4
Okay.
After the hearing stage, do you know if 21 there's any other steps that are taken procedurally with 22 respect to --
23 A
I know there are some -- probably, room for appeal 24 of a decision, and after that I don't know.
25 G
Okay.
After the hearing stage begins, is your Acme Reporting Company na..a......
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office still involved?
2 A
Oh, yes.
Very often, we're -- we vnuld be in-3 volved in giving testimony.
If we had input into the s.taff 4
position, then we would probably provide witnesses at the 5
hearing.
6 0
I see.
Okay, let's focus for a moment on how 7
your office makes a recommendation to the Commission with 8
respect to a regulation, if we can speak in this -- somewhat 9
in the abstract.
If a petition would come in, and recommend to a change in one of the permissible radiation levels that you 11 have in 10 CFR Part 20, what steps would this office take 12 in analyzing that recommendation, and how would it reach 13 its conclusion with respect to it?
I know that's a big 14 ques tion.
15 A
There are two ways -- two important aspects of 16 most petiticas.
One is the scientific validity, the basis 1-on which tne recommendations are made -- the petition, and 18 the other is, given that even those bases were correct, 19 how would this impact the regulatory strategy of the Agency?
20 For instance, if the petition requests that the
$4wLs 21 occupational-gross limit be lowered on sound scientific 22 grounds -- the grounds' may not be sound from the standpoint l
23 of regulation, because of the way the industry operates.
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I 24 For instance, if the occupational exposure level is too low, A
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25 then we may get a higher population gross, because of the l
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estuil procedures in doing maintenance jobs.
If the occu-2 pational dose limit is too low, then the time that an employee 3
can go in to do a job is'more restrictive, and those parts i
4 of the job that require setup now take a larger amount, I
5 proportionately, of the time for him to do his work, e 1 6
g What do you mean by setup?
7 A
In other words, a fellow has to go in and find a 8
valve, okay --
9 4
- Okay, to A
-- attach a wrench -- he's not doing anything, 1
11 you know, productive now, with respect to what he has to do.
12 Then he turns the valve.
When he's turning that valve, that's 13 the actual work.
But all of that preliminary time, you see,
~
14 takes up a larger proportion of his available time to do 15 that work, if the dose limits are too low.
So we have to l
16 move a lot more people in there --
1; 4
All right.
18 A
-- with a lot more unusable time, or more unpro-19 ductive time.
So it may' be very well to say that, yes, we 20 should lower $he occupational dose limits for this reason --
47 21 but by taking a look at the actual effect of this on total 22 dose, it may be quite the opposite.
23 G
I see, so you're~saying that if you would require 24 more people to do a job where there was a setup time, because 25 of a lower dese, then you'd have a greater number of people 1
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getting a lower dose?
2 A
Yeah.
3 G
Than you are with the higher --
4 A
That's right.
And you may actually increase the 5
total dose to the population, the worker population, and so 6
we have, on the one hand, yes, it looks like, from a scien-7 tific point of view, that we should lower the dose limit.
8 But from the practical standpoint, it may do just the 9
oppocite of what it was intended -- I'm not saying that to that's actually what happens, but these are the kinds of con-11 siderations that are made.
12 So, from a technical standpoint, we may come up 13 with one conclusion, and then we have to weigh-that conclu-14 sion a Jainst what actually 'goes on out in the industry.
15 G
Well, when you reach an occupational or a public 16 dose permissible level, what do you mean when you reach that 17 number?
What's the significance of that number that you 13 come out with?
19 A
Well, that's a -- the level is actually a guide.
20 We practice as low as reasonably achievable.
What we try 21 to do is get the smallest dose possible from any of the 22 operations of the industry.
The dose limit is strictly that M"Mf the dose limit.
In other words, we do not permit employees 23 j
24 to exceed that limit.
What we try to do is get them as 25 far below that limit as we r can.
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O By setting a limit, are you -- is the NRC stating 2
that it -- to its best knowledge, exposures below this 3
limit will have no adverse health effects?
4 A
No.
The Commission and the general view is that --
5 and prudent view is that any exposure to ionizing radiation 6
can be harmful.
So the objective, therefore, is to reduce 7
the exposure as much as possible, within the state of the 8
art or whatever.
And therefore, the limit is set knowing 9
that some small health effects are possible from exposure to 10 the limit -- unmeasurable, in most c :es.
But the ALARA 11 principle is applied, to reduce exposures as far below that 12 as practical.
13 THE REPORTER: 'What principle?
14 THE WITNESS:
A-L-A-R-A.
As low as reasonably 15 achievable.
16 BY MR. PEARSON:
17 0
Is the NRC of the view that there's a linear reln-18 tionship between health effects and exposure?
19 A
That's what we practice.
20 G
That's what you practice?
Okay.
If that were the 21 case -
getting back to the example that you just mentioned, 22 with respect to the total cumulative dose to persons, if 23 you had a lower occupational, permissible dose, in the regu-24 lations --
25 A
okay.
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g would that example that you just gave, which might 2
result in the Commission recommending a higher occupational 3
dose level, in your mind conflict with the operating prin-4 ciple that the exposure to radiation has a linear effect 5
with respect to the --
6 A
I'm not sure that I --
7 Do you follow the question?
8 A
I'm not sure that I advocated a higher occupa-9 tional exposure level.
10 g
okay.
I didn' t mean to imply that.
11 A
Okay.
But what we might recommend is not lowering 12 the limit.
13 okay.
My question is, would that recommendation --
14 once again we're speaking in the hypothetical --
15 A
Okay.
~
16 Would that recommendation conflict with the operat-1; ing principle that there's a linear relationship between is radiation exposure and public -- or adverse health benefits?
19 A
No, no, it wouldn't, for the simple reason that 20 the lower the amount of radiation that you can have --
21 occupational, or the general population exposed to, must 22 give you benefit.
Now, the as low as reasonably achievable 23 is also based on how fast can a -- and how efficiently can 24 the jobs be done, within the industry.
25 So if you can find a way to do the job faster and Acme Reporting Company ac2,....m.
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better, right -- have the people in there doing the job 2
more efficiently, for less period of time -- less exposure 3
time, that's the kind of thing that ALARA points to.
4 Okay.
5 A
And we would encourage this.
It's in the regula-6 tion.
7 0
Okay.
In 10 CFR Part 20, you have certain limits 8
established.
Does the ALARA concept work in supplement to 9
those limits?
10 A
Actually, the ALARA concept should come before 11 those limits.
12 g
Well, what if the ALARA concept would result in exposures o'f persons above what the limits in 10 CFR 20 would 13 14 indicate?
Would that logically occur?
15 A
No.
16 O
And why would that not logically occur?
i 17 A
The limits are individual limits.
There are no 18 population limits in 10 CFR Part 20.
The type of discus-19 sion we've had talked about an effect that the job -- it 20 took on a large number of people in collective doses.
And 21 as of right now, 10 CFR Part 20 speaks to individual doses.
22 So one would not have a procedure that would give, let's 23 say, a maintenance employee greater than a 1-1/4 REM per 24 quarter, you see -- when he got to his 1-1/4 REM per quar-25 ter, he'd be pulled from that job, or the overexposure would I'
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be reported.
2 G
Okay.
He would compute that 1-1/4 REM figure, or 3
whatever the figures are -- you would take into account 4
the operating procedures on site as part of your decision 5
making?
6 A
Those are mostly Alexander's types of considera-7 tions.
8 G
Okay.
9 A
Occupational Standards Branch -- but generally, to the doses are not computed.
They're measured, in other 11 words, by a film badge', or a thermoluminescent dosimeter, or 12 some other way.
Occasionally, where there's, let's say, 13 an airborne exposure, one has to fall back upon the record-14 ing measuring devices within the plant, and then back-15 calculate to see what kind of exposure the employee might 16 have gotten.
But this is rare.
1; It's most apt to be a situation where, if the mea-13 surements can be read off of somt sort of --
19 G
Okay, all right. ' So, getting back to the question 3) of deciding on staff recommendations, with respect to a rule-21 making, what other factors do you take into account during 22 your considerations?
You take into account the scientific 23 dat, of course, with respect to the effects of low-level 24 radiation?
25 A
Yes, that's what the technical staff does.
Acme Reporting Company l
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1 4
Okay.
2 A
And knowledge of procedure and so forth -- the 3
actual application in the industry.
4 G
Okay -- the work procedures.
5 A
That's right.
That's Alexander,-- that would be 6
the Occupational Health Standards Branch.
7 G
Okay.
8 A
Our branch just usually calculates the effects 9
of exposure.
to G
Okay, would other branches insert other consi-11 derations into the rulemaking -- decision-making process?
12 A
outside of strictly general consideration of techni-13 cal expertise, I don't know.
14 G
Would -- in reaching a phantom level recommenda-15 tion, would the staff take into account the economics of 16 the industry?
17 A
Oh, yeah, that's part of it.
Part of it is eco-18 nemics.
But I consider that to be a technical --
19l 0
I see.
And who would actually be concerned with l
20 the economic impact of a change in the regulations?
Which 21 organ within NRC would do that?
r A
I don't know the branch that's involved, but there 23 are people within NRC who do those sorts of things -- eco-l l
24 nomic impacts.
25 G
okay.
They would always consider the technical Acme Reporting Compony
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feasibility?
I guess that's -- that would be part of it too, 2
I would guess.
3 A
Technical feasibility of what?
4 g
Technical feasibility of the industry, in limiting 5
exposures to a certain level?
6 A
Yes, that's another consideration.
We have to 7
look to see if there are -- there is equipment out there to a
do the job.
9 0
Do you have a sense for how these various factors 10 are balanced, with respect to formulating a final recommen-11 dation to the Commission?
12 A
No.
13 4
Is there any policy statements on that?'
14 A
I'm not aware of any.
I'm not familiar with any.
13 When you say, am I aware of how they're balanced --
~
16 0
Right.
1 A
-- I gave you an example before, one of the types l
18 of balancing that's done.
19 Right.
20 A
That's what I'm familiar with, that kind of con-21 sideration.
22 G
Okay.
But you wouldn' t know if -- for example,
23 if the economics would be very expensive -- whether that 24 would constitute a veto on the -- on, say, low-lerpl limi-l 25 tation, or would that simply be another factor that would be i
Acme Reporting Compony m, n......
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taken into consideration -- which are given greater weight 2
in the decision-making process?
That's the kind of thing 3
I'm 1 coking for.
4 L
Oh.
Well, with respect to exposure of the general 5
population, Appendix I of 10 CFR Part 50 gives a number --
6 a valuation per unit of exposure, $1,000 per man-REM.
If 7
the dose to the population, in the design stages, can be S
calculated to be reduced ~by an increment, which is less 9
than $1,000 per man-REM, then it's recommended that that 10 particular -- is required, actually, that that particular 11 piece of equipment, or whatever, be installed in the plant.
12 So there, there is a number.
Let's say that a 13 piece of equipment cost $2 million, and would reduce the 14 exposure -- population exposure by 20 man-REM.
Twenty man-15 REM times 1,000 -- that'a $20,000 -- they would not put in is that piece of equipment, to reduce the population exposure.
17 If, on the other hand, you reduced it to 1,000 IS man-REM for a $100,000 investment, boy, that piece of 1
l 19 equipment goes in, all right.
It's a two-way sword.
If -- in 20 the design stage, a plan comes in, and it's seen that there's 21 a piece of equipment that doesn't -- that is not economi-22 cally effective in reducing the doses in there, the option 23 is for the applicant to take that out.
So it can work both 24 ways.
25 On the other hand, +.here is no number -- $1,000 Acme Reporting Company i
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1 per man-REM or something 1ike that, that is applied for 2
occupational exposure.
So the economics -- you haven't got 3
some handy-dandy guide to work against, and it's a little 4
more complicated.
5 4
So in some cases, an existing piece of equipment w %.a y der &
6 that could limit exposure, if it's uneconomical, could be
)
/
7 removed, and another piece'of equipnent that would be eco-8 nomical, would be ordered to be --
1 9
A Yes, placed -- only in the design stage.
10 0
The design stage of the entire --
11 A
Yes, when a facility -- when an application comes 12 in, like for a construction permit, and during the construc-13 tion permit stage, there's nothing built -- it's all' designed 14 and laid out for the staff.
The st.aff and the applicant 15 both make analyses -- the staff makes its own independent 16 analysis, and based on the actual radioactive releases 17 calculated, that is to say, calculated radioactive releases, 18 the types of equipment that are recommended, the distribu-19 tion of the population around the proposed plant and so forth 20
-- doses are calculated.-
21 And if it's found that the doses calculated do l
22 not meet the specific dose' design objectives in Appendix I, 23 then something has to be added to the plant, to correct the 24 calculated releases.
Sometimes it's very difficult for the 25 plant to meet that kind of release.
Acme Reporting Company n
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One particular'and most limiting radiorcelide is 2
iodine, and there are times when it's rather dif#icult for 3
the plant, without an enormous expense, of millions, in 4
filters, and so forth, to reduce its iodine, to meet the 5
Appendix I objectives.
But they have to meet those objec-6 tives, regardless of the cost of the piece of equipment.
7 Now, if the total population dcse, after meeting l
8 the dose design objectives of the 10 CFR Part 20, are met, 9
it would be very unusual that they didn't meet the -- that any l
10 more equipment would be economically feasible, to reduce the l
11 total population dose.
It would be hard for me to envision 12 anything different than that.
13 4
But if some piece of retrofitted equipment would 14 be economical, to reduce the population dose, would the NRC 15 require that retrofitting?
16 A
If the dose design objectives -- that is to say 17 the individual dose design objectives, are met, it's my ad 1 15 belief that NRC would not require any further equipment.
19 20 21 22 23 24 l
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G How are those design objectives determined for any 2
particular commercial plant?
3 A
They are in the regulations.
4 Okay.
Mil 5
A Sut those design objectives are in the regulations.
{po:oIsle Parsont hl3/79 6
g And that's 10 CFR, 20?
Ope 2 A
No.
That's 50.
8 4
That's 50?
9 A
Yes.
10 4
Okay.
Now, what if those objectives would be changed 11 af ter a plant was constructed?
Would those changes ever be 12 retroactive to an existing facility?
t 13 A
I think we can look at that with what has gone on 14 with Appendix I of 10 CFR, Part 5 0, as they exist now.
All 15 of the plants are being retrofitted or have been retrofitted 16 to meet the new 10 CFR.
t-4 Okay.
18 A
Because now, the technical specifications for opera-19 tion are based on Appendix I of those design objectives now.
c.
3 So the,a'ffluent releases must meet those guidelines new.
21 G
Okay.
In 10 CFR Part 20, there are, as I recall, 22 standards for permissible exposures within restricted areas 23 and unrestricted areas.
Is that accurate?
24 A
Yes.
25 Okay.
Could you speak to what those exposure levels Acnue Reporting Company 202, $29 4868 3
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are, say, initially, in restricted areas?
2 A
I can't.
I don' t know enough about them to -- about 3
the numbers, and so forth.
4 G
Okay.
Am I accurate in thinking that the exposure 5
levels for restricted areas are different than for unrestricted 6
areas?
7 A
- Yes, a
G Okay.
Why would that be?
9 A
I could only give you speculation because it's more 10 apt that nembers of the general population would be in the 11 unrestricted areas, the non -- those persons who would not 12 be considered to be employees of the licensees would be more 13 apt to be in those locations or probably only allowed to be 14 in them..
15 Restricted areas are those areas where actual opera-16 tions are going on where persons who are actively employed 17 in that kind of business are present.
18 G
Is it generally true that under the existing NRC 19 regulations, persons in restricted areas are permitted to 20 receive a higher radiation dose than persons in unrestricted 21 areas?
22 A
That's my impression.
Yes.
23 G
Okay.
Do you know why that decision was made?
24 A
I don't.
23 G
You also have dif ferent standards with respect to Acme Reporting Company i
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1 radiation and radioactive materials.
Is that accurate?
2 A
I'm not sure.
0 Okay.
We will just, proceed.
For persons who are exposed to radiation, you've indicated that there 's a certain l
4 5
quota or exposure rate that is permissible.
6 A
Yes.
7 0
Can you speak to how the accumulation of exposure 8
is trapped over time to assure that particular employees or that the public sector does not receive exposures in excess 9
to of the limits?
11 A
I gave you my understanding of that.
12 g
Okay.
A Mr. Alexander, that's his bag.
q 0
Okay.
The licensee is required to report over-14 exposures to the Commission as well as total occupational 15 16 exposure for a facility at the termination of employment of t-the person at that facility.
At that time, those doses are 18 reported to the Commission.
The total occupatio r $ W J
that is to say, if the 19 person has been on more than one job -- can be reconstructed go from the termination reports that we receive here.
- Because, 21 as a -person tracks through industry, unless he changes his 22 name, or things like that,, or tries some devious things, can 23 be summed here because cach time he ends his tenure of work 24 at a particular plant, that report is made to the NRC.
25 Acme Reporting Company i
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IIe may go into anothe. plant at the-terminatio'n of
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that.
And sc we have a number of termination reports on par-3 ticular individuals.
And I believe that's how we keep the 4
sums of the total exposures.
5 Tne other information is kept by the licensee, which 6
is inspectable.
That information is inspectable by NRC per-sonnel, but does not have to be recorded g
G When you are considering standards, you interrelate g
with the Environmental Protection Agency in their work in 10 this regard?
11 A
They write the overall environmental standards.
In 12 other words, when 4 0 CFR 190 goes into ef fect, then we will 13 be bound by that.
G What will 40 CFR 190 do?
14 A
That sets the permissible population exposure to 15 radiation.
I believe it's 25 millirem per year total body 16 dw 4-W Hu%
1-and 75 -- some thing like that.
And, the re fore, NRC will have 3
to set its business so it does not exceed 40 CFR 190 levels.
ig 19 G
Okay.
Do you know when 40 CFR 190 is scheduled to come into effect?
20 21 A
I believe it's December of this year.
I'm not sure.
22 I think it's December.
23 G
Will the ::RC regulations have to be tightened to I
y meet EPA 40 CFR 190 standards or loosened, or what?
A I don't believe they will have to be tightened.
25 i
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1 I think we ' re pretty well within them now.
There's a possi-2 bility for multiple unit sites that there may be a limit im-3 posed by 40 CFR 190.
But I don' t know how it's going to be 4
done.
5 Most sites that I know about can make that right 6
now.
7 G
When you're considering any petition for rulemaking 8
or any rulemaking generated from any initiative, is EPA 9
routinely notified and does EPA normally participate in that to rulemaking?
11 A
I can only tell you my only experience in this 12 regard.
Back to the NRDC petition again, it's very likely 13 that there will be joint EPA /NRC hearings in that area.
I 14 know that NRDC petitioned both EPA and NRC in the same area.
15 And it turns out that EPA initially denied the petition.
16 And then, I believe that they've reopened it; re -
17 opened consideration.
And that's part of why the hearing is 18 being held.
If EPA doesn't act fast enough, I imagine that 19 the Commission will go ahead with the 20 0
Is it your normal procedure, when you receive 21 petitions for rulemaking changes, that you notify EPA and 22 other Federal agencies of that receipt and invite their par-23 ticipation?
24 A
I don't know.
I'm not in that line.
25 Okay.
Have you -- do you normally contact the Acme Reporting Company
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Occupational Safety and Health Administration when rulemakings 2
come in involving workers?
3 A
I don' t know.
I believe they might also be a party 4
to this joint hearing too.
But I don't know what the normal 5
procedure is for contacting them.
6 G
Would you know of any normal procedures of the 7
same sort involving NIOSH, N-I-O-S-H, the National Institute 8
of Occupational Safety and IIealth?
9 A
Not with petitions.
We work with NIOSH in other to ways.
One specific way is with respect to Three-Mile Island.
11 Secretary Califano requested assistance in getting worker uAdv 13 exposure data at Three-Mile Island and route to Chairman 4
13 Hendrie in this regard.
14 And Mr. Purple was appointed as the coordinator of 15 tha t, !!r. Bob Purple who is my boss.
I worked with him 16 closely on this.
And we had that with NIOSH and we have 17 supplied them with information and material.
is G
Well, wo will get to that in some greater detail 19 in a minute or so.
Do you work with fashioning any standards 3
other than standards with respect to permissible radiation l
l 21 levels?
I e
A Yes.
23 4
What other kinds of standards do you work in --
24 A
Well, standards with respect to the medical appli-25 c c.tions --
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G Okay.
2 A
-- of radioactive materials.
3 G
You mentioned --
4 A
Some of these relate to such things as medical 5
misadministrations.
Do physicians who, for one reason or the 6
o the r, who are -- le t ' s s ta rt that o ve r again.
If there is an incorrect application of a radio-w 8
isotope during diagnosis for treatment, how is that managed?
How should the NRC be notified?
Should the liRC be notified?
9 10 At what level of mismanagement should that report be made, if at all?
These kinds of things are considered.
11 12 In the general license to use readioactive materials 13 in diagnostic kits, should veterinarians be allowed to be 14 part of the general license rather than operating under 15 specific licenses, these sorts of things.
If our inspection 16 and enforcement people find something out in the industry on t-control of radioactive materials in plant were requested to 18 help out to write a new rule to take care of that situation.
As a matter of fact, we 're involved in something 19 like that.
3 21 G
Okay.
But what do you mean if they find out some-thing involving --
22 A
In othe r wo rds, there 's a way in which' radioactive 23 materials can be stored under lock and key outside of the 24 control area of a nuclear power plant.
However, the controls 25 Acme Reporting Company
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inside -- you remember not itoo long ago, some urdn~ium got out 2
of a facility; I've forgotten.
Some fuel material was just i
3 taken out and the people found it in a field.
4 Our I&E people said the regulations don' t provide 5
for things like that.
ife ' re working on how to control those 6
now inside the restricted areas.
So we ' re writing a regula-7 tion now to tighten up on the handling of materials.
8 G
How would you go about making d'ecisions with respect 9
to regulations of that sort?
10 A
Nell, you make decisions on controlled access.
Or 11 if one looks at a whole variety of different types of decisions 12 that could be made, do you control the access, do you lock 13 the materials up, I me an, a whole bunch of things.
And then --
14 or a series of decisions.
15 And then one recocmends, via a series of elimination 16 or discussion considerations, which is the best choice to 1-nake --
18 G
Is it a common sense kind of determination?
19 A
Yes.
m G
Do you have any criteria, guidelines, re gulations 21 or other documents that would guide - decisionmaking of that 22 sort?
23 A
This one, no.
That kind of -- this particular 24 situation, no.
Gene rally, if we came up with a decision, l
25 certainly if we cace up with a decision on this, we would send i
l Acme Reporting Company 62021 629 4958
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1 it over to Inspection and Enforcement.
And if they thought 2
we were way of f base, they would make their recommendations i
3 and say, we think it ought to be this way, because they' re the 4
people who really know about what is the most. ef fective way to. handle it.
5 6
G I see.
Maybe I'm incorrect here.
Did you indicate that when you're fashioning a new radiation level standard, you have no criteria guidelines or other documents to really 8
direct your decisionmaking there also?
9 10 A
I think I nentioned that we just handle it from a technical standpoint.
If there are technical considerations 11 in ef fect, then that's our consideration that goes in the 13 paper that goes to the Commission for their decision.
We don' t 13 make the decision on that.
We make the recommendations 14 along those lines.
la.
G Okay.
You make a recommendation based on the health 16 e f fects, I guess. Okay?
g A
Yes.
18 4
Ano the r o f fice -- yo u tell me i f I ' m wrong he re --
19 another office would make a recommendation perhaps based on y
the inspection and enforcement impacts of a particular change.
g1 A
No.
Not necessarily.
What happens is that the recommendation that's made comes up from all the offices.
So 23 all of these things have to be taken care of, resolved before the final recommendation goes to the Commission.
,a.
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g Okay.
Who resolves all those?
2 A
Well, it's a matter of just talking with one another 3
and going round and round until a resolution is made from 4
of fice to office.
5 g
So there's no single person below the Commission 6
level who could resolve. the differences of opinion among the 7
different NRC offices and come up with one coordinated recom-a mendation for the commission?
9 A
That's correct.
If there are a number of technical to recommendations which are opposite in effect or which conflict 11 those conflicts have to be ironed out before the recommendation 12 goes out.
13 g
What happens if those conflicts are irresolvable?
14 A
I don't know. I've never seen a situation when they we ren ' t.
15 16 Have there ever been dissenting recommendations made 17 to the Com:nission?
13 A
Oh, yes.
19 g
I assume if there's a dissenting recommendation made to the Commission, that indicates that there was some sort of 20 a conflict that could not be resolved at staff level?
21 A
I see where you're going.
22 23 g
All right?
A Yas.
3 g
How is it decided whether to continue working to 25 Acme Reporting Company an nune s
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resolve or whether to submit with a dissent to the Commis-2 sion?
How do you end the process?
3 A
I don't know.
'I don't know when to end the pro-l l
4 cess.
But if I were making those kinds of decisions, at 5
some point, it would become obvious that if there is a techni-6 cal disagreement, at some point, that we'd get to a -- say, 7
well, I'm not going to change from here, and thr.tr e as far 8
as we go -- that would be the dissenting point of view.
We 9
couldn't go any further than that.
10 0
Okay.
When something is presented to the Commis-11 sion, is it presented by means of an oral presentation as 12 well as a written submission, or is it simply a written 13 submission, or how is that --
14 A
In my understanding, it's both.
15 G
It's both?
16 A
Both, first written, and then the Commission has 17 time to digest it, and then there is an oral presentation 18 by the staff.
19 G
Okay.
Is the oral -- who usually conducts the 20 oral presentation?
Do you?
Is there --
21 A
In my experience, generally it's the individual 22 who had major responsibility for coordinating the response.
23 For an NRDC petition, it would be Bob Alexander.
I believe 24 he gave a presentation to the Commission on that.
25 0
All right, okay.
Do you have personal involvement Acme Reporting Company l
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with the present 10 CFR Part 20 standards?
Were you involved 2
with the proposal and promulgation of these standards that 3
are now in effect?
4 L
No.
5 g
For how long have these standards been in effect?
6 A
A number of years.
7 G
Can you be at all specific?
8 A
No -- well, they were in effect when I got here 9
in '72.
They were in effect before that.
My guess is pro-10 bably somewhere around 20 years.
I'm not sure of the exact 11 number of years, but there's -- a long time.
12 4
Okay.
Have there, to your knowledge, been many petitions to change Part 20 standards since they have become 13 14 effective?
15 A
I imagine there have been quite a few.
I'm only 16 familiar with three or four, maybe up to five of them.
But 17 I'm sure there are a lot more.
That is -- well, I know there have been plenty in the medical area, all right --
18 the three or four or five have been in the reactor area, 19 20 applicable to nuclear power --
21 O
Nuclear power --
22 A
Power generation.
I know there have to be a 23 tremendous amount.
Waste disposal is part of it.
I know 24 there are petitions on waste disposal.
Dose limits -- I 25 know there are, with those.
Medical -- I know there are a Acme Reporting Company
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lot of them there.
A whole bunch of petitions.
2 0
Do you have familiarity with any of these petitions 3
-- firsthand knowledge?
4 A
Yes, I've had -- I've made technical input to 5
several of them.
6 G
Could you tell us about those?
7 A
One in particular was a petition by, I believe, 8
Honicker, and this was a petition to shut down the nuclear 9
industry, all nuclear power reactors.
10 When was this petition received?
11 A
I believe it was last year,
'78.
And I was involved 12 in writing some of the technical analysis, in responde to 13 contentions, on that petition, and testified -- almost --
14 never quite got to testify in court.-nThe case happened to be 15 thrown out.
They came to the wrong court.
16 NRR was responsible -- had the basic responsibility 17 for that petition.
I have had technical input to the NRDC 18 petition.
l 19 G
Let me interrupt you -- what was your technical 20 input for the --
l 21 A
Ch, answering questions on radiological health 22 effects, analyzing some of the arguments made by the petition-23 er, and responding to them, and also being available to 24 give testimony.
25 4
Did you just state that the nuclear industry was Acme Reporting Compony
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compelled to meet'the radiological health standards?
Your 2
testimony went beyond that?
3 A
What we did was, whera a piece of research in 4
the field was analyzed or used as a -- used for a conclu-5 sion, the basis for a conclusion, we went back to the ori-6 ginal material, and actually examined what the researcher 7
said.
And in some instances, we found that there was dis-8 tortion in the way the material was presented.
We also 9
brought in other evidence, other material, research material, 10 that applied to the same situation, and came up with conclu-11 sions on the individual contentions.
We didn't -- as part 12 of the technical analysis.
We didn't make any decision 13 on whether or not -- or the petition should be denied.
We 14 just looked at the technical aspects.
15 4
Okay.
You were just mentioning t~a NRDC --
16 A
NRDC.
The NRDC mentioned some recent research that 17 we at NRC had already analyzed, and so we included a response 18 to the presentation at NRDC in the petition.
h ere respon-19 sible for that.
That was both Mancuso, Stewart Kneale's
^
62 &
20 work, and Irwin Bose,'s work.
We had responses -- and 21 they're included as an appendix to the petition -- a response.
22 O
Okay.
Would it be possible for us to simply 23 review the files for those petitions in those proceedings?
44 Would it be a problem at all?
25 A
Copies of the recommendations --
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Okay.
Were there other petitions?
2 A
I can't recall the names of them.
3 g
Okay.
When you've fashioned standards, with respect 4
to radiation --permissible radiation levels, is it fair to 5
say that the primary information which you consider is 6
available scientific analysis of the health effects of ion-7 izing radiation?
Is that a --
8 A
No, I don't fashion the standards -- ok~ay.
9 O
Who in the office does?
10 A
Starting from there -- would you repeat that?
11 4
Okay.
Let me rephrase the whole question.
12 A
Okay.
13 G
I know that what your office does is analyze 14 the radiological health effects, okay, of ionizing radiation, 15 and you come up with standards, okay, which you would recom-16 mend, and they would go through the entire rulemaking process, 17 okay -- you would recommend some level?
1 18 A
Okay.
19 4
Okay, fine.
When your particular office is reach-3) ing its own recocmendation; before it gets tossed into the 21 pot with other people's inputs, as it were, do you exclu-22 sively consider, on the scientific side, studies that per-23 sons other than NRC employees have made?
Or do you also 24 commission studies of your own, with respect to ionizing l
l 25 radiation and its effects?
1 I
l Acme Reporting Company 1
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A We have a limited capability to have research.
2 We can fund to a limited ^ extent what we call technical 3
assistance, and that can be funded -- those sorts of things 4
can be funded by individual offices within NRC, without going 5
through research.
6 For instance, the *ype of thing that we can do --
7 and that is to say, let's.ssue a contract to do a litera-8 ture search, to come up with the best concentration factors 9
for radioactive materials in water, so that we can use 10 those materials in our calculational models.
Or if there are 11 data on effects, let's put out a contract to have those 12 data reanalyzed independently, to see if we get the same 13 results as other researchers in this area.
14 We have done that with the Mancuso-StewartrKneale 15 data at Hanford -- those kinds of things we can do.
Basic 16 research, on the other hand, where laboratory -- glassware 17 research, is generally not within the scope of the types 18 of things that NRC does; The Office of Research has a much 19 broader area.
If a particular type of research cannot be 20 funded within an office, then it's requested that Research 21 fund it, and they go out and contract it, and they follow 22 those contracts through."
23 So it's quite possible that we can do a small 24 amount of research, with respect to scme of the technical 25 decisions that we make.
Most often, however, we count on Acme Reporting Company 2ca,........
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research by -- and analyses by groups outside of NRC, whether 2
it be DOE, or research funded by universities, or done at 3
universities, funded by other people, or other governments, 4
for that matter -- summaries of research that are presented 5
in international documents by the ICRP, and so forth.
6 0
You mentioned the use of models.
Could you just 7
give us a general feeling of -- what do you mean by that?
8 A
Ch, sure, certainly.
If we have radiation re-9 leased into the environment, we would like to be able to 10 calculate how that material gets to man, and what the expo-11 sure to man would be.
So one can measure directly -- what 5
12 one would like to be able to compute, based on a release, d
13 what a man sitting downstream might gat, and that's a mathe-14 matical calculation -- and the parameters that go into this, 15 and that calculational technique is a model.
16 0
So the model is simply the method by which you 17 compute the --
~
IS A
It's a mathematical description of the real world.
19 G
Okay, okay.
When you're originally taking into N
account scientific data and other information that would 21 generate your recommendation, would you use a model in r
that step of the -- of your analysis, or would the model 23 follow that?
Do you follow me?
24 A
In my line of business, what I would see is a 25 recommendation from -- or a piece of information in a document A, cme Reporting Company m,
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that says, one could get so many health effects per unit of I
2 exposure.
They have already modeled to get that.
3 G
Okay.
4 A
I'd take the end result.of that.
5 G
Do you have any standards with respect to trans-1 6
porting materials to and from plants?
Do you work with 7
standards --
8 A
No, that's not my branch.
9 G
Okay.
Have you ever considered any standards-10 with respect to the availability of potassium iodide, or any-11 thing like that?
12 A.
Not standards.- I'm actively involved right now 13 in responses and considerations of the use of potassium 14 iodide as a prophylactic for thyroid exposure.
We have re-15 ceived letters both from the Congress and from our Commis-16 sioners asking us about -- asking us to review certain docu-pW 17 ments that oppose this material, asking us whether or not A
18 we agree with this, whether we have recommendations on the 19 use of potassium iodide, and within a week or two we should 20 have the response of the Commission, on an office level, 21 that is to say, a joint office analysis of this situation.
22 G
When were these requests made?
l 23 A.
I guess they came in over the last three months.
24 G
Is it your understanding that these requests were 25 generated by the Three Mile Island incident?
Acme Reporting Company 2 * " " "i
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A Yes.
2 G
Okay.
Have you had any other requests generated 3
by the Three Mile Island ~ incident that --
4 A
Oh, we have numerous -- numerous requests, letters 5
from the public, asking such things as, is it safe for us 6
to drive through Three Mile Island, or requests from Congress-7 men saying, I have two of my constituents who work at Three 8
Mile Island, and have gotten these deses -- what's the chance 9
they' developed cancer?
Those kinds of things.
10 We have a host"of physicians'and~ industrial organi-11 zations writing us, saying, I have this neat test for deter-12 mining the effects of radiation -- shouldn't we look at all 13 the people around Three Mile Island?
Things like that -- a i
14 whole raft, a variety, of materials like that.
15 0
Are you reconsidering any of your permissible is radiation levels as a result of Three Mile Island?
t-A No.
18 4
Have you received any requests to do that?
19 A
I haven't seen any, but I imagine there hrve -- or 20 will be.
21 O
Okay.
Are there any studies that have been under-22 taken with respect to any of these areas, to your knowledge, 23 since Three Mile Island?
24 A
Well, there are studies tha* have been undertaken 25 by the State of Pennsylvania, and some studies by the Acme Reporting Company I
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Federal -- by Federal agencies.
2 G
Anybody at NRC?
3 A
Yes.
There, I believe, is an attitude survey 4
going on with people around Three Mile Island, but I'm not 5
much more familiar with it than that.
6 4
Okay.
You indicated you were Project Manager for 7
a radiation -- epidemiological study.
8 A
Yes.
9 G
Could you tell us about that?
10 A
The Congress directed NRC to perform a feasibility 11 study.
The aim of this was to determine if there are popu-12 lations which are suitable'for follow-up epidemiological 13 studies -- effects.
14 4
When did Congress direct you to do this?
15 A
The -- we knew that this was coming, in, like, Octo-16 ber or November of 1978.
The actual law was signed, 7 O
'M 17 think, somewhere around -Ncic:c.ber $4$" /
vember 6, about the turn
%f.1 18 of the year -- and we had started working on this before 19 that time, in anticipation.
20 0
Okay.
21 A
The contract has been issued, by the way.
And we 22 should have a report to Congress on progress of the contract 23 and preliminary results at the end of September.
24 G
Okay.
What is the goal of the study again?
25 A
The goal of the study is to find out if there are Atme Reporting Company va,
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-- well, what the best' populations to study, from the stand-2 point of low-level radiation effects, are, what -- if there 3
are no optimal populations-to study, to recommend what data 4
are needed, what steps should be taken, what kinds of things 5
can be done to get the numbers for Congress, give Con-6 gress a feel for the costs necessary for doing these studies, 7
and the time that it might take to do them -- to let Con-8 gress make a well-based judgTnent on what they want to do in 9
this area, how they want to continue.
10 So this study is to inform Congress of what it 11 will have to do, and how much it will have to spend, and 12 how much effort it will-take, if Congress really wants to ex-13 Plore the area of health effects of --
14 A
If Congress wants to get an answer on the dose 15 response -- how many REM it takes to cause so many effects, 16 you know, within certain bounds.
17 4
What do yott mean, within certain bounds?
18 A
In other words, let's say, you want to be 50 percent 19 sure that your number's riiht --
20 0
Oh, I see.
21 A
-- or do you want to be 95 percent sure that your 1
22 number's right?
Those kinds of considerations.
23 0
Okay.
Well, in the past, when the standards of 24 10 CFR Part 20 have been drafted, what degree of certainty 15 is tagged to those?
Acme Reporting Company
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A I don't know what those are.
2 0
Okay.
Do you know with whom I could speak with 3
respect to drafting these actual standards now in place?
4 A
I have a man in my branch who is really good in 5
this regard.
6 G
What is --
7 A
His name is Baker, Robert Baker.
8 g
And you say really good --
9 A
Yes, he's been-involved -- he's an old-timer, and to he knows how these things were developed, what went into 11 them.
He was involved in the Appendix I considerations --
12 very sharp.
13 S
Okay, that's good to know.
Now, in addition to 14 this study that Congress mandated, does.the NRC have any 15 other ongoing studies with' respect to the health effects of 16 ionizing radiation?
17 A
Yes.
We reported to Congress on the means and 18 capabilities of EPA and NRC in the area of low-level health 19 effects.
Also, within that document, was a compilation of 20 the studies being carried out by NRC in the various offices 21 with respect to these -- so you might want a copy of that, 22 if you don't already have one.
l j
23 g
Oh, yeah.
I would like a copy of that.
24 A
Okay.
25 4
Can you just estimate the number of studies Acme Reporting Compcny l
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1 ongoing at the present time?
2 A
I can't even give you a guess, you know, with any 3
degree of accuracy.
~
4 0
okay.
Let me focus for awhile on your actual 5
involvement of knowledge of the NRC's reactions to the Three 6
Mile Island accident.
When did you first find out that 7
there was a problem at Three Mile Island?
8 L
Back in March.
Well, we found out that something 9
was going on in the first week, but we had virtually no 10 information of the extent other than, you know, what we 11 started hearing and reading.
We had no -- there were no 12 documents, no papers, no reports that came to this office, at 13 least to my branch, in the first week.
We knew very little, 14 officially, about what was going on.
~
15 G
Okay, the action commenced on a Wednesday, so 16 when you say the first week, do you memn through the follow-17 ing Wednesday, or do you mean --
18 A
As a matter of fact, it was a number of weeks 19 before we started getting regular communications -- descrip-20 tions of what was going on.'
And Baker, actually, had called 21 up and said, isn't there anything available for us to look 22 at?
Where is the material?
So finally we started getting 23 information.
24 g
Well, how did you react to this --
25 A
We were annoyed.
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O You would have expected to receive information?
2 A
Sure, we're the -- wetre calculators.
We ' re the 3
people who would estimate the health effects.
4 O
Estimate the health effects of the releases?
5 A
Sure.
In other words, if,there were some infor-6 mation to be gotten out of releases -- if there were some 7
information on relesses, I'would have expected that to come 8
to the branch, so that we could make some preliminary esti-9 mates on what the effects would be, in that area.
10 G
So you would have expected that once information 11 became available as to the amount of radiation released, 12 and to the off-site dose that that release would cause, that 13 that infor7ation would be transferred to you, and you could 14 then look at it very quickly, or take analysis, whatever --
15 A
Yeah.
16 0
-- and determine what the health effects would be?
17 A
Yeah.
18 G
Okay.
And ycu' heard nothing --
19 A
Ch, it was quite some time before we started getting 20 the individual incident reports or -- I've forgotten what 21 those sheets were.
They started coming -- we got our first 22 ones, I think, in about two weeks.
23 4
Two weeks?
24 A
But we had scme information -- by getting on the 25 phone, you know -- we had to actively go out and search out i
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information -- you know, get some feeling of what was going 2
on.
3 0
Did you first hear of the accident through the 4
media?
5 A
I can't recall.
I can't recall.
My impression is 6
that I walked into the office one day, and somebody says, 7
hey, there's something going on in Pennsylvania -- a release.
8 I said, what is it, and that was all the information that 9
was available at that time.
10 0
Did you at that time make a telephone call to any-11 one else within the Agency or elsewhere to find out what 12 was going on?
13 A
No, no, because from time to time, we get informa-14 tion like this, and it's of no veracity.
But we -- let's 15 see, I can't recall when the first calls were made around, 16 to find out what was going on, clearly.
I do know that 17 there was no briefing -- formal briefing, ever, within this 18 office, as far as I know, to tell us where we were and what 19 was going on.
20 g
Well, the action commenced on Wednesday, March 21 28, and I would imagine'that the media, by Thursday morning 22 at least, would have picked up on it quite a bit.
23 A
Yes.
Well, I'll tell you, by Friday of the week,
~
24 we had the epidemiologist and I, had developed what we 25 thought might be a good plan for follow-up studies.
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4 Okay, the week after that -- on Thursday, the 2
second full day of the accident, did you contact anyone with 3
respect to what was going on?
4 A
I did not.
5 g
Did anyone in this office, other than Mr. -- you 6
said Mr. Baker contacted somebody?
7 A
Yeah, I don't know exactly when he did it.
8 g
Okay.
9 A
But I personally didn't contact --
10 g
Okay, do you know if Mr. Purple did?
11 A
No, I don't.
12 g
Okay.
Did you at any time contact anyone with 13 respect to the accident, and offer your services, or did any-14 one in this branch --
15 A
Well, we started -- on Friday of that first week, 16 when we started considering what kind of studies might be 17 performed, on the population around Three Mile Island, we 18 wrote a mamo and got it into the system recommending these 19 thing = be done.
hd 2 20 g
Okay.
21 22 23 l.
24 25 Acme Reporting Company l
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o.
Did you at any time go over to the Incidence 2
Response Center that had been set up by the NRC to manage the 3
accident or at least keep in touch with it?
4 A
No, no.
I was never personally in the Incidence 5
Response Center.
With my later activities with respect to 6
NIOSH/NRC activities,.
"n-I was in contact with the 7
Center but never went down there.
8 0
Have you ever learned subsequently or discussed 9
with people subsequently why this office wasn't contacted to during the accident?
11 A
No.
12 0
What then was the first thing that this office 13 did as a result of its knowledge of the accident?
14 A
I don't know what the first -- the first step of 15 the office.
I know we did in the branch, describe that to you.
16 G
Okay.
You said you would begin.to consider the 17 followup study.
18 A
Yes.
As a matter of fact, Pob Goldsmith who is the 19 epidemiologist of branch called some people he knew at A
20 Columbia University and asked what types of studies might be 21 recommended.
I understand that some of the staff and faculty 22 of Columbia University met on Saturday, the first Saturday, 23 and we had information from them on Monday.
24 0
They called in?
25 Acme Reporting Compony 2 u. u. 4...
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1 A
They called in on Monday and talked to Bob and I
2 gave him some information, and we wrote the memo recommending 3
that certain studies might be considered.
4 0
Do you know why Bob Goldsmith called Columbia?
5 A
Oh, he's -- he's a graduate student at Columbia 6
University in epidemiology, and he knew.some of the' faculty 7
very well.
8 O
Do you know who he knows there?
9 A
No, I don't.
10 g
Do you know who he called?
11 A
I could find that out but there are some pretty 12 high powered epidemiolo
-- at that time we didn't know 4
13 what the doses were.
So our recommendations were kind of 14 far out,.certain aspects.
15 g
Would you find out who he contacted and who 16 considered it and who got back?
17 A
Sure.
Is G
I would also like a copy of the memorandum that l
19 you put together *tcommending studies.
There is no problem 20 there.
Can you characterize for us from your memory what 21 kinds of studies you recommended?
22 A
No.
I can't give you all of them.
I know that one 23 was -- let me job this down.first.
l 24 g
Go ahead.
25
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A one of the studies involved -- it's called 2
amniocentesis which is a study.that can determine whether or 3
not there is a birth defect or a genetic defect in the fetus.
4 It's a pretty -- it can be a pretty traumatic type -- it&s a 4
5 needle -- and there is a pessibility of injury.
Albeit the 6
rate of ill effects is low, it turns out that this was not 7
a recommended study and in retrospect it shouldn't have been.
8 But this -- because we didn't know what the doses were at 9
the time, these were the kinds of things that could -- we 1
10 envisioned could have been done.
'- 11 0
I see.
To whom did -- when did you send this
- 12 memorandum?
13 A
I think it went the week following the accident.
14 G
The initiation of the accident.
15 A
Uh-huh.
16 4
And to whom did you send it?
1; A
This went to I believe the office director, Mr.
is Minogau.
A l
19 G
Do you know what happened to the memorandum after 20 you sent it?
21 A
Oh, yes.
It was -- we -- there were some discus-22 sions and it was decided that it really wasn't the -- we also 23 recommended that NRC provide some funds so that the studies 24 could be initiated rapidly.
It turns out that, for whatever l
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reason, whether the funds were available or they couldn't 2
be gotten up, that this was not -- it wasn't our job, it 3
wasn't NRC's job to go out and do the particular type of work.
i 4
0 So none of the recommendations was adopted?
5 A
Not at that time.
Subsequent to that time, the 6
state has done them.
The State of Pennsylvania has initiated 7
pretty much what we had come up with early on.
8 0
Was there a written response to this memorandum 9
prepared by anyone?
6vb}?)du k utJ W 10 A
No, no, we - _Bi-li called in and we talked it over.
A 11 O
Were there minutes of that meeting?
12 A
No, I don't think so.
13 0
Do you have any of ~ his personal notes 'of. that meeting 14 or if there is any documentation at all?
15 A
I am sure there is no documentation.
16 Q
When was that meeting held?
17 A
I can't recall for sure; maybe the second week 18 after the accident or something.
19 0
Do you recall who was in attendance?
w 20 A
Probably Bob Goldsmith and myself and Mr. :linog and s
21 there may have been someone else.
22 What else did you or your branch do with respect to 23 reacting to the accident?
24 A
There were some meetings with -- early on among l
25 2.-
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various people within the branches to consider what kinds of 2
tests should be done, what kinds of studies should be done.
3 Mainly, as I remember what was discussed in tl:_se meetings, 4
was you have to know what the people were exposed to before 5
you decide what kind of tests you want to perform.
6 After that, various members of the branch traveled 7
up to Three Mile Island to interact with both the state and 8
other Federal agencies in discussions of followup studies.
9 Bob Goldsmith and I met with people from NIH.
10 0
You went up to Three Mile Island?
11 A
I was up there several times, mostly --
12 4
When was it you went up?
13 A
Well, a month of two after.
This was with 14 respect to the NIOSH cooperation, picking up data"for NIOSH.
15 But there were meetings with -- there was at least one 16 meeting with National Cancer Institute personnel and 17 Department of. Health, Education and Welfare people:also 18 discussing potential followup studies.
19 There were three of us -- three'or four of us who 20 represented NRC on a subcommittee to an HEW committee which 21 was studying the effects of ionizing radiation in general.
22 The subcommittee was chaired by Arthur Upton of the National 1
l 23 Cancer Institutes and deliberations of that subcommittee 24 concerned what followup studies should be done, what emphasis u
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should be placed on these followup studies:
Should they be 2
considerad as studies to look at the effects of radiation or a
the studies to look at the effects of a possible and things a
like that?
We met five or six or seven times with that 5
committee.
6 G
"With" that. committee, you said?
7 A
Yes, with the subcommittee, and their recommenda-8 tions were made to the parent committee chaired by i
9 Dr. Frederickson of the National Institutes of Health.
10 0
Let me clarify the parties here with respect to l
11 followup studies.
First, you were suggesting some followup 12 studies.
13 A
Early on.
14 0
Okay, early on.
Am I correct in thinking that the 15 NRC abandoned that because the State of Pennsylvania and 16 others decided to take up those kinds of studies?
1; A
No.
They were abandoned for reasons other than 18 that.
I think thac the major reason is that that kind of 19 research study is not done by NRC.
We had full knowledge that 20 other agencies, state and Federal, do those sorts of things 21 that were involved and would be doing their own studies.
22 0
When you say 'those sorts of things", you are 23 speaking of studies like amniocentesis?
24 A
That's right, yes, the things that we recommended, 25
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the types of things that we recommended, and that more than 2
likely the studies would be initiated.
We felt some sense 3
of urgency to get these things -- to get studies started 4
because we thought that there may be some loss of information 5
by people moving out of the area, getting.the earliest 6
results of the highest levels of exposure, that kind of thing, 7
It didn't happen that way.
The studies have been performed 8
or are being performed.
9 G
Did NIOSH come up with specific followup study to recommendations at about this same time?
11 A
It was another week.
No, let me take that back.
12 a
Okay.
13 A
About the second week the state was involved pretty 14 heavily and NIOSH and CDC were involved in recommending the kinds of things -- or in considering the kinds of things 15 16 that should be done.
Those studies weren't instituted until --
17 what is it, August nowl-- June -- so there was some long A
is period of time before any of the studies were initiated.
19 O
So NIOSH was one.
20 A
Uh-huh; CDC.
21 4
What studies did NIOSH -- to the best of your 22 recollections, what studies --
23 A
Oh, I can't recall what NIOSH recommended.
They 24 had a protocol or recommended studies.
CDC also had some 25 Acme Reporting Compony
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studies.
You might check with Dr. Upton's subcommittee to 2
get all of the -- those pieces of material.
We krsw the state 3
was involved early on.
They had a pretty ambitious program 4
already under way for other purposes which was -- and that 5
program was adapted to fit and extended to fit the Three Mile 6
Island situation.
Then of course a whole raft of people 7
from the outside -- the University of Pittsburgh and EPP.I --
8 G
What was that last one?
9 A
E-P-R-I.
10 0
What is that?
11 A
That's Electric Power Research Institute out in 12 California.
They are funding some studies with the state, 13 providing funds for the state to do some work.
We know that 14 the National Institutes of Mental Health were involved in 15 setting up studies.
We know -- I think it's -- I believe 16 it's the Department of Defense that was in doing some 17 attitudinal studies.
As a matter of fact, they wanted to go 18 in with NRC on the same questionnaire, and the questionnaire 19 arrived here and we were absolutely flabergasted at t!a kinds 9
of_ questions that were being asked.
We asked to be separated 21 from -- you know, take the two scare things apart.
That l
22 questionnain's ridiculous.
l 23 G
Are you keeping track of the different studies that 24 are going on?
25 J
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1 A
As to the results?
Well, there are no results in 2
yet.
We know what studies are going on though.
We will 3
certainly know what the results of those studies will be.
That 4
is to say, we will be informed of what they will be.
We have 5
our ideas about what they'll reveal.
6 0
To your knowledge, is anybody at NRC being 7
consulted with respect to the progress of these studies or 8
asked advice on the progress of these studies?
9 A
Not in the recent past, not with respect to my 10 branch.
Bob Goldsmith assisted in constructing the question-
. 11 naire that's being used or that has been used for the 12 population census within five miles of the plant.
13 0
Whose is that?
14 A
shat's a -- that's a government -- I believe it's 15 CDC is performing that.
He's been contacted by the State 16 of Pennsylvania several times since that time to -- and has 17 met a couple of times to talk over the other studies.
So 18 we've bee' involved in that regard.
19 0
What other kinds of involvements have you had with 20 the Thren Mile Island accident?
21 A
Nothing other than the interaction with NIOSH on W
22 the worker deaths-tb W 23 0
On the worker deathr.
I don't think we talked 24 about that too much.
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A No.
I introduced it some time back by saying 2
that Secretary Califano wrote a letter to Chairman Hendrie --
3 0
Correct.
^
l 4
A
-- requesting assistance, and that NRC provide 5
NIOSH with dosimetry information on workers, with the idea 6
in mind of establishing a worker registry to allow for future 7
follow-up studies, and Mr. Purple, Mr. Robert Purple, was --
8 in Chairman Hendrie's response to Secretary Califano, he 9
agreed that we would cooperate to the fullest extent, and 10 assign Mr. Robert Purple as the coordinator.
11 Since that time, I have been responsible for the 12 coordination of activities between NRC and NIOSH.
We've 13 had a meeting here at headquarters.in this building, and 14 had an individual from Three Mile Island -- he works for 15 NRC, Office of Inspection and Enforcement, come down and 16 give a presentation on the types of materials, the types of 17 data, types of records, that are being kept on workers and 18 contractors.
19 0
And who is that?
20 A
His name is Kinneman, John Kinneman, K-I-N-N-E-1 M-A-N.
He's with Region 1, NRC, Inspection and Enforcement.
l 22 And Mr. Kinneman came in to give his presentation to NIOSH --
l l
23 came in from Cincinnati, and locally.
In addition, we have 24 met with Met Ed and some of the representatives of their 25 consultant firms.
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THE REPORTER:
What was that?
2 THE WITNESS:- Met Ed, that's Metropolitan Edison.
3 On site -- to find out what sort of materials are available, 4
and the results of that meeting were also sent to NIOSH, 5
as well as some of the data forms, and so forth -- the kinds 6
-of things that are being kept.
7
-BY MR. PEARSON:
8 Okay, are there -- I assume the letter from Mr.
9 Califano to Mr. Hendrie is available?
10 A
Yeah.
11 g
We'll get a copy of that --
12 A
Sure, and the response --
13 G
And the response, and were there any minutes or 14 notes kept of the briefing by Mr. Kinneman?
15 A
No.
It was reported in -- just in a short way, 16 in our weekly events.
NRC has a weekly events publication --
17 it's in there.
The meeting was on the 17th of last month, I 18 believe --
19 G
Okay.
20 A
-- 17th or 19th of last month.
21 g
If we could see that, that would be helpful.
22 A
I'll see if I can dig it out.
Generally, those 23 things get thrown away.
l 24 G
And --
25 A
Let me take some notes.
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G All right.
If you have any follow-up documenta-2 tion with respect to the -- to this study, and this worker 3
registry --
4 A
Yeah.
~
~
l 5
0
-- that would be also good.
6 A
I think I can provide something on that.
7 0
What's the status of that effort right now?
8 A
At that meeting, the -- the fellow at NIOSH was in 9
charge, and his name was Frazier, Tod Frazier.
And he's 10 in the NIOSH office in Cincinnati -- said that they would 11 consider the presentation of the material, and write us a 12 letter -- contact us, as to what their recommendations would 13 be, from the standpoint of material to be recorded, data to 14 be collected, and so forth.
15 And it's been roughly a month now, and we haven't 16 received it.
17 0
Were there any' other studies or post-TMI involve-18 ment that we haven't discussed about yet, that you'd like 19 to bring out?
20 A
Nothing -- you mean, from the standpoint of health 21 effects?
22 G
That's correct'.
23 A
No, there's nothing that I can think of.
The 24 potassium iodide study was brought up as a sequelae to Three 25 Mile Island, but that was always there.
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4 What do you mean, that was always there?
2 A
In other words, the idea that potassium iodide 3
could be used prophylactically, has always -- has been known
)
4 for some time.
The point is that great attention has been 5
called to its use, and to establishment of a position 6
within the Agency, because of Three Mile Island.
It's no-7 thing,-- it's not new.
No, I can't think of anything else.
8 G
Okay.
Can you think of any other involvement that 9
you may have had, at the' time of the accident, which we 10 have not yet spoken of?
11 A
Not that I can recall.
12 4
Okay.
Do you have any other ccmments to make with 13 respect to the accident ind the amount of involvement you did 14 or did not have in it?
15 A
outside of the initial disappointment and frus-16 tration, after that first week and a half was over, we became 17 actively involved in it.
And I felt a lot more comfortable IS with the position of the Branch, and so forth, that we were 19 having our say.
20 0
Mm-hmm.
21 A
It also became quite cle'ar that it wasn't unusual 22 in retrospect to see that we hadn't gotten good information, 23 because at that time, early on, nobody had good information, 24 and there appeared to be general disorganization throughout 25 whatever Agency one was interested in.
And so it wasn't Acme Reporting Company u v n.....
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unusual in that regard. 'The -- as time went on, we have 2
taken a much more active part, and those things that we had 3
recommended early on, the types of considerations, have been 4
initiated, so that's -- we just hope that we haven't missed 5
anything by not getting in there earlier.
6 G
Were you aware of the recommendations that were 7
made at the time of the accident by NRC, with respect to 8
evacuating the Three Mile Island vicinity?
9 A
Only vaguely -- only vaguely.
I have the impres-10 sion, and I can certainly be wrong, that we were the first 11
'o recommend evacuation.
And it was held off for a couple 12 t.f days, and then it was taken off -- but I could be re-13 versed.
Maybe it was the State that recomnended it.
But I 14 think that NRC did it.
15 4
Would you have liked to have played a role in 16 recommendations of that sort?
17 A
Yeah, I think so.
18 0
Do you think that you would have had a significant 19 role to play in advising the decision-makers with respect to 20 evacuation recommendations?
21 A
I hope I would have.
I' don't know for sure.
22 4
Well, do you think the information you could have 23 provided would have been of value?
24 A
I think it would have been of great value.
25 0
Why?
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A Because they wouldn't have evacuated.
I would not 2
have recommended it.
3 0
You would not have?
4 A
Yeah, I didn't think the doses were high enough to 5
call for that.
6 S
Well, one of the figures that was mentioned was a 7
release of 1,200 millirems that had been measured, and was 8
believed to be at the north gate, or at least at the boun-9 dary of the property.
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10 A
Well --
11 4
How would you have reacted to that kind of infor-12 mation?
13 A
well, the dosimetry information I finally got, was 14 considerably lower than that.
Now, if it looks -- if it 15 looked like the population distribution and so forth, and 16 wind direction, was such that there was considerable dose to 17 be gotten, I would have recommended -- the dose would --
IS O
You would have recommended evacuation?
19 A
Yes.
But as it looked to me, I would not have 4
m recommended it.
Once the -- once the largest dose is --
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21 the largest releases probably were never measured.
In other 22 words, early on in the early hours of the accident, those 23 things were never accurately known.
The largest doses were 24 past.
And in my estimation -- that it was already too late 3
for evacuation.
If evacuation was to be made, the largest Acme Reporting Company l
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dose had already been incurred.
Evacuation was made on the 2
basis of uncertainty in doses.
I don't argue with that.
3 I thought that things were pretty well measured by the AHRAM system that was there -- the helicopters that 4
5 came in and so forth.
They were there fairly quickly.
The 6
follow-up studies with dosimeters and things -- that took 7
some time before a response came in, helter-skelter, later 1
8 on -- but I didn't think that the doses were -- potential 4
9 doses were high enough to warrant 360-degree, five-mile l
10 evacuation of -- it was. prudent, I wouldn't argue with that.
11 g
Well, let me ask you a hypothetical question.
.I 12 A
Mm-hmm.
13 0
If you were there, and the information came in 14 that there was a release of 1,200 millirems from the plant, 15 and you assumed that was an off-site reading --
16 A
At the site boundary?
17 0
At the site boundary --
i 18 A
I'd have to ask some questions.
19 G
Okay 20 A
What is it, what material is it, what direction is 21 it blowing in -- where is it going -- if it was uniform Z!
around the site, that kind of dose -- and if we're talking 23 about a dose rate, in other words, 1,200 millirem per hour, 24 or something like that, I would recommend somebody getting out.
25 If we're recommending -- if the dose is something Acme Reporting Company l
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like, oh, a maximum of 50 or 60 millirem per hour, and the 2
wind la olowing pretty fast -- getting it out of there, 3
there's no large dose that's going to be gotten.
Your 1,200 4
millirem per hour might seem high, if a person is there for 5
10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> at that concentration, yes.
6 0
Mm-hmm.
7 A
All right, but if it's going by fast, a person 8
may get one or two millirem from that kind of dose rate.
So 9
there are lots of things to consider.
10 0
What if the only information you had was one read-11 ing in a slight northerly wind?
12 A
one reading in a slight northerly wind, I might 13 think twice about not thinking about it, or --
14 0
okay.
And if your information -- once again, this 15 is a question -- hypothetically and after the fact, and I is recognize all of that --
17 A
How good is the dosimetry, has to be part of it.
Is I have confidence that the' dosimetry is fairly accurate, and 19 we can track the path of the con'. amination, and if I have any 20 feelings about evacuating anybody, it's going to be down-21 wind, in the path of the cloud, rather than just taking an 22 overall action.
l 23 G
And assuming you also want to know if it was a 24 continuous release, or a simple puff?
l l
25 A
Mm-hmm.
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0 And if it were~ continuous, what would your reac-2 tion be?
3 A
It depends upon the rate.
4 0
Okay.
5 A
How much is getting out -- what kinds of calculated 6
dose can we have, what kinds of dose we have.
If we're 7
talking about a few millirem, no, I wouldn't evacuate.
We 8
might cause more trouble by evacuating.
9 0
What if the calculated rates were 100 millirem?
10 A
100 millirem per hour?
100 millirem to people --
11 real dose, or calculated dose, I'd recommend -- if it looks 12 like that's what the rates are going to be, or that's what 13 the doses are going to be -- I'd have to -- I'm not so sure 14 now.
If the total dose were 100 millirem, I'm not so sure.
15 If it's 100 millirem per hour, and it looks like that's 16 going to continue for a while -- are you looking for when I 17 would recommend --
18 4
I just want a sense -- I understand --
19 A
I haven't -- this is the first time I've thought 20 about, quite frankly -- about whether or not I would recom-21 mend it -- evacuation.
Maybe a lot of that is based on 22 hindsight, of what the doses actually were, or, you know, l
23 were measured to be.
Given a hot situation, I'm not so sure 24 I --
25 4
Okay.
Can you think of anything else you'd like Acme Reporting Compony 202' 425 4444
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1 to speak about that we haven't covered?
2 Okay, well, I guess that concludes the deposition.
3 Are we on the, record?
All right, number 2 would be the 4
professional qualifications of the members of the Radio-5 logical Health Standards Branch.
Number 3 -- what is this --
6 A
That's position dcecriptions for the branch mem-7 bers.
8 G
Okay, position descriptions of those branch members.
9 Number 4, the petition submitted by Mr. Honicker, H-0-N-I-10 C-K-E-R.
11 A
It's Ms.
12 0
Ms. Honicker?
Okay, number 5, the NIDC petition, 13 number 6, the report to Congress --
14 A
On needs and capabilities.
15 4
On needs and capabilities.
Number 7, the identi-16 fication of parties that Mr. Goldsmith contacted at Colum-17 bia University.
18 A
And this is the copy of the memorandum that we 19 wrote, number 8.
20 0
Okay, copy of memorandum that you wrote, with 21 respect to recommending --
~
22 A
Follow-up studies.
23 4
-- follow-up studies, all right.
Number 9 is the 24 letter from Mr. Califano to Mr. Hendrie, with respect to 25 coordination with NIOSH.
Number 10 is the response to that Acme Reporting Company m, n.....
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letter.
Number 11 is - -
2 A.
Weekly news items.
3 0
Follow-up information with respect to the coordi-nation with NIOSH, which may take the form of a weekly news 4
5 item and nothing more, and number 12, any other documenta-6 tion you have on that same subject.
7 (The documents referred to 8
were marked for identifica-9 tion as Exhibits 2 through 12.)
to (Whereupon, at 12:45 p.m.,
the deposition was 11 recessed sine die.)
12 I have read the foregoing pages, 13 1 through 75, and they are a true 14 and accurate record of my testimony 15 therein recorded.
K4 W
17 MICHAEL A.
PARSONT 18 Subscribed and sworn to before 19 me this day of 1979.
20 21
~
~
NOTARY PUBLIC o,
My Commission Expires:
23 24 25 i
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REPORTER'S CERTIFICATI 4
5 DOCKET NUMBER:
6 CASE TITLE:
DEPOSITION OF MICHAET, DARSONT 7
HEARING DATE:
August 13, 1979 3
LOCATION:
Rockville, Maryland 9
10 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 above case before the 13 PRESIDENT'S CO3BIISSION ON THE ACCIDENT AT THREE MILE ISLAND 14 and that this is a true and correct transcript of che 15 same.
16 17 18 i Date: August 14, 1979 J.f L,f),.
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21 Official Reporter Acme Repping Company, Inc.
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2-0 M PROFESSIONAL QUALIFICATIONS of 7r. Michael A. Parsont My name is M'chael A. Parsont, I am Chief, of the Radiological Health Standards Branch in the Office of Standards Development of the U.S.
Nuclear Regulatory Comission.
I have served in this position since November 1978.
In this capacity, I supervise and direct the activities of six staff professionals in areas concerning the determination of health risks and effect from exposure to ionizing radiation, radiation epidemiology and regulation of the use of medical devices and pharmaceuticals containing radioactivity.
In addition I am responsible for developing radiological health standards and guides and for the evaluation and assessment of the radiobiological health impacts on the public from proposed and licensed facilities.
Such efforts include the determination of relationships between low-level radiation exposure and health effects from direct radiation and radioactive materials emitted from planned or existing nuclear facilities and from the medical use of radioactive materials.
I am also responsible for directing, coordinating and evaluating technical support research performed by national laboratories and industrial contractors to establish the bases for regulations, standards and guides.
I serve as an advisor and coordinator in: radiobiology for technical assistance contracts.
I represent the NRC at international symposia, and other meetings in areas of radiological impact assessment.
~
From September 1972 until November 1978 I served as a radiobiologist and an environmental scientist on the staffs of the Office of Standards Develop-ment and Nuclear Reactor Regulation, respectively.
In these positions I performed evaluations of the health effects of ionizing radiation; prepared the Radiological Assessment and Radiologiccl Monitoring Sections of Environmental Impact Statements; and performed numerous stuotes related to the impact of NRC proposed and licensed facilities on the environment.
I received a B.S. in Public Healt.: from the University of California at Los Angeles (1955), a M.S. in Radiology from Colorado State University (1962) and a Ph.D. in Radiation Biology from Colorado State University (1967).
I completed additional undergraduate studies in genetics and endocrinology at the University of California, Berkeley and graduate studies in Sanitation Engineering and Public Health at the University of California at Berkeley and Los Angeles, respectively.
I have more than 13 years of professional experience in Public Health, Radiation Biology, Environmental Sciences, research evaluation and coordination and standards development.
This experience was gained at the Alameda County Health Department, Alameda, California; Sandia Labora-tories, Albuquerque, New Mexico (Aerospace Nuclear Safety); NUS Corporation, Rockville, Maryland (Environmental Studies); and the AEC-NRC.
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