First of all, I appreciate that the reference levels in existing exposure situation have been reduced into half, from previously recommend 20, to 10 mSv per year on this new version. But considering that Japanese government opted the maximum of 20 mSv in case of Fukushima, most likely any national government would choose the reference maximum of 10 mSv, which I think still very high, because the “public” includes small children and pregnant women. Considering your remark in the lines 675, 676 and 677 “The Commission recommends paying particular attention to children and pregnant women, for whom radiological risks may be greater than for other groups of individuals,” wouldn’t it be fair to make different references for children and pregnant women?
Also, your references have a note attached. “The long-term goal is to reduce exposures to the order of 1mSv per year.” But how long is “the long-term goal”? Some ten years? A few decades? Several decades? One hundred years, or several hundred years? It is so vague that it seems as if this note were added to give excuse that the references are too high.
You discuss with the term “affected areas”. But you don’t define which areas are the affected area. It can be understood that any area where the level of radiation stays higher than before the accident, which, in case of Fukushima, covers quite a big area in northeast of Japan. It can also be read the area of 20 km radius where the Japanese government once has given an evacuation order, but you must take in account that other national governments gave an evacuation recommendation to their subjects from fur bigger area. (e.g. 80 km radius by USA, UK, Australia, New Zeeland, and South Korea).
In lines 360 to 362, you say, ”Some residents will choose to stay in affected areas, when this is allowed, and others will leave; among those who leave, some will return and others will relocate permanently.” It may depend on how you define the “affected areas”, but in fact, there are many people who couldn’t “choose”, but had to keep living there, most of them for economic reasons. In case of Fukushima, those who had “chosen” to leave, in spite of economic difficulties, were called “voluntary evacuates, and to begin with, there were small economic supports, mainly they subsidized for the rents in relocated place. But the government stopped them two years ago, after six years of the accident. Since then, the statistics of “voluntary evacuates” have disappeared and those who had no option but to return for economic reasons are counted as if they had “chosen” to return.
In your report you frequently mention the need of “self-help protection action”. This is reasonable, it is specifically important in the long-term phase. But the affected people would have to recognize that authorities have done whatever they can to avoid exposure to radiation for them to willingly accept to understand and carry out the self-help actions.
In this sense, transparency is essential, specially the measurement of monitoring. You mention in lines 1010 to 1018 in the Emergency Response chapter, “Environmental monitoring is required to provide an accurate picture of the radiological situation… Fixed and mobile radiological monitoring equipment can be used… Radiation aerial monitoring also provides useful information on the degree and extent of environmental contamination in the case of widely affected areas.” And you say in lines 2993 to 2995 for long-term phase, “Characterisation of the radiological situation progressively enabled informed planning and implementation of longer-term actions, including the establishment of detailed environmental monitoring plans…” I would like you not only to mention the importance of monitoring but also to specify how the environmental monitoring should be conducted. In case of Fukushima, forests and farmland are not monitored by fixed and mobile radiological monitoring equipment but the value on contamination is only CALCULATED from the measurement of aerial monitoring, which is making a lot of residents and farmers worried.
Talking about farmers, in your draft there are lot of remarks about foodstuff contamination although nothing is mentioned about farmers who produce the foodstuff in affected areas. For many years they have been asking national government to measure the contamination on the soil of the farmland with which they work with their hands, but the government not only denies measuring contamination of the soil but also do not accept the values that were measured by independent specialists. The national government only gives the value calculated from aerial monitoring measurements.
The fixed and mobile radiological monitoring measurements and the value on contamination calculated from the value of aerial monitoring also would have to be more precise for your references to be practical. In Fukushima the measured values are on one meter height from the ground, which is fine for the adults but for the children and animals the measuring point is too high. I repeat what you say “children are the ones whose radiological risks may be greater than for other groups of individuals” (lines 675 to 677). On top of the vulnerability that children have, they would have to bear with ambient contamination measured for adults.
Talking about your references of less than 10 mSv per year, it must be made clear how the Sievert per year can be measured. In Fukushima the 20 mSv per year is measured as 3.8 microSv per hour, which is much higher than 20,000 microSv divided by 365 days and further divided by 24 hours. The calculation is done with the supposition that the residents would stay in the house for 16 hours a day and a wooden house cuts radiation in 40 %. But farmers and children who are fond of outdoor sports most likely stay outside more than 8 hours. On your table you state that “The current recommendation recognises that the most appropriate reference level may be lower than the corresponding band under some circumstances (lines 2020 and 2021) and never “higher” under some circumstances.
As I mentioned above, “considering that Japanese government opted the maximum of 20 mSv in case of Fukushima, most likely any national government would choose the reference maximum of 10 mSv,” and practically there would be people (children, farmers and pregnant women) under much higher exposure than the level you recommend, wouldn’t it be more realistic to lower your reference level of 10 mSv per year?
Last but not least, you talk about public confidence was lost in case of Chernobyl, which coincide with collapse of the USSR (2664 to 2667). In Fukushima public confidence in information has also been harmed. Japan’s ranking in Word Press Freedom Index was drastically lowered from 11th in 2010 to 67th in 2019. You have not mentioned anything about public confidence in ANNEX B FUKUSHIMA. In this annex I have an impression that you thoroughly have looked at the information made by the authorities but you are not much listening to the affected people who live with fear in affected areas.
Thank you very much.
Seiko Nishikawa