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On April 13, the Japanese government announced that it had approved a plan by Tokyo Electric Power Co. Holdings Inc. (Tepco) to discharge treated water currently being stored in tanks at the Fukushima No. 1 nuclear power plant into the Pacific Ocean.

It is important to highlight specific concerns with regards to this decision and offer recommendations to help ensure that the interests of all stakeholders are protected. Our unease centers primarily on how this unilateral decision may set a dangerous international precedent.

Tepco, the power utility managing the damaged plant, has shown a lack of transparency and good faith around the water issue. We believe that fully transparent independent monitoring and oversight of the environment must be done prior to, during and after any such release to ensure that the process is acceptable to the global community.

The 2011 accident at the Fukushima No. 1 nuclear power plant caused tremendous environmental, economic and societal hardship. Many of these problems have been addressed creatively and industriously, but, 10 years later, many huge challenges still remain and will continue to remain for decades to come.

The cleanup of the accumulated contaminated water being stored on site is both a technical and socioeconomic challenge. At present, approximately 1.2 million tons of this water is stored in more than 1,000 large tanks at the plant, and the amount increases daily.

Tepco proposes that once treated to remove all radionuclides besides tritium (a radioactive form of hydrogen, which is considered one of the least dangerous to health), it can be diluted with seawater to very small concentrations and gradually released into the Pacific Ocean. The dilution and discharge option, recommended by both the International Atomic Energy Agency and the Japan Nuclear Regulation Authority as far back as 2014, was one of several evaluated by official committees in Japan, and was selected on the basis of technical feasibility, time, cost and safety.

The release would begin in two years’ time and will require approximately 30 years to complete. It is possible that this approach is the least objectionable of several problematic options, but it has been justified on a number of bases that could be considered questionable.

The IAEA and the United States have expressed support for the release plan. But even at this late date, no clear technical plan or environmental impact study has been made public, and the proposal has been developed without any significant consultation with neighboring countries, the international community or even stakeholders in Japan.

Because of this, several nations, notably South Korea and China, have expressed their opposition. The Japanese fishing industry, which fears that the global market for all Japanese seafood products, not just those from Fukushima, will suffer irreparable harm, has also expressed firm opposition. The discharge proposal should be considered a transnational release of radioactive material, and existing IAEA agreements, among others, stipulate that concerned nations and other stakeholders should be consulted in such cases.

In particular, IAEA guidelines stipulate that special provisions are needed when a release can conceivably have radiological impacts outside the territory or jurisdiction of the country in which it originates. No one has credibly argued that the proposed discharge from the Fukushima No. 1 power plant will not impact, be detectable in or cause concern to other countries.

On the contrary, countries around the Pacific rim in particular are justified in demanding to be consulted even if the impacts are estimated to be small. Others have cogently argued that the proposed release may be a violation of obligations under marine environment treaties such as the 1974 London Convention of the International Maritime Organization.

The merits of those arguments may well be tested in the courts. It is beyond doubt that such unilateral action is unethical. In such a controversial and highly visible case, Tepco and the Japanese government should be actively seeking fuller participation and input from stakeholders, including those in other nations, and demonstrate clearly that their concerns are being conscientiously addressed.

Allowing the release to proceed unilaterally without genuine international consultation and engagement would set a dangerous precedent and further damage the international rules-based agreement system. If Japan insists upon making such large long-term discharges based only on its own assurances, it would lose standing to oppose similar releases by others.

The international community should be alarmed as well. Quite a few nuclear power nations could be tempted to defy opposition from their neighbors and release radioactive material to the ocean freely, using the Fukushima example as a precedent. What is to prevent the Russian Federation from unilaterally releasing radioactive liquid waste into the Arctic Ocean or the Sea of Japan? Or China into the Sea of Japan or the South China Sea? Or the United Arab Emirates to the Persian Gulf?

Unlike nuclear arms nonproliferation, the international system for monitoring radiation releases under the umbrella of the IAEA essentially works on the honor system and it is easily abused. Nations cannot be compelled to do the right thing. Even diplomatic pressure and the pressure of public opinion sometimes prove insufficient, but they remain the best tools. The provision of transparent international verification in relation to such a discharge is an important part of that.

Official Japanese talking points stress the purported safety of the planned discharge by claiming that similar releases from nuclear facilities are “common” or “normal.” This is disingenuous and deceptive. Tepco assures us that, after a lengthy and expensive process of treatment using its ALPS radionuclide removal system, the radioactive concentrations in the water will be similar to those of other controlled releases and should be considered similarly routine and require minimal regulation.

But during normal nuclear power generation and fuel processing, tritium is generated in relatively predictable quantities and released on a designed basis as part of normal operation. In the case of the Fukushima No. 1 nuclear power plant, the release is an emergency stopgap intended to prevent possibly more catastrophic consequences that might occur from burst tanks or overburdened pipes, as well as being a convenient solution to the lack of space to build more tanks. Nothing about it is “normal,” and as such it demands closer scrutiny and oversight and a more thorough regulatory regime.

The ALPS system does, in fact, appear capable of removing all radionuclides of concern except tritium when operating at top condition, but it is dangerous to assume that all 1.2 million tons of water currently being stored, as well as the similarly large additional quantity expected to be generated, will be effectively treated to the required rigorous standard without fail over the course of decades.

The many potential failure points are both technical and human: pumps wear out, filters clog, gaskets deteriorate, wrong levers are pulled and workers get disgruntled. Would Tepco be adequately transparent about such incidents and their consequences? Would we be informed, for instance, if 10% of the strontium 90 had somehow escaped into the Pacific? Unfortunately, the international community cannot make that assumption. The company’s prior lack of transparency and their bad faith, particularly on the water issue, is well-documented.

From the beginning of testing and implementation of the ALPS system in late 2013, Tepco assured the world that the only radionuclide of concern that remained in the water after treatment was tritium. The dilution and release plan was heavily promoted to the public on that basis.

In late 2018, however, the company admitted that 75% of the tanks — more than 750,000 of the 1.2 million tons of treated water — still contained above-limit levels of strontium 90, cobalt 60, ruthenium 106 and many other radionuclides that the system had failed to adequately remove. Upon learning that this fact had been intentionally concealed by Tepco, the public was outraged. Those supporting the release plan seem to hope that this massive betrayal of trust has been forgotten.

For all of these reasons, even if experts were unanimous that the planned release theoretically posed no risk to the ocean ecosystem or to human health, it should not be allowed to proceed without a robust impact assessment and verification process in place. The public needs to know now what kind of monitoring and transparency efforts will be implemented, and by whom.

Because of the transnational implications, the monitoring regime should be international and cooperative in scope. It should be a participatory process developed in consultation with all stakeholders, in Japan and internationally. Tepco’s untrustworthy track record further necessitates that the verification be provided by independent third parties.

Tepco has never provided the public with a detailed inventory of the mix of radionuclides currently present in each tank and their levels; this should be done immediately and independently verified. The radionuclide content of the water should similarly be independently verified after treatment and prior to release.

The spread of the radiation through the ocean environment should be closely monitored, as well as its effects on marine life. A verification framework that includes qualified independent researchers should be quickly established and funded. It will have to remain in place for the 30 years or more that the releases will require, and for many years following their conclusion.

The IAEA can play a constructive coordinating role and has offered its technical support in monitoring the implementation of the plan. We fear, however, that the IAEA will find itself overly dependent on the Japanese government for access, and that it will be overly conciliatory in its approach to the detriment of the global community.

The vast majority of the effects of the Fukushima disaster have fallen upon the Japanese people, and most of the decisions about how to respond are theirs to make. However, this accident has also had many consequences beyond Japan’s borders, and it should be clear that discharging this contaminated water into the Pacific Ocean concerns more than just the Japanese nation.

There is nothing normal about this water release plan and an enhanced and internationally coordinated response in monitoring and verification is justified, reasonable and proportionate.

Azby Brown is the lead researcher for Safecast, a volunteer-based nonprofit organization that conducts open, independent, citizen-run monitoring of radiation and other environmental hazards worldwide. Iain Darby is a physicist and environmentalist volunteer with Safecast.

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