ML12340A607

Official Exhibit - NYS00422B-00-BD01 - Interim Report (Main Text), Investigation Committee on the Accident at Fukushima Nuclear Power Stations of Tokyo Electric Power Company (Dec. 26, 2011)

ML12340A607
Person / Time
Site:	Indian Point
Issue date:	12/26/2011
From:	Tokyo Electric Power Co
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 22873, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12340A607 (49)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit NYS00422B Entergy Nuclear Operations, Inc. Submitted: June 29, 2012 In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3) c:..\,.~""R REGlI~;. ASLBP #: 07-858-03-LR-BD01

• l~'~...

Docket #: 05000247 l 05000286 Exhibit #: NYS00422B-00-BD01 Identified: 10/15/2012

• 0 Admitted: 10/15/2012 Withdrawn:

~ ~

....,,1-

? ~

0.... Rejected: Stricken:

• • • • il Other:

emergency measures should be taken, including a review of emergency evacuation preparation zones. In response to this request, the NSC provided "Initiatives to lift the Evacuation-Prepared Area in Case of Emergency designation [or the TEPCO Fukushima Dai-ichi l'JPS i"...ccident" the saflle day. On .August 9, based on tPis reply~ tl-}e NE!U--IQ decided to prepare a "Review of evacuation areas," which addressed the foHowing three points to be confirmed (i) the safety of nuclear power reactor facilities, (ii) a decrease of the air radiation dose rate, arId (iii) restorh'1g of the public service functions arId infrastructure.

On the same day, NISA referenced the report "Regarding the confirmation of safety of nuclear power reactor facilities of the TEPCO Fukushima Dai-ichi NPS" stating that it was unlikely that a hydrogen explosion \vould occur and unlikely that the nucl~1T reactor cooling system might fail due to following countenmvasures taken such as the filling nitrogen into the prima.~yr containment vessel &'1d the establishment of a system of circulation cooling including the treatment of accumulated drainage water in reactor buildings, a multiplexing of electric power supply, the relocation of an emergency power source to higher ground, and the establishment of sea wall; and that even if the nuclear reactor cooling system did fail, the effect of radiation on the emergency evacuation preparation zones might be sufficiently lower tha.ll the index provided in t.1-te NE Guideline.

Based on "the Radiation Monitoring Action Pian for Homecoming regarding Evacuation Prepared Areas in Case of an Emergency," which was established on July 25, lVIEXT conducted various monitoring activities in r.~1h'1fuTJ.-soma-slli, Tanlura-shi, !(a\vaucrJ.-mura, Hirono-machi and Naraha-machi. As a result, it was discovered that measurement points, including main spots ne.ar schools, in all of the mwncipalities did not exceed 19pBv/h45 46 MEXT made an armounced 1his on August 9 .

Additionally, on September 19, aii cities, wvms and villages in the emergency evacuation preparation zones created disaster recovery prOhTf3111S and subnutted t~en1 to t~e ~ffiR--"-qQ.

Based on these disaster recovery programs, the NERHQ decided that conditions (i) to (iii) for lifting the emergency evacuation preparation zones were met 45 Areas in SOllIe pmts of Ivfinarni-soIn3-shi, TanlUra-shi and Kavv3uchi-mura showed llleasm-ed values of air radiation dose rates exceeding 3.0fLSv/h. ] ]owever, it was established that the measured values were only found in Ih-o-nited areas and that lifting the ernergency evacuation preparation zones should not be dependant 011 theril.

11', A brief announcernent was prOlnptly Inade on August 9. AnlOre detailed version \vas published OIl August 16.

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The NERHQ exchanged opinions on the lifting of emergency evacuation preparation zones and disaster recovery \vith the leaders of the cities, to\\'11S and villages concenled imd Lhen, on Seplenlber 30, asked Lhe NSC its  ::I(i vice on the lifting of enlergency evacuation preparation zones. On the same day, the NSC replied that it had no objection to the NERHQ' ideas with conditions that appropriate measures should be taken on radiation monitoring as well as decontamination acti\,'ities. On the same day, the NERHQ issued a directive a."'ld statement that the emergency evacuation preparation zones of the cities. to\\TIS and villages should be lifted.

4. Measures ta..l{en to address the risk of radiation exposure (1) Radiation control standards

a. International Connnission on Radiological Pmtection (ICRP)

IeRP is lli'1 international nonprofit orgaIlization n1adc up of a COlTllTittcc of experts that was founded by the lntemational Society of Radiology and provides radiological practitioners with recommendations and guidance on radiation protection. It was reslludw-oo tu be responsible [or a \vluer r;mge uf rauiaLiuIl prutecLiun uutsiue the IIlewt..:al science 3rLd given its present mune 1.11 1950.

ICRP has established a framework for radiological protection based on data derived from actuai facts and the impact of radiation exposure coilected and scrutinized by the UN Scicntil1c Committee on the EJTccts or Atomic Radiation (lJl"~SCEAR) and pro\'idcs advice on radiation exposure limits ror radiation control. TCRP ha, established a concept or radiation exposure dose to correlate with risks or hunlan health and also provides recommendations on how to estimate the radiation exposure dose for various situations.

!eRP \vorks together \vith UNSCE.A~R) the \Vorld Hea!th Organization (\VHO) a.lld t~e IAEA For example, the IAEA respects ICRP recommendations and assists member countries to participate in consensus-building efforts and establishes the international basic safety' standards [or radiation protection to be implemented in member cowltnes.

The first TARA publication (Pub. I) containing its recommendations, which were approved in the previous year of 1958, was issued in 1959. The IAEA's general basic recOlnn1endations that succeeded the first one were Puo. G(1964), Pub, 9 (1966), Puo. 29

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(1977), Pub. 60 (1990) and Pub. 103 (2007)

b. ICFJl standards TCRP recommendations c1assily the hamllul elTects or radiation exposure on human heahh into two categories: "detemlinistic eiTeclS" and "stochastic eiTects" A "detemlinistic eITect" is ai'l effect or serious impact such as death or eel] malfUi'lction that deterministiccally occur with high radiation dose. A "stochastic effect" is an occurrence of cancer or hereditary effects (bereinafter referred to as "cancer, etc. ") that is induced by the gene (DNA) llluwtlon and stochastically caused by relatively low radiationdose (refer to Pub, 103, (55)). No cases of the occurrence of a detefl11i!1istic effect ,,,ere confinned by the nuclear accident at the Fukushima Dai-ichi NPS. The ICRP concept is briefly described only in tenns of liS toehas tic eiTects as follows:

ll Epidemiological data, on \vhich ICRP rccol1llncndations arc based, ha\'c nmirJy been collected and analyzed from a life span study (hereinafter referred to as "Life Span Study")

of atomic bomb survivors in Hiroshima alld Nagasaki conducted by the Japall-US joint RailiaLiun Erred.s Resecu-dl Fuwu.ialiuIl (RERF, ihe ALumil: BUIUO CasualLy CUIIlIIlissiuIl, or ~A13CC until 1975) since 1950 (refer to Pub. 103, A.4.4). The results of this research study based on that data show that with regards to nuclear atomic bomb survivors who were exposed to more than lOOmSv of radiation dose from all atomic bomb, there is a statistically signirica.i'lt rclationship bchv'ccn radiation dosc w'1d Clli'1Cer rates (the higher the radiation dose, the higher the Callcer rate). On the other hand, with regards to alomic bomb survivors who were exposed [0 less thall lOOmS, orradiation dose leom all atomic bomb, it has not yet been concluded due to insufficient data as to whether there is a clear relationship behveen the radiation dose and ca.'1cer rate. The !CRP recommendation, however, is based on a model (hypothetical theory) that, from a conservative standpoint there is a proportional relationship between the radiation doses and cancer rates (a recommendation in 2007, Pub. 103,3.2.1). Additionally, a recoITllllendation h"! 1990 (Pub.

hO, :l4,2) was also based on premise ora proportional relationships both lor low radiation doses and low radiation dose rates. lbis model, which is not based on the so-called threshold meory that 10\v radiation dose has no radiation eiTect, is called a

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linear-non-1hreshold dose-response (LNT) model, or linear model (hereinafter referred to 1l47 as "LNT 111odel ). Additionally, according to the LNT tllodel, in high radiation doseradiation dose as "veIl as "veIl as in Imv radiationradiation dose dose, cancer rates increase or decrease depending on radiation dose. Hence, if radiation exposure does not have any other merits (for example, economic or medical), then radiation exposure is not justified. And, even if' the radiation exposure is justified, such radiation radiation doses should be controlled to be as low as reasonably achievable ("Principle of Justitication,"

"Principle of Optimization of Protection", Pub. 103,5.6).

Based on this concept, the iCRP classifies situations where people might be exposed to

{f* f fa_lauon l ' n .

~rom anuc ear reactor aCCl~ent mto nYo types:

"p:1~mtlon (i" . emergency SItuaTIOns. . ,,48 and "existing exposure situations,"" and provides 1he recommendation for an "radiation emergency situation" thal: (i) for occupational exposure, the reference level of life-saving operations (infonncd volunteers orJy) should be "no restrictions on exposure" L.~c reference level'u for o1her urgent rescue operations should be LOOOmSv or below 500mSv", and 1he reference level of o1her rescue operations should be "below IOOmSv";

emu (ll) fur public expuswe, the refereul:e level shuuhl be 20II1SV Lu 100II1SV per year52 .

47

'lhe "LNT" in "LNT model" stands for "Linear Nontln-eshold Dose Response. 'P 48 i~.J.l "radiation emergency ~ituation'P i~ de~cribed a~ one that m'i~e~ a~ the re~ult of ml unexpected event and requires prompt Hction in order to Hvoid or rt'du(~~ !.my wJve:r;t: consequences to publi(~ health (refer lo lCP1) Pub.

101,52)

An "existing exPJsurc situation" is deSLTIbcd as a situation V..*hL'IC exposure already exists at a highL'f levclthan usual and a decision on the need for eontrl11 need~ to be taken, including risking long-tClm exposure to residual radioactive matelial ii-om a nuclear or radiological ClllcrgCllCY after thc Clllcrgeney exposure sih13tlOll has beCll declared to he over. Exposme to residual radioactive material flDm a nueh~m' reactor accident is cited a.;; an example (Pub. 1m, li.3).

'>I, A "reference level"is as follmvs: Tn emergency or existing contmllerable eXT'0sure situations, this represents the level of dose or lisk, above \vhich it is judged to be inappmpliate to plan to a11mv exposure to occure (e.g.,

implementation of evacuation zones), and belmy ,yhich optimaization of protection should be implemented (l\lb.

103, 5.9.2.).

51 TIle [eRP recommendation issued in i '})() (Yub. ()l.J, G.ll) states that it shouid be below 5Cx.lmSv (5,()C,OmSvfor skin). 'ihe ieRi) recommendalion issued in 2007 slales lhal "helm\" iDOOmSv" should he one oplion 52 lCH..P publication 63, "\-vhich preceded the lC1\..P 2007 recommendations, stutes that, in tenllS of public eXj.XPSUfe in illi emergency, (i) if a exposure dose more thilli50mS'v is avoidable in a temporary stay-indoors evacuation, (ii) if aexposu.re dose more than5()'v'mSv is avoidable i.."1 a teJ.llpG'Tmy slay-indoor.,; evacLlaLion (o,vithin a week), (iii) if a c:'qY.J:'.ur...: do~c l11C,[C than l,lJl)J:mSv i~ 11'iOid.:.!blc in Hn p'~TIl1<ml-'Ilt rcl(y...:ation (OVl-T 11 wcck), (i\') if 5lXlrnSv Dl thymid expi.JSUIT is avoidable th..roug..h the distribution of stable itxllne, then these actions shall be nearly uhvays

.illslif'ied. HmVeVL'T, ir only less th~n onc-tcnth or the exposure dose (relocatioll in (iii) sholll,i he less thml 1(X)mSv/month of the eXl)j)sure dose) is avoidable, then the~v shall not be al\\'ays optllnized. In tenns of food, if the dose rate more than 1OmSv/yem' is avoidable in the presC1ibed action, then that action should nem'ly always he jUf.'tified.

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Additionally, the ICRP provides a recommendation that in an "existing exposure situation," reference levels should be established \vithin the nmge of lInSv to 2011lSV per year depending on the situation (Pub. 103,6.5).

Additionally, a nonnal situation that does not Call under "radiation emergency situations" or "existing exposure situations" shaH come under "planned exposure 3

situations," An exposure limit in the case of public exposureS is lmSv/year.

Radiation exposure is classified into two kinds: "exiernal exposure" and "internal exposure" E"iemal exposure occurs "hen the body is exposed to radiatoion from the radioactive source outside the body. internal exposure occurs ,,,,hen the body is exposed to radiation from the radioactive source ira..side the body. In the Life Span. Study described above, the exposure dose received by individuals was estimated based on a radiation dose of direct irradiation from the exploding atomic bomb, in other words, the primary exlema!

exposure, derived fron1 a rclations:hip bcL\vccn the distw"'1cC bch\"ccn L.1.C point \vhere each individual affected by radiation exposure and the center of the explosion, with or without shelters, and the characteristic of the atomic bomb dropped. Hence, neither the secondary exLernal expusme [mIll rawuadi ve falluut [ruIlI Lhe explusiun nur ihe inLelIIal eXIJusw-e tl:lat each individual received from tl:le radioactive fallout Vlere tak:en into consideration.

Thus, if the radiation exposure (the secondary extemal exposure and intemal exposure) iliat each individual actually would have been affected by was taken into consideration, ilie actual exposure radiation dose may have actually been higher thun the estimated exposure dose. Thu,. it is likely that the cancer rat"" that were based on the data leom the LiCe Span Study were overestimated against the estimated exposure dose.

External exposw-e occtrrS vvhen the radioactive source is outside the body while internal exposure occurs continuously until the radioactive source decays out through radioactive disintegration or it is excreted from the body When radioactive material is taken in and remains in a specific part ofilie body, ilie surrounding ceils ofilie radioactive materia! are intensively exposed to radiation 54 (Pub. 103, 4.3.2). 'Il-Iis does not occur in external An "Cxposllrc limil" is an amol1111 Ill!ll an individual \voilld nol he !l11mvcd 10 nxx..';vc in a pbll11Cd CXpOSUTC sItuatIOll 54 Tn the ClUTent nuclear accident most of the radioactive mateTial \vas released as gas. Thus it ~ems that there is no need to take into consideration the effect of radioactive materials ingested hy the oTJwnism as solid matter.

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exposure". The ICRP recommends that internal exposure should also be evaluated based on the a predicted dose (cOlllmir-ted dose) which is expected to receive over a period of 50 years (for a minor, tmtil he or she is 70 years old) fron1 Lhe tin1e that the r:Cl(iioactive material is taken into the body As described above, the efTect 01' internal exposure cannot be deady deiined using the epidemiological data in the Life Span Study. Various studies are cUi'Tently being conducted, but the mecha..'1ism or how internal exposure uITects Ui'1 organism has not yet been c1aritied using factual data.

c. Siandards in Japan In Japa.ll, the follm:vLl1g sta..l1dards have been established based on all ICRP recommendation (Pub. 60) issued in 1990.

Firstly, the NSC has set up the N10 Guideline (refer to Section 2(3)b above) as clncrgcncy countcnncasurcs against accidents in nuclear facilities.

This NE Guideline formulated the "indices of stay-indoors evacuation and evacuation".

A stay-indoors evacuation should be conducted if a predicted effective dose from external exposw-e (prewcleu expusw-e tu rauiuacLive Illalerial ur railiaLiun while uutuours uwing a period of radiation discharge) is 10 to 50InSv, an.d evacuation (or a stay-indoors evacuation into concrete buildings) should be carried out if the external radiation dose is more than 5OmSv.

Secondly', thc l"-ffi Guideline romlulated the "indices or protecti\'c mcasures concerning the intake or stahle iodine tahlel," a, a guideline lor taking stahle iodine tahlets to protect the thyroid gland leom radiation exposure. The stable iodine tablets should be applied "vhen a predicted equivalent dose of infant thyroid gland exposure to radioactive iodine is more than 1OOmS" (in principle for people ullder 40 years old).

In addition, with regards to food, the NERHQ formulated the "Index for restrictions on the intake of food and beverages;; in the tabie beiow as a b'1lideiine for discussions on vvhether or not it is neceSS(h")' to take measures to restL"1ct food (h"1d beverages 56 .

.,~ The TCRP also points out that the evaluation or inlc'Tll!ll eXyxlsure is milch more di lTieult lhml lh!lt or eX1C'Tllal

__ c:qX)surc (Pub. 103,4,5).

)() The "Tndex for ref..trictions on the intake of t(m and beverages" set" t\\'o criteria: (i) 50mSv(vear of thymid gland equivalent dose t()f radioactive iodine, and (ii) 5mSv(vear of effective doset()r radioactive cesium. Tndex

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Table V-I index for restrictions on the intake of food and beverages I I ITarget I Radioactive iodine Radioactive cesium I . . I IDrinking water 1300 200 I.,.. K~l1 ~"_ I",,,,,

IlvlllK (UIU-l other dairy products I..JUU 200 I Vegetables (excluding root VPUP I? nnn

.-0-1-""

Itables and tubers) I I . I IVegetables 1- 500 I '=(\{\

I Cereals 1- JW I Meat, POTrt;;:

-.=>=>~,

fish. others 1-I 500 Uni TBq/kg Prepared b,lsed on t,e guidelines of "Emergency Preparedness for Nuclear Facilities" (first puhlished in .Tune 1980 and last revised on AUs'llst 23, 201 I)

Nex~ concerning ,yorkers engaged ill radiation work ill radiation controlled areas (hereinafter referred to as "radiation vmrkers"), Japan has [onnulated "!op..ization Radiation Injury Prevention Rules" (hereinafter referred to as "loni7ation Rules"), "Rules for Commercial Nuciear Power Reactors concerning Installation, Operation, etc." (hereinafter ieferred to as "CommercirJ Re,actor Rules'l "Notice on Exposure Limits l3ased on Provisions of Commercial Power Re<lctor" (hereinafter referred to as "Commercial Reactor Notice"), and "National Personnel Authority Rules 10-5 (Prevention of Radiation lnjmies in StaffY, which states that the radiation exposme dose (hereinafter referred to as "Dose LiJYIit") of radiation \vorkers should be less LlJ.aIl or equal to lOOn1Sv/5 years a..l1d less than or equal to 50mSv/year57 based on ICRP recommendations. In this regard, valiles in the T!lh1c V-' arc scI rOT_ llcilhL'T or which 10 eXITed lhe L'1itL'1i!-l 57 AItidc 4, Paragraph (1) of Ionization Rules; AIticlc 9, Paragraph (1) of Commercial Reactor Rules; AItidc 6, Paragraph (I) of Commercial Reactor Notice: and Article 4, Paragraph (I) of National Personnel Auth01ity Rules 10-5.

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however. it is stipulated that in emergency sitnations"_ the exposure limit shall be lOOlnSv, Hl Article 7, Paragraph 2 of ionization Rules; At1icle 9, Pm-agraph 2 of ConU11ercial Reactor Rules; AJtide 8 of Com111ercial Reactor Notice: and Article 4, Paragraph 3 ofNalional Personnel Authority Rules 10-5.

(2) Radiation dose limit for radiation workers in an emergency

a. Raising the exposure limit to 250mSv TEPCO executives, who had been staying at the Prime Minister's Office since the accident at the Fukushima Dai-ichi NPS, ,,,ere infonned by corporate headquat1ers that radiation levels at the site 'vere rising. The TEPCO executives recogpized that it wight be impossible to continue operations to llllU1age the nuclear accident if they insisted on the current legal exposure limit and asked tlie NSC and NISA for tlieir advice. In response to this request, at the PnlTIC I'-,,1inistcrs OlIke in the a11cmoon of ~1I1arch 14, it \vas decided that the exposure limit for emergency operations should be increased from lOOmSv to 250mSv At that time, consideration was given to the fact that ICRP Pub. 103 stipulates thal the eXIJosw-e limit fur eIIlergency wOIkers shuulJ be SQUIUSV tU 1,OOOIUSV, 250IUSV59 is h91f t~e !m:ver liwit, arld t~e "Regulatory Guide for Reviev.ing Nucle(l.f Reactor Site Evaluation and Application Criteria" developed by the Japan Atomic Energy Commission In j 964 describes that the exposure to be temporarily allowed based on the recommendations of the guide is 250mS\.

Tn response to this implementation, on the same day, the Ministry of Health, Labor and Welfare and METT worked together to prepare a ministry order and a notice to the elTect Tnese rules delIDe situations of "1,.,111I,.,TgI,.,11ey operation" <-18: "those when: a dismteT ()ccurs or is iikcly to o<.x;ur, where mgently neccss31Y aCTion should be Taken to handle thc damage to nuclcar poyver reactor facihties that might OU11,.,T\,\,isc Sl.."l-iOU:;iy JisIUpi ihL: OIX...*HltiOIl of a lludL:<lr n.:adm" (ColllIm.:n.:ial RL:adm Ruk:::;); "U10:::;('; wha\.:

,lil accident that is n;lc'vant to the pn. )'visions 01 iu....tick 42, Paragraph (1) (iCCUrS and elllergcrKY operation is n.:quircd to prevent health pmbk:rr..;" in "vorL.Ts . from radiatiml in zones n.:lcvant to said paragraph" (Jonization Rule::;); and "thux \\here an ac~ident thal is relevimt tu pru',;"i::;ic.'n::; uf }ll*tide 20, 1>t.:ri.l6Ti.lph (1) uc~ur';"i.md L'mLTgL'llC} ope.'ration is :n.:quinx! to p:r"':\'c"lll pmbbns fmm radiation" (!'Jationul Pl-TImlllcLALuthmily Rules 10-5).

59 Pub. 103 D..HS not yet !:xX'll incorporated 1.1110 Japal1esG 1m,v. The Ibdiatiol1 Council Basic Committe'i":, hm'./ever, impknK'l11cd a "Second Tnlc'Tim Rq)()11 on lhe Tnlmdl1dion or lhe 2007 RccomnK..'l1(iHl;ons (Puh. 1(1) or the Intcmal10nal Commission on Radiological Protection OCRP) into Domestic ~)'stems" in Janum."y 2011, stating that the ex:IX):-oure limit in an emergency in Japan should he hrought into line \\'ith the recommended value that is intemationally accepted.

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iliat from ilie date when a nuclear emergency is declared to ilie date when the nuclear eluergency is lifted in a zone where eluergency countenneasw-es BlUst be taken the exposure limit should, in Lmavoidable circumstances, be 250111S",60, S0111etinle after midnight the same day, they asked MEXT Radiation Council 6 ! for advice. The Council debate the proposed exposure limit by email throughout the day until just before dawn the following day Ut"'1d replied that it was reasonable. Tn response to this advice, the 1\1inistry of Health, Labor and Welfare and METI formulated a ministry order'2 and a notice to that effect, dated April 14 and ilie ministry order and notice were issued (published in an official gazette) on Ivlarch 15.

b. Discussion on raising the exposure limit to 500mSv On March 17, three days alier raising the exposure limit for emergency workers from lOOlnSv to 250I11S\,. a discussion \vas held at L.'c Prin1c I'vfinistcr's Office to rruse L.'c exposure limit even fur1her to SOOmSv. In response to this. the Ministry of Health. Labor and Welfare and METI started to prepare a plan to iliat effect within ilie Ministries.

Huwever. Lhere \vas ultllnaldy nu inslrudiuIl Lv Lhal erred [mIll Lhe rrlIIle tviirilsler's Office.

c. Loweting the exposure limit to lOOmSv On August 30, the TVfinistl)- or Health, Labor w'1d \Vc1rare stmtcd discussing lo\vcnng the exposure limit Cor emergency operations hack to IOOmSv. The Ministry, under mutual

'll1e Ministyr ofllealth, I.amr and Welfare received a repolt to that eftectfmm a I.al)()r Standards Bureau oft'icer.

lhe .tvtilllstry, lUlder the .tv1inister's direction, advised the Prime Mmister's Office stating that the prescribed exposme hmit shouid not be raised immediateiy to 25C)]:nSv, but rather to 2Cl)mSv. AncL finaiiy, at the government affairs level, it ,vas discussed and decided that the eXI)()sure limit should he raised to 25(")mSv.

61

'il1e Radiation Council discussed lhis sLl~iecl in an advisory meeling. They reached a consenSLlS hastxl on lhe "Second Interim Report and replied that the exposure limit suggested in the ministry order and notice \"'as reasonable. Additionally, the discussion continued lmtil 03:00 the tollmviIlg day, but the date of the reply \:vas, as per ooth tvlir..i:::L.ri.e::;' intention, po:::teJ a::: .Mar...:h 14, ,>vhich i::; ,>vhen !.he pa..rt,icipant::; :::ta..rt,eJ !.heir Ji::;cu:::::'10n by L'lllail.

62 The "miDisll} ordL~ on the sr':_'i_~iul mks of OrdiD.l-lnCC on Lhe Prevention of IO!1iLing F.l.-I{jiation HcL,-:ards for responding 10 evenls reslllting rmm lhe 2011 Tol10kll Dislricl-ofT lhe P!leific Ckeml Fm1hqll!lke" !l1ld "the notice on ex:pOS'llfe limits based on the Rules for COllllllercial Nuclem: Fmyer Reactors oJnccming Installation and Operation" \vere exclusively for the unavoidahle urgent acti"ities necessary-" for responding to events ref-oulting from the 2011 Tohohl Disuict-d'fthe Pacific Ocean Emthquake.

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arrangement wiili TEPCO, METL and oilier organizations, excluding staff who had alreao)' been involved in this mnmgelnent before the exposw-e linnt \VEiS raised, stalted to ilnplelnent a ministry order63 where the p:brase "in unavoidable circun1stances" should be changed to "in unavoidable circumstances and in circunlstances the Minister or Health, Labor and Welfare deems unavoidable" lor the "ministry order on the special rules of Ordlna'-'lce on the Prevention or Tonizing Radiation Hazards to respond to the events resulted from the 2011 Tohoku District-off the Coast of Pacific Ocean Earthquake", and asked ilie Council of Labor Policy for advice on October 24(". The COllllCil replied iliat it

,vas reasonable. TIle ministrv order beCillne effective as ofNovelnber 1.

(3) Organizational framework for radiation control at TEPCO

a. Organizational jj'amework for radiation control before the nuclear accident (a) Orga.**...izational frtb"TIe"l';:orkfor radiation control before the nudear accident The Ionization Rules define a controlled area as an area where the level of radiation may reach beyond a specified amount (Article 3)"5 The Rules stipulate iliat concerning Iluclear puwel SlaliUIl uperalms \v11u are invulveu in rawaLiun work: (i) the ueslgnateu

['.rea sh91! be c!e['.r!y marked vlitiI a SigIl tiIat sho\vs access to tiIe 9.rea is restricted to iliose individuals who require access in order to perform ilieir duties (Article 3), (ii) radiation workers shall not be exposed to more than a specified radiation exposure dose (Article 4 to ()), (iii) radiation 'workers shaH be equipped 'with measuring instruments designed to mea,ure exposure dose (Article R), and (iv) radiation workers shall he educated about the elTects or ionizing radiation on organisms (Article 52 (7) and agree to undergoing a physical examination (Article 5(>>). in addition, as an agreement anlOng 63 TIle lvfinistry order revisecL a<; per a minisrry order, the specialmles of' ()niinance on the Prevention of'lonizing I-(auialion Ila/.arus I'm resrxmuing lo evenls resulting rmm the 2Ui I Tohoku DisLlicL-olT the Faciric Ocean 1 .'~.~1_ ~ __ ~1_~"

.c'UUll[LI<l1>.t:.

64 'ihe "ministIY order on the special mlcs of Ordinance on the Prevention of ionizing Radiation Hazards to resp:.::nJ. tu e\,'ents resulLing i'rJl11 the 2011 'lohuku District-ulI the Paci1ic Ocean Earthquah:.e" \-vas uriginally a l(..:mlxmlry spc'i.!iul rniristIj' mUcl. HL'llCC, l~c :tv:1ini~.~,.' of Hculth, Lacor und \};lclfup..; Jid not bolhc'f a.~.:killg lhl!

P.l!tiialion COUl1eil for ativiec.

(;5 Arlick 1, P~rat~r~ph (1) or Toni/,alioll Rilles ddilles !l "eolllmlled !lrca" as an !lrca I.vhere Ihe lolal or effective dose from external radiation and effective dose from radioactive material in the all" ma\.' reach more than 1.3mSv every 3 months, and \vhere the sUTface denf-oity of radioactive material may reach more than one tenth of the limit value designated in tahle 3 of the Rules.

• 848*

OAGI0001550_00060

operators who are involved in nuclear operations, which is not a statutoI}' regulation, TEPCO shall have radiation workers registered as professional radiation operators \vith a radiation worker certificate provided by the Central Registration Center of Rrl(iiation Workers located at the Radiation EfTects Association.

(b) Control of radiation radiation doses TEPCO controlled exposure doses based on in-house manuals including the "Radiation Field Control Manual" in order to protect its radiation workers from radiation exposure as follows: a TEPCO radiation ,vorker ,vas supposed to equip the!1l.selves "lith a rentn1 ala..rm pocket dosimeter (APD) in the access c-Ontrol zone of the controlled area before they entered that controlled area to perform their duties. The extemai exposure dose that individuai radiation workers received was measured with an APD and cOlnbincd \viL.~ da~ \v'r~ch included the individual's munc, hours 'worked w"'1d duties. using a mechanical control to measure the exposure. In addition. TEPCO nuclear power station staff were supposed to be tested to measure the level of internal exposure using a whule buuy L:Uwlter (WBe) unce eveI), three IIlunlhs.

TEPCO partner comp::ulies, too, ,,,ere expected to follov.*' a siIPilar exposure control program for their staff in the same way TEPCO did for its staff.

h. Organizational frml1ework for radiation control after the nuclear accident (al Establishment of temporary and emergenc.y mdiation controlled 7.()nes Aller the nuclear accident at the Fukushima Dai-ichi NPS, radiation levels increased throughout the entire premises of the nuclear power station. However. TEPCO ,vas not initially \"/il!ing to redefine a controlled area as stipulated in its in-house safety Gii regulations . On April 27, however. as described in Section c(b) below. based on the fact that a femaie radiation worker received radiation exposure ,,>reater than the aiiowed exposure lirrIit, f~TJSA instructed TEPCO to 'validate its orgar.tizational [ra..llevvork [or radiation control and implement measures to rectiry this silllalion . Tn re'3ponse to this, on (iii This is e"XVected to he detennined hy a hcensee of reactor opemtions hased on Article J7, Pm"agmph (1) of the Act on the Regulation of Nuclear Source MateTiaL Nuclear T'uel Material mld Reactors.

-844-OAGI0001550_00061

May 2, TEPCO designated the entire premises of the Fukushima Dai-ichi NPS as a tenlpon-u-y 1:md enlergency radiation controlled zone to be controlled in the smne lllanner as a radiation controlled zone. It "vas decided Lhat Lhe controlled zone should be treated as a controlled zone stating that it would be marked with a sign showing that access to the designated area is restricted to those individuals who require access in order to perfoml their duties, other necessary signs ;,vould be installed, a.."'1d that radiation workers must be equipped with a rental APD and other protective equipment67 (0) Registration as a ..adiaiion WOI'Kel' At the Fukushima Dai-ichi NPS, from the date of the nuclear accident throug.h to!\1ay 10, radiation workers were allovved to carry out their duties inside the temporary and emergency radiation controHed zone alter receiving a brief30-minute explanation about hov~" to protect L.1.cmsch'cs [ro111 radiation and ho\v to \vear protccLi vc cquiplncnL 1'1 addition, (although there is no legal obligation to do this) there was a delay in radiation workers getting registered as professional radiation workers with a radiation worker L:ertiuL:ale pwviJeu by Ute Central Regislratiun Center uf RawaLiun Workers lliul so some radiation v/Orkers performed tl-teir duties ,:vitl-tout a radiation ,vorker certificate.

(c) APD (aIann pocket dosimeter)

TEPCO had about 5,000 APDs installed at the cntrai'lCe to the controlled :/one or Units I to (, and at the entrance to the centralized waste treatment iilcilities in Units I to

(" but most or them were covered in water and damaged by the tsunami. Hence, as a temporary arrangement, it ,vas decided to perform radiation control measures using about 320 l~~PDs that had been kept in a Seismic Isolation Building. Sometime behveen March 12 and 13, SOO APDs (200 of them from the Fukushima Dai-ni NPS) were 67 TEPCO designated the entire premises of the Fukusrillna Dai-ichi NPS as a temporm-y and emergency radiation ci..lllL."-'JlleJ. L:i..ll1e, bUL 110 :oi..gr..::; ht.n:e l:x::en installed Lo indicate Lhis. }\. ddiLiunally, the fullmving measu..."'""es \vcre lal.;.en inside the Sc-i~.II'..ie Isoi:Jtion Building: from l'v'1areh 12, air do~.e rales \~:c"n,; measu.Hxi; from lv'1ar...:h 24, lh(.;

c!...lJ.ll'.cntmtion of raditK!c!ivc nl<:!iLTIul in Lhc UIT \vas mCaSUfL'1J; on M.-f:!fCh 26, an air vcWaLof \\iUS in<::lalbJ; on M!lrch 27., radiation lead shields V.,'L'IT plHeed on \vindmvs: !l11d hct\VCCll April 1 and R; nom mats '>VL'IT Tql1aecd I3ecau~c of thesc mca~mcs, nun April 4, the conccntration of radioactivc matcnal in the air of the Seismic Tsolation Building fell helm\' regulation limits (Ioni7ation Rules and Commercial Reactor Rules). Tt was then decided to treat the inf..ide of the Seismic Tsolation Buildinp. as an lmeontaminated area.

-84[;-

OAGI0001550_00062

provided as aid supplies from Kashiwazaki Kariwa Nuclear Power Station.

UnfOltunately, hmvever, there "vas a lack of cOllllllunication be-u:veen the pickup

\-\-'indo\-v personnel that received Lhe A.PDs and Lhe health physics team Lha1 desperately needed them, and these APDs were simply stored, unused until April 1. Many workers ieil the Fukushima Dai-ichi 1'<PS ailer the earthquake and initialiy very few remained to perfoml their duties. Gradual1y more a.'1d more joined them ui'1til there were not enough APDs and by March 15 not evelV worker was able to wear an APD. Tn response to this situation, Mr. Masao Yoshida, head of the Fuk<IShima Dai-ichi NPS (hereinafter referred to as "site superintendent Y oshida") decided to let only the leaders of an operational b1fOUP v*/ear AJJDs on behalf of the entire group as long as the follm:vi.ng conditions were met: (i) the assumed total radiation doseradiation dose per job is not great (less than aboutlOmSv), (ii) air radiation dose rates at the worksite are knovm, (iii) cn\"iromncntal dose rates gradient (dilTcrcncc between air radiation level faies in L.~c same space) is not great, and (iv) all members of an operational group always together at a worksite. This decision was made based on the following assessment: the provisory dause, which sLaLes ihal "huwever, if it is cunsiderably ilifficwl tu perfuHn ihe sald measurement '.vit..l:l tl:le s(lid radiation measuring instru..rnent, the s(lid dose from extem(ll exposure may be computed using the dose equivalent, and if it is also considerablv difficuit to compute it, then the said vaiue may be obtained through caicuiations,;; of Article 8, Paragraph 3 orroni,~ation Rules stipulating that lithe measurement or radiation dose It-om external exposure according to Article 1 shall he perlonned hy wearing radiation measuring instrunlent on parts of the body specified in the following items",

was applicable to this case. As described above, a sufficient number of APDs ,vas finally obtained on April 1. TEPCO decided to have a!! of its \vorkers \'vear APDs from the same day and to not allow them to work ifthere were not enough APDs.

(d) l'"l'lmm.g:ing access tu mid frum a cuntrullEd li-ca Aller the nuclear accident, acce:;s to and rrom the controlled area orthe management system was initially rendered inoperative for calculating the exposure doseradiation dose of individual radiation \vorkers. TEPCO decided io n1aIlualiy calculate me

-84fi-OAGI0001550_00063

radiation dose radiation dose of individual radiation workers using APDs. On April 14, TEPCO had five sinlplified instlUlnents installed in the Seismic lsolation Building for gaining access to and frOln the controlled area lTIm1agelnen! syslen1. At Lhe san1e tilne, they introduced a radiation work pemlit with bar code pallems so that the names and radiation doseradiation dose of individual w'Orkers could be aUlomalica11y recorded6 );,

c. Occul'rence of exposed subjects and theil' countel'il1easures (a) Subjects exposed to contaminated watel' fmm the lJnit 3 tul'bine building On IvIarch 24, lhree ,vorkers frmll a TEPCO partner cOlupany (mille staff Inelllber A in his 30s, rrm1e staff member B in bis 20s, nn.d ill!11e stu-if member C in his 30s), ,,"ho were installing electric cables under the snrface of the basement floor of the Unit 3 turbine building, were exposed to high radiation dose while working immersed in contaminated ,vaLer. 1'1 Lenl1S of radiation doscradiation dose (external exposure), stall' member A received 1XO.1 mSv. staff member B received 179.34mSv and staff member 69 C received 173rnSv before they had finished working On .rvlan.:h 24, ihese lluee slaIT Ineluuers were in[uIIneu that Lhe air rawaLion Jose rate at tl-te v/Orksite in tl-te basement of tl-te Unit 3 -D.rrbi.l1e building "/[I.s about 2mSv/h on tl-te previous day, March 23, before they walked dmvn to their worksite. Thev put on Tv-vek protective suits and charcoal fiiter masks and also carried an APD with them AdditionaHy, starr members A w'1d B put on Iol'\" quarter shoes w"'1d stalT member C \vore high boots. Then they headed lor the worksite. Their APD wa, set to sound an alaml once each time the extemal radiation doseradiation dose reached 4mSv and to sound a continuous alarm for three minutes to alert them that the external doseradiation dose had reached 2()mSv.

The three staff members found that there was a pool of water about 15cm deep

(;~ tr.

from :tvf3feh 17, f3di3tion \yor!:.;:ers \'.'ho did not go .rough the Seislnie Isol3tion Building were ex-peeted to att.ach /\DPs at J 'vil1age and to reconi the day's levels \vhen returning the /\DPs upon finishing \vork for tl-Je day . .T

'village had APDs from more than one manufacturer. Hence, the Acces Contml Devices ,vere implemented em

.Ttme 8.

(;9 '111ese three ~aff memher~,- A, l-l and C \vere tested to measure their intemal radiation doses follmving the incident. Tn terms of intemal radiation doses, f.otatt' member /\ received 39rnSv, staff member 11 received 35mSv and staff member C received OmSv.

,:147, OAGI0001550_00064

covering the entire floor They thought that it was probably only seawater and decided to stml larking. Their APD sounded before they struted "'larking. HO\VeVel~ they thought Lha! either their APD had sowlded to tell thenl Lha! its battery ,vas llat70 or that their APD had malrunctioned due to the rollowing reasons: they had been inlonned in advance that the air radiation dose rale at the worksite was about 2mSvFn, and they had heard alai'111S before indicating a.-'1 APD malCunction or as a.-'l alert to charge a llat APD battery, Thus they proceeded with installing the electric cables, Later staff member A heard the APD sound continuously and wondered if the air radiation dose at the worksite could be higher than expected. Ho\'vever, he thought it ,vas inlpOltant for .heni to complete their j ob to restore the pmver supply so they contLl1ued ,,,orking.

After completing their job, it was discovered that these three staff members were all likely to have recei ved high radiation dose, Stall' members A and B in particular were at a r~gh risk of radiation heat blliTtS frOln L.1.cir feet bcii'lg soaked in radioactive 'water because they were wearing low quarter shoes thus subjecting them to continuous localized exposure. They visited Fuk-ushima MedicnJ University Hospital and the Naliunal insliLule uf Rawulugical Sciences lu gel cleanell. up <:inll.have a checkup anll. get tested to measure t~eif intem91 radiation doses. The localized f['.ciiation dose bot~ staff members A and B received on their feet was 466mSv. Neither staff member A nor B suffered radiation heat burns on their feet.

In response to this incident, on 1\1arch 25, TEPCO w"'1d its p&"1ncr comp<mics decided that ir workers lind something at their vvorksites contraIY to what they are told in advance, they should report to the Station ERC to seek directions and that workers should leave their worksites immediately if they hear an APD sound its alarm. Tney gave their \'vorkers instructions to this effect.

(b) Subjects exposed to radiation exceeding the dose limit for femaIe staff (5mSv for thi"EE mmiths)

Four whole body coun1ers (WRCs) thaI had been installed at the Fukushima Dai-ichi 70 An APT) sounds repeatedly \vhen it.;;; battery is running 1m\' in the same manner a.;;; \vhen the exiemal radiation dose has reached the upper limit.

-848-OAGI0001550_00065

NPS were rendered inoperative due to a power blackout and an increase in air radiation dose rate. On lvim-dl 22, TEPeO borrowed vehicle-11l0unted \lVBes fronl jAEA and had fuell1 installed at Ona...hmna. TEPCO started IneastLn-Ilg Lhe internal radiation dose of individual workers who were engaged in emergency work at the Fukushima Dai-ichi NPS using these WBCs. As a resuit, on April 27 and May i, it was discovered that two 71 female stalThad received radiation dose exceeding the dose limit lor women that is 5mSv tor three months.

Female worker 0, in her 50s, who was exposed to 17.55mSv of radiation, had mainly been engaged in firefighting related jobs at the fire station gatehouse near the Seismic Isolation Building excluding the period from March 11 to 23 ,:vhen she h.ad been temporarily evacuated to the Fukushima Dai-ni NPS. While she was working there, she refueled lire engines more than once outside the Seismic Isolation Building. Female

\-vorker D lUld been \v"orking at L.'c gatchousc until she reccrved L.'c instruction of evacuation issued from the FukllShima Dai-ichi NPS on March 23.

Female staff member E, in her 40s, was exposed to 7.49mSv of radiation while she hau been engageu ill healthGue-rdaleu \vurk as a laisis learn IneIuuer ill Lhe Seismil:

Isolation Building during tl-te period from IV!arch 11 to 15. !n tl-te Seiswic Isolation Building, she usually stayed in the emergency response control room on the second fioor. Whenever someone was injured or sick she went to the sickbay iocated near the en1rlli"'lCe on the riGt floor to take care OChl111 or her. She also \vorked ncar the cntrlli"'lCe of the Seismic Isolalion Building whenever emergency personnel arrived from outside.

The doors of the entrance to the Seismic Isolation Building, which were bent and twisted at the time, \vere only temporarily sealed up. Hence. the air radiation dose rate on the first floor \vas higher thaJl that on the second floor. !n addition, fema1e staff member E has not returned to the Fukushima Dai-ichi NPS since leaving there on March 15.

A common factor in both. ferrwle staIr members D and E, \vho vvere exposed to radiation, \Vas that both orthem had spent a long period or time near the entrance of'lhe first Jloor of the Seismic Isolation Building, where the air radiation dose rate had been 71 ATticle 4, Paragraph (2) of Ionization Rules, ATticle h, Paragraph (1), Item (1) of Commercial Reactor Notice

-849-OAGI0001550_00066

relatively high since the day of the nuclear accident. One factor specific to female staff Inelllber D "vas that she ,vas engaged in refueling operations several tilnes outside the Seismic Isolation Building.

On May 2, TEPCO summarized the causes or these radiation exposure incidents in which its staiT received radiation dose beyond aiiowable dose limits and established measures to prevent similar incidents in the future UI'1d reported their l1ndings to 1'-ITSA.

This report describes the causes of these incidents as follows: after the nuclear accident, access to and from the Seismic Isolation Building was not properly controlled iintially, the double-entry doors to the Seismic isolation Building ,,,ere not airtight and the doors to the Seismic Isolation Building \vere bent al1d t:visted by the hydrogen explosions in Units I and 3, TEPCO concluded that these factors resulted in female staff members D and E inhaling radioactive materials, Based on this conclusion, TEPCO implemented lTIcasurcs to prevent similar incidents in the future as [0110\\,3: (i) on and after ~..1:arch 23, the Fukushima Dai-ichi NPS shall be managed and controlled without female workers, and (ii) the concentration of radioactive materials in the air shall be reduced in the Seismll: isulatiuIl SuilLling by installing a lucal ventilatiun IIladline. ill aUwLiuIl, TEPCO decided to implement t~e follm:ving addition(ll measures for t~e p..rture: (i) t~e entire prellllses of the Fukushima Drn-ichi NPS shall be treated as a controlled zone, (ii) radiation workers shaH wear proper protective equipment to match their working en\*ironments, (iii) a system shaH be implemented to control exposure, 0\") internal exposure doses ror individual workers shall be measured more onen (once a month when incidents have occurred and once every three months during nomml times), (v) individuai radiation workers shall be tested to measure internal radiation doseradiation dose if the external radiation dose they have received exceeds 1OOmSv~ and (vi) they shall not be allowed to work at the Fukushima Drn-ichi NPS if the e>.1emal radiation doseradiation dose they hnve received exceeds 200mSv. TEPCO reported these findinb'S (c) Subjects exposed to radiation exceeding the dose limit for urgent emergency work (250mSv)

-850-OAGI0001550_00067

Subsequently, it was discovered that, on Juue 10 two workers (male staff member F in his 30s and luale stru-'fllleluber G in his 40s), on June 20 1 \vorker (lnale stafflnelnber H in his 50s), and on July' 7 three "~yorkers (male statr 111elnbers I, J, and Kin Lheir 20s) had been exposed to radiation over 250mSv or the radiation dose limit, which was newly mandated by law.

i'ifale stall' members F, G, a.."'1d H kept \-vatch in the main control room or Units 3 a..'1d 4 during the period from March 11 to the evening of March 13 and subsequently they were engaged in their work several times. The exposure dose that these three staff 111elllbers received \vere as [ol1O\\'s: staff 111elllber F received 678.081nSv (SS.08nISv of external dose al1d 590mSv of internal dose), G received 643.07mSv (103.07mSv of extemal dose and 540mSv of internal dose) and H received 352.08mSv (IlO.27mSv of extemai dose and 241.81mSv ofinternai dose).

Staff ll1C111bcrs F lli'1d G v\"ere engaged in collecting plant data in the main control room. Staff member H was the leader of additional staff in the same room. After the earthquake. the air radiation dose rate increased in the main control room of Units 3 and

4. StallIIlt)IIlber H insLructeu the uLher stall in the lUUIIl lu wear maSKS. Un[orLlUlaldy, t~ere "lere not enough ch[l.fcmd filter m[l.sks, ,vpjch cml screen out volatile iodirle, for each staff member in the room. Some staff in the main control room wore charcoal filter masks and others wore dust fiiter masks, which cannot screen out volatile iodine, uutil charcoal filtcr masks \vcrc dc1i\'crcd from the Scismic Isolation Building in thc evening or March 12. Stall' members F, G. and H wore dust IiIter ma,ks until the charcoal /iller masks were delivered leom the Seismic Isolation Building in the evening orMarch 1272 in the control room, individual staff members 'vere in charge of specific panels and 'vere engaged in checking their respective panels on a continua! basis. Staff members F a..'1d G spent most of their time checking the meters nearest the emergency doors. which were 7

bent and twisted by the blast of the explosion '. On the evening of March 13, these three staJI members \\'-ere replaced \\ith backup members aLid th.en moved to th.e Seisrr..ic 72

'll1ey shared a charcoal filter mask \vheneverthey had to work outside the main control room Some other staff members, tr}o, \vere engaged tn checking meters jUf.o1 a.s f.o1att" members f and G \vere, but they were nowhere near the emergency doors.

-851-OAGI0001550_00068

Isolation Building. At dawn on March 15. they were instructed to evacuate to the Fukushilna Dai-ni NPS. Subsequently \\*hen they tl10ved to the Seismic Isolation Building of the Fukusmma Dai-Ili NPS, Lhey "vere grouped into temns to collee! data in the same rooms in regular shills lor intervals or several hours)4 Additionally, starr member F was engaged in vent operations with two other starr menlbers on March i 3.

StalTmember G was engaged in refueling operations \\'ith two other stalTmembers near Unit I on March 12. Staff' member H had not been engaged in any outdoor operations lll1til he moved to the Seismic Isolation Building. From March 14, he was engaged in refueling operations or checking fire extinguishing pmups at his \vorksite. In addition.

these three st~ff members hnri not tnken stable ion1 11e tablets until they moved to the 75 Seismic Isolation Building on the eveuing of March 13 . Additionally, staff member F had occasionally smoked cigarettes belore the explosion in Unit I on March 12.

Additionally', stU.L'IlTIClnbcrs F a..."'1d H \\"orc glasses.

Fnrther, three staff members, I, J, and K, had been engaged in both restoring meters to their former state in the main control rooms of Units I and 2, and securing electric power supply UUlUUOlS, slaying nIainly in the SeisIIllc Isulatiun Builwng sinet) ihe eartlIquake. The radiation dose t~at t~ese tlu"ee staff members received ,vas as follov.*'s:

staff member I received 308.'J3mSv (4'J.23mSv of extemal dose and 25'J.70mSv of intemal dose), staff member J received 475.50mSv (42.40mSv of e,,1emal dose and 433.10mSv or internal dose) a...,d stalT member K received 350.20mS\ (31.30mS\ or extemal dose and 327.90mSv orintemal dose).

Early in the moming or March 12, the main control room shiH supervisors orUnits I and 2 instructed the staff in the rooms to \vear masks. Staff member K \vore a charcoal filter mask. Sta.ff member l most likely \vore a dust filter mask, at least in the beginning.

Staff member 1 joined the operations in the control room from that same day and from the very be6>inning wore a charcoal fiiter mask.

74 from Mm"dl 15, younger f..'tatt* members \vere excluded fiDm the teams to colle.ct data in the main crmtn)] room, Additionally, staff memher C'" \vho had already been found to have received a high exiemal radiation dose at that time, ,vas excluded from \,-'orking in the main contml room 75 Staff memher f says that as tar a.;;; he remembers, he did take :-.table irxline tablets, but there is no record shm\ing that he did.

-852-OAGI0001550_00069

Subsequently, staff members L J, and K were engaged in restoring meters to their fonner state in the ll1ain control rooms of Units 1 and 2 and in carrying Ineters to the control r001115 "veafing Tyvek protective suits and charcoal filter lnasks.

The emergency doors to and ITom the main control rooms of Units I and 2, which had been bent and twisted by the blast (Tom the explosion in Unit I, were only temporarily sealed up \vith vinyl sheets. 1'-,,1eters on the side or Unit 1 yvere located in a streanl of air flowing from the emergency doors. Staff members L J, and K were also engaged in restoring these meters to their previous state.

Additionallv. there ,vere sweets and drinks on the tables in the main colltrol rooms of Upits 1 a..l1d 2. These three staff members sometimes ate and drank at the table "ithout wearing masks. Moreover, staff members J and K sometimes took their masks off and spent shorl. periods of time without them or they loosened their masks because their brcaL.~ fogged up L.~cir lTlasks or their n1usks were too tight giving L.1.C111 a headache.

Additionally. staff members I and J wore glasses.

A common factor in both staff members F and K receiving radiation exposure was that buuI uf lheIIl were engageu in Ulelr Julies ne;u- the eIm::)rgem.:y uuors. NiUloovel~ a conunon factor 1..11 staff members F, C; H, and J receiving radiation e:'<:.posure Vias that they wore dust filter masks instead of charcoal filter masks while they were working.

TEPCO summarized the causes of radiation exposure for staff members F and G on June 17 a...,d those or stall' members H, r, J, und K on August 12, und reported these findings to NTSA. The reporl. descrihes the suspected causes ofradiation exposure a" (i) it was dillicult to wear masks properly and implement protective measures to control radiation even more effectiveiy. (ii) its staff had no choice but to eat and drink in the main control room, (iii) the arms of glasses created a gap behveen the face and the mask, and (iv) its workers were engaged in their duties near the emergency doors, where the concentration of radioactive material was estimated to be extremely high. Based on th.ese estirrilltions, TEPCO decided to implement the follov.ing measures to prevent similar radiation exposure in the future : (i) infonnalion shall be shared more elTiciently and equipment and material including masks shall be placed in their proper location, (ii) staiT shall eat and/or drink only in designated areas, (iii) staiT shalileam how to use and

-858-OAGI0001550_00070

manage protective equipment for personal protection, and (iv) staff shall complete a pre-\vork smvey.

(d) Health care provided for staff engaged in emergency works TEPCO conducted funher evaluations on the internal exposure its staff received.

Subsequently, it was discovered that some employees who had been ;,vorking on the premises of the Fukushima Dai-ichi NPS quit immediately after the nuclear accident and their whereabouts remained unkno;Vll. TEPCO collected and compiled this data and rep0l1ed their findings to l~'1SA. On July 7, NISA pelfonned an on-site inspection to confirm th..at identification ,,'as not conducted properly, not even "lith public/official identification; that upon issuing a ;vork permit the license was not delivered by hand; and that access to and from llie nuclear power station was not managed exactly accorclli"'1g to spccilk rules ai'1d regulations prescribed by nuclear po\vcr station authorities. On August I, based on this on-site inspection, NISA reprimanded TEPCO and instructed TEPCO to provide a report summarizing how it would improve its sysleIIl.

Prior to JUfle 8, access to tl-te Fukuspima D(li-lcpj NPS ,vas possible even \vithout a work permit. From June 8, access to the station required a work pennit. However. a work pennit was oniy issued if a partaer company had confirmed the ori6>inal publiC/official dOCUJllcnt 'with a photo attachcd. TEPce issued copics or thc \vork penni1. Thu-:, TEPCO's work pennit were handed out on a per partner company ha-:is, not on a per person basis. TEPCO decided that learn July 19 work pemli!s should be handed mIT directly to individual ,vorkers on a per person basis.

!n addition) TEPCO asked its partner companies to perform aggregate data research.

As a result, it was discovered that a total of 150 workers (11 workers in March_ 00 workers in Aprii and 73 workers in May), ;vho previousiy belonged to TEPCUs partaer comparIies and vvorked on the prerrIises of th.e nuclear pov..*er station) \vere tillable to be contacted. On August R, TEPCO announced this. Subsequently, TEPCO and its panner companies fully examined all lists of their employees and establislied their contact details. As a result, as of October 31, only 16 of the 150 w'Orkers were lIDable to be

-854-OAGI0001550_00071

contacted. In addition, as of this date, employees who had worked on the premises of the station after july were all contacted.

On May 17, the NERHQ developed a "Policy for Im111ooia1e Actions [or the Assistance or Nuclear Sunerers" implementing long-tenll health management and a database capable or tracking the exposure radiation dose over the long-teml ror ail "varkers engaged in emergency operations to help control the CUi'Tent situation, Tn response to this situation, on June 27, the MHLW established an "investigative commission for long-term health management of workers at TEPCO's Fuk-ushima Dai-ichi l~'PS" lead by Ivlr. Yoshiharu Aizawa, vice-president of Kitasato University School of Medicine. The cO!11.!11ission discussed hmv to conduct long-tenn health management of employees engaged in emergency work even after they left their current jobs induding acquiring necessary infommtion and conducting health checks. On Scptc111bcr 26, the comrnission dc\dopcd a report lli'1d issued lli'1 UlIIlOunCC111cnt to L.killt effect (4) Radiation dose iimit for government empioyees in an emergency

a. Radiation dose liwit for government employees in emergency worJ.r.s As per the description in Section (I) c above, Article 4, Paragraph 3 of the National Personnel Authority Rules 10-5 prescribes that the dose iimit for govemment employees in emergency 'works shall be 1OOmSv, which is the saJne [or general *workers.

On the morning or March 1(', a staJTmember ofNalional Personnel Authority in charge orNational Personnel Authority Rules learned via a news report thal both the MHLWand iviETI had raised the radiation dose limit for workers engaged in emergency works. "Vith regards to national government employees emp!oyeed in regular government service, it is likely that, for example, Nuclear Safety Inspectors might be engaged in emergency worksat a nuclear power station. Hence, a staff member immediately asked MHLW to pro\,ide r..im "villi th.e relevillit documents. To discuss the liilltter, th.e staIr member also phoned a Defense Ministry staff member in charge of a "Ministry of Defence official directives concerning staff health care" that is quoted from National Personnel Auihority Ruies iO-S. At approxilnately 18:00 on ivlarch 16, the smne siaiInlelnber asked

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ilie MEXT Radiation Council advice on a ministry order revision iliat ilie exposure limit should be 2501115" to respond to events resulting frolll the 2011 Tohoku District-off the Pacific Ocean Ea..t1.hqua]:,-e fran1 Lhe date \v'hen Lhe nuclear elnergency is declared 10 the date when the nuclear emergency is lilled, in a zone where emergency countenneasures must be taken in unavoidable circumstances .. Tne Radiation Council had a debate on the proposed dose lImit by email l1'om 18:30 to 19:30 that day. They reached a consensus a.-.,d replied that it was reasonable. In response to this advice, the National Personnel Authorily revised part of ilie Nuclear Disaster Special Measures Law, Article 28 of ilie National Personnel Authority Rules 10-5, as follows: !lin response to events resulting frmll the 2011 Tohoku District-off the Pacific Ocean Earthquake from the date ,;vhen the nuclear emergency is declared (pursuant to Para;,'faph 2 of Article 15 of ilie Nuclear Disaster Special Measures Law enacted in )999, No. 156) to the date when the nuclear emergency is lifted (pursuant to "Paragraph 4 of th.c A.."1idc, in a Lone \vhcrc ClTICrgcncy countermeasures must be taken prescribed in Paragraph (X) of Article 17 of the same Law),

in unavoidable circumstances ilie exposure limit "lOOmSv" (prescribed in Item (3) ofilie SaIne P,u-agraph), cuncenllng lhe applicaLiun uf lhe pruvisiun uf Paragraph 3 uf ArLide 4, should be repl::lced v/itl-t tl-te dose liIPit of 250mSv." TPis revision ,vas published in a govemment gazette ilie next day, March 17, and took effect iliat day Additionally, Nuclear Safely Inspectors who worked in the Fuk-ushima Dai-ichi Nt'S safety inspectors' onicc col1ecting infonllation aner the nuclear accident (refer to Section 1112(7) above) were not directly engaged in emergency operations in reactor huildings.

Derense Ministl} stal; including Sell' Derense Force personnels, are govemment employees for special government service and they are not directly subject to National Personnel ,A~uthority Rules 76

, Ho\'vever, Paragraph 2 of Article 26 of "Ministry order on health care management of Defense Ministl} staff" stipulates that "the limit of effective dose equivalent for directees (workers under management) \\ho are engaged in emergency vv-orksto prevent radiation ha/ards srwll comply' vvith the rules of stllirr \\ho are engaged in emergency works (Paragraph J or Article 4 orNalional Personnel Authority Rules 10-'i.

76 ATticle 2, Paragraph en Item (16): Article 2, Pm"agraph (5} ATticle:1 Paragraph (2): and Article 16, Paragraph (I) of the National Puhlic Service Act

-85fi-OAGI0001550_00073

Hence, ilie limit for ilie effective doseequivalent shall comply wiili ilie rules of National Personnel Authority Rules 10-5.

In response 10 Lhe declaration of the nuclear eluergenC)' state on the flight of March 11, at 19:30 on the same day the Self Defense Forces issued a "Sell:Defense Force action command conceming the impiementation 01 nuclear disaster dispatch service (or nuclear emergency events at the TEPCO Fukushima Dai-ichi Nuclear Pm*ver Station Ut'1d Ful-ushima Dai-ni Nuclear Power Station," From March 17, Se1t:Defense Force personnel were engaged in flushing water out into a spent fuel pooL but none of iliem received a radiation dose exceeding 1GOUlSV, ,,,,hieh ,vas the previous radiation dose limit prior to being changed.

h. Radiation dose limit for local government employees in emergency works Provisions of the Industrial SafeLy' lli'1d HcalL.1. Act, raL.1.cr tluu"'1 L.1.0SC of L.1.C National Personnel Auiliori1y Rules, are applied to local govemment employees including police officers and firemen77 Hence, ilie radiation doser limit for local government employees in eIIleJgem..:y operatiuIls was raiseu LU 250IIlSV unlvlan:h 14.

i\~ guideli.l1e on tl}e radiation dose !iIPit for police officers (lJld firemen cont9ined ill t~e NE Guideline prepared by the NSC in June, 1980, stipulates iliat "ilie upper limit of radiation dose, especially for those who are engaged in emergency ,varks in a nuclear accident site among those engaged in disaster prevention vi/arks (Tor example, stall' other than radiation workers employed at the nuclear power station a, well a, experts dispatched from the national govemment, those who are employed at police or lire stations, Self-Defense Force personnel, those vvho are empioyeded in urgent medical care service),

shall be 1nOmS" in terms of effective dose for emergency ,vorks in urgent al1d lUlavoidab!e circumstances to prevent a disaster from worsening and to save lives. Additionally, ilie

'Manual for firetlghting activities at nudear power facilities'; prepared by the Fire and Disaster rv1llilagement Agency in ~vrarch 2001 stipulates L.~at L.~e "radiation dose lin-Iii shall bel nOmSv ror emergency works 10 save hve'), There ",,-ere no changes in them.

None of the mobile police o1l1cers and firenlen engaged in flushing water out into a 77 ATticle 5R of the Local Public Service Act.

-857-OAGI0001550_00074

spent fuel pool were exposed to radiation dosesexceecling lOOmSv.

(5) Radianm1 expmmre Df dtizens

a. Screening level before the nnclear accident The HManual lor radiation emergency medical care activities in Fukushima Prefecture,::

-vhlch ;,vas created in 2004 fiscal year ui'lder the authority or the Fukushima prefectural government. was based on a previous manual "What should be done in radiation emergency medical care and how," which was prepared by ihe NSe in July 2001 and stipulated that the screening level for residents n (a criterion of cOlnprehensive OULer body deal) up) should be 40Bq/cm2 79. The Fukushi!112 prefectural govel11ment, \vmch l!1itially decided ihat ihe value was equivalent to 13,OOOcprn (counts/minute), used 13,OOOcpm as a criterion for comprehensi ve entire body dean up.

b. Raising the screening level after the nuclear accident TIle NERLHQ aL the OiI-site CenLer, which stalleu WSCUSSIUJCl UIl SClet)Illng level settings on rvl(1.fch 12, asked tl}e ERe advice on tl:le criterion of 40Bq!cm2 or 6,OOOcpm on ihe morning of March 13. The ERe asked ihe NSe for feedback and ihe NSe responded saying that stable iodine should be ,,>iven to those "ho experienced radiation dose rates of more thai'1 10,OOOcpm, rUi'-H1Cf adding that G,OOOcpm should be replaced \vith 10,OOOcpm8o ,

However, this response was not communicated rrorn the ERe to the NERLHQ. Instead, a message submitted to the NERLHQmerely stated that the NERLHQopinion should be

&..Tet:ning VI/ouid me<.U1 the monitoring servi<..:e mal determines wheLher or noi a monitoring subject has 1:x:::eJ.l L:OnLalllillalcd by wwoactivit); and ihu;:\ needs tu Lx; ucconimIlllwLcu. &n;'-~llng IIlOIllioIlng is <..:tllluudw h.Y' holding radiation dose mCi-bUfi..-111L11l equipment o\\;r the subject being monitored to measure the level to v.. hich h(.;

or she has been contaminated. 'Inc screening lc,,'cl is the lc'vcl that iIlmcatcs 'ivhcthcr a screening su"Qjcct needs to Ce JeC(mtmllL."1ateJ ifhis or her level shuuld exceed !.he limit.

K..ll0\vlcdgc of ramali!...)!.} LTIlcrgL'IlCY lllcdicCll care" (in March 2(X)3) in EKlialiol1 mCaSUIL'll1L'lll for i!lilial exposure medical CHIC. Addilionallv, a n()te i~ Hltachcd l() lhi~ CriIC'1i()ll ~lating thaI this vahlc is ~Ilhjccl 10 ch~-I11gc al any civen tUlle that the government decidcs it nceds to be changcd.

RO ~-- IO,O()()clJm is a v;lue that the NSC has decided is equal t~ 40Bq/cn? and is used, a..;; a cliterion fmm a safer f.oide (conservative) point of "iew.

-858-OAGI0001550_00075

8' respected '.

At 14:20 on l"viarch 13, the head of the NERLHQ issued insnuctions based on Paragraph 3 of ~Article 15 of Lhe Act on Special Measures Conceming Nuclear En1ergency Preparedness to the heads or Fukushima Prerecture, Okwna-machi, Futaba-machi, Tomioka-machi, Namie-machi, N araha-machi, Hirono-machi, KalSurao-mura i',,1ina'-'11i-soma-shi, Kmvauchi-mura lli"'1d Tamura-shi to the elTect that the screening level should temporarily be adjusted to 40Bq/cm2, or 6,OOOcpm. The Fukushima prefectural government decided to use the criterion value of 40Bq/cm', which was orii,>inally a criterion value defined in the "lvfanual for radiation enlergency 111edical care activities in FukushilYl.1! Prefecture" stating that 40Bq/cm2 ,;vas equivalent to 13,OOOcp!11., al1d started screening based on a screening level of 13,OOOcpm On March 13, a tearn of radiology experts" was dispatched to visit the Fukushima prefectural govcffil11cnt office to provide radiation ClTICrgcncy 111Cdical carc. The regional medical division of the Fukushima prefectural government, which was in charge of screening activities, asked the team for advice on how to most effectively conduct screening. TIle learn uf experls Jiscusseu lhis amungsL theIIlsd ves amI, as a lesul~ uecideu to implement a specl(ll "Fukuspima version" screening program. for external ,vhole body cleansing for the follO\\1ng reasons: there was not sufficient water due to water supplv suspension: the night temperature was below freezing, thus it was risk'Y, especially for sick or i11 people, to be decontaminated outdoors; a.."'1d it \vas necessary to take care or people swirtly and sarelv with limited slarr All or these J"actors made it dillicult to conduct screening and standard tolal extemal body cleansing. Also, they provided the regional medicine section vvith advisory instructions. One oftne advisory instructions was to raise the screening level to 1OO~OOOcpm equivalent to 1~LSv/h (an exposure rate at 10em from body surface)", which is prescribed as a screening level for the general public receiving a body surface contamination check in the ;'Manual for First Responders to a Radioloi,~cal The NSC investigated \vhy and ho\" their feedhack had not been communicated to the T.r}l.:al nmergency Rt.'srxmse Center As a result, It \vas disco,rered that the crmnnent "ms faxed to the PRe and that it "ms recei\red hv a st!lfT lllL'lllOCT \vho had OCL'll dispatched rmlll thc NSC SC(.:rcl:-rri!lt !md Lh!lL no onc hml seen it since H stil1 rC1ll3l1lS 3 lllvstcrv.

fG Dispatched fi'Ol;l PuK1.li University, Hiroshima University and NTRS.

fn \\'hen mea<.,'Ured \\ith the GM Sun;ey Meter" Aloka TGS-J3h" (Scm \vindO\\' diameter).

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Emergency, 2006 " developed by lAEA Contrary to instructions from the head of the Local Headqurulers, the Fukushilna govenullent office accepted this advisory insuuction and decided to use lOO,OOOCPlTI as lhe screening level for external ,,,,hole body cleansing.

Additionally, Fukushima Medical University Hospital, providing screening services orits own to its patients Irom March 12, also used I OO,OOOcpm as a screening level due to a lack or \vater. This Caet \,vas also taken into consideration when the Fukushima prefectural government raised the screening level to IOO,OOOcpm.

In the early moming of March 14, having leamed via an ERC medical treatment team's repOll that the Fukushima prefectural govenllnent had raised the screening level, the NSC held a discussion on the notion that if the entire 13,OOOcpm should be from iodine resulting 84 in internal exposure, whether it might be equal to an equivalent dose of 100mSv , wmch is the criterion of stable iodine administration. At 04:30 the same day, the NSC provided the ERe \\'i1...1. advice to L.1.C cITed L.killL "scrccr.dng criterion should not be raised to 100J)OOcpm, but instead remain at the current value of 13,OOOcpm". However, the Fuk'UShima prefectural government continued to use I OO,OOOcpm for its screening service.

Subset[ueuUy, lhe NSC hdJ [mUler iliscussiUIC:i uaseJ un upiniuIC:i [ruIlI InLUllcipaliLies t..l:lat ,,*'ere engaged in providing screeniILg services at tl:leir loc,,] sites afLd at 14:40 on March 19, provided the ERC \\ith the revised piece of advice "regarding screening criterion of radiation emergency medical care, if which stated that screening criterion should be raised to IOO,OOOcpm.

c. Implementation of screening "What should be done in radiation emergency medical care and how" stipultes that releva'1t local govemments~ under ml..-TJaI cooperation ,,,,,;th their partner organizations, are specilYing places where to conduct rescue and evacuation operations as well as planning to conduct screening services , if necessary. In response to 1his situation, 1he "Manuai for radiation emergency medical care acti,,'ities in Fukusr..irrkL Prefecture" stipulates that a medical treatment team shall be established, which "ill be led by the divisional councilor R4 This a.;;sumption stands on a sater side (conservative) point ofvie\v, although much of the actual contamination appears on the outer f..'llrrace of clothes and r>ther wearable items.

-8f)O-OAGI0001550_00077

of the hygiene services division of the department of health and welfare services in the Nuclear Eluergency Response Center and that a screening team shall be established imd

,\,ill consist of hemLh and \vdfare service s1::1 n: core-city hemLhcare center starr, doctors from the prefectural hospital and the medical association, and radiology technicians IT-om the Fukushima Regional Association or Radiological Technologists, which wili conduct body-surface conta.-*nination monitoring ;,vith surve) meters to detennine if monitored individuals or subjects need decontamination.

In response to the declaration of a nuclear emergency state by the Japanese government on the night of l'vfarch 11, the Fuk-ushillla prefectural govenllnent decided to inlplelllent screening services an.d started doing so fue next day, on March 12. Hmvevef, there 'vere far more monitoring subiects than expected so there were not enough staff members from within the prefecture to allow them to adequately handle all screening services". The Fukushinm prefectural gOVCITill1cnt asked L.1.C national govcmIl1cnt, local gOVCITlll1cnts, universities and the Federation of Electric Power Companies for their cooperation in conducting screening services at evacuation facilities and permanent facilities designed for COIIlIIllUlily use. Niure ihan a iotal of 200,000 JIlOIlltmiug subjects representing over 1070 of tl-te prefectur(ll population received screening services. The count rate of tl-tose monitoring subjects was between 13,000 and 100,000cpm The number of subjects who needed partial external cieansing was 901, and the number of subects whose measured count rates \vas higher thw"'1 100,000cpm w"'1d needed whole body' c1eai'lsing \\-'as 102.

However, the cmmt rates or those monitoring subjects whose mea.;;ured exposure \Va.:;

higher than IOO,OOOcpm was below the designated level when they removed their clothing.

d. Medical checks condncted fo .. the citizens of Fukushima Prefectu ..e On May 19, the Fukushima prefectural government established the Fuk-ushirna Prefecture Health. ~v10nitoring Surve:.v Research Corrnr..ittee to discuss hov.. to conduct medical checks ror the citizens or Fukushima Prefecture. Tn response to those committee The maximum munher of facilities used for SLleening services was 42 on Mm'ch 19 (including 10 evacuation fac*ilities and nvelve permanent facilities meant for connnunit.y use).

-8f)1-OAGI0001550_00078

discussions, on June 30, ilie Fukushima prefectural government began delivering sets of inquilY forms, which dealt luainly with dietmy and behavioral records frotH Ivlarch 11, to individual evacuees fron1 Namie-n1acbi, Iiiaie-nlura and Yam.aldya district of Kawamata-machi, who were subjects participating in the survey. The same set of inquiry fonns was deiivered to aii remaining citizens oftne prefecture on and ailer August 26. Tne survey induded fonns for entering basic survey details as \\'el1 as medical checkup, Q&A survey, and thyroid gland examination results. The results of the survey are to be managed and maintained in a database on a long-term basis.

e. Distribution of stable iodine Stable iodine is a chernicaliliat mainly consists of non-radioactive iodine. Taking iodine

[or radiation exposure can heip prevent radioacti ve iodine [rom being incorporated into the thjToid gland even after radioucti vc iodine 1U15 entered the body. Thus stable iodine is used to prevent thyroid gland cancer from occurring.

The "guidelines concerning ilie preventive intake of stable iodine tablets" prepared by the NSC In April 2002, uesuibes hu\v tu ueleuniut: whether ur HuL stable iudine Lablels should be tak:en stating tiIat "various protective measures C,Ul be implemented, including shelter, evacuation and preventive intake of stable iodine tablets, in accordance \\1ili the NERHQ judb'l11ent." Additionally, while addressing concerns regarding ilie side effects of satblc iodine, these guidelines also stipulate that great care should be taken to ensure residents take stable iodine tablets as safelv and as soon as possible in an enlergency situation where it is predicted that the infantile thyroid gland equivalent dose due to radioactive iodine wiii reach 100mSv, and if the NERHQ instructs residents to take stable iodine as a preventive measure.

The NE Response Manual prescribes iliat the "Technical Advisory Organi7ation in an Emergency" staff shaH provide a technicai advice in the "Joint Council for Nuclear Emergency Response" established in L.~e OIT-site Center and L.~at a draft of protective intake polley implemented by the Urgent Emergency Measure:; Pollcy-making Committee should be reported to the NERHQ, thal !he NERHQ' decision on the intake of stable iodine tablets should men be communicaled by me head of me NERHQ to me head of me

-8f)2-OAGI0001550_00079

NERLHQ, who should convey this information to the governors of local govemments, and finally that the governors of local govenunents should then provide this infonnation to their residents 86 .

At 13: 15 on March 12, the NERLHQ issued a written order to the leaders of the prefectural government and respective municipalities (Okwna-machi, Futaba-machi, Tomioka-machi, Na'-'11ie-machi) to t,"'1e elTed that "irinstructions are issued [or residents to take stable iodine tablets, it should be decided by all possible means that stable iodine tablets be distributed to evacuation facilities and that a sufficient number of pharmacists and doctors should be stationed at these evacuation facilities.

Moreover, as described in b above, the NERLHQ asked the ERe for nrivice an.d its 2

comments on a draft that the screening level should be changed to 40Bq/cm , or 6,OOOcpm. In response to this request, lbe NSC told lbe ERC lbat instructions should be given at L.1.cir screening services to the cllcct L.1.at stable iodine tablets should be prov"idcd to those who had radiation dose of more than IO,OOOcpm. However, this infonnation was not communicated to the NERLHQ On the nighL uf l'Vi<:U-dl 14, the ERe rmxliL:al lreailntml learn was in[unneu thaL Lhe evacuation of hospitalized patients v.,'ithi.fl a 20k'1l radius had not yet been completed :md they provided this infonnation to the NSC. In response, a few hours later at 3: 10 on March 15, the NSC provided the ERC advice to the effect that the hospitalized patients should hm'c taken stable iodine tablcts \vhen they \verc cvacuated according to a provision conceming "Rules on the intake of stahle iodine tahlets in the evacuation of hospitali/.ed patients Irom an evacuation /One (within a 20km radius}." The ERe sent this advice to the NERLHQ by fa"\:. Ho\vever, that same day. the NERLHQ ,vas busy relocating to the FlLlcushima Prefechrra! Office building. It \'vas not lLYltil later that evening~ after they had completed their move, that they discovered the fax conveying this advice. The NERLHQ, which considered it highly likely that in addition to hospitaiized patients many elderly citizens li ving in local corrllllU11ities aild hospital starr still rerrwined, created illl instruction fl(, The manual for radiation emergency medical care acti"ities in fuku."hima Prefecnu"e stipulates that the intake of stahle iodine tahlets should lJe communicated by the leader of the I.ocal Emergency Response Center to the leader of prefectural local headqumters, to the leaders of medical treatment teams of prefectural local headqumters, and finally to the leaders of the respective mlUlicipalities.

-8f)8-OAGI0001550_00080

draft to the effect that subjects who should take stable iodine should include residents other than hospitalized patients. That nigh~ the NERLHQ provided the ERe \vith its instluction draft stating thai residents H*ho should tak_e stable iodine tablets should include all citizens that still remained within a 20km radius. Tn response to this, the ERC asked the NSC ror advice on this instruction dralt. At Oi :25 on March i6, the NSC distributed advice to the ERe to the eITect that all of those who remained \\ithin a 20km radius should take stable iodine tablets while being evacuated according to the "Rules on having those who remain in evacuation zones (within a 20km radius) take stable iodine tablets when being evacuated." TIle l~r:RLHQ, ,vhieh confinned this advice via the ERe, issued a \vlitten order at 10:35 the sa.rne day to the le~t1ers of the Fukusmn1u prefectural .. govem.rnent nnd 12 affected municipalities to "have those who are evacuated from evacuation zones (within a 20km radius) take stabie iodine tablets.;; However, the Fukushima prefectural government did not [ollov~" L.....~s instj'liction on Lh.c intake of stable iodine tablets because L.~c govcmn1cnt had already confirmed that there were no subjects who remained within a 20km radius.

Additionally, the Basic Disaster Prevention Plan stipulates that the "National GuveIIIIIlent (wiEXT anu l'viHL W), japan Reu Cross, 1u(';<:11 guvernrnenLs awl nudew operators shall cooperate vllti} each oti}er in storing and mairrtfljpjng radiation measurt.l1g materials and equipment, decontamination materials and equipment, stable iodine tablets, medicinal chemicals and equipment for emergency relief activities, as well as materials a.'1d equipment Cor medical services. II Six regional mUi'1icipalitics SUITOUi'lding the Fukl1,hima Dai-ichi NPS and Fulm,hima Dai-ni NPS (Hirono-machi, Naraha-machi, Tomioka-machi, Okuma-machi, Futaba-machi and Namie-machi), as per the advice in the "Manual for radiation emergency medical care activities in Fukushima Prefecture." already had 136,000 stable iodine tablets on hal1d, \\hich corresponded to t~ree doses for t~e estimated population of intake subjects (below 40 years old) in an EPZ (Emergency Pianning Zone), which is a re,,>ionai zone within a IOkm radius requiring enhanced comprehensive disaster pre\enLion planning. Additionall~y, hvaki-sll1 ill1d KoriyarrkL-slli, w-hlch w-ere not designated as FPZ, also stored and maintained stahle iodine tablets Moreover, the Fukushima prefectural govemment stored and maintained 68,000 stable iodine tableis in the Enviro11l11ental Iviedical Research Insiituie located in OkLU11a-macru

-8f)4-OAGI0001550_00081

for tourists and oilier visitors to ilie prefecture. The local Government also asked ilie ERe and other orgmlizations to help secw-e stable iodine tablets and were able to obtain approximately' 1,360,000 s1::lhle iodine tablets fron1 a nmjor stable iodine 111anufacturer and from the Jbaraki prefectural govemmenl.

On March 14, the Fukushima prefectural govemment discussed whether or not stable iodine tablets should be distributed to al1 mUi'licipruities within urI approximate radius or 50km of the nuclear power station and reached the decision to distribute two tablets to each resident ofYOlUlger ilian 40 years old within iliese zones in each mnnicipali1y. By ivIarch 20, the Fukushima prefectural goveullnent had distributed approximately 1,000,000 stable iodine tablets to residents living in mllnicipa!ities in the Harra.1l-dori and Naka-dori districts.

Additionally, around and alier March 15, some regional municipality offices surroundiL'lg tIle Fukusmnm Dai-id:11 NPS dish-ibutcd stable iodine tablets to h1.cir residents of their own accord. For example, on March IS, the Miharn-machi town office not only distributed stable iodine tablets to its residents. but also instructed them to take ilie tablets.

In the nilddle uf the night uf Nian.:h 13, Niih::uu-IIIadil town ufficials ltwneu that the radiation level had increased at tl-te Onagmva Nuclear Pm:ver Station. \}.,1 eatl}er forecast.s predicted rain wiili an easterly wind for ilie following day, March 15. Miharn-rnachi town officials were afraid that its residents might be exposed to radiation and decided to distribute stablc iodinc tablcts to its residents a...,d instnlctcd L1cm to takc the tablets. At 13:00 that day, Miharu-machi to\m omcials, u,ing a municipal disa,ter management radio communication network, made sure that each and evety resident was infomled of this decision. They distributed stable iodine tablets to approximateiy 9570 of object residents lmder supervision of the local pharmacists. Later, health and \ve!fare service section staff of the regional medical division of the Fukushima prefectural government learned that the Miharu-machi to\\n office had distributed stable iodine tables and instructed intake subjects to take them vviL1.out directi'ves [rom either the national or local govelThl1ents. In the evening of' the same day, the section staff' instructed Miharu-machi Lo\\,n omcials 10 stop distributing stable iodine tablets and recover all of them as there had been no instructions fron1 the national govemn1enL lviiharu-nmchi town officials did not obey ibis

-8f)fj-OAGI0001550_00082

demand.

(6) Damage in radiation emerge!!~y medk~J fadlities radiation emergenry "What should be done in radiation emergency medical care and how" (refer to Section (5) a above) states it is criticai that an radiation emergency medicai care service system shall be implemented with integrated UI'1d orgnni/,ed operations and with mutual complementary roles of the following medical facilities to provide effective and efficient radiation exposure medical care: "medical facilities for primary radiation emergency medical treatment" to provide initial Inedical care and elnergency treatment, "uledical facilities for secondary radiation emergency medical treatment" to provide professional treatment, an.d "medical facilities for tertiary radiation emergency medical treatment" to provide highly specialized treatment. In Ihe manual [or radiation emergency medical care activities in Fukushima Prefecture, L.1.C Fukushima prefectural govcrmncnt has designated L.1.C [ollO\vmg five locations as medical facilities for primary radiation emergency treatment: (i) Fukushima Prefectural Ono Hospital in Olmma-machi, Futaba-gun; (ii) Fukushima Prefecture Agrl(;ullw-al Couperatives Futaua Wdf,ue Huspital in FuLaba-madu, Fulaua-gwl, (iii)

!!p.lunura Hospital in TOluioka-macpj, Futaba-gurl; (iv) Fukuspirna Rosai Hospiwl in Iwaki-shi; and (v) Minami-soma City General Hospital in Minami-soma-shi; and one iocation, as a medical faciiity for secondary radiation emergency medicai treatment:

Fukushima iVfcdiea1 University Hospita1 in Fukushima-shi 87 Three of the live medical facilities designated for prim3TV radiation emergencv medical trealment in Fukushima prefecture, 000 Hospital, Futaba Welfare Hospital, and TmanlUTa Hospital, are ioeated in Futaba-glUl within a 10km radius of the Fukushima Dai-iehi NPS.

These three hospitals \vere all exposed to large mnOlmts of of radioactive materials discharged from the Fukushima Dai-ichi NPS. According to an order issued by the head of the NtRHQ at 05:44 on March 12, each of the three hospitais was in an evacuation zone, 87

"\J;lb.ut should tx:: dono:.:: in rw..!ialicm CTIlC'l't:c'no:.::y mo:.::dio:.::al o:.::ap..; and hmv" slato:.::~. t..~ut mo:.::dio:.::alIH'...:ililio:.::s for pri..mary radiation 1...1111...Tgcncy treatment s...hould b(~ 10(..:atl...'iJ "neHr nudc<:!r facilities", Hnd mcdic!-ll facilities for Sl..:Gondary T!-liliation L'll1L'TgL11CV IrcalmL11t should he at !l loc!ltion "wherc patiL'1lts or individlwls cxp)scd 10 radiation C!-ln he tramfclTed from nuclem: facilities or medical facilities for prunary radiation emergency treatment in a proper manner and in a relatively short time." Additionally, 1VmXT ha.o;;; designated NTRS, in Chiha-shi, as a medical fac.ility torter1iary radiation emergency treatment for the eastem Japan hlock.

-8f)f)-

OAGI0001550_00083

which prevented the hospitals from functioning as medical facilities for primary radiation enlergency 11leclical treatment. TIle other nvo 11ledical facilities for prilllmy radiation enlergency medical treatInen! are located in I\vaki-sm and Minann-sonm-shi. Mnanri-solTm City General Hospital located in Minami-soma-shi was located in what became a deliberate evacuation /.one on April 22.

Additionally, as described above, pre-designated medical facilities lor radiation emergency medical treatment and other medical organizations were not able to function at full capacitv.

Some of those who were injured at the Fuk-ushima Drn-ichi NPS did not have their injuries treated for three days. For example, a TEPCO st8..L'f Inelnber, \",ho ,vas near the reactor building of Unit 1, suffered a broken left arm during an explosion on March 12 al1d required an operation. He was initially transported in a TEPCO business vehicle to 000 Hospital, which had been designated as a medical facility for primary radiation emergency medical LrcauncnL As per L.1.C description above, L.1.C hospital, \v1:1ich \V"as in a deliberate evacuation zone, had already transferred all hospital functions to another location. After being transferred to another hospital he was denied the operation due to a lack of water. To make matters worse, he was separaleu [lUnl TEPCO slaiI whu hau been assisLing hiln anu lhus was leLl alulle

'.Vit..llOut ::U1Y money. Subsequently, t..llls staff member Vll:l.s moved from one evacuation facility to another En route to another evacuation facilitv_ he was told that his clothes had been contaminated \Vith radioactivity. Finally he had to surrender his contaminated dothes. It was at yet another evacuation racility that he \\'"as able to be supplied extra clothes to \vear. Lists of evacuees helped this stalTmemher learn of his familv's whereahouts and he was final Iv ahle to get in touch vvith them On March 14, he Ilew Irom Fukushima to Tokyo aller his family reserved a flight for him. Tne nexi day, March 15, he visited NiRS to have radiation testing.

Subsequently, he '.vas able to have an operation on his left arm at a hospital in Tokyo.

5. Contamination of agricnltural, livestock, marine products, the air, soil and water (1) Cont"-lnination of water, beverages "-lId food, and the response taken

a. Ctitetia on the restriction of shipment (before the nuclear accident)

Prior io the nuclear accideni there was no criieria by which food and beverages

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OAGI0001550_00084

contaminated with radioactive material was directly restricted. The only criteria on food and beverages conta.minated \vith radioactive Inaterial ,vas the Index88 for restrictions on the in1ru(e of food and beverages indicated 89 by Lhe NSC (refer to Section 4 (1) c above).

The index is a guideline lor discussions on whether or not it is necessary to take measures to restrict load and beverages, but does not provide criteria lor taking measures to restrict their shipment.

This index provides a guideline for each of the following five food categories: (i) drinking water, (ii) milk and dailY products, (iii) vegetables, (iv) grains, and (v) meat, eggs, fish, and othec in terms of: (i) radioactive cesium, (ii) uranilllll, and (iii) plutonimll and three alpha-isotopes oftransufaraium elements; but ony provides a b'Uideline for p:1t1!oactive iodine for the following three food categories: (i) drinking water, (ii) milk and dailY products, and (iii) vegetables (excluding root vegetables and tubers)'lO.

The National Basic Disaster Prevention PlaL'1 stipulates that the national govcm111cnL shall conduct research on food and beverages contaminated with radioactive material to determine effective and useful measures and, if necessary, instruct relevant organizations Lu resilicL shipIIIeIlL aml/ur intake uf such cunlanullaleu fuuu awl beverages, anu ihe lut..:al gm*'el1unent implement t~e measures.

The Radiation Monitoring Guidelines n established by the NSC states that !be air radiation dose rate, the atmospheric concentration of radioactive materials and the radioactivity concentration or environmental samples (drinking \\"a1er, leal)' vegetables, raw milk and rainwater) shall he measured as soon as possihle immediately aller a nuclear emergency and decisions regarding protective measures 01 what should be done and how it should be done shall be determined based on the measlll"ed cumulative exposure, in addition) the manuaJ for radiological environmental monitoring in an emergency~ prepared

'lhe National Basic Disaster 11:cvention IJlan states that the NE Guideline established by the NSC shall be fully respected to detennine pmfessicmal andlortechnical mart..ers.

~9 '!11e index for restriction:": on the intake of t0cid and l1e".'erages \V3S estahli:,,:hed in 199X ha:o.ed on guidelines from the NSC Envin:mmental \~lorking Group Specializing in Disaster Prevention 1vfea.<"'lu"es for Nuclear Pmver Stations

~-,I Tt is explained that any food that involves an extended period of time henveen the incoq)()ration of radioactive matelials and the time of shipment was excluded 91 The National T1a<;ic Disaf.o1er Prevention Plan states that the NE Guideline established hy the NSC shall he fully respected to cletennine professional andlortechnical matters.

-8f)R-OAGI0001550_00085

by the Fukushima prefectural government states that as soon as the government is infonned of the occurrence of a specific incident, an elnergency 1110lutoring project shall be developed and ilnplelnented to de1emnne Lhe necessity of urgent actions and that Lhe following items shall be measured: radioactive iodine and radioactive cesiwn included in environmental samples (drinking \vater, lea(y vegetables, raw milk and rainw'aler), the air radiation dose rate a.."'1d the concentration orradioacti\,'e iodine in the air.

b. Detecting a high level radioactivity in plants In response to the current nuclear accident, frOlu Ivlarch 12, elllergency 11lonitoring activities to measure the air radiation dose rates and perfonn dust sa.111pling \vere conducted at local sites. However. there was no monitoring of leafY* vegetables or raw milkn.

On ~,,1arch 15, th.c Fukusllima prefectural govcmnlcnt collected weeds ai'ld nlc<<surcd them. As a result. radioactive materials that far exceeded the index values for placing restrictions on the intake of food and beverages were detected in weeds that had been colledeu at a lucatiun beyuml a 30hlulawus uf the F ukushiIIla Dai-idIi NPS.

In response to this, t~e Fukushima prefectural goverrunent '.vas '.vorried about food ::uld beverages contaminated with radioactive materials. During that time, however, there were only two germanium semi*conductor detectors available to measurethe radioactivity, and local gm,'cmmcnt olTicials \vcrc not ready to monitor a \vide rai'lgc or food a...,d beverages.

Hence, the local government a,ked the NERLHQ to perfoml monitoring of food and beverages. which, under ordinary circunlstances. they should have done thenlselves. Tn response to this request, the NERLHQ decided to ask the japan Chemical Analysis Center (JC,A~C) to perform monitoring of food and beverages. Thus through the mup..m!

cooperation of both the NERLHQ and the Fukushima prefectural govemment, full*scale implantation offood and beverage monitoring began in Fukushima Prefecture.

The ~v1iL'1isti') of Agriculture, Forestry llild Fisheries (lVIAFF) designed a [rlli"11ev\"ork93 In 92 The fuku."hima prefecuu'al govennnent ~iaff tIl charge of this matter eX1)lained that this vms hecau.<;e "yve thought \ve had to analyze air dust first due to the very limited number of measurement instmments and equipment availahle. ,.

93 Tnitially, the two monitming institutes \vere ahle to test a total of ahout fix(v samples a day.

-8f)9-OAGI0001550_00086

which the full cost of monitoring would be borne by MAFF and all food products produced in local lllwllCipalities other than Fukushinla Prefecture ,vould be transpOlted to and nleasured by JCAC and/or Lhe National Institute for Agro-Enviroml1ental Sciences (NJAES). Municipalities successively started to contact measurement institutions themselves seeking cooperation in perlonl1ing monitoring oC lood and beverages.

c. Provisional regulation value for food and beverages The MHLW, which is in charge of the Food Sanitation Act, had never exanrined the adequacy of existing criteria for strategies on \"hat to do \vith food and beverages distributed ,;vithin Japan. if they \vere conta.minated \vith r~nioactive !1l.aterials.

On March 15, as described above, a high concentration of radioactive materials was detected in weeds that had been collected in Fukushima Prefecture. The MHLW stall in charge of L.l-..tis ll1attcr L.~ought S0111C action should be taken wiL.1. regard to L.1.C radioactive contamination of food. They determined, however, that any action should be consistent with the Act on Special Measures Concerning Nuclear Emergency Preparedness. In other

\\iOlUS, they iliJ nul iIIlagine lhaL any adiuIl cuuld be taken un lhe basis uf lhe Fuuu S(l~t}itation Act. rVle(l~t},vpile, l\tlAFF Vias \vorried tl"tat agricultural products tpight be seriouslv impacted bv rumors. Hence, they detennined that in order to prevent agricultural products from being negatively affected by rumors, it was necessary to develop general cnh., ;a Cor deciding whether or not a.."y Cood in question should be a1lo\ved to be dislributed within disaster-alreeled regions as well as to non-alrecled regions. On March 16, MAFF strongly urged the MHLW to implement criteria for food exposed to radioactive materials in accordance ,vim the Food Sanitation Act. in addition to this urgent request from M,A.FF, the MHL\V itself determined that it \vas necessary to examine food distributed in a wide range of areas on the basis of the Food Sanitation Act and decided to exanrine the adequacy of criteria for radioactive material as prescribed in the Act Finally, the rv1HL \V decided tl"'illL the hidex [or resh--1cLions on L.~e intake of food WId be\.'erages, which the NSC had implemented based on the simulation of a nuclear accident within Japan, should be adopted in order to take swift and appropriate action and solve the current elnergency situation. Tne lYIHLW decided to adopt the Index as the provisional regulation

-870-OAGI0001550_00087

value for food and beverages in accordance with the Food Sanitation Act The MHLW naturally took into consideration the significant potential effects of radioactive iodine on childhood Lhyroid cancer and adopted the Codex Lndex94 (lOOBq/kg as the criterion for all food and beverages in temlS of radioactive iodine). The MHLW also decided that milk and dailY products exceeding the criterion oi' i OOBqJlg should not be used i'or modiiied dIY mi1k Cor in Gmt or Cor milk to be directly consumed. Additionally, on ~vfarch 17, the MHLW issued a notice to all prefectural governments to the effect that the index value indicated by the NSC should be adopted as a temporaJY provisional re,,'ulation value (hereinafter referred to as "prnvisiollal regulation values") and that any food or beverages exceeding this criteria should not be provided for hUl11.n..11 cOP..5umption pursuant to Paragraph 2 of Article 6 of the Food Sanitation Act In terms of the Basic Food Salety Act. the MHLW did not have to ask the Food Safety Conllnission [or advice (hcrcinallcr referred to as "Ad\icc") on L.1.C c1Tccts of L."'1c implemented provisional regulation values on food security and health. However. the MHL W decided that it was proper to ask for arbitraJY advice in accordance with Paragraph 3 uf ArLide 24 uf the SaIne Ad. On the uther h:mu, Altide 11 uf the Ad stipulates that in a situation "lhere t~e l\1.1----I...L\V must ask the Food S(liety COlmJ1ission for advice, t~e l\-1..J-!L \\1 does not have to comply in the event of an exceptionally urgent case. The MHL W implemented the provisionai re,,'uiation vaiues after deciding that they had to take urgent action on rood ai'1d beverages contaminated \vith radioactive materials95 .

Additionally. on March 20. the MHLW minister a,ked the Food Salety Commission for advice on the index value (provisional regulation value) for radioactive material in food and beverages. On October 27 of the sanle year, the Food Safety Commission issued a notice addressed to tl-te lV!HL\V minister on the effects of the implemented pro'l/isiona!

regulation value on food security and health in which no evaluation results per isotope were provided.

94 Codex Standards, hich include fi.'od standards, guidelines and cr:oo:ies of practice to prot~:::t the health of consumers and ensure fair trade practices in foed trade. are implemented by the Codex Alimentmius Commission estahlished by the lJnited Nations, FAO and W[ [0 9~

Thus the prmisional regulation value, \vhich had been implemented \\ithout advice rrom the frxxl Safetv Commission, is called a "provisional regulation value."

-871-OAGI0001550_00088

d. rl'ovisionai reguiation vaiue fo1' seafood On April 4 ofLhe san1e year, 4,080Bq/kg of iodine 131 "vas detected in ymmg sand eels that were caught orr the coast or Tbaraki Prerecture on April I. Detailed data was sent to the i\'fWLW.

As described above, the NSC Indices for restricting L1e intake of food a.-.,d beverages contain no criteria for the restriction of seafood contaminated with radioactive materials nor do the provisional reb'lllation values based on the Indices for restricting the intake of food and beverages. Hence, the ivrnLVV decided that it \vas necessary to inlplelllent temporary rebrulation values for seafood in teffil..5 of radioactive iodine an.d thus begall all urgent discussion with the NSC. As a result of the discussion, the MHLW decided to adopt 2,OOOBq/kg as a criterion value for seafood in terms of radioactive iodine, with the Ut'1dersuu'1ding that a criterion value of 300Bq/k. g for drinking \vater, milk ai'ld dairy products, and a criterion value of 2.000Bq!kg for vegetables in terms of radioactive iodine were already implemented as regulation values and could be used as references, and because bUlh seafuuu anu vegetables were dassilieu as suliu fuuu,. AU April 5, uu ihe basis of the [I.dvice% of the NSC, the IVll-!LvV issued a notice to [Ill loc[lj govenunents to the effect that provisional re.l,'lllation values for seafood in terms of radioactive iodine should be LOOOBq/kg and that any seafood exceeding this criterion should not be provided forhwna."'1 consumption pursWlt'1t to Paragraph 2 of Article (; Or1.1e Food Sa.'1itation Act.

e. Provisional regulation values for tea Tea was classified as "other" in the index for restricting the intake of food and beverages, The provisional regulation value for tea \vas 500Bq/kg, On !'-itay 11 of t~e same year, radioactive cesium exceeding the provisional regulation value of500Bq/kg was detected in

% 'lne NSC has maintained one-third of 50mSv of thyroid gland equi';mlent dose (refer to Section 11 (1) c aoo".,re),

'."hich has heen t1)e intervention r<'ldiation cL0se level fi)r fi)l.)li out~ide the three categories a...;; defined in the Tnc.1e-: for festrictions em the intake of'ti.>cxl and beverages, since the NSC first developecl the Tndex values. TIle NSC el~ained calculation re~'lllts indicating that radiation do~ \v()uld be ,\-ithin the maintained value even if ml additional 2Jx)()Hqlkg ""vere ingested from seafood for one year. 'lhus, the NSC replied to the effect that a Clitenon value of 2,(x)()Bqlkg for vegetables could provisionally and safely be applied to the index value for seafrxxI in tenns of radioactive iodine 11sing the Tndex for restJicting the intake of fexxI mId beverages as a reference.

-872-OAGI0001550_00089

green tea leaves produced in Kanagawa Prefecture. In response to this, the MHL W asked fowteen local govenllllents to pelfonn !lIOre intensive 11lOnitoring of green tea leaves.

Additionally, on May 13, radioactive cesiunl exceeding the provisional regulation value was detected in unrefined tea leaves produced in Kanagawa Prerecture. In response to this, on iViay Hi, the Tvl-H~L\V asked fourteen locru governments 10 perronll monitoring O(

u..'1refined tea leaves to restrict the distribution or u..'1refined tea leaves that exceeded the provisional regulation value (500Bq!kg).

Because unrefined tea leaves were monitored \\ith the same criteria as green leaves, there \vas a consensus among the relevant local govermnents97 and \,,11:hin the national government that monitori.ng unrefined tea leaves ac-co[ri1 11g to the sarne criteria as bJYeen leaves did not fit reality based on the follO\\ing reasoning: umefined tea leaves may have a concentration of radioactive cesium lIve times greater than that of green leaves because they arc cL.~~.'-proccsscd; lli'1d tc~ \\':hich is nearly ahva:ys for drinkiL'1g, is prepared by steeping tea leaves in hot water reducing concentration levels. However, on June 2 of the same year, the MHL W issued a notice to the effect that the same temporary regulation value shuuld be applied lu all lypes uf lea leaves iuduwug wlldlueu lea leaves un a regular basis. Re!ev(l~t}t industry groups, '.vorried t..l:lat tea product.s IPight be negatively affected bv rumors, strongly recommended the monitoring of tea leaves. Ultimately, all locai govemments decided to perform monitoring of unrefined tea leaves.

f, Restriction of tap water intake With the exception orthe Index developed by the NSC (300Bq!kg ror radioactive iodine and 200Bq/l\:g for radioactive cesimn), no provisional regruation value has been defined for tap '.vater.

On March 18 of the same year, 170Bq/kg of radioactive iodine was detected in tap water that had been conected in Ful:ushima-shi on March 16. Tri response to this, the

~v1HL \V stili'ted to discuss de\'eloping criterion values [or tap vvater just as th.ey had [or 97 Some municipalities. \,-'hich had believed that monitoling unrefined tea leave:'l according to the :'lame clitena as green leaves had little scientific hasis, initially refused to monitor unrefined tea leaves. Hmvevec relevant induf->1rv gmups strongly urged them to reconf->ider and eventually each of them decided to comply.

-878-OAGI0001550_00090

food and beverages. On March 19, the MHLW notified all municipalities of "Measures to be taken for tap ,vater to protect citizens fi-mll radiation exposw-e resulting frmll the Fukushinm Dm-ichi NPS and Fukushinm Dai-ni NPS," ,,,,hich induded: 0) refraining frOlTI drinking tap water exceeding index values indicated by the NSC (300Bq/kg 01 radioacti ve iodine, 200Bqllg 01 radioactive cesium); (ii) tap water may be used lor domestic use

\\'ithout Ui'1Y concern; UI"'1d (iii) drinking tap \vater is not restricted if' there is no access to

. d*nn-mg altematl"ve k* water9' .

This notice did not mention drinking water for infants. Subsequently, more than lOOBq/kg of radioactive iodine ,vas detected in tap water in Fukushilna-shi. On lvIarch 21.

the l\Ill-!LW notified mlJ!1icipaiities to the effect that \vater suppliers should promptly inform citizens to refrain from providing tap water to infants if their tap water exceeded lOOBq/lg of radioactive iodine.

Additionally', th.c n1onitoring of tap "v'mer \V'as strengthened. On I'-,,1arch 18, ~vl&-XT notified all local govemments of the "Strengthening of monitoring of environmental radioactivity levels nationwide in an emergency at the Fukushima Dai-ichi NPS and Fukushinru Dai-ui NPS" Lu ihe dIed ihai nuclide analysis uf dean waler (lap Walel]

should be performed ::u1d tl}e results should be reported to !\AJ:'XT. !\loreover, on l\ll:1.fch 21, the MHLW asked all local govemments to provide the ministry with tap water monitoring information that had been requested by MExr as wen as any additionai tap water monitoring in Connati on, if' available, Subsequently, based on the results oltha! monitoring, the MHLW asked municipalities to restrict the intake 01 tap water il their tap water supply was lound to contain levels exceeding the mdex value())

On ,A~pri! 4 of the same year~ based on up-to-date monitoring results, the !'v1HL\\1 issued

'llie notice provided by the lvlllL'vV states that criterion 'values for radiological protection established by the 11temation,J Conhuission on Radiological Protection (lCRP) on ,yhich the index values indicated by the NSC arc hasecL to,)k intf) consideration the effects of long -enn e:\"o::,ure to radiation; the temporary intake of \vater exceeding the lCRP index 111ay not hm'e any effect on human hea1th~ and the intake of tap '.vater based on the "Principles for Tnierventi{)n for Protection of the Puhlic in a R!lrliological Emergency" may not he re::.,tlicted in a situation ""vhere sate alternative drinking 'ater is not easily availahle and there is St.'lious conl"'.t.'lTI for human health as a re::,ult.

99 ()n March 21 , the MI II"W asked litate-mura village office in FuJ..."llshima I)refecrure to restrict the intake of tap water and then asked the fukushima, fuaraki, Chiha, and TolTo prefectural govennnents to re:sbict the intake of tap \vater hy infant.;; in ce:tiain meas in each prefecnu*e.

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a "Future monitoring policy on radioactive materials in tap waterlOO," in "vhich monitoring policy, intake restrictions and guidelines for lifting restrictions were stipulated (this policy

,,,'as revised on June 30 of Lhe SaIne year, based on the premise Lha! Lhe elTecls of the Fukushima Dai-ichi NPS accident were going stabilize.

g. Shipping I'eshictions The National Basic Disaster Prevention Plan stipulates that the national government shall conduct research on the radioactivity contamination of food and beverages to detennine effective and useful measures al1d, if necessary, instruct relevant organ17 utions to restrict the shipment and/or intake of any contaminated food and beverages.

On March 15, a high concentration of radioactive material was detected in weeds that had been collected (refer to b above). On ~..1arch 17 of L.1.C SaIne year, the l'lliRHQ r started 10l a discussion on measures to be taken for contaminated food and beverages On March 19 and 20, radioactive material exceeding the temporary regulation value was ueLedeu in: (i) law milk [wnl Fukushinla pre[edw-e; (ii) spinach [lUIn ibalaki, Todtigi ;mu Gumna prefectures; at}d (iii) le<;l~/ veget.ables from Gumna prefecture" it} response to this, on March 21, head of the Government Emergency Response Center provided the leaders of the Fukushima, Ibaraki, Tochigi. and Gooma prefecturai governments with instructions to restrict shipment bascd on Paragraph 3, Articlc 20 or the Act on Special 1\1casurcs Concerning Nuclear Emergency Preparedness. or (i) raw milk ITom Fuku,hima prerecture.

](jj lhe .tv1llLW: (i) requested local govel11ments to cany out monitoring of tap water mamly 111 .Fulmshlllla Prefecture mId its neighlxnil1g ten pret'ecttu"es more thmI once a \\'eek; lii) requested water operators to implement intake restrictions mId noiil~' alltxted residents of lhese resuictions if radioactive lllaLelial in the tap \-vater exceeded lhe guideline values for lhree conseculive days; (iii) deGideJ lo lin reslriclions ir moniloring rindings averaged helmv the prm;isionallimit 'values tor three consecutive days and if monitoring results indicated that lOln~l!t~":~~~:~~~~:;l~:~~~~~~~\~~~~~~~:~~~~~~:~~,~vemment to issue instructions to restrict t~e shipment of t(~')d D.'1d l"lE:"..'erages wa~ :>8 follmY~: local municipalitie~ are to pelioll11 monitoring of food and heverage::~ monitoring results are tn 1)IC cone(~ted, aggregater-L and unified hy tl-Je 7'v11-IL\XI; lU1ified monitnring results are to 1)IC repnrted tn the Nl',RHQ; the Nl'RHQ ,,,ill evaluate monitming results to determine ,-,,'ht.'ther or not provisional regulation values of fexxl Sanitation Act have been exceeded: and if exceeded, the NERHQ v,ill a"k the NSC ti.lr ad,ice, and. if nece:'\sary the head of the Nl--:RIIQ \\111 issue instmctions to all relevant municipalitie:'\ to restlict the shipment and intake ofti:x"Xl and bevemge:'\, ba<>ed on Pamgmph 3, Article 20 of the Act on Special Mea.<"'lu"e:'\ Coneeming Nuclear Pmergency Preparednes..<;.

-8711-OAGI0001550_00092

102 and (ii) spinach and leafY vegetables from Ibaraki, Tochigi and Gunma prefectures Additionally, on l"viarch 22, it ,vas discovered that a high concentration of radioactive nm!erial ,vas detected in S0111e vegetables fron1 Fukushima Prefecture. On March 23, the Government Emergency Response Center provided the head oj' Fukushima preJ'ectural government with instructions to restrict the shipment and intake 01 certain vegetables.

Subsequently, instructions to restrict shipment were successively issued.

Subsequently, on April 4 of the same year, the NERHQ issued a notice for "Strategies for monitoring planning, shipping restrictions and abolishing shipping restrictions on the basis of products and regions for the follo\ving reasons: many nmnicipalities asked the II NERHQ to restrict shipment on a per-region basis rather than on a per-prefecture basis, and the NERHQ determined that it was necessary to establish requirements to abolish shipping restrictions. This notice slates that: (i) shipment of a product shaH be restricted if it is anticipated L.~at a sigrJlkai'11 quantity of the product exceeds a tcnlpora.....*Y regulation value within a wider range of regions and intake of a product shall be restricted if a significantly high concentration of radioactive material is detected in the product; (ii) legiumi shall be establisheu un a per-pre[eclme-basls, huwever, regiuns shall be eslablisheu on a per-block b<:l.sis if tl}e relevaflt prefectuf<:ll or mupicipal office cat} <:Iiford to m[mage and maintain them: and (iii) shipping restrictions shall be lifted on a per-region basis bv dividing a prefecture into more than one reb~on, monitoring shaH be perfonned weekly on a per-region basis in more thlli'1 one municipa1ity, fu"'1d if inspection findings register belm\"

provisional limit values three consecutive times, then restrictions shall be lined iJ' an application is made by the relevant municipal ollice.

From the same day. each of the municipalities planned and performed monitoring of food a.l1d beverages according to the policy described above. The NERHQ instructed them to restrict shipment or lift shipping restrictions accordingly.

It was discovered that iower ievels of radioactive iodine were detected in food and be\erages v",bile radioactive cesium exceeding pro\'isional regulation values ,vas detected ID2 TIle range of monitoling results \vas not alway'S consi~tent v.ith shipment restrictions. for example, if the shipment of spinach from three other prefectures \vere re.'micte.(l then spinach from Fuhlshima \\'as also restricted even if its monit01ing result.;;; \vere not mTived " a'i it \vas pre~'lmled to have a higher level of radioactivity, hecau."le of its proximit:,v to the fu1.ushima Dai-ichi NPS.

-R7fl-OAGI0001550_00093

in some food products. Based on this finding, on June 27 of the same year, the NERHQ revised their previous policy, which had gone into effect on April 4 of the same year, to include the follm\'ing ne\-,.' provisions: (i) a product "viLlI limited shipping tilDe shall be monitored at least three days before it is due to be shipped; and (ii) restrictions on shipment shaH be liiied according to the foHowing conditions: restrictions on shipment based on the detection or radioactive iodine shaH be ma."'laged as per the conditions described above while restrictions on shipment based on radioactive cesium shall be managed on a per-reb>:ion basis; and restrictions on shipment shall be lifted if all monitoring results gathered frOlll Inore than three locations per lllUnicipality \vithin the previous llionth are belm:v provisio!l!11 reb'Ulation values.

On August 4 of the same year, the NERHQ revised theirnotioe of "Monitoring planning, developing shipping restrictions and abolishing shipping restrictions on the basis of products and regions" for th.c follovving reasons: radioactive ccsiurn exceeding provisional regulation values was detected in beef. and the time for harvesting rioe was approaching (refer to Sectionh(b) above).

h. Otller problems concerning shipping restrictions (a) Fatm animaIs(cattle) feed On March 19 of the same year, MAFF provided cattle farmers with a "Notice on famling ma'-'lagcmcnl" (hcrcinal1cr referred to as "Notice on FaJTning ~\'1w"'1agcmcnt") \'1a prefectural goveml11enL, in the Tohoku and Kanto 103 districts to the effect that in order to prevent or reduce contanlinalion of livestock products with radioactive material, caUle raised in regions where airborne radiation levels higher than normal have been detected shall be fed \vith hay from grass that has been cut~ gathered and stored prior to the date of the nuclear accident in Fukushima Prefecture and stored indoors bevond that date:

drinking water for cattle shaH be kept in a sealed water tank to prevent falling dust 1m "ihis notice \'vas sent to SLX prefectural govennnents in the Tohoku district under the jurisdiction of the 'lohoku Regional Agliculnmll Admini~tration Offic*e (Aommi, h"'ak, Miyagi , Akita, Yamagata and Pukushima) and ten prefectural government" in the Kanto district under the jmisdiction of the Kanto Regional Agricultural Administration Office (lbaraki, Tochigi, C:;-unma, Saitama, Chiha, lokyro, Kanagawa, Nagano, Yamanashi and Shi71Loka). Tt was also sent to other prefectural govemments from the Agliculnu*al Administration Offices as a reference. Therefore, this notice \vas only meant as a reference fix cattle fanners in Niigata Prefectme

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particles from entering: and cattle will not be sent to graze until furtber notice.

Additionally, on April 14 of the same yem-, !vlAFF provided cattle fEU1ners \vith a notice via prefectural govennnents in Lhe Tohoku and lZanto districts to Lhe drec! that in order to prevent or reduce the contamination of cattle with radioactive material via farm

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coarse leed (InCludIng paslure grass and Slraw), a proVIsIOnal pemllsslble value**' 01 radioactive material contained in Ja,"'1n coarse reed (including pasture grass a.-.,d straw) would be established. and that values of radioactive material contained in farm coarse feed that is produced hereafter shall, if used for cattle, be below the prescribed provisional permissible value.

AdditiO!l.n1ly. on August 1 of that year, prior to the upcoming rice an.d \vheat fall harvest season, MAFF notified all prefectural governments that in order to prevent contamination of cattle with radioactive material via rice bran and wheat bran.

aprOi:lslOnlli 1 . "1..1 PCTI11lSS1u.lC 1

VlliUC . O.Lr rauloactn*'c 10'\ ...:l'* . 1 ITilltcna.. ',.-l' contmneu l' j' In a..---rn coarse .LCCU

...:I as well as in cattle feed including rice bran and wheat bran shall be established. MAFF also notified all prefectural governments that the use, production. or distribution of cattle feeu ex(;et::)wng provisional peunissible values shall be avuiueu.

(b) Measures for beef On Juiy 8 of the same year, radioactive cesium exceeding the tempormy re,,'liiation

\'aluc (500Bq/kg) \vas dctcctcd in becr shipped It-om Fukushima Prcrccture.

Subsequently, radioactive cesium exceeding the temporary regulation vmue \Va';

detected in beef shipped from prerectures other than Fukushima Prefecture.

Tne root of this problem was that the Notice on Farming Management was only addressed to cattle farmers. The Notice \vas not communicated to grain farmers, \vho produced rice straw. Furthermore. information and guidance provided to cattle farmers 1("4 l'he notice a!~.() pre:o,cril;es that, in tenns of dairy cattle feed, the provisional pem1i:o~..,ih!e ".,'alue of radioactive iodine and r<'ldioactive cesium shall he 70T1q/kg and 300T1qlkg, respecti"ve1y, in terms of commercial cattle feer1-o the radioactive cesium value \\ill be lOOT1q/kg, and in tenns of cattle feed fix cattle other than dairy' cattle and commercial cattle, the radioactive cesium value wil1 be 5/XX)Dqlkg 1("6

[he notice al~o presclihes that the maximum provisional pell11issihle value of radioactive cesium contained in feed for commercial cattle, horses. pigs. domestic fmvls and other domestic animal~ shall be lOOT1qlkg and lOOl1qlkg in feed fix cultured fi~hes.

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was inadequate and it was discovered that cattle farmers had fed their cattle rice straw that had been stored outdoors and 1110St likelv contanlinated with radioactive Inatelial.

On Jul)' 19, the NERHQ instructed the Fukushima prefectural govel1unent to restrict the shipment or commercial cattle and subsequently, on August 2, instructed the Miyagi, jwate, and Tochigi prej'ectural govemments to restrict the shipment oj' commercial cattle.

On August 4 the NERHQ updated their notice on "Strategies for monitoring planning, developing shipping restrictions and abolishing shipping restrictions, on the basis of products and regions" (established on April 4 of the same year, revised on June 27 of the sarne year (refer to Section g above)) al1d Ub'Yeed to pa.rtially lift shippin.g restnct!op..5 based on the premise that all cattless or all cattle fanms ;vould be testedj(~.

On and alier August 19 of the same year, the local govenrments that had been instj'liCtcd to rcsh--ict L.~c smpn1cnt ofbccf developed a policy to test w"'1d sr.tip cOl1llTIcrcial cattle, and submitted an application to the NERHQ requesting that shipping restrictions be lifted In response to their request, the NERHQ lifted shipping restrictions on L:UIIlIIltm..:ial l:ullle lhaL hau been raiseu amI Illanageu aL:cunling tu lhe guvenlIIlent puliL:Y for testirlg ,uld spipping cOITunerci,1j cattle.

(c) Measures fot' rice hat'vested in 2011 On Apri1 8 or the same year, the head or the NERHQ obtained a tra.."'1Srer cocn"'icicnt (0.1) of radioactive cesium transrerred Irom soil to unpolished rice hased on the results or analyses perl'onned by the National Institute l'or Agro-Environmental Sciences on rice fields and harvested rice. Tne NERHQ issued a poi icy to the effect that the upper limit of radioactive cesium shall be 5,OOOBq/kg so that the concentration of radioactive cesium contained in unpolished rice would be below the provisional regulation value (500Bq/kg) pursuant to the Food Sanitation Act, and that planting restrictions should be ordered to prollibit the plw,ting of rice seedlings in regions \\-'here radioacti \'e cesiuill contained in Ireshly harvested nce \\"ould most hkely exceed the proviSiona1 regulation value.

I\)5 One or more of the commercial cattle first shipped is tested on a per-fann hased.

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OAGI0001550_00096

On April 22, the NERHQ issued a planting restriction order to the head of the Fukushilna prefectural govenllllent to restrict the planting of rice seecUings \vithin a 20kJl1 radius of Lhe Fukushima Dai-ichj NPS as well as in deliberate evacuation Lones and emergency evacuation preparation zones.

In August oj'the same year, MAFF released a plan to conduct a two-stage research process due to the fol1O\ving circumstance: rice is a staple rood, a large a'-'110Ui'11 office is grown and eaten in Japan and there are various lypes of distribution systems in Japan. Tn the first stage, prior to the upcoming rice fall harvest season in 201 L a preliminary survey 107 should be conducted to study the trends in the concentration of radioactive

!11..ateriaL In the second stage, a !11!1in sunreylO~ should be conducted to detef!11ine whether or not shipping restrictions are required after the rice harvest. Tri the main survey, the provisional regulation value was not exceeded in any region. However, on a.'1d before Novclnbcr 30 of the SaIne y'car, radioactiv'c ccsiurn exceeding the provisional regulation value was detected in unpolished rice (not tested by direct sampling in the main survey) that was produced in Fukushima-shi (formerly Oguni-mura) and Date-shi (fuHnedy Ogwil-Illma awl Tsukiuate-IIlma). lUlespUI1Se LO this situatiuu, the NERHQ inst..'Ucted tl"te Fukuspjrn,l prefectural goverf1~rnent to restrict tl"te shipment of rice produced in these aforementioned regions in 2011.

(2) Conta..d...anon of soil, etc.

a. Schoolyards and the other educational facilities in Fukushima Prefecture Fukushima Prerecture requested the NERLHQto indicate the criteria ror reopening the schools and the other educational facilities in the prefecture. in response to the request, lVIEXT begal1 to consider the criteria 107 111e follO\ving decisions \Vere made: (i) mUlllcipalities that have been insuucted to restrict shipment, (ii) their neighboring l11mlleipalities, and (iii) those cities, to\\TIS <uid villages of other n1mlleipalities ,yhere radioactive cesium contained in fmmland soil exceeds 1,(xx)T1q,fl,cg as "ven as \vhere a11Tadiation dose rates exceed 0.1 ~lSv/h, should pelfonn a similar SLlr<.'ey for three consecuti,,'e days,one \veek prior to han'e:'!ing. Those municipalities

,vhose re:-,'Ults indicate a value exceeding 200Dq/kg shall be "regions requiring a.T) intensive :-Ufvey for the main sun'ey and those ,,,hose re~'U1ts indicate a \'alue helow 200Dqikg shall he "regions requiring a hasic survey" IC~ Tn "regions requiTing an intensive ~'Urvev" one sample \vas collected per approximately ISha and in "regions requiring a ba~ic survey" sample~ \\'ere collected per city, to\'m, or village based on previous smaller populations.,

which preceded the merging of many ",ill ages and to\\TIS into larger cities (an average of seven samples per municipality').

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OAGI0001550_00097

From April 6 to 7, MEXT requested the Nuclear Safety Commission to deliberate on the criteria for reopening by presenting the results of the air radiation level rate Ineasurenlents preschools and nursery schools within the prerecture (except those in the evacuation area within a 20km radius or the Fukushima Dai-ichi NPS), However, the Commission, as an advisory agent, replied to the lVfinistry that some pla.-'med criteria showd be proposed first.

On April 8. MEXT was directed by the Prime Minister's Office to deliberate on the criteria for the use of school facilities as a matter of the "hole Govemment. Therefore MEXT began consulting on the criteria of use \'vith the Nuclear Safety Commission.

At the time, lVIEXT believed that it ,,'as necessary to consider the consistency of the criteria for the establishment of the planned evacuation area, which was deliberated within the Govemment, and the contribution of intemai exposure. On April 11, the N'ERHQ specified L.~c area \-\,here t..'c cU111ulati\'c radiation dose nmy exceed 20InS\' as L.'c pla..-o'li'lCd evacuation area based on the criteria of 20-1 OOmSv that had been established by the ICPR in the event of an emergency when evacuation is required (a reference level for public exposw-e ill the event of;m "lawaliuIl eIIlergeUL:Y situatiun" ill the recuIIlIllemlaLiun issueu in 2007). ~.1E.XT decided 20InSv/year, \vpich is tl-te upper lilPit established by tl-te ICPR for a situation after an accident has stabilized (a reference level for public exposure in the event of an "exiting exposure situation" in the recommendation issued in 2007) as the erik,. ;on 1(J9.l1o. FUi,ther, T',,1EXT estimated that the contribution orthe internal radiation dose to the whole radiation dose is 0 to 5.(,% (2.2% on average). Because this contribution wa, small, the Ministry decided not to tal,e the efTect or internal exposure into consideration and to calculate the total exposure as external exposure. Assuming a student stays indoors for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> and outdoors (in schoolyard) for eight hours a day~ al1 air radiation dose rate of 3.XIlSv/h corresponds to 20mSv/year of exposure. Therefore MEXT decided to adopt this 109 \Vhen establisrLing the criterion of 20mSv/year, !-vffiXT took u1.e risk of confusing t.1.e local govenHnents when the national goveri"Hnent indicated a criterion that \Va') too low into consideration because me Fukushima Radiation Health Risk Adviser explained that exposme belm\' 100mSv does not affect health.

110 The Educa1J.On Minister explained in parliament that 20mSv/year, which is the lower hmit of the reference level of 20 - 100mSv/year, was the starting point of the deliberation on the criterion. It is now under investigation as to why such an explanation was made.

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OAGI0001550_00098

value as a guide. Furthermore, the Ministry considered that "it is appropriate to decrease the dose rate that students m-e exposed to as 111uch as possible "vhile adopting the criterion of 1 - 20I11Sv/year as the reference level aller an elnergency situation has stabilized as a tentative guideline," and "even if an air radiation dose rate exceeding 3.8"Sv/hour is measured, the level that students are exposed to can be limited to 20mSviyear by talcing countemleasures to ensure activities are mainly done indoors," Based on this consideration, MEXT established the "Provisional view regarding the judgment of the use of schoolyards and educational facilities in Fuhtshima Prefecture" indicating that: (1) activities in the schoolyard should be restticted to approximately one hour a day \vhen an air radiation dose rate exceeding 3.8JlSv/h is detected in the schoolyard, nn.d (2) the schoolyard call be used as usual when an air radiation dose rate below 3.8).lSv/h is detected. MEXT submitted this provisional view to the NSC via the NbRHQ and asked [or its advice on April 19. This vie\v n1canL L.killt no upper limit \\"as established on the air radiation dose rate for schoolyards that can be used as per (1) above. and the schoolyard can be used without any limitation when the air radiation dose rate is less than 3.~).lSv/h as per (2).

CUIlsiuering thal il is requireu tU reuul:e the rawatiuIl uuse uf sLuuenLs as IIluch as possible, t~e NSC Jap(l~t} acLtpitted in its response to t~e request from rvlE..XT that the vie'.\*'

of the NERHQwas to minimize the radiation doses of students. on condition that: (1) the resuits of measurements such as the consecutive monitoring shouid be reported to the Committee approximately once every tVl"O \v'ccks, w"'ld (2) approximately onc pocket dosimeter should be distributed to each school and provided to a faculty stalTmember who represents the activity paUem of the students to check the exposure condition.

On the same day. after receiving this response, MEXT notified Fukushima Prefecture of the abovementioned "Provisional viev.' regarding the judgment of the use of schoolyards and educational facilities in Fukushima Prefecture" with the condition indicated in the NSC 's advice.

On ~v1ay 11, ~vfEXT suggested t\vo measures for L.~e surface soil in h~e school}'ard, "to lntensivel:y gather and store underground" and the "upside-do\\,n replacement method," as elrecti ve exposure reduction methods based on the result of the investigation conducted by JAEA On May 27, me Ministry decided to provide ilnancial support [0 me owners of

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OAGI0001550_00099