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

Draft document: Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident
Submitted by Ichiro Yamaguchi, National Institute of Public Health
Commenting as an individual

#1 Optimization and ethical issues

The reference levels are discussed regarding optimization. There were many good local activities regarding risk communication and management using semi-quantitative risk assessment for each affected person after the accident at the Fukushima Nuclear Power Stations of Tokyo Electric Power Company encouraging both residents who have stayed in affected areas and also who have evacuated from an affected area assisted by economists and social scientists and facilitated by clinical psychologists and communicators utilizing the  Environmental Justice Collaborative Problem-Solving Model advocated by US-EPA.

Although risk assessment/management is an useful method, the limit of trade-off analysis for risk management is obvious because compensation cannot always be expected. Without fair compensation, no matter how effective, it will not be ethically acceptable if it imposes costs on a specific group in society. On the other hand, even inefficient policy can be justified if without implementing that inefficient policy, it is difficult to eliminate the large burden of a specific group. In addition, benefits and costs are defined as WTP and WTA, but their value depends on the individual's ability to pay. In other words, since the difference between rich and poor has a large impact on the magnitude of benefits and costs balance, efficient policies can be unethical in itself in some cases when people who receive benefits and those who receive costs are at the different wealth status. Furthermore each risk recognition links to justice (e.g. risk perception differences between natural and artificial risk) as discussed in the risk communication strategy provided by MEXT, Japan.

Based on the above, it would be summarized that cost-benefit analysis has the limitation that it cannot be applied if there are significant issues of fairness so that these good local activities regarding risk communication and management were focused on also fairness issues as the concept of "Justice" is discussed in Publication 138. Therefore these activities based on co-expertise with relevant persons having lay-expertise would be good to be reflected in this document mentioning the background information and the basic principle of fair compensation and human right issues adding the discussion in (227).

#2 Foodstuff management and Protective actions for the long term

The other important factor in a rural area would be the conflict between social position of each resident and cultural values on consuming the traditional natural local food reflecting the complex social situation including court battles so that residents had to find the realistic and modest solution also considering young mothers and fathers who care radiation risk to their children by carrying out local risk communication activities. These activities would be also good to be reflected in the section " Foodstuff management ".

#3 Decontamination including waste management

Adding "ashes after incineration, sludge from water treatment", the issues on filters would be good to mention in the section " Decontamination including waste management ".

#4 Additional radiation dose estimation

For workers involved in cleaning or decontamination operations, they are not treated as members of the public for their work(175). Some of these workers would have been moved to the affected area from higher natural background area so that gloss doses would be possibly decreased. That means the radiation risk of this operation is relatively small for those workers. In the mean time that means additional radiation dose assessment would depend on the evaluation of background level. After the accident, a city in Fukushima chose the inside the city hall surrounded by the thick walls for reducing the radiation from deposited radionuclides due to the accident. In the recovery phase, radiation dose due to deposited radionuclides has been decreased by the decontamination operation and weathering so that the estimated additional radiation doses to residents living in wooden houses became negative due to higher background radiation at the background radiation evaluation place. This is not a matter of radiation protection since the purpose of personal monitoring service for residents is to seek the residents who exposed higher doses. However a resident confused since estimated additional radiation doses due to the accident to many residents were zero since the evaluated background level was comparatively higher that the true additional radiation doses. Therefore this city decided to re-evaluate additional radiation doses by improving the quality of background radiation dose assessment for residents in 2017. This might be an unique example to be learned from the past accident relating the discussion on residual dose in (67).

#5 Ethical preparedness of disaster epidemiology

The development of epidemiological studies is important as mentioned in (203) and preparedness would be also important for this issue so that it would be good to refer "Some institutions are experimenting with writing data collection protocols and obtaining Institutional Review Board approval in anticipation of disasters." as indicated at NIH Disaster Research Response (DR2)( in the section " Health surveillance".