The 2010s have been a time of change for the ICRP. In responding to the Fukushima Daiichi disaster, the commission has turned to ideas of participation and ethics: engaging stakeholders in a ‘co-expertise’ process for the first time (through the ongoing Dialogue Seminars) and explicitly addressing the issue of the ‘ethical foundations of the system of radiological protection’ in Publication 138. In light of these commitments, it is especially heartening to see that this draft - an update to Publications 109 and 111, penned with the benefit of an additional decade of experience - has received comments from a wide range of individuals, as well as representatives of organisations dedicated to radiological protection (e.g. IPPNW), NGOs (e.g. Green Peace Japan), citizen-science groups (e.g. Takagi School), and grass-roots organisations (e.g. Metropolitan Coalition Against Nukes) from across the world. This constellation of actors bring diverse ethical positions and ways-of-knowing about nuclear issues to the table, which promise to enrich our understanding of radiological protection and serve as a solid basis for continuing to hone this document and ensure that the System of Radiological Protection meets the needs of peoples worldwide.
We would like to offer three brief comments on the document that draw from our experience of studying nuclear issues as Science and Technology Studies (STS) scholars.
First, a short note on ethics. A credo of STS is that (seemingly) timeless values do not have timeless articulations. On one level, this position draws our attention to the ways in which ideas of ‘justice’ and ‘dignity’ (central to ICRP recommendations) are not unitary, but open to different interpretations across cultures. On a second level, it draws attention to how cultures are themselves non-homogeneous. Within each society one will find different, often conflicting, ideas of the ‘good’ or the ‘just’, which have been brought together through historical contingency. Public controversies that rage around the management of radiological risks can therefore be understood to revolve, not just around matters of fact, but around matters of value. On a third level, this position draws our attention to how our understanding of the ‘political situation’ informs our impressions of what a fair or just intervention might be (Barry 2012). In the case of nuclear disasters, the imagined temporality of the political situation could prove influential. Do we imagine the exposure event as starting at the moment of the disaster, for example? Or do we consider the conditions under which a specific community was chosen to host said nuclear facility? After all, the siting of nuclear facilities is far from random. Geology clearly plays a role. So too does population density: built (primarily) to satisfy the demands of cities, nuclear plants are inevitably constructed in more rural areas, so as to minimise the number of people put at risk by the plant. Of course, nuclear plants are also NIMBY (‘not in my back yard’) facilities. Cases of voluntarism certainly do exist, but even those who avidly support nuclear power in principal are often unwilling to live near nuclear facilities in practice (DiNucci & Brunnengräber 2017). As a consequence, nuclear facilities are routinely sited in areas where civil society is weak - Aldrich (2008) providing evidence to suggest that authorities in Japan actively avoided selecting areas with strong social ties and local networks, on the grounds that they are more able to mobilise resistance, which may lead to costly delays, or even the cancellation of the project. The unequal geographies of nuclear generation can be expected to influence actors’ perceptions of what a ‘fair’ or ‘just’ response to a nuclear disaster is. This was especially clear in the case of the Fukushima Daiichi disaster. Operated by the Tokyo Electric Power Company (TEPCO), the plant was built for the benefit of the Kanto region, rather than the Tohoku region in which it stands. This was not lost on people living in or near the affected territories. Historical discourses of Tohoku as Japan’s ‘internal colony’ were revived (Hopson 2013), framing the 20mSv/yr threshold as a symptom of the region’s abandonment.
Second, in planning for nuclear emergencies, it is worth noting that the affected ‘local community’ also be ‘international’, either because the affected territory is home to foreign nationals or because the plant is located at the literal margins of a society. In either case, organisations responsible for contingency planning should be aware that, in the event of a disaster, they will not be the only body responding to the exposure situation. Moreover, inconsistencies in responding organisations’ responses may exacerbate the ‘psychological stress caused by urgent actions’ in the emergency phase (¶87. See also: ¶35-38). One example of the confusion caused by uncoordinated actions can be seen in the response to Fukushima Daiichi disaster. The decision taken by some states to evacuate expatriates well outside the 20km exclusion zone mandated by the Japanese state (in some cases, advising evacuation for those as far as 50km away) caused significant confusion and led many to doubt the adequacy of Japan’s safety measures. Meanwhile, the case of Aachen demonstrates how confusion can be sowed by un-coordinated contingency planning for exposure situations near state borders. The German city of Aachen is located in North Rhine-Westphalia, directly bordering Belgium. Three of Belgium’s seven nuclear reactors (Tihange 1, 2 and 3) are sited within 100-km of the municipality. Public fear about the danger these plants pose to Aachen were heightened in 2012 and 2014, when inspections revealed hairline fractures in the reactor pressure vessel. Concerned that they would not be able to distribute potassium iodide tablets to its citizens swiftly enough in the case of an emergency at Tihange, Aachen, along with the neighbouring municipalities, decided to preemptively distribute these tablets between 1 September and 30 November 2017, accompanied by educational materials, such as brochures and a video. These actions created confusion on both sides of the border, demonstrating the shortcomings of conducting emergency planning without engaging neighbouring bodies. In cases where nuclear facilities are sited near state borders or expatriate communities, we recommend that the entities responsible for emergency planning not only ‘determine, in advance, a set of internally consistent actions’, but to work with relevant counterparts to plan a coordinated response ([emphasis added] ¶87).
Third, we would be eager to see the ICRP elaborate on the notion of participatory preparation for nuclear disasters, with reference to successful case studies. The draft notes that, while the exigencies of a nuclear disaster do not allow for stakeholders to shape the emergency response, it is possible to engage stakeholders in planning for the disaster response (¶51). This is a laudible ambition, but two challenges can be anticipated. The first pertains to political will. Our point here is not to repeat common critiques of political short-termism - though it is certainly true that actors may not leap to devote time and resources to planning for a hypothetical (and improbable) event. The deeper issue is that a participatory mode of planning would demand that the state actively induce nuclear host communities to imagine a disaster and its effects upon their lives. Such an exercise is unlikely to generate support for nuclear power. To the contrary, it can be expected to foster fear, even resistance. For this reason, those who have a declared interest in nuclear generation may be loathe to promote such activities. Again, the example of Japan is instructional. In the years preceding 2011, efforts to promote nuclear power as entirely safe - a narrative commonly called the ‘myth of safety’ (anzen shinwa) - led state actors not to mitigate certain risks. To act on the risk, it was reasoned, was to publically acknowledge it, thereby fuelling a sense of danger. Similar concerns could be expected to generate resistance to enrolling members of the public in emergency planning.
The second challenge relates to concerns the practicalities of predicting our priorities in an emergency situation. Post-disaster conditions are alien to our experience, both at the collective and individual level. On the collective level, nuclear disasters are always unique, not only in regard to their sequences of events and effects, but also in terms of the local geographies, publics and politics they are embedded in. While contingency planning aims to take these factors into account, geographies, publics and politics are not stable constants, but co-shaped by the disaster. Drawing on existing cases is useful and necessary to imagining (hypothetical) future conditions, but is also limited by these factors. On an individual level, radiation cannot be sensed. Although we are constantly surrounded by (lower levels of) radiation, few individuals ever experience the threat of an emergency exposure, so have limited experience from which to draw in informing the planning process. Hence, the question arises as to whether any of us can effectively predict our priorities in (future) alien conditions. This is by no means to suggest that the notion of participatory emergency planning is defunct. The ambition remains laudible. And creative ways in which to evoke a nuclear emergency scenario could no doubt de devised. (A colleague lightheartedly suggested simulations, in the vein of the ‘wargames' staged by militaries across the world.) Further consideration of how stakeholder participation in planning for an emergency exposure situation may differ from engaging stakeholders in responding to an existing exposure situation would be welcomed, however.
Thank you for your time and consideration. We hope our comments have served as useful starting points for reflection on core issues raised in this draft, and look forward to continuing to engage with the Commission in its efforts to refine the System of Radiological Protection.