Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident

Comments on the TG93 Draft Report “Radiological protection of people and the environment in the event of a large nuclear accident"

Yuko Yoshida

Chernobyl - Health Survey and Healthcare Support for the Victims – Japan Women’s Network

Comments as an individual

General comment:

The ICRP should not finalize a publication of a "Radiological protection of people and the environment in the event of a large nuclear accident" by simply adjusting the draft text. The situation in Chernobyl and Fukushima, on which the draft was based, is not correctly described. Publication based on inaccurate information is considered invalid. As the ICRP itself emphasizes, a publication should be refined from the beginning, involving stakeholders.

Specific comments:

2£®Annex A “CHERNOBYL” does not describe the contents of the “Legal Regime of the Territories Exposed to Radioactive Contamination in Consequences of the Catastrophe at the Chernobyl NPP” established in Russia, Belarus and Ukraine in 1991. The draft should describe the contents of these legal systems and how ICRP evaluated them in the context of “Radiological protection of people and the environment in the event of a large nuclear accident”.

3-1. NAIIC £¨The Official Report of the Fukushima Nuclear Accident Independent Investigation Commission, National Diet of Japan, Tokyo, 2012£©is listed in the reference of Annex B, but there is no referred part in the text of the draft.

3-2-1. The description regarding difficulties associated with evacuation of hospital patients and the elderly (B2.1, Line 2923-2925) is quite different from the description of NERHQ, 2011a, which is the reference in this part.

¡¾Description in the Draft B2.1¡¿There were also significant difficulties encountered when evacuating 2924 patients from hospitals and nursing homes within the 20-km evacuation zone, which resulted 2925 in more than 50 deaths (NERHQ, 2011a)

¡¾Description in NERHQ, 2011a¡¿Evacuation of people who need care in emergency were hospitalized and lived in nursing homes within 20 km radius from the NPS was completed after evacuation instruction without delay.

In fact, this description in “NERHQ, 2011a” is not true. Thus, the listing of doubly incorrect references indicates that TG 93 does not properly grasp of the original text of the references.

3-2-2£®The official report of “The Fukushima Nuclear Accident Independent Investigation Commission£¨NAIIC£©” and its Reference document provide details of this matter in Section4.2.3 “Evacuation of all patients in hospitals” (Report; pp.380-389, Reference Document; pp. 98-105). (Refer to Table1)

There was one hospital case where dozens of patients died in connection with the evacuation. However, the cause of this unfortunate event was the Regional Nuclear Emergency Preparedness Plan, which stated that "Evacuation of hospital patients is basically done by the hospital alone".

¡¡In the Fukushima nuclear accident that accompanied the earthquake and tsunami, it was almost impossible for this hospital (393 inpatients at the time, including 192 serious patients) alone to find medical institutions to evacuate and to secure appropriate evacuation means for serious patients. The hospital could not obtain active cooperation from Fukushima Prefecture and local governments for serious patients’ evacuation. The communication of evacuation information was not successful, and ultimately severely ill patients were forced to evacuate for long time and long distances without the assistance of medical staff.

¡¡Before the evacuation, however, the hospital suffered water outage and power outage due to the earthquake. They had to rely on water storage tanks for drinking water and emergency power sources for electricity. On the evening of the 11th, the fuel supply had run out and the emergency power supply had stopped functioning.

3-2-3. The draft (para. 54) states:. "Lessons learned from the Fukushima accident, for example, suggest that the unplanned evacuation of elderly or medically-supervised people from nursing homes may have caused more harm than good for these people"

  However, as described above, in the situation of power outage and water outage, there was a high possibility that staying in the hospital without evacuating would also endanger the lives of patients.¡¡

  On the other hand, among the 7 hospitals located within a 20 km radius of the Fukushima Dai-ichi NPP, 3 hospitals that were able to find places of refuge and means of evacuation at an early stage completed evacuation of all patients on the 13th, with no deaths related to evacuation.

¡¡¡¡Therefore, we cannot simply say that evacuating "might have caused more harm than good for these people”. The evacuation issue of patients in hospitals should be evaluated after careful investigation of individual cases, and simple generalizations run the risk of leading to misjudgments.

The draft states, that the Commission (para. 66) pays particular attention to equity in the distribution of exposures within the groups of affected people, and (para. 67) recommends using reference levels to guide actions to reduce individual exposures and limit inequity. However;

The 1 mSv public exposure limit proposed by the ICRP is a well-known value internationally.

In the event of a nuclear accident, the introduction of a "reference level" in an area would result in multiple radiation protection standards within the certain region or within a country.

As a result, local residents who are subject to the reference level may feel unfair and distrustful of the administration, which in turn may cause unnecessary friction among residents.

It should be compatible with giving priority to people with higher dose while maintaining the conventional radiation protection standards.

     5£®In the Conclusion of the Draft (para.227), ICRP states “The issue at stake is not to make people accept the risk, but to allow them to make informed decisions about their protection and their life choices (i.e. respecting their dignity)”

¡¡In order for the affected people to make a decision, it must be accompanied by a guarantee of their later life. It is missing from this text that sufficient compensation and support from the government and nuclear companies are essential to respect any decision.

[Reference]

Table1.¡¡ Evacuation of all hospitalized patients within a 20 km radius of the F-1 NPP
(Order of evacuation date for seriously ill patients)

Source: The official report of The Fukushima Nuclear Accident Independent Investigation Commission (NAIIC) pp380-389 (in Japanese),

Reference Document of the NAIIC report, pp98-105 (in Japanese)

http://warp.da.ndl.go.jp/info:ndljp/pid/3514027/naiic.go.jp/pdf/naiic_honpen.pdf¡¡

http://warp.da.ndl.go.jp/info:ndljp/pid/3514027/naiic.go.jp/pdf/naiic_sankou.pdf

The official report of The Fukushima Nuclear Accident Independent Investigation Commission (NAIIC) - Executive summary¡¡£¨in English£©

http://warp.da.ndl.go.jp/info:ndljp/pid/3514027/naiic.go.jp/wp-content/uploads/2012/07/NAIIC_report_hi_res4.pdf