We, the Thyroid Cancer Support Group "Ajisai No Kai" (https://www.ajisainokai.net/), are the group of Fukushima families whose children had thyroid cancer surgery after the 2011 Fukushima Daiichi Nuclear Power Plant (FDNPP) accident and their supporters. We cordially request that considerations be given to amend the new ICRP report as described below.
Four items are listed for 3 paragraphs and 1 section.
(102) Thyroid dose monitoring
Given the lessons from Japan where thyroid dose monitoring was only conducted in an inadequate manner, ICRP should make recommendations to develop detailed guidelines on post-accident monitoring which include 1) who should be given priority for monitoring, 2) how many to monitor, 3) where the monitoring should take place, 4) who should conduct the monitoring, 5) which monitoring equipment to use, and 6) when to monitor. Furthermore, short-lived iodine and tellurium are also known to contribute to the thyroid dose in addition to iodine 131. ICRP should recommend more extensive monitoring in accordance with the experiences in Chernobyl where monitoring was conducted on many residents for a wide range of radionuclides.
(134) Regulatory limits of food and water and restriction of distribution and consumption
ICRP should recommend that the central and local governments release detailed information on the contamination levels of food and drinking water before instructing restriction of distribution and/or consumption.
(201) Thyroid monitoring programme or thyroid screening
Thyroid screening after a nuclear power plant accident is invaluable from multiple aspects such as relieving anxiety of residents, early detection and early treatment of thyroid cancer, and keeping track of the rate of thyroid cancer occurrence. First-hand accounts of Fukushima residents and thyroid cancer patients should be accurately reflected in the ICRP draft report. Also, it is not clear what justifies limiting thyroid screening to individuals with thyroid absorption doses of 100-500 mGy. According to the LNT model, even a small amount of radiation exposure could lead to excess occurrence of thyroid cancer. ICRP should recommend that thyroid screening be offered to children living in areas with an additional annual exposure dose of 1 mSv or more.
4.3.2.1. Steps of co-expertise process
This section places an emphasis on a dialogue with affected residents and involvement of experts. However, the ICRP draft report should incorporate the techniques of “consensus building” utilized in the fields of political science and public policy. This includes “stakeholder analysis” for careful consensus building, so as not to exclude residents who do not share opinions of the government or main experts. Furthermore, experts should not be limited to researchers funded by the nuclear and related industries or deeply involved with decision-making of the central and local governments. ICRP should recommend inclusion of experts with various stances to avoid “conflict of interest” and ensure “neutrality.”
A total of ten items numbered 1) to 10) are listed for sections B.2., B.3., and B.4.
1) Stable iodine tablets
Please add the following to (B 5):
Immediately after the Fukushima nuclear accident occurred, stable iodine tablets were never administered to the vast majority of Fukushima residents, causing great anxiety among them. However, it became known by a media report at a later time that stable iodine tablets had actually been administered to and taken by the staff and their families at Fukushima Medical University (FMU), located 60 km from the FDNPP. This has contributed to residents’ mistrust of the prefectural government, FMU, and experts.
2) SPEEDI
Please add the following as there is no mention of SPEEDI in this section.
The Japanese government has developed a computer simulation system to predict dispersion of radioactive fallouts in emergency, System for Prediction of Environmental Emergency Dose Information (SPEEDI), which has been used in emergency drills for nuclear power plant accidents.
Immediately after the accident, news organizations requested release of the SPEEDI prediction data. Ministry of Education, Culture, Sports, Science and Technology (MEXT) did not comply with the request stating, “the SPEEDI prediction data may not accurately reflect actual situations because real conditions at the reactors are not known. Release of such data might cause unnecessary confusion.” Instead, MEXT only released part of the data on March 23, 2011. Moreover, despite receiving the SPEEDI data, Fukushima Prefecture did not share it with residents. It was not until April 25, 2011, over a month after the accident, that the entire SPEEDI data was released.
Because the SPEEDI data was not immediately shared, residents had no way of knowing the wind direction or the dispersion patterns of radioactive materials. Consequently, some residents evacuated to areas with higher radiation levels and students outside the evacuation zone continued school club activities outdoors under the radiation plume, sustaining unnecessary exposure. For about 40 days from the March 11, 2011 accident until April 19, 2011 when MEXT released “Provisional thoughts on the use of school buildings and schoolyard within Fukushima Prefecture,” there were no restrictions on outdoor activities in areas other than the planned evacuation areas. During this time, children stood outside for a prolonged amount of time waiting in line for water trucks, and students belonging to soccer, baseball, and track and field clubs often ran around in the dusty, radioactively contaminated schoolyard.
3) Re-opening of school
In (B 8), please make the following changes to the second and fifth sentences with additions shown in red:
The second sentence
On 19 April 2011, the national government decided to restrict the outdoor activities of children at schools where the annual dose could exceed 20 mSv per year or the hourly dose of 3.8 µSv/h. As of 19 April, 13 schools exceeded the dose limit.
The fifth sentence
In May 2011, the national government issued a notification to Fukushima Prefecture to reduce the dose to children at schools from April 2011 to March 2012 to 1 mSv, and offered financial support for decontamination to schools with dose rate measurements > 1 µSv h-1. However, the school survey was only conducted in five locations including the middle and the four corners of the schoolyard, not reflecting high-level radioactive contaminations that might have been present in the immediate vicinity of the school buildings or the gym, in the rain gutters, side ditches or puddles, on the grass or in the flowerbed, near the stone fence encircling the school grounds, and in the school route where students walked. This has led some school children from Fukushima to file lawsuits against the government, demanding the right to receive education in a safe environment.
4) Screening
(B 16) states, “With regard to body surface contamination of residents, screening surveys were implemented in Fukushima Prefecture, including people evacuated from the 20-km zone.” Please add the following:
In the guidelines before the Fukushima accident, the body surface screening level was set as the radioactive iodine 131 surface contamination density of 40 Bq/cm2 or the GM tube surface contamination survey meter measurement of 13,000 counts per minute (cpm). This screening level was based on the fact that the thyroid equivalent dose of an infant reaches 100 mSv in an environment where the surface contamination level exceeded 13,000 cpm. However, because the background radiation level increased after the accident, many residents exceeded the surface contamination level of 13,000 cpm. Combined with lack of water for decontamination, the screening level was then raised to 100,000 cpm.
5) Radiation exposure dose measurement
In (B 17), please add the following:
Simulation results by SPEEDI showed a possibility that internal exposure by radioactive iodine 131 could exceed 100 mSv even outside the designated evacuation zone. An emergency advisory organization at the Nuclear Safety Commission released a memorandum titled “Strengthening the monitoring relating to exposure dose assessment,” requesting the Off-site Center (OFC) and MEXT’s Emergency Operational Center (EOC) to conduct direct measurements of the thyroid doses in children. However, the background radiation levels at the time prevented immediate implementation of the thyroid dose monitoring.
When a child in Iwaki City was found to have a high thyroid dose, more accurate monitoring was considered. However, this was never pursued due to several reasons such as 1) The equipment it too heavy to transport, 2) It is highly likely that the child and the family will be forced to travel far because it will be too difficult to find a location (where the radiation background level is low enough) to conduct the monitoring with high accuracy, and 3) There is a possibility that the follow-up monitoring could cause great anxiety in the child, the family, and the community.”
Furthermore, accuracy and validity of the thyroid dose monitoring survey for 1080 children remains strongly questioned because the background radiation levels where the thyroid dose monitoring was conducted far exceeded the screening level of 0.2 µSv/h. The Ministry of the Environment expert committee even pointed out the issue of what was used as the background level (an individual surface contamination level instead of an ambient radiation level) to subtract from the actual measurements.
6) Breast milk survey results
Please add a new entry on the breast milk measurements as follows:
A consumers’ cooperative in Moriya City, Ibaraki Prefecture, took an initiative to organize a citizen-run breast milk survey which began on March 23, 2011. The survey detected radioactive iodine in some of the breast milk samples: 55.9 Bq/kg from a mother in Kashiwa-City, Chiba Prefecture on March 30; 48.8 Bq/kg from a mother in Moriya-City, Ibaraki Prefecture on March 22; and 11.3 Bq/kg from a mother in Tsukuba-City, Ibaraki Prefecture on March 23. These results led the central government to conduct its own breast milk survey on April 25, targeting 23 mothers in Fukushima Prefecture, Ibaraki Prefecture, Chiba Prefecture, and Tokyo. Radioactive iodine was detected in 7 breast milk samples: 1 from Iwaki-City, Fukushima Prefecture, 5 from Ibaraki Prefecture, and 1 from Chiba City, Chiba Prefecture.
7) Internal exposure measurements
In (B 20), please clearly specify the source for the “whole-body counting and the bioassay method using urine” mentioned in this paragraph.
Additionally, numerous scientific researchers have recently elucidated that part of the radioactive cesium released from the nuclear reactors of the FDNNP exists as highly radioactive microparticles called the “cesium ball.” These cesium-bearing microparticles are water insoluble and not expected to undergo a biological decay. It is undeniable that once incorporated inside the body, they might remain within the blood circulation and the organs, emitting high levels of radiation. Please include the research results of the cesium-bearing microparticles in the draft report and additionally explain that internal exposure by the cesium ball would be difficult to measure by the whole-body counter or the urine testing.
8) Thyroid ultrasound examination (TUE)
In (B 42), please clearly specify the source for the phrase, “Childhood thyroid cancer cases found in Fukushima Prefecture are unlikely to be the result of radiation exposure after the accident.” (FYI: A draft version of the Interim Summary for the second-round screening of the TUE was released in June 2019 by the Thyroid Examination Assessment Subcommittee of the Fukushima Health Management Survey (FHMS) Oversight Committee. The Interim Summary draft was submitted to the Oversight Committee on July 8, 2019 and formally adopted on July 24, 2019, a later date than when the ICRP draft report was made public in June 2019.)
Additionally, please add the following content:
Since the implementation of the TUE in October 2011, over 200 patients have been diagnosed with thyroid cancer but the exact number of patients is not known. Fukushima Prefecture has issued separate interim summaries on 116 and 71 confirmed and suspected thyroid cancer cases from the first and second rounds, respectively. Both interim summaries essentially state that “The detection rate of thyroid cancer was multiples of ten higher than prevalence rate/proportion estimated from the Japanese cancer statistics data.”
The Interim Summary for the second round includes phrases which suggest possible effects from radiation exposure such as, “(In) the second round (…) showed the highest detection rate in the 13 evacuated municipalities, followed by Nakadori, Hamadori, and Aizu,” and “The male-to-female ratio is close to 1:1, which is different from what tends to be observed in a clinical setting (about 1:6).” However, the Interim Summary concluded that “no association is seen between thyroid cancer detected in the second round and radiation exposure” because 1) Thyroid cancer is found more in older children, which is a different age pattern from the Chernobyl, and 2) Analyses of an association between doses and thyroid cancer detection rates using the absorbed doses to the thyroid estimated by UNSCEAR by age group and municipality, revealed no dose-effect relationship. Multiple members of the Oversight Committee and the subcommittee contested this conclusion, but the Interim Summary was adopted as is by the Oversight Committee at the sole discretion of the Committee Chair.
Regarding the fact that many cancer cases have been detected, the Japanese government and Fukushima Prefecture point out that these cancer cases will not have required any treatment even at a later time. On the other hand, the thyroid surgeon who has operated on these patients insist that strict surgical indications had been applied to the operated cases.
9) The status of the pediatric, adolescent and young adult thyroid cancer patients
Please add the following regarding the status of the patients.
Patients who are diagnosed with thyroid cancer at FMU are immediately told that the cancer is “not the result of radiation exposure.” This effectively suppresses any opportunity for the patients to share simple questions and anxiety about radiation exposure, forcing them to seal their feelings.
Not only are they refused their own copies of blood testing results or pathology reports even if requested, but they are also warned by FMU not to leak their clinical information to a third party. The patients are not allowed to have anyone other than family members in the examination room. The FMU hospital is always crowded, and it’s not rare to have to wait for 4-5 hours to be seen by a doctor after the blood work is done. No information is given for an option to receive a second opinion. Some patients feel unsatisfied by the care they receive which does not adequately address the physical issues unique to adolescence or the concerns of school life. Patients who undergo surgery are asked to participate in multiple research projects, but they are never given any explanation or written materials regarding the outcomes of the research.
10) Securing transparency and stakeholder involvement
Please add the following regarding the FHMS:
The FHMS has struggled with securing transparency from the beginning, with no improvement in sight after 8 years. Repeated requests by Fukushima residents as well as thyroid cancer patients and their families to reflect their first-hand account have gone unanswered. Residents’ mistrust of the Japanese and Fukushima governments persists.
(Note: The original comments in Japanese are in the attached PDF file. コメントの日本語原文はPDFをご覧ください。)
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