I thank ICRP for providing the opportunity to comment on the draft documentFRadiological Protection of People and the Environment in the Event of a Large Nuclear Accident .
Comments in general Comments in general
The draft recommendation states that, in light of the Chernobyl and Fukushima nuclear accidents, major impacts on human health and the environment cannot be avoided when large nuclear accidents occur, and that the draft provides a framework for how to protect people and the environment from the effects of radiation after such large accidents. Nuclear accidents are hardly avoidable, especially in Japan where it is predicted that an earthquake of magnitude 8 or greater will occur with a 90% within 30 years. The best way to protect the public from radiation exposure is to preempt possible causes for exposure. It is willful negligence to turn to discussing how to protect the affected populations after large-scale nuclear accidents while duly noting that the operation of nuclear power plants will inevitably actualize such possibilities of injury. This is on top of the fact that the effects of the Chernobyl and Fukushima catastrophes will last for an unfathomable span of time. Why do we still need to count on the nuclear energy at such an irreparable cost when the humanity around the world retains the necessary technology to produce electricity in a sustainable, safe, and affordable way? The members of the ICRP should know better than anyone else that radioactive contamination and exposure have irreversible impact. However, the members have not made any suggestions as to the phase-out or shutdown of nuclear power plants, which is the most reliable path to radiological protection. This is the most serious flaw of the ICRP recommendations, and the social responsibility of the experts should be questioned.
Further, spent nuclear fuels have been stored in many countries where nuclear power plants are operated, and humans don't even know how to dispose of them. Only Sweden and Finland have adopted a method of burying them by digging a deep hole in solid rock that itself has not had any geological change for hundreds of millions of years. Even in Japan, a country that lacks geosphere stability, there are nearly 20,000 tons of spent nuclear fuel. Given this, the dangers of radioactive materials remain even if nuclear power plants are shut down. In addition, the radioactivity deriving from the TEPCO's Fukushima Daiichi nuclear power plant continues to lie “naked” on site with no place to go. The focus of radiological protection in the future should be shifted to stopping nuclear power plants, and based on this, protecting people and the environment from possible nuclear accidents caused by spent fuels.
The draft defines the role of the authorities as "to develop a radiological protection culture" by providing expertise and information for the public to make decisions about the lives of individuals. Proper knowledge of radiation exposure is required to protect people's health, and the ICRP recommends the LNT model as the basis for this knowledge. However, the information provided by the Japanese authorities to schools and society regarding the risk of low-dose radiation exposure after the Fukushima accident has tended to downplay, or worse yet, to disregard the risk. “Supplementary Reader on Radiation” (Houshasein Fukudokuhon), which was disseminated by the Ministry of Education, Culture, Sports, Science and Technology to schools, and “Basic Information on Radiation Risks”, which was issued by the Reconstruction Agency, are two examples to evidence this among many other available sources. Several former and current Japanese members of the ICRP were involved in writing these publications, and current Japanese members of the ICRP are involved in providing the basic information. It is questionable whether children who are not properly educated about the LNT model, which is the bedrock of radiological protection, can “develop a radiological protection culture” to protect themselves.
The ICRP also recommends that stakeholders participate in all phases of emergency and recovery situations. However, few know or heard about the cases in which stakeholders' opinions were respected (by the Japanese authorities) after the Fukushima nuclear accident. The former (Dr. Sasaki Y. and Dr. Inaba J.) and the present (Dr. Kai R. and Dr. Sakai K.) ICRP members provided written opinions as experts in a form signed by seventeen experts in favor of the Japanese government’s position in the lawsuit that was brought by evacuees from contaminated area against TEPCO and the government at the district courts of Chiba, Kyoto, Tokyo, and Fukuoka. Evacuees are stakeholders of the disaster, and the experts through written opinions made claims against the evacuees. This fact indicates that the ICRP recommendations should first be understood clearly by the Japanese members of the ICRP
NCRP’s conclusion in Commentary 27 and ICRP’s usage of the LNT model as its overarching principle show that there is no better alternative to the LNT model for radiological protection in terms of practicality and prudence. Nonetheless, in this draft, the term “LNT model” never appears. Neither has NCRP’s Commentary 27 been cited. The phrase “no threshold” for the purpose of radiological protection should be replaced with the term “LNT model.”
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