29 June 2023

Note on the dialogue between Japan and the PIF Expert Panel on 1 June
(IAEA Safety Standards relating to justification)

Background1.
During the intensive dialogue conducted virtually on 1 June 2023, one member of the PIF Expert Panelraised the issue of justification of the planned discharge of ALPS treated water. In doing so, he referred toparagraph 2.11 of IAEA Safety Standards Series No. GSG-8 (Radiation Protection of the Public and theEnvironment). The paragraph reads as follows:
2.11.
For planned exposure situations, justification is the process of determining whether a practice is,overall, beneficial, i.e. whether the expected benefits to individuals and to society from introducing orcontinuing the practice outweigh the harm (including radiation detriment) resulting from the practice. The
benefits apply to individuals and society as a whole, and include benefits to the environment. Radiation
detriment may only be a small part of the total harm. Justification thus goes far beyond the scope ofradiation protection, and also involves the consideration of economic, societal and environmental factors.
2.
The expert asked whether the Government of Japan (GOJ), or the Nuclear Regulation Authority (NRA)
specifically, has considered benefit and harm for neighboring countries including PICs resulting fromdischarge of ALPS treated water in accordance with paragraph 2.11 of GSG-8.
3.
At the conclusion of the dialogue on 1 June, the PIF Secretariat requested the Japanese side to provide
it with any explanation or documents that Japan may wish to provide regarding the point in question. This
note is prepared in response to this request to make clarifications on the position of the GOJ.
4.

As explained below, the GOJ considered whether the expected benefits to individuals and to society asa whole outweigh the harm resulting from the practice, in accordance with relevant IAEA Safety Standards
including GSG-8. As confirmed by impact assessments performed to the highest international standards, noharm is expected from the discharge, including to PICs. In contrast, there will be considerable societal benefits
to reconstruction and rehabilitation of the areas affected by the Great East Japan Earthquake of 2011.

Requirement and Process of Justification in the IAEA Safety Standards
5.

The IAEA Safety Standards have three different levels of documents. The IAEA website states thefollowing:“The Safety Standards consists of three sets of publications: the Safety Fundamentals, the Safety
Requirements and the Safety Guides. While the first one of these establishes the fundamental safety
objective and principles of protection and safety, the second set out the requirements that must be met toensure the protection of people and the environment, both now and in the future. The Safety Guides
provide recommendations and guidance on how to comply with the requirements.”
Thus, Safety Guides are subordinate instruments which, while not mandatory per se, provide
recommendations and guidance on how to implement basic principles and requirements.
6.
With regard to justification, at the first level, the Safety Fundamentals (Principle 4) states that “facilities
and activities that give rise to radiation risks must yield an overall benefit”. At the second level, the Safety
Requirement (Requirement 10 of General Safety Requirements (GSR) Part 3) states that “The government or
the regulatory body shall ensure that only justified practices are authorized”. States are required to implementthis principle and requirement by referring to recommendations and guidance contained in appropriate Safety
Guides.
7.
In this connection, GSG-8 “covers the generic application of the requirements given in GSR Part 3
that relate to the protection of the environment and protection of members of the public in planned exposure
situations …”. GSG-8 “does not deal with the application of the requirements in GSR Part 3 to specific types
of facility or activity or in specific exposure situations”(paragraph 1.9). Paragraph 1.9 also explicitly identifies
GSG-9 (Regulatory Control of Radioactive Discharges to the Environment) as a Safety Guide that is
applicable to “Regulatory Control of Radioactive Discharges to the Environment”.
8.
Therefore, with regard to justification of the discharge of ALPS treated water, both GSG-8 and GSG9 are relevant Safety Guides for a planned discharge of radioactive materials.

Process of Justification in the Case of ALPS Treated Water Discharge
9.
The GOJ fully considered and observed the process of justification in relation to ALPS treated water
discharge in compliance with the relevant paragraphs of the IAEA Safety Standards at all three levels.
10.
In regard to justification, similar to Paragraph 2.11 in GSG-8, paragraph 2.2 of GSG-9 provides
recommendations and guidance on how to implement the principles and requirements in relation to regulatory
control of radioactive discharges to the environment such as ALPS treated water discharge. It states that “[f]ora facility or activity to be authorized, it is required to be demonstrated that the introduction of that practicewill produce a positive net benefit (i.e. the expected benefits to individuals and to society from the practiceoutweigh the harm, including radiation detriment)”. Further, paragraph 2.3 of GSG-9 states that “[j]ustification
applies to the overall practice and not to individual aspects of the practice, such as discharges”. The GOJ
understands that discharge of ALPS treated water corresponds to “individual aspects”, and decommissioningof Fukushima Daiichi Nuclear Power Station (FDNPS) corresponds to “the overall practice”.
2.2. For a facility or activity to be authorized, it is required to be demonstrated that the introductionof that practice will produce a positive net benefit (i.e. the expected benefits to individuals and to2society from the practice outweigh the harm, including radiation detriment). Decisions regarding
justification should be taken at a sufficiently high governmental level to enable all the considerations
that may be related to the benefits and detriments to be taken into account. Any decision onjustification should always involve consideration of the radiation doses expected either to be incurredor to be averted or reduced, according to the circumstances. The radiation dose to the public is only
one of the factors involved in the justification process. Many other factors, well beyond radiation
protection considerations, will need to be considered in determining whether a practice is justified.
2.3. Justification applies to the overall practice and not to individual aspects of the practice, such asdischarges, which can be authorized or exempted from the requirement for an authorization only if
the practice as a whole is already regarded as justified.
11.
Therefore, with regard to the discharge of the ALPS treated water into the sea, the GOJ is of the viewthat a decision on justification should be made for the overall decommissioning process of FDNPS, which
includes the discharge of the ALPS treated water into the sea. It is to be noted that the IAEA Review Teamstated in 2020 that “the proposed objective of completing the disposition of the ALPS treated water by thetime of the end of the decommissioning work is aligned with current international good practices”. 1
12.

In this framework, the GOJ examined benefits and harm of decommissioning as a whole. With respect

to the benefits, the GOJ concluded that ALPS treated water discharges are essential to reconstruction andrehabilitation of the areas affected by the Great East Japan Earthquake of 2011. This is described in “BasicPolicy on handling of ALPS treated water at the Tokyo Electric Power Company Holdings’ Fukushima Daiichi
Nuclear Power Station”2 issued by the Council of Ministers for Decommissioning, Contaminated Water, andTreated Water in April 2021. With respect to harms, when the GOJ adopted the Basic Policy, the GOJ was ofthe view that it is highly unlikely that any discharge would have a negative impact on people or theenvironment. That view has been confirmed by impact assessments performed to the highest international
standards.

Process of review of the safety related aspects
13.
After the Basic Policy was adopted, the NRA as an independent regulator conducted thorough review
of TEPCO’s discharge plan, which was prepared on the basis of the Basic Policy, fully taking into account theIAEA Follow-up Review of Progress Made on Management of ALPS Treated Water and the Report of the Subcommittee
on Handling of ALPS treated water at TEPCO’s Fukushima Daiichi Nuclear Power Station, 2 April 2020, p.20. (Available
at: https://www.iaea.org/sites/default/files/20/04/review-report-020420.pdf)
2 Available at: https://www.meti.go.jp/english/earthquake/nuclear/decommissioning/pdf/bp_alps.pdf
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relevant IAEA Safety Standards. As a result, the NRA confirmed that the impact both on humans and theenvironment would be minimal and that there would be no measurable transboundary impact34.
14.
The GOJ also asked the IAEA to conduct reviews of TEPCO’s plan as well as the work of the NRA.
The IAEA has been conducting these reviews against all the relevant IAEA Safety Standards. Most recently,in May 2023, the IAEA issued a review report stating that its findings “provide confidence in TEPCO’s
capability for undertaking accurate and precise measurements related to the discharge of ALPS treated water.
Furthermore, based on the observations of the IAEA, TEPCO has demonstrated that they have a sustainable
and robust analytical system in place to support the ongoing technical needs at FDNPS during the dischargeof ALPS treated water”. The IAEA is expected to release a comprehensive report which contains results of
the reviews.

Meanings of Benefit and Harm in GSG-8 and GSG-915.
During the dialogue, one PIF expert, referring to paragraph 2.11 of GSG-8, stated that there needs tobe benefit to other countries like PICs brought by the discharge of ALPS treated water, because the harm fromthe discharge is not zero. On this point, the GOJ is of the view that paragraph 2.11 does not require benefit toeach individual country within the scope of review. Rather, the question is whether the planned activity will
result in benefit to society overall, and whether the benefit will outweigh any harm.
As stated above, the GOJ is of the view that further progress in decommissioning of FDNPS, includingin the handling of ALPS treated water, is materially beneficial to the people of Japan and not harmful to thepeople of any other country.
16.

17.
As TEPCO’s radiological environmental impact assessment (REIA) demonstrates, the impact onhumans (a representative person) within the exposure assessment area (range of 10 km × 10 km around theFDNPS) would be about one-thousandth of the radiation dose received from a single dental X-ray. The closest
PIC, the Republic of Palau, is over 3,000 kilometers from the discharge site, far beyond any area in which an
impact of the discharge could be felt. The REIA also takes into account the effect of bioaccumulation andExecutive Summary of TEPCO’s Radiological Environmental Impact Assessment (REIA) report states “ (1) in the case ofdischarge of ALPS treated water from the seabed approximately 1km offshore from the FDNPS, the foreseeable radiologicalimpact on the people who are most likely to be affected in the vicinity of the discharge point is minimal, specifically, theexposure level is assessed to be approximately 1/500,000 to 1/30,000 of Japanese safety standard set according to theinternational guidelines; (2) the exposure level on plants and animals inhabiting the 10km x 10km sea area around theFDNPS is only about 1/30,000,000 to 1/1,000,000 of the lower limit of the exposure range proposed by ICRP as thethreshold at and below which reference marine biota is not expected to suffer deleterious effects from exposure (derivedconsideration reference level); and (3) the impact on areas far from the discharge point (transboundary impact) wasevaluated to be undetectably low.”(REIA is available at the following site from Page 264:https://www.tepco.co.jp/en/hd/newsroom/press/archives/2023/pdf/230220e0101.pdf#page=264)
4 The NRA’s confirmation is detailed in “Review Results Document on the Application for Approval toAmend the Implementation Plan pertaining to Specified Nuclear Facility (Installation of ALPS Treated
Water Discharge Facility) of Tokyo Electric Power Company Holdings Fukushima Daiichi Nuclear PowerStation”, dated 22 July 2022. (Available at: https://www.nra.go.jp/data/000399110.pdf)
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long-term accumulation, further assuring the absence of harm to any PIC given the distance from the discharge
site. Furthermore, the model range for simulating tritium diffusion of the REIA is 490 km x 270 km. Even
within the model range, the impact is evaluated to be minimal, with the highest result evaluated at the model
boundary being 0.00026 Bq/L. In other words, the maximum annual average tritium concentration at theboundary of the calculation domain in the simulation is significantly lower than the natural backgroundconcentrations of tritium in seawater (about 0.1 to 1 Bq/L), and is expected to become even lower by furtherdispersion outside the boundary. The IAEA supports the GOJ’s position on this point in its report published inApril 20235.
18.
The GOJ fully understands the concerns of neighboring countries including the PICs. It is with thisrecognition that the GOJ has committed to be fully accountable and has responded to these concerns.
19. To this end, the GOJ would be happy to continue to respond to any question to address concerns of thePIF Members and their people.

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See IAEA report (page 24) (available at: https://www.iaea.org/sites/default/files/report-4-review-mission-tepco-andmeti.pdf)
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