Comments for the draft report of “Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident”
Noboru Tatebe , On behalf of “Campaign Against Radiation Exposure“
1. Conclusion of our comments
Many citizens and radiation workers were exposed to radiation by the serious accident at TEPCO's Fukushima Daiichi nuclear power plant. And wide range of environment was contaminated by the large amount of radionuclides.
The ICRP 2007 Recommendation that introduces emergency exposure situations and existing exposure situations and tolerates people's exposure was the basis for measures taken by the Japanese government, including officially declaring an evacuation order based on the radiation exposure level of 20 mSv/y.
The ICRP 2007 Recommendation, which allows people to tolerate exposures, is opposed to the proposed update. Therefore, the report “Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident” should not be published.We should aim for denuclearization.
2. Basic characters of the draft
(1) The draft is in line with the “ICRP 2007 Recommendation” prepared by ICRP to promote nuclear power plants even after the Chernobyl nuclear accident.
(2) The draft includes the following items to let residents accept the exposure to radiation from large nuclear accidents.
(¢¡) Application of the principles of justification and optimization.
(¢¢) Introducing emergency and existing exposures.
(¢£) Use of “reference level”: The “reference level” is not the “dose limit” that determines the maximum value of radiation exposure, but the level of radiation exposure to which residents are made to tolerate. The draft recommends the reference levels of 100 mSv or less for emergency exposure and 10 mSv per year or less for existing exposure. They are very high levels compared to the public exposure limit of 1 mSv per year. They are embodied by the “justification principle” and “optimization principle”.
(¢¤)Immediately following the Fukushima accident, the ICRP issued a “statement” to “radiate protection” measures using the “reference level for emergencies and existing exposure situations” (March 21, 2011) which recommend to use the “reference levels” in Japan to “ensure an adequate degree of protection with respect to exposure to ionising radiation in emergency and existing exposure situations” based on their 2007 recomendation and following pub.109 and pub.111.
The“reference level” at the time of the accident recommended by the ICRP was effectively used as a “radiation exposure level” for post-accident measures in the country, even though it was not yet introduced in Japanese law. The Japanese government and Tokyo Electric Power Company (TEPCO), which should be responsible for the accident, did not provide adequate radiation protections to the residents in the affected areas nor gave proper compensation to the victims of the Fukushima accident.
For example, in the Fukushima Daiichi nuclear power plant accident, areas below 20mSv per year were excluded from the evacuation order. As a result, even after 6 months after the accident, about 4 million residents lived in a high-concentration contaminated area where the surface contamination concentration of radioisotopes that do not emit alpha rays exceeds 4 Bq / cm2, which is one of the conditions considered as a radiation control area.
3. Problems concerning the contents of the draft
The draft includes the following problems:
(1) It is totally ignored that there are actually perpetrators who should be responsible for the nuclear disasters, and the exposed citizens and workers are the victims caused by the perpetrators.
(2) Protection of human rights of victims and recovery of their human rights from violation are not regarded as the fundamental issue.
(3) Justification is treated as a part of the ethical goal and there is no concept of victims' human rights.
(4) In response to the Fukushima nuclear accident, the perpetrator, the government and nuclear industry, should be responsible for providing “radiation protection” based on a public exposure limit of 1 mSv per year without considering the socio-economic factors to protect the industry’s benefit.
(5) It is not specifically mentioned that the individual choice to avoid exposure was not guaranteed in the Fukushima nuclear accident.
(6) It is said that social factors should be emphasized rather than radiation protection in order to deal with large-scale nuclear accidents. This recommendation imposes large numbers of residents and workers on radiation exposure in large nuclear disasters.
(7) The draft recommends that people who are non-radiation workers will be mobilized as responders in the radiation work in the recovery period and engaged in radiation work at 1-20mSv per year. This recommendation is contrary to the present Japanese official guideline and plan. In Japan, the decontamination work by volunteers is controlled at the exposure limit of 1 mSv or less per year in the official guideline. The bus drivers who are engaged in evacuation of residents at the time of an accident in the disaster prevention plan are not radiation workers, so their contracts are made at 1 mSv or less per year.
(8) It is still too early to mention the results of the ongoing pediatric thyroid examination in Fukushima in this document.
(9)Evaluation of the health effects of exposure below 100mSv is completely underestimated. The recent surveys including the INWORKS and childhood cancers after medical CT are not referenced in this draft.
(10) The LNT is adopted just as a hypothesis in this report. However, the relationship should be accepted as a fact with scientific evidences.
(11)“Radiation protection culture” mentioned in this draft leads to the establishment of the policy which neglects human rights of residents by forcing them to accept radiation exposure from the large nuclear disasters.