I thank ICRP for providing the opportunity to comment on the draft document�FRadiological Protection of People and the Environment in the Event of a Large Nuclear Accident .
ANNEX B. FUKUSHIMA
In regards to the Fukushima nuclear power plant accident, there are many incorrect evaluations, as well as other important matters that are not mentioned. If the accident is to be used as a basis for the revision of protective measures, an accurate understanding of the accident is required. In the official report of the Fukushima Nuclear Accident Independent Investigation Commission�ANational Diet of Japan (NAIIC), the problems of during and after the emergency evacuation from the viewpoint of residents were examined. However, they were only listed in the references.
B.1. Introduction
In the draft they stated that “a large quantity of radioactive materials was released into the atmosphere due to explosions in the reactor buildings of Units 1, 3 and 4”, but the largest amount of radioactive material was released as a result of damage to the No. 2 Unit.
B.2.1. The fact that SPEEDI data was not utilized during the emergency evacuation is a serious problem. Since the flow of the plume was quite accurately predicted by SPEEDI, if residents had been informed of this information, they would not have evacuated to locations within the path of the plume, and they could have avoided unnecessary radiation exposure. Why is SPEEDI not mentioned in the draft?
The set up multiple Off-site Centers was recommended but at the time of the accident there was only one in Fukushima Prefecture. This single Off-site Center did not function because it was located in the evacuation area. This was a serious error! Even now there is no more than one Off-site Center in each of the areas surrounding the power plants in Japan, so the situation has not improved. It is obvious that similar problems will occur if another accident occurs.
Also, at the time of the accident, more than half of the primary radiation emergency medical institutions were also located in the evacuation area, and they did not function after the accident. Even now, there are hospitals and nursing homes that will need to be evacuated in the event of an accident, so it is highly likely that similar tragedies will occur.
In Japan, there are not enough medical facilities, and hospitals are always crowded and beds are always occupied. If an accident caused a large number of people to be contaminated and their hospitalization was required, it would be highly likely that they would not be able to receive treatment. Within the Quantum Science and Technology Development Organization (the former National Institute of Radiological Sciences) they have the Core Advanced Radiation Medical Center, however, less than 10 people per day can be treated for serious contamination injuries in the facility. If many people were severely exposed, as in Chernobyl, it is questionable that the facility would be able to cope with the situation.
B.3.4.
(B.16) If the body surface contamination level of residents exceeded 13,000 cpm, they should be decontaminated and iodine tablets should have been taken. Since many people exceeded this level, the temperature was very low, and there was no hot water or change of clothes etc., it was impossible to decontaminate those people. Therefore, the decontamination level was raised to 100,000 cpm. In addition, iodine tablets were not given to those who exceeded 13,000 cpm .
It is well known that the thyroid measurements of 1,080 children are not reliable (Ministry of Environment https://www.env.go.jp/chemi/rhm/conf/conf01-06b.html).
(B5) The fax sent by the Nuclear Safety Commission (NSC) to the Nuclear Emergency Response Headquarters with instructions on the taking of iodine tablets was not forwarded on to the Local Nuclear Emergency Response Headquarters. The instructions were also faxed to the Fukushima prefectural government, but for two days no one noticed them. By the time the instructions were found, the evacuation had been completed. The governor of Fukushima Prefecture was supposed to issue instructions without waiting for instructions from the NSC, but the prefectural government did not deliberate on the problem. Although local governments were capable of making their own decisions, only three municipalities ended up giving recommendations to take iodine tablets. This is because the negative side effects of iodine tablets were emphasized in advance. As a result, only around 10,000 people took the tablets.
In an earthquake-prone country like Japan, an accident similar to the Fukushima nuclear power plant accident is highly likely to occur again. Although radioactive iodine contamination spread to areas more than 40 km from the plant, the authorities decided to distribute iodine tablets to households located within only 5 km of the nuclear power plant.
The experiences and knowledge gained from the Fukushima nuclear accident have yet to be utilized.
B.4.4. Decontamination and waste management
In reality, decontamination is not possible, and what is actually being done in Fukushima is the relocation and redistribution of radioactive materials.
Even now, there is no final disposal site for the radioactive material that has been packed in flexible plastic bags after it is collected from decontamination work. More than 10 million bags of radioactive materials are being stored at locations in Fukushima prefecture. To reduce the volume, if the bags contain less than 8,000 Bq/kg of combustible materials they are incinerated and the contaminated soil is used for roadbeds, embankments, and fields. There is strong opposition from residents regarding this redistribution of radioactive materials. So far, more than 3 trillion yen has been spent on this harmful "decontamination" policy. This is a fundamental problem with radioactive material that cannot be eliminated.
(B35) It is stated that, "Decontamination was completed in all areas except the difficult-to-return zone", however this does not mean that environmental radiation levels have fallen below 1 mSv/y. Decontamination work could not bring the level down to 1 mSv/y or lower so the government lifted the evacuation order, saying that there would be no health problems if the external dose was not more than 20 mSv/y. At the same time, they stopped providing housing support to evacuees.
A total of 30 lawsuits have been filed against TEPCO and the Japanese government in the evacuation districts. The evacuees are actually stakeholders, but the government does not listen to them and in fact, is fighting against them in court. Members of the ICRP in Japan are on the government’s side and are also hostile to stakeholders. Isn't this against the ICRP's recommendation?
B.4.7. Health surveillance
(B 42) It is stated that, "childhood thyroid cancer cases found in Fukushima Prefecture are unlikely to be a consequence of radiation exposure after the accident", however, there is no firm evidence for this conclusion. Here is evidence that doesn’t support the conclusion.
1, Fukushima Medical University (FMU) took the lead in planning and implementing the survey of thyroid cancer for the Fukushima Prefectural Health Management Survey (FHMS) (http://fmu-global.jp/fukushima-health-management-survey/.). However, the survey has a critical problem. It is not possible to determine the real thyroid cancer incidence rate in Fukushima. Cases diagnosed as malignant/suspected during what the FHMS calls the “follow-up observation course” are not reported to the Prefectural Oversight Committee (POC).
2, Private NGO, 3.11 Fund for Children with Thyroid Cancer has found that 17 thyroid cancer cases were not reported to the POC (https://www.311kikin.org).
FMU, in response to criticism of their insufficient disclosure of information, reported that 11 thyroid cancer cases were found of patients of “follow-up observation course”. Therefore, as of July 2019, the number of patients who were not included in the cause-and-effect analysis was at least 28.
3, In its interim report, the POC acknowledged that the incidence of thyroid cancer was several tens of times higher than the sporadic incidence rate in both their first and second round surveys. Moreover, a clear regional difference was observed in the second round survey that was not observed in the first survey. Though the area classification was not changed in the first round, once the regional difference was observed in the second round, FMU changed the classification based on the dose estimation by UNSCEAR 2013, which is not reliable. (Documents of the 35 meeting of the POC).
There is no point in doing a cause-and-effect analysis when dose data is unreliable and numbers of patients is inaccurate.
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