August 3, 2011
Skilled Veterans Corps for Fukushima,
General Incorporated Association
To
Messrs.
Goshi Hosono
Minister of State for the Cleanup from and Prevention of Nuclear Accident;
Yoshiyuki Ishizaki
Deputy Chief Director of Nuclear Power & Location, Tokyo Electric Accident

Skilled Veterans Corps for Fukushima, SVCF Association hereby proposes following terms and conditions aimed at “Substituting unnecessary radiation exposure of the young labor engaged in the cleanup works of the damaged Plant by the introduction of elderly persons to the best of their ability in these tasks. “SVCF also assumes and claims that necessary expenses for various activities should be paid by the responsible organization in need of the clean up works, including industrial injury insurance (at least minimum wages being paid), whereas SVCF members volunteer in the cleanup works.

I. Immediate participation of SVCF in the cleanup works

As an achievable target that can be immediately provided without shifting major preparations, arrangements or alterations in the current system, SVCF announces the willingness to participate in the following two projects quite positively. Although it is desirable to proceed as a national project, SVCF may not stick to the mode of project at an onset.

A. Participation in the monitoring of environmental pollution both within the damaged Plant and in the 20 km evacuation zone thereof (heavily polluted areas to be examined).
SVCF has already started a preliminary feasibility study and holds many qualified members for the monitoring team, members who have completed a series of practical training courses.

B. Participation in the debris disposal and decontamination works in the heavily polluted areas both within the damaged Plant and in the surrounding 20 km evacuation zone.

Many SVCF members hold licenses for operation for special large vehicles, and SVCF can provide on-site workers as well. Besides, SVCF is prepared to offer several types of heavy machinery.

II. Request an establishment of a proper system that enables optimal work allocation in the nuclear power facilities as well as radioactive health management for the workers after their exposure to radioactivity.

We deem it necessary to establish a system such as listed below for the assignation of aged veterans to work optimally, instead of young workers.

A. Exposure monitoring and tracing system for all workers engaged in nuclear power plants throughout Japan

Under the current system of radiation controls and regulations, the following relevant organizations are managing their respective subjects.

1) Radiation Dose Registration Center (Radiation Effects Association, Incorporated foundation). The Center keeps track of and maintains individual dose records for the holders of legal radioactive management booklets. Nevertheless, the Center does not introduce optimal work assignment, equalization of dose, and so forth.

2)　Individual companies (employers of workers)

The companies are under obligation to keep exposure levels that do not exceed the permissible dose, but only during an employment term. They have no further obligation of dose accumulation once the employment ends.

Not only in the Fukushima Daiichi Nuclear Power Plant but in nationwide nuclear facilities (presumably similar in most major industries) each contractor bears the above obligation as employer under the vertical subcontracting system:

Electric power generating company
　↓
　Prime contractor (Toshiba, Hitachi, Taisei Kensetsu, etc.)
　　↓
　　Affiliate companies, or various specialized manufacturers
　　　↓
　　　Various installation companies
　　　　↓
　　　　Local subcontractor (or Manpower dispatching services)

3) Nuclear power facilities (power generating plant, spent fuel reprocessing facility, etc.)

This organ monitors and controls individual doses, which are not to exceed the allowed limit. They report the results to the Radiation Dose Registration Center and respective employers.

With regard to a long time span necessary for achieving “the Mid-term issues” specified in the Government-TEPCO Road Map to the completion of cleanup works and a longer one for the dismantling of stricken reactors, it is necessary to predict a radiation exposure level and plan a labor allotment for all workers engaged not only in the Fukushima Daiichi Nuclear Power Plant but in nuclear facilities nationwide.

In order to secure long-term assurance and safety in the nuclear work environment, it is desirable to study and prepare for the sufficient availability of manpower in the event of another severe accident, however unlikely that may be.

B. A system which enables optimal work allocation in terms of dose and age

In order to assign retired persons effectively, it is desirable to establish a system which enables an optimal allocation of (preferably all) workers engaged in multiple companies and their work environments.

C. Request an establishment of a long-term radioactive health management system for workers being exposed to radioactive conditions at the damaged Fukushima Daiichi Nuclear Power Plant.

Under the current system, except for large major companies, it is doubtful that the health management system for the radioactivity contaminated workers will have been renewed once the employment contract ends. It is desirable that a radioactive health management system be established on a national level.

III. Proposal for an alignment and enforcement of the stance toward the Mid-term issues after the completion of urgent provisional facilities

The objective and measures stipulated in the Step No.1 & No.2 of the Roadmap are just of a provisional or makeshift nature for the temporary facilities. Although the critics point out various problems against the measures, it is to be applauded that the concerned parties have performed the remedial tasks successfully in such a short term, and under severe conditions beyond our imagination.

Nevertheless, it is indispensable to build up the system for tackling the “Mid-term issues” that are required after the Step No.2, aiming to achieve the dismantling of damaged reactors, and, in addition, to establish the sustainable control system for keeping the nuclear waste safely in the long run. Each of the measures requires not makeshift, but sustainable facilities that need well-managed systems, and also, certainly requires new concepts and frameworks basically different from currently applied ones. Furthermore, it seems to be hardly practical to achieve the aforesaid 2 proposals under an internal system run by TEPCO. Its alternative will be something like the following:

In place of the “Fukushima Daiichi Stabilization Center” now administered as a division in a privately owned TEPCO, the government shall step in and provide a cleanup team to a new comprehensive “National Project Team”.
At present, TEPCO is carrying out the cleanup works (Action planning, procurement, order, management, execution, etc.), and, instead, the National Project Team shall take over all the works. The National Project Team may consist of the TEPCO staffers, manufacturers of nuclear-related facilities, civil contractors, and, in addition, some project managers that specialize in the progress and quality control, and are disinterested and neutral in any of the active facilities, consequently, shall be reorganized in a comprehensive National Project Team.