My Comments on the Update of ICRP Publications 109 and 111:
1. Stakeholders: ICRP is seeking world-wide comments/feedback on the update of its publications on “Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident” based on its experience from Chernobyl and Fukushima. While the Japanese citizens have been given the deadline extension till Oct. 25 to respond in Japanese, have the people affected by the accident in Chernobyl also been given such a discretion with an extended deadline and the possibility to respond in their own languages? ICRP should make special efforts to obtain the feedback from those who had been seriously affected by the disasters in Fukushima and Chernobyl as they should be able to provide their valuable feedback based on their first-hand experiences. Without their feedback getting reflected in ICRP’s new publication, it would be totally meaningless. As ICRP stresses the importance of having the stakeholders on board in the process of updating its documents, the victims of Fukushima and Chernobyl are the most important stakeholders whose voices should not be ignored.
2. Conflict of interest? ICRP is supposedly “an independent, international organization that advances for the public benefit the science of radiological protection, in particular by providing recommendations and guidance on all aspects of protection against ionizing radiation.” Because of ICRP’s claim of being “independent”, the Japanese government seems to respect and follow the safety standards established in the ICRP publications. However, ICRP’s claim of being an “independent” organization is highly questionable as many Japanese individuals who are key members of ICRP committees (e.g. Messrs. Kai, Fujita, Sato, Ban and Honma) responsible for establishing “international standards” are indeed the staff members of the nuclear regulatory agency, authority and research institutes under the Japanese government at the same time. If most of the ICRP committee members from other countries represent their national authorities promoting the nuclear industry, ICRP should not claim itself to be an “independent” organization. Is it fair that the individuals within ICRP striving to establish “new international safety standards” in the event of “a large nuclear accident” are also at the receiving end, having to abide by them at the national level?
3. Lies, double standards and avoiding responsibilities by the Japanese government authorities and the nuclear industry: Many sleepy and sparsely-populated communities in Japan were enticed in the late 1960s and thereafter by the government and power companies to accepting nuclear power plants in exchange for financial support and job creation. They were convinced of the safety of such plants. They were also made to believe that they were contributing to making much-needed cheap and clean energy available in the country with little energy sources against the backdrop of rapid economic growth. When the meltdown at Chernobyl was reported in 1986, they still did not imagine that such a disaster could occur in Japan. They were however forced to wake up and accept the hard reality when the powerful earthquake and tsunami hit the Tohoku region on March 2011, resulting in the meltdown of nuclear reactors in Fukushima, which subsequently forced hundreds of thousands of residents to flee from their communities. Many still remain as evacuees outside Fukushima after more than eight years since the disaster. Both the Japanese and Fukushima municipal governments have forced many of them to go back by terminating the housing subsidies. The government authorities claim that Fukushima’s radiation level is now safe for them to return to, but the radiation level the government is imposing on them has gone up to 20mSv/year after the meltdown, while the standard applied to the rest of the country is still 1mSv/year as currently recommended by ICRP based on the LNT model. Why should the Fukushima residents who fled to other areas must accept the double standards on safety and return? Rightly, many families with young children are reported to stay put where they are despite the economic hardship they face as they fear long-term impact of radiation exposure on children if they return home.
4. ICRP assumes that “a large nuclear accident” will occur in the future and seems to be conditioning us to accepting lower ICRP safety standards, but should we accept lower standards? No!
Considering Japan being one of the most earthquake-prone countries in the world, the Japanese people had been lucky enough to not to have experienced such a disaster till 2011. Now, we are all forced to wake up and accept the reality that a large, horrendous accident can occur again in the future, and in any day. We have also been forced to face the truth that nuclear power, in case of a severe accident, can be astronomically expensive and far worse than anything in terms of environmental destruction and health hazard. Japan, being a small island nation with high population density, cannot afford to ruin its environment by nuclear disaster when there are other sources of energy we can rely on. We must keep our country as clean as possible for our future generations. In view of what happened and what is still happening in Fukushima (e.g. Though PM Abe lied to the world at the IOC conference in Buenos Aires in Sept. 2013 by declaring the problem of contaminated water from the Fukushima plant being “under control,” this is still a serious issue which very much exists with us today.) after more than 8 years since the meltdown, the new guidelines/recommendations for Japan should be focused on how we should avoid such a disaster totally by decommissioning, as soon as possible, all the nuclear reactors existing in this country (Decommissioning of all nuclear plants is now supported by the majority of the Japanese. According to the opinion poll conducted by Mainici Shinbun, on 11-12 March 2017, 55% of the respondents were opposed to restarting of nuclear reactors compared to 26% supporting it). Even some labour unions are opposed to this idea for fear of losing jobs, but such people should be assured of job security as decommissioning of nuclear reactors would take many years, as we have seen in the case of Fukushima. Our nuclear regulatory authorities and research institutes can oversee and contribute to safe decommissioning processes applicable not only to technicians and workers directly involved in dismantling the reactors and facilities but also to minimizing the impact of dismantling operations on the environment and the health of the residents in near-by communities.
5. The problem is the government’s and power companies’ secrecy, closed-mindedness and non-sharing of vital information with stakeholders. No wonder, people have little trust in them and in the information provided by them. The Fukushima’s prefectural wide examinations on thyroid cancer conducted on those who were under 18 at the time of nuclear meltdown in 2011 covered about 380,000 people. After three rounds of checkups, 273 persons were diagnosed with thyroid cancer as of March 2018 (Reported by Ourplanet. 2018/Dec. 14). Considering that the data from the national cancer research center show only 1-2 cases, or 3 at most, of thyroid cancer among 1 million children, Dr. Hisako Sakiyama, a member of Takagi School, (See her article “Shinkokukasuru koujousengan no tahatsu” in Ronza, March 17, 2017) as well as Dr. Tsuda of the University of Okayama are alarmed by the high number of the children in Fukushima diagnosed with the disease. As early as in April, 2016 when the number of children diagnosed with thyroid cancer reached 166, Dr. Tsuda stated that the incidence rate among the children in Fukushima was 146 times as high as that of the national average (see https://news.livedoor.com/article/detail/11420160/). Despite strong concerns expressed by these and other specialists, the Japanese government and the Fukushima municipal authorities, aided by a group of “scientists” of dubious reputation, still keep denying the correlation between the meltdown and a high number of children diagnosed with thyroid cancer. They claim that the high incidence rate is due to screening effects. They also claim that the radiation level emitted into the atmosphere after the accident in Fukushima was far lower than that in Chernobyl. However, according to Mr. Hiroaki Koide, formerly of Kyoto University, who gave a lecture at the House of Councilors Hall on Sept. 11, 2019, the amount of radiation emitted in Fukushima was equivalent to that emitted by168 atomic bombs dropped in Hiroshima. In view of this, no one can surely deny the correlation between the meltdown and children’s sickness. Moreover, there are many problems with the results of this prefectural checkups. One is that the figure representing the number of children diagnosed with thyroid cancer does not include those who had moved away from Fukushima and had subsequently been diagnosed with the disease elsewhere. Another problem is that there were many children, as many as 2,523 as of January 30, 2018, who had not been diagnosed with any clear- cut disease but had been placed in the category requiring observation and follow-up. However, no information on the children in this category has been made available by the municipal authorities thereafter as to what happened to them (See the document entitled “Keikakansatsu no matome” prepared by Mr. Toshio Yanagihara, a member of the plaintiff’s legal team in the Fukushima evacuation trial, Jan. 30, 2018).
To sum up the above, I strongly suggest ICRP to make as much effort as possible in bringing all stakeholders on board in the discussion for the update of the new ICRP publication. If ICRP is an independent organization as it claims to be, it should also encourage all government authorities concerned and the nuclear industry to engage in open debates with those who refute their claims. Without such processes, ICRP might not be able to convince citizens, the important stakeholders in society, to come on board in changing international safety standards with respect to nuclear accidents.