July 18, 2023
(Updated version July 19)
Commentary: The IAEA Comprehensive Report does not provide a "scientific basis" forthe oceanic release of ALPS-treated radioactive wastewater.
The release plan should be halted and consideration given to
the implementation of alternative proposals
Citizens’ Commission on Nuclear Energy (CCNE)
Chair: Kenichi Oshima
Committee Members: Masashi Goto, Nanako Shimizu, Tsunehide Chino,
Hajime Matsukubo, Ruiko Muto, Akiko Yoshida

Summary Points:● The IAEA Comprehensive Report lacks recognition of the serious implications of the discharge beingfrom the melted-down nuclear reactors.
● The IAEA review does not guarantee the safety of actual oceanic releases.
● Oceanic releases are not consistent with the IAEA safety standards at least as regards 1) "justificationof radioactive discharge to the environment" and 2) "broad consultation with interested parties".
● A complete revision of the Decommissioning Roadmap of the Fukushima Daiichi Nuclear Power
Station (FDNPS) is necessary. A coercive oceanic release will hinder accident responses at the FDNPS andthe ongoing recovery of the affected regions.
● Feasible alternatives to avoid oceanic release have already been proposed. The release plan should be
stopped and the implementation of alternative proposals considered.

The International Atomic Energy Agency (IAEA) has issued a report1 on the discharge of treatedwater from the Fukushima Daiichi Nuclear Power Station (FDNPS)'s Advanced Liquid Processing System(ALPS) into the ocean. Director General of IAEA, Dr Grossi, states in his foreword to the report that "theapproach and activities to the discharge of ALPS treated water taken by Japan are consistent with relevantinternational safety standards.” This is said to be an "endorsement" of the Japanese government's and the
FDNPS’s operator Tokyo Electric Power Company (TEPCO)'s plan2.
As stated in the IAEA Comprehensive Report, the review, conducted in light of IAEA safety
standards, was initiated at the request of the Japanese government after its decision3 to conduct an "ocean

1

IAEA Comprehensive Report on the Safety Review of the ALPS-treated water at the Fukushima Daiichi Nuclear

Power Station. July 2023 (hereinafter abbreviated as "IAEA Comprehensive Report")
https://www.iaea.org/sites/default/files/iaea_comprehensive_alps_report.pdf
2

https://www.bloomberg.co.jp/news/articles/2023-07-04/RX9J8GT0G1KW01

3The Inter-Ministerial Council for Contaminated Water, Treated Water and Decommissioning issues, " Basic Policy

1discharge" in April 2021. This was to ensure that the Radiological Impact Assessment (RIA) reportsubmitted by TEPCO and the review process by the Nuclear Regulation Authority (NRA) were consistent
with IAEA safety standards.
The IAEA, however, did not conduct a comprehensive review of all items included in the IAEA
safety standards. Furthermore, since the IAEA is an organization that promotes the use of nuclear energy,
the IAEA safety standards focus on the safety of nuclear facilities, and the IAEA itself is not necessarily
neutral in terms of environmental and human rights protections.4 In fact, the IAEA did not evaluate
options other than ocean discharges, nor did it assess possible long-term effects on marine ecosystems andfisheries. The IAEA's Comprehensive Report is based on the documents submitted by the Japanese
government and TEPCO, solely on the premise that the Japanese government had already decided torelease the radioactive water into the ocean, and merely confirms the decision to go ahead with the oceanic
release. Thus, the IAEA Comprehensive Report does not prove the oceanic release itself "scientificallycorrect"5.

1．Poor recognition and evaluation of the fact that the “contaminated water” to be treated comesfrom the melted-down nuclear reactors.
The water6 discharged into the ocean is “treated radioactive wastewater” that was generated bydirect contact with the nuclear fuel in the melted-down reactors. This water is essentially different fromthe water discharged from a conventional reactor (containing tritium), and it is inappropriate to make asimple comparison of the two7. An intentional discharge into the ocean of treated radioactive wastewater
generated from a reactor that has been involved in an accident has never occurred before.
Nearly 70% of the water currently stored in tanks after ALPS treatment contains residual
radionuclides other than tritium in excess of the overall regulatory concentration limit. The government
and TEPCO are assuming that secondary treatment will remove these radionuclides to below theregulatory limit. However, it is doubtful whether this process can be carried out properly. The doubt is dueto the following facts.
First, there is only a slight track record of secondary treatment with ALPS, and it is uncertain
whether its decontamination performance can be maintained for a long time to come. The IAEA
comprehensive report did not verify the performance of ALPS secondary treatment. Therefore, there is no
realistic guarantee of the safety of the discharge.
on handling of ALPS treated water at the Tokyo Electric Power Company Holdings’ Fukushima Daiichi Nuclear Power
Station," April 13, 2021. https://www.meti.go.jp/english/earthquake/nuclear/decommissioning/pdf/bp_alps.pdf
4

https://www3.nhk.or.jp/news/html/20230710/k10014124091000.html

5https://www3.nhk.or.jp/news/html/20230707/k10014121881000.html

6

The water in question falls under the category of “nuclear source material, nuclear fuel material, or substances

contaminated by such material " as defined in Article 62 of the Reactor Regulation Act.
7

This is not to say that effluent from conventional reactors is safe and free of problems. It is known that radionuclides

are concentrated in the seabed sediment and benthic organisms in the surrounding waters, and it has been reported
that the incidence of leukemia is statistically higher around nuclear facilities which have high tritium discharges. Ian
Fairlie (2020) The Hazards of Tritium, https://www.ianfairlie.org/news/the-hazards-of-tritium/

2Second, TEPCO has not clarified the total amount of radioactive substances that will ultimately
be released. The company does not clarify the duration of the release, either. Even now, regarding theradiological impact assessment, TEPCO has indicated nothing more than measurement results for only
three tank groups as source data8 for the 64 radionuclides. In other words, the complete picture of whatkind of water is about to be released has not been revealed.
Third, there is a valid concern that the operator may not disclose proper information about thewater being released. In fact, it was only after media scoops in 2018 that it was revealed that radionuclides
other than tritium greatly exceeding the regulatory limits remained in the ALPS treated water that was
supposed to be only tritiated. Until the news exposure, TEPCO had submitted data to the government
councils only for the period when radionuclides other than tritium fell below the regulatory concentration
limits. This incorrect data was also used in explanations to the public and at public hearings.
Fourth, the IAEA safety review did not include an assessment of contingencies, and the
optimistic "assumptions" of the government and TEPCO were accepted as they were. The ocean discharge
with treatment of contaminated water from the melted-down reactors is the first attempt of its kind in theworld, and safety assessments must be conducted on the assumption of contingencies such as issues with
ALPS performance and problems during radionuclides measurement.
Fifth, the IAEA review does not assess the cumulative effects of the large amounts of radioactive
substances that have been released since the Fukushima nuclear accident occurred in 2011. It is firstly
necessary to clarify the effects of the past release of contaminated water and then to assess the cumulative
effects of additional and intentional discharges. Even now, radioactive dust and water continue to leakfrom the FDNPS through various routes, and the onsite contamination around the reactors remains grave.
The regulatory dose limit of 1 mSv/year at the site boundary has not been met. It is thought that additional
and intentional releases of radioactive substances will further aggravate this illegal situation.

2．The IAEA review assumes "ocean discharge" as an only given choice, and does not sufficiently
comply with IAEA’s own safety standards.
The IAEA review is premised on the Japanese government's "ocean discharge" decision and does
not evaluate options other than oceanic release, such as storage in large robust tanks or mortar
solidification, which have often been raised as viable methods for handling the ALPS treated water.
The International Commission on Radiological Protection (ICRP) Fundamental Principles ofRadiological Protection9 and the IAEA Safety Standards, which are based10 on the ICRP principles,
require that if radioactive materials are to be released into the environment, the release must be "justified"8

The type, amount, and physical and chemical form of radioactive materials released into the environment.

9

ICRP (2007) "ICRP Publication 103: The 2007 Recommendations of the International Commission on RadiologicalProtection" https://www.icrp.org/publication.asp?id=ICRP%20Publication%20103
10

The IAEA Safety Standards consist of Safety Fundamentals, General Safety Requirements (GSRs), Specific Safety

Requirements (SSRs) for facilities and activities, and General Safety Guides (GSGs) and Specific Safety Guides (SSGs)
for the specific implementation of these safety requirements.

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by showing that the overall benefits of the action exceed the damage caused by the release11. Thisjustification must take into account economic, social, and environmental factors beyond the scope ofradiological protection.
In this regard, the government and TEPCO have repeatedly stated that "there is no other option"and "it is essential for decommissioning and reconstruction processes" without specifying who will benefit
and what kind of damage will be caused by the ocean discharge and whether the benefits outweigh thedamage. In other words, neither the Japanese government nor TEPCO have implemented the justification
process, and thus the government's decision to go ahead with the oceanic release does not comply with
IAEA safety standards. Furthermore, the IAEA itself admits that it did not evaluate the justification
process because the request from the Japanese government was made after the decision to release theradioactive wastewater into the ocean. This indicates that the IAEA itself has failed to assess whether or
not the basic principles of radiological protection are met. Therefore, the IAEA's conclusion that theoffshore release plan complies with IAEA safety standards is seriously flawed.
As stated in the IAEA Comprehensive Report, "the issue of justification of the discharge of
ALPS treated water is inherently linked with the overall justification of the decommissioning activities
taking place at the FNDPS and thus is influenced by broader and more complex considerations”12. What is
now required of the government and TEPCO is just such an "overall" justification.

3．The IAEA Comprehensive Report does not adequately reflect the actual circumstances in which
local and other interested parties are consulted.
The IAEA Comprehensive Report concludes that the activities and approaches taken by thegovernment and TEPCO regarding stakeholder involvement are "consistent with international safety
standards" based on the fact that the relevant ministerial councils were open to the public and public
hearings and other forums were conducted on the issue. However, this conclusion is false. The information
11

For justification, GSR Part 3 states, "Principle 4: Facilities and activities that give rise to radiation risks must yield an

overall benefit.” 2.11 of GSG-8 “Radiation Protection of the Public and the Environment”, established on this basis,states that "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 or continuing the practiceoutweigh the harm (including radiation detriment) resulting from the practice. The benefits apply to individuals andsociety 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 of radiological protection, and also involves the consideration of
economic, societal, and environmental factors." 2.12 also requires emergency situations to be justified. Furthermore,
Chapter 4 of GSG-9 “Regulatory Control of Radioactive Discharges to the Environment” states that unjustified releases
should not be permitted.
IAEA (2014) GSR Part 3 Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards
https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1578_web-57265295.pdf
IAEA (2018) GSG-8 Radiation Protection of the Public and the Environment https://wwwpub.iaea.org/MTCD/Publications/PDF/PUB1781_web.pdf
IAEA (2018) GSG-9 Regulatory Control of Radioactive Discharges to the Environment https://wwwpub.iaea.org/MTCD/Publications/PDF/PUB1818_web. pdf
12

IAEA Comprehensive Report, p. 19

4

providers to the IAEA review were limited to the Ministry of Economy, Trade, and Industry (METI),TEPCO, and the Nuclear Regulation Authority (NRA). As a consequence, the IAEA did not examine how
the opinions and requests expressed by fishermen, local residents, the general public, and also neighboring
countries were handled, nor the content of the discussions, nor the methods used to hold the discussions,nor the degree to which they were reflected in policy decisions. The result is that the IAEA
Comprehensive Report contains no mention of these matters.
The IAEA Safety Standards require that interested parties should be broadly consulted. Theinterested parties specified in the IAEA Safety Standards include local producers, the public andenvironmental groups13. In addition, taking into account transboundary impacts, citizens of other countries
and neighboring countries are also included as interested parties14.
In practice, the government and TEPCO have rarely held substantive consultations with a wide
range of stakeholders. At the public hearings held by METI (Secretariat of the Subcommittee on Handling
ALPS treated water) in 2018 (held at three venues in Tomioka Town and Koriyama City of Fukushima
Prefecture, and Tokyo on August 30-31, 2018) and also at other consultation meetings, the majority of the
speakers were opposed or cautious about oceanic releases. The IAEA Comprehensive Report commends
NRA for taking public comments15. However, that too remained a mere formality in which opinions were
just heard, and objections, concerns and alternatives raised by the public were not considered. After the2018 public hearings, the series of hearings conducted by the government prior to the decision todischarge the water into the ocean have only included representatives of the “relevant organizations”
designated by the government. In addition, the attendees were mostly men, and the opinions of the otherhalf of the population, women, were not reflected.
Since 2018, no government-sponsored public hearings or other meetings for the general public
have been held16. The opinions of interested parties, as defined by the IAEA safety standards, have neverbeen reflected in decision-making. What the government and TEPCO have been doing are solely public
acceptance promotions as a measure against "reputational damage", into which large sums of taxpayers'
money have been invested.
13

IAEA Comprehensive Report, p. 94

14

IAEA Comprehensive Report, p. 95

15

IAEA Comprehensive Report, p. 16

16

Public hearings, public comments, and public opinion polls in newspapers and other media conducted during theprocess of studying contaminated water treatment also showed a majority opposed to the releases. For example, of the
44 speakers at the ALPS subcommittee hearings in three venues, only two agreed with the dumping of the water into
the ocean (one of them with a conditional agreement), all the others voicing opposing views (https://cnic.jp/8163). At the"Forum for Hearing Your Opinions" sessions on the handling of ALPS treated water (April 6 and 13, 2020), thefollowing statements were also made: "The direct impact of this ocean release is not reputational damage, but actual
damage, which will continue until the disposal is completed" (Fukushima Prefecture Ryokan Hotel and Public Health
Trade Association) and "As a fisherman in Fukushima Prefecture, I will continue to advocate our position that we areopposed to the oceanic release of treated tritium water. We would like to ask for your continued support" (Chairperson
Satoshi Nozaki, Fukushima Prefectural Federation of Fisheries Cooperatives Associations). In addition, looking at thesorting out of the 4,011 responses to the official call (April to July 2020) for written submissions regarding the handlingof ALPS treated water, it is estimated that most are opposed to the release of contaminated water with treatment.
https://public-comment.e-gov.go.jp/servlet/Public?CLASSNAME=PCM1040&id=620220008&Mode=1

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4．A thorough revision of the Fukushima Daiichi Nuclear Power Station’s accident managementand decommissioning process is needed.
On August 24, 2015, METI responded to the Fukushima Prefecture Fisheries Federation, saying,"We will take the necessary measures, including careful explanations to all parties concerned, including
those in the fishing industry. No action will be taken without such processes and the understanding of
those concerned17.” TEPCO also responded to the federation on August 25 of the same year, stating, "Nodisposal will be conducted without the understanding of the parties concerned, and the ALPS treated water
will be stored in tanks on the power plant site18.”
Nevertheless, TEPCO, in its submission to the NRA in November 2022 of the "Application
Documents for Approval to Amend the Implementation Plan for Fukushima Daiichi Nuclear Power
Station Specified Nuclear Facility" (regarding the handling of ALPS treated water)"19 altered this promiseto "No discharge to the sea shall be made without the approval of the relevant ministries and agencies,"
and this was rubber-stamped by the NRA. This dishonest and opaque process of ignoring commitments
made to stakeholders is completely overlooked in the IAEA Comprehensive Report.
In addition, the cost advantage that was presumed for the offshore release is no longer available.
The Tritiated Water Task Force established under METI, which mainly conducted technical studies,
evaluated ocean discharge as superior under the following assumptions20: discharge period of 91 months(treatment rate of 400 m3/day), cost of 3.4 billion yen, and facility size of 400 m2. However, the ALPS
subcommittee, established later by METI, concluded that 22 trillion becquerels of tritium per year would
be discharged (equivalent to 10 times the annual amount discharged from the FDNPS before the accident)
and that the discharge period would be 20 to 30 years21, which already differed from the assumptions
reached by the Tritiated Water Task Force22.
Since then, preparations have been made to actually release the water into the ocean. TEPCO hasannounced that it will cost about 43.7 billion yen over the three-year period from FY2021 to FY2024
alone for the construction of facilities to discharge water from the undersea tunnel and for radiologicalmeasurements23. Further, the Japanese government allocated 30 billion yen in a supplementary budget for
FY2021 for "Measures for disposal of ALPS treated water" (including measures against reputational

17

http://www.abetomoko.jp/files/uploads/国から漁連への回答書__2.pdf

18

https://www.tepco.co.jp/news/2015/images/150825a.pdf

19

https://www.tepco.co.jp/en/hd/newsroom/press/archives/2022/20221114_01.html The altered wording appears in

the original Japanese document III, Part 3, 2.1.2 “Management of radioactive liquid waste, etc." on page III-3-2-1-2-6
at https://www.nra.go.jp/disclosure/law_new/FAM/140000272.html - https://www.nra.go.jp/data/000410090.pdf
20

https://www.meti.go.jp/earthquake/nuclear/osensuitaisaku/committtee/takakusyu/pdf/016_05_01.pdf

21

https://www.meti.go.jp/earthquake/nuclear/osensuitaisaku/committtee/takakusyu/pdf/018_00_01.pdf

22

The Task Force based its calculations on 800,000m3 of stored water as of June 2016. Currently, it has increased

significantly to 1,340,000m3. The size of the facility is also expected to be much larger than 400m2, judging from theconstruction status of the ALPS treated water dilution/discharge facility and related facilities. Further, the area overwhich contamination will spread due to the oceanic release is far larger than the alternative proposal by the Citizens’
Commission on Nuclear Energy (mortar solidification plan), which would yield the smallest scale of contamination
dispersal.
23

https://www.tepco.co.jp/press/release/2022/hd11127_8712.html

6damage)24. The cost of maintaining and managing the temporary tanks over the next 30 years will also be
added. Ocean discharge is thus considered to have lost its cost advantage over other options.
The offshore discharge of radioactive wastewater takes as its premise the "Mid-and-Long-Term
Roadmap towards the Decommissioning,"25 which calls for decommissioning the plant in 30 to 40 years
after the accident. As clearly shown by the fact that the nuclear fuel debris has scarcely been removed at
all from the reactors 12 years on, and that it is still hard to predict how many years it will take to complete
the removal, the current roadmap of ‘decommissioning in 30 to 40 years’ is utterly unrealistic.
The Citizens’ Commission on Nuclear Energy (CCNE) has repeatedly pointed out the need tooverhaul the Mid-and-Long-Term Roadmap and proposed realistic solutions that would not require releaseof contaminated water26. Ignoring the opinions of local residents and the general public and forcing thedischarge of radioactive water into the ocean may instead hinder the viability of the decommissioning andsocio-economic recovery. That would be to the detriment of the people of Fukushima Prefecture and allothers concerned.
The government and TEPCO should rescind their decision to release the radioactive water to theocean and start over with fundamental discussions, including a drastic review of the decommissioning
schedule. An immediate step is to consider the already proposed alternatives that do not involve oceandischarge.
For inquiries, please contact:
The Citizens’ Commission on Nuclear Energy (CCNE)
iTEX Bldg. 3F, 16-16 Yotsuya-Sanei-cho, Shinjuku-ku, Tokyo 160-0008, Japan
TEL: 03-6709-8083 Email: email@ccnejapan.com

24

https://www.meti.go.jp/earthquake/nuclear/hairo_osensui/pdf/sesaku_2112.pdf

25Mid-and-Long-Term Roadmap towards the Decommissioning of TEPCO's Fukushima Daiichi Nuclear Power

Station Units 1-4. https://www.meti.go.jp/english/earthquake/nuclear/decommissioning/index.html
26

See Citizens’ Commission on Nuclear Energy (2022), Our Path to a Nuclear-Free Japan,

http://www.ccnejapan.com/20220826_CCNE202305.pdf Chapter 2 (especially, 2.3 and 2.4). In addition, according to
METI's explanation, long-term storage in large tanks was rejected because it would go against the principle ofcompleting decommissioning in 30 to 40 years and the area required for installation would be insufficient. Mortar
solidification was also rejected because it would require evaporation prevention measures and new regulatory standards
in addition to the difficulty of securing space (October 25, 2020, oral explanation by Mr. Okuda, Director of Nuclear
Accident Response Office, Agency for Natural Resources and Energy, METI, October 25, 2020). These points havebeen discussed by the Working Group on Engineering and Nuclear Regulation of the CCNE, and we would like torequest public discussion and third-party evaluation of these proposals.

7