1. The Nuclear Regulatory Commission has primary
responsibility and regulatory authority for health and safety measures
as they relate to the operation of commercial nuclear plants. While the
NEC has certain requirements in connection with radiation exposure and
medical monitoring of workers at nuclear plants, it has no requirements
for medical examination of workers other than licensed reactor
operators, and even those examinations are only performed to assure that
the operators do not have physical or mental conditions that might
impair their ability to perform their jobs safely. Metropolitan
Edison's (Met Ed)
administrative procedures go beyond this NRC requirement and provide
that all radiation workers receive routine medical examinations to
assess any possible radiation-related illnesses. The NRC only requires
monitoring and reporting of radiation exposure for workers who, in the
utility's view, are likely to receive doses beyond NEC-specified levels.
Met Ed does not keep, and the NRC does not require it to report, a
record of the total radiation exposure of workers from both occupational
and nonoccupational (for example, medical and dental) sources.
2. The Public Health Service agencies of the U.S. Department
of Health, Education, and Welfare (HEW - Now the U.S. Department of
Health and Human Services), whose sole mission is protection and
promotion of the public health, have very limited responsibilities with
respect to radiological health matters relating to the location,
construction, and routine operation of commercial nuclear power plants.
3. Although there were designated channels of communication
and specific responsibilities assigned for federal agencies responding
to the radiological emergency at TMI (for example, Interagency
Radiological Assistance Plan), the existence of these channels and
responsibilities was generally unknown to many high-level federal
officials. In several instances during the course of the accident, some
federal agencies were unaware of what other federal agencies were doing
in providing support personnel and resources.
4. Research on the biological effects of ionizing radiation
is conducted and/or sponsored by a number of federal agencies. In fiscal
year 1978, the federal government spent approximately $76.5 million on
such research. More than 60 percent of this funding was provided by the
U.S. Department of Energy. With the the exception of potassium iodide,
there are no drugs presently approved by the Food and Drug
Administration for the prevention or mitigation of adverse effects of
5. States have primary responsibility for protecting the
health and safety of their citizens.
health officials and health-care providers in the TMI area did not have
sufficient resources to respond to the potentially serious health
consequences of the accident at TMI. Responsibility for radiological
protection in Pennsylvania rests with the Department of Environmental
Resources (DER). At the time of the accident/the Pennsylvania Department
of Health was not organized to respond to radiological emergencies, and
maintained no formal liaison with DER on radiological health matters.
6. During the accident, TMI-area hospital administrators
found no one at the state level with authority to recommend when to
evacuate patients and when to resume normal admitting procedures The
Pennsylvania Secretary of Health viewed his department's role with
respect to area hospitals as informational, not advisory.
7. During the first days of the accident. Met Ed did not
notify its physicians under contract who would have been responsible for
the on-site treatment of injured, contaminated workers during the
accident. The emergency radiological medical care training provided to
these physicians to provide on-site emergency care to such workers was
8. Met Ed experienced several radiation protection problems
during the accident: a) the emergency control center for health physics
operations and the analytical laboratory to be used in emergencies was
located in an area that became uninhabitable in the early hours of the
accident; b) there was a shortage of respirators; and c) there was an
inadequate supply of uncontaminated air.
9. NRC regulations on health physics education of nuclear
power plant workers leaves the details of such things as course content,
frequency, and attendance to the discretion of the licensee, subject to
NRC inspection. Similarly, NRC regulations for environmental
radiological monitoring leaves the details and methods of how these
requirements are to be implemented (for example, types of dosimeters,
kind of sample analysis) to the discretion of the licensee, subject to
NRC inspection and approval.