Category: Documents

Sept 24th 2004
PETITION
FUKUI PREFECTURE

To: Shoichi Nakagawa, Minister, Ministry of Economy, Trade and Industry
From: Issei Nishikawa, Governor, Fukui Prefecture

On the 9th of August 2004 an accident occurred at the Mihama Nuclear Power Station Unit 3 reactor. This incident seriously injured 11 people 5 of which lost their lives. This was the biggest disaster to date in the history of Japanese nuclear power.

In Fukui Prefecture we have worked hard for many years to win the people s trust and to build a safe reputation for nuclear power. It is extremely regrettable that this accident has destroyed that trust and the reputation of nuclear power in Fukui Prefecture.

I have serious misgivings about the government policy of leaving the supervision of the secondary loop to the autonomous safety inspections of the utilities. I strongly urge that the Government strengthen its involvement in the secondary loop inspection regime and establish a comprehensive strategy emphasizing prevention of accidents before they occur. The Government is responsible for ensuring safety and I strongly petition that it respond.

I petition that the Government undertake, as rapidly as possible, a responsible response to the issues raised in this petition.

Governor, Fukui Prefecture
Issei Nishikawa.

[EXCERPTS OF ISSUES RAISED]

1. Concerning the Investigation into the Cause of the Accident and Establishment of Measures to Prevent Reoccurrence

The government should undertake a comprehensive technical investigation into the rupture of the pipe, the direct cause of the accident. In addition the government should investigate the problem of supervision of the thickness of the pipes and address the companies  general approach to safety, which can be thought of as the background which caused the accident.

The government should make all efforts to carry out a thorough deliberation of the application of and supervision of safety procedures listed below, and implement a comprehensive strategy to prevent the reoccurrence of similar accidents:

• the utility s autonomous management system which address requirements of outside consignors
• method of assuring that the utility s data management system and inspection regimes are appropriately in place
• accurate sharing of technical information with other utilities  and manufacturers

2. A Reassessment of Measures to be Undertaken for Aging Nuclear Power Plants

We are entering an era where nuclear power plants are aging, demanding even greater thoroughness of inspections. The Mihama Unit 3 accident was an accident brought on by the fact due attention was not paid to the aging problem.

A reassessment of the measures to be taken for the nation s aging plants must be undertaken which establishes the methods of inspection and assessment that include a detailed investigation into damage due to aging which has occurred in Europe and the USA, analyses and appraisals of safety regulation and management methods, investigation and examination of the newest knowledge and information, and inspection of aging nuclear power plants.

4. Building a Radically Different Safety Management System

(1) The government should constantly take the newest knowledge and information, including information which can be gleaned from examples of accidents both domestic and international, establishing clear safety standards, maintenance standards, and inspection guidelines based on scientific rationality.

5. Establishing a Comprehensive System whereby the Safety Authority will be Located within Local/ Regional Authorities where Nuclear Power Plants are Located

The regulatory functions of nuclear power plant safety should be transferred to the local/regional areas where nuclear power plants are located, and should adopt regional solutions in alignment with the area.

6. Nuclear Inspection and Research Organs

In order that nuclear power be trusted by the people and become an industry that is well established within the region, it is absolutely necessary that a research and development body be established at the site of the local/regional authority where the nuclear power plants are located. We demand that the government establish such a body in Fukui Prefecture. This body will look into the causes of accidents and incidents, undertake inspection and analysis etc. on potential accidents and incidents, be a testing and research institute which will undertake inspection and research concerning safety issues, and, undertake a wide range of nuclear research over a broad area of discipline.

7. The Government s Safety Regulatory Regime

(1) In this day and age of fast pace new technological developments, it is necessary to rapidly incorporate new knowledge, with a government safety regime which aims for precision, reliability, transparency, fairness, and speed.

We demand that a regulatory regime for safety be established which can be trusted by the citizens of this nation and whose seat of responsibility is clearly delineated. This would entail a fundamental revamping of current nuclear power safety regulation such as bringing together into one entity such organs as the Nuclear Safety Commission and the Nuclear and Industrial Safety Agency (NISA), making transparent what are the responsibilities and roles of government and industry respectfully, etc.

(2) We demand that a Nuclear Power Accident Investigation Committee (provisional name) be established. This committee would have the authority to propose investigation into the cause of serious accidents at nuclear facilities or into indications where such accidents may occur, and to issue recommendations concerning policies to prevent accidents.

8. The Government’s Role in Recovering Trust in Nuclear Power

The government must commit its utmost to recover the trust of prefectural citizens in nuclear power lost as a result of this accident, eradicating anxiety and suspicion. This should be undertaken by investigating the causes of the accident, and, with regards to deliberation concerning measures to prevent reoccurrence and the current state of the utility’s inspection results, the government should explain and report thoroughly to the local/regional authorities where the plants are located, making the information public in a timely and proper manner.

END

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku
Kyoto 606-8203 Japan
Phone:+81-75-701-7223
Fax: +81-75-702-1952

14 May 2004

Mr Stephen Timms MP
Minister for Energy
C/O The British Embassy
Tokyo, Japan
Tel: 03-5211-1332
Fax: 03-5211-1270

Dear Mr Timms

We are Japanese citizens, consumer, professional and anti-nuclear organisations from Osaka, Kyoto, Aomori, the Tokyo and central Japan regions. We write to you concerning BNFL’s hopes of resurrecting business with Japanese electric utilities concerning MOX (mixed oxide) fuel use, this time at the Sellafield MOX Plant (SMP).

Trust in BNFL has been destroyed in Japan. The December 1999 BNFL data falsification scandal is still very fresh in the minds of the Japanese public. In a recent Fukui legislative session, distrust concerning BNFL was raised yet again, and an important conservative Fukui legislator in the region, Akihiro Ichise adamantly stated he would not allow BNFL MOX fuel in Fukui.

If BNFL were serious about regaining trust, as a first step it would reveal all its quality assurance data for MOX fuel made for Kansai Electric at MDF. This includes the top, middle, and bottom measurements of all pellets diameters for the Takahama Unit 4 fuel. Then and only then can inroads be made to get to the bottom of past scandals.

On 16 December 1999, the then MITI minister Takashi Fukaya declared the “collapse of trust for BNFL”. BNFL’s poor track record since the 1999 MOX fuel quality control data falsification incident has assured that this view remains unchanged today.

The multitude of safety violations at Sellafield over the years which have been documented by the British newspapers also continue to shock Japanese citizens and nuclear safety officials in the prefectures that intend to use MOX fuel in Japan.

BNFL’s lack of technical experience and its management inability were also stated in the Japanese courts in 2000 and 2001. (See attachment.) The inability to successfully operate SMP have further confirmed BNFL’s lack of technical experience and management inability.

The motive and extent of the MDF falsification has yet to be determined by BNFL or the NII. This has significant generic implications beyond “bored workers” or an “outdated MDF plant”.

In its verdict the Fukushima District Court also quotes from the report issued by the BNFL-Manufactured MOX Fuel Data Problem Investigation Committee set up by MITI. The title of the report quoted and date issued is, “BNFL-Manufactured MOX Fuel Data Problem Investigation Committee Report” , 22 June 2000. The court states:

“The report severely criticizes BNFL’s corporate constitution stating, ….’The occurrence of such a state of affairs is proof that the system for quality control is frail, showing inadequacy in the site management by those responsible for quality assurance work. This sort of company is not qualified to conduct business in the field of nuclear power.’ ”

Once again it should be noted that the committee does not state “the MDF plant is not qualified”, but “this sort of company” is not qualified, referring to BNFL as a whole. Simply having built a fully automated new plant, the SMP, which is yet to operate successfully, will not solve this problem.

How can BNFL possibly expect to gain the trust of Japanese electric utilities when it continues to hide, or adamantly ignore addressing, past problems The crucial, unresolved issues concerning the 1999 falsification of Kansai Electric MOX fuel quality assurance data reveal significant current problems with BNFL :

• – BNFL has ignored issues raised by Kansai Electric in the company’s 1 March 2000 Report concerning other forms of cheating, suspicious data in other fuel pellet lots manufactured for Kansai Electric at MDF. [See Kansai Electric (2000), An Investigation into the Problem of BNFL Fabricated MOX Fuel, 1 March 2000.] This is also addressed by the BNFL committee set up by MITI and documented in the Fukushima District Court verdict of 23 March 2001. (See above.)
• – BNFL states the SMP plant is “fully automated”. But this means very little to us in Japan, since in the past BNFL secretly made changes to “failsafe” checks, making them no longer “failsafe”.* [* Nuclear Safety Inspector Was Kept in the Dark by BNFL, The Independent, 8 March 2000.] BNFL described its automated check on pellet diameter at MDF as “failsafe”, when in actuality it had made changes to this test which made it no longer “failsafe”, while keeping this fact from the NII. Indeed we understand form the May 10th issue of Nuclear Fuel that the SMP is not even operating due to commissioning problems.
• – BNFL has failed to identify individual(s) who sabotaged Japanese customer fuel.* The fact that it does not continue to investigate this matter indicates that BNFL must not be concerned if these people work at the SMP plant it hopes to operate. (*The Kansai Electric Report of March 2000 goes extensively into the incident in which a screw was inserted by an unknown person or persons into the MOX fuel rod manufactured for Kansai Electric. The media in the central region of Japan also reported on this incident with many newspapers printing photographs of the fuel rod picturing the pellets and the inserted screw. BNFL, however, never exerted effort into resolving this problem.)
• – BNFL has yet to identify the motives for the data falsification that took place at MDF, but, nevertheless, is attempting to sell the SMP to Japanese customers. There is genuine concern in Japan that manufacturing ability at BNFL is deficient , and that this could possibly have lead to cheating on quality control. In other words cheating not just because workers are bored, but cheating as a necessary part of passing MOX pellet lots.

A case in point is TEPCO elaborating in its Fukushima Court testimony that BNFL could not meet Mitsubishi specifications for Kansai Electric MOX fuel. TEPCO states,

”…It is pointed out that, ‘Although Mitsubishi had sought the automation of the pellet random sampling inspection during examination of the manufacturing process conducted at the time of pre-production [of MOX fuel for Kansai Electric], BNFL did not accept this, stating that this improvement would be too difficult to make.’ From this it can be easily imagined that BNFL’s production capability and quality control ability is deficient when compared to that of Belgonucleaire. It has to be said that since the ratio of disqualified pellets during the random sampling inspection at BNFL is 1.25 percent, the manufacturing ability and quality control ability is in a low state.”

Kansai Electric in its March 2000 report also address BNFL’s production problems stating,

“According to production validation made by MHI [Mitsubishi], the outer diameter of pellets produced at MDF satisfied the specification but had a process capability index as 1.04 which is less than 1.33 which is criteria regarded as an index for “production being stable”.

The Kansai Electric Report continues,

“On the number of samples in the AQL for outer diameter inspection, MHI initially proposed to BNFL the extraction of 20 pellets by way of weighing extraction method. Against this, BNFL indicated that there was no proper distribution of diameter due to the performance of the grinding machine, and asserted that the account extraction method would be inappropriate.”

A track record of falsification and secretly altering checks and yet declaring them “failsafe”, refusing to release quality control data that will prove one way or the other if other types of falsification have taken place, coupled with a process capability index which did not meet the criteria for stable production, no proper distribution of pellet diameter … These and other problems all point to the possibility that other forms of falsification much more devious than simply “copying data because of boredom” have taken place at BNFL. This definitely cannot be resolved simply by starting up another plant, the SMP, at Sellafield..

Our view is that if you and BNFL are genuinely interested in regaining trust, BNFL would be addressing these issues.

Yours sincerely,

Aileen Mioko Smith
Director,
Green Action (Kyoto)

Yoko TOMIYAMA
Chairperson,
Consumers Union of Japan

Shigetoshi IWAMATSU
President,
Japan Congress against A- and H-Bombs (GENSUIKIN)

Hideyuki Koyama
Director of
Osaka Citizens against the Mihama, Oi and
Tkahama Nuclear Power Plants(Mihama no Kai)

Kazue SUZUKI
Nuclear Campaigner,
Greenpeace Japan

Ryoich HIRANO
Chair,
Nuclear Fuel Waste Intake Arrest Action Committee

Hideyuki BAN
Co-Director,
Citizens’ Nuclear Information Center

ATTACHMENT:

In a statement to the Fukushima District Court last September, Tokyo Electric (TEPCO), as defendant in an injunction case brought forward by citizens groups, asserted that the company has a low assessment of BNFL MOX technology. TEPCO states,

“Belgonucleaire has abundant experience in the manufacture of MOX fuel. In comparison, however, BNFL’s MOX fuel fabrication facility is…by nature that of a demonstration plant level… its manufacturing experience …by far inferior to that of Belgonucleaire. ”

In further testimony, TEPCO once again emphasizes BNFL’s lack of experience as a whole in MOX fuel fabrication. The company states:

”… BNFL which fabricated MOX fuel for Kansai Electric began operations in 1993, and, moreover, its annual manufacturing capacity is less than one-quarter that of Belgonucleaire, resulting in an extraordinary gap in manufacturing experience. The disparity is remarkable* between the two companies’ experience. [*Translator’s note: “conspicuous, remarkable, marked, striking, prominent” in Japanese].

TEPCO court submission to Fukushima District Court. Submission (Yo) #33,

18 September 2000.

Clearly, TEPCO considers BNFL to be inexperienced and technically inferior to Belgonucleaire, and therefore, by association, to COGEMA.

The Fukushima District Court in its 23 March 2001 verdict also addresses the BNFL problem. When addressing the types of falsification conducted by BNFL on MOX fuel manufactured for Kansai Electric, the court acknowledges,

”… when the measurement value went slightly above the specification value, the inspectors [at BNFL] undertook such practices as re-measuring the pellet, rotating it 90 degrees.”

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com
Contact:
Aileen Mioko Smith Mobile:
+81-90-3620-9251

For Immediate Release: 25 April 2003 Contact: Aileen Mioko Smith 　 Mobile: +81-90-3620-9251

On 25 April, Green Action and other Japanese citizen and consumer organizations issued an appeal to governments party to the Non-Proliferation Treaty asking them to urge Japan "not to go forward with separation of massive quantities of plutonium at the Rokkasho Reprocessing Plant."

The Rokkasho plant (800 tons HM/year) is located in Aomori Prefecture, northern Japan and is scheduled to begin uranium commissioning this June according to Japan Nuclear Fuel Ltd (JNFL), owner/operator of the plant. Reprocessing is scheduled to start in 2005. The plant is capable of separating out 7 tons of weapons-capable plutonium a year.*

The Appeal is being sent by facsimile to key governments party to the NPT. Satomi Oba, director of the Hiroshima-based organization Plutonium Action Hiroshima, will be traveling to Switzerland on 28 April, addressing the Appeal further during the NPT PrepCom being held in Geneva 28 April – 9 May.

The Appeal is being issued by: (Alphabetical Order) Citizens’ Nuclear Information Center, Consumers Union of Japan, Green Action, Greenpeace Japan, Mihama-no-Kai, No Nukes Asia Forum, Plutonium Action Hiroshima, and Stop the Monju.

The Appeal states, "The Japanese people have in our collective memory the devastating effects of Hiroshima and Nagasaki. We are therefore seriously concerned with the current build-up in nuclear tensions in the Far East — the Korean Peninsula and Japan. This, more than anything, urges us to write to you today."

"Japan has a program to use massive quantities of plutonium for civil use. In spite of there being no demand for plutonium in Japan due to a standstill in the implementation of this program, Japan is going forward with preparations to operate a huge reprocessing plant capable of separating out massive quantities of plutonium." Japan already has a huge plutonium surplus**, 4.1 tons in Japan and 32.4 tons stockpiled at reprocessing plants in France and Britain.

The organizations point out Japan’s problematic track record when it comes to plutonium management. In 1994 the then Nagasaki mayor Hitoshi Motoshima called plutonium management Tokaimura, "careless to the extreme". This year an SRD (Shipper/Receiver Difference) of 206 kilograms (recently questionably revised to 59 kilograms) of plutonium was recorded at the Tokai Reprocessing Plant (120 tons HM/year). The Appeal states, "Japanese sloppiness with plutonium management is a serious concern considering the scheduled operation of the much larger scale Rokkasho Reprocessing Plant."

The Rokkasho plant, if operated, will be the first large-scale plant capable of separating plutonium in a non-nuclear weapons state.

* According to the IAEA, 8 kilograms of reactor grade plutonium is one "significant quantity", enough to make one nuclear weapon.

**Latest figure: December 2001. Quantity in 2003 is greater.

Immediate release:

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com
Contact:
Aileen Mioko Smith Mobile:
+81-90-3620-9251

Stop Rokkasho Reprocessing Plant in Aomori Japan —

For Immediate Release: 25 April 2003 Contact: Aileen Mioko Smith Mobile: +81-90-3620-9251

On 25 April, Green Action and other Japanese citizen and consumer organizations issued an appeal to governments party to the Non-Proliferation Treaty asking them to urge Japan "not to go forward with separation of massive quantities of plutonium at the Rokkasho Reprocessing Plant."

The Rokkasho plant (800 tons HM/year) is located in Aomori Prefecture, northern Japan and is scheduled to begin uranium commissioning this June according to Japan Nuclear Fuel Ltd (JNFL), owner/operator of the plant. Reprocessing is scheduled to start in 2005. The plant is capable of separating out 7 tons of weapons-capable plutonium a year.*

The Appeal is being sent by facsimile to key governments party to the NPT. Satomi Oba, director of the Hiroshima-based organization Plutonium Action Hiroshima, will be traveling to Switzerland on 28 April, addressing the Appeal further during the NPT PrepCom being held in Geneva 28 April – 9 May.

The Appeal is being issued by: (Alphabetical Order) Citizens’ Nuclear Information Center, Consumers Union of Japan, Green Action, Greenpeace Japan, Mihama-no-Kai, No Nukes Asia Forum, Plutonium Action Hiroshima, and Stop the Monju.

The Appeal states, "The Japanese people have in our collective memory the devastating effects of Hiroshima and Nagasaki. We are therefore seriously concerned with the current build-up in nuclear tensions in the Far East — the Korean Peninsula and Japan. This, more than anything, urges us to write to you today."

"Japan has a program to use massive quantities of plutonium for civil use. In spite of there being no demand for plutonium in Japan due to a standstill in the implementation of this program, Japan is going forward with preparations to operate a huge reprocessing plant capable of separating out massive quantities of plutonium." Japan already has a huge plutonium surplus**, 4.1 tons in Japan and 32.4 tons stockpiled at reprocessing plants in France and Britain.

The organizations point out Japan’s problematic track record when it comes to plutonium management. In 1994 the then Nagasaki mayor Hitoshi Motoshima called plutonium management Tokaimura, "careless to the extreme". This year an SRD (Shipper/Receiver Difference) of 206 kilograms (recently questionably revised to 59 kilograms) of plutonium was recorded at the Tokai Reprocessing Plant (120 tons HM/year). The Appeal states, "Japanese sloppiness with plutonium management is a serious concern considering the scheduled operation of the much larger scale Rokkasho Reprocessing Plant."

The Rokkasho plant, if operated, will be the first large-scale plant capable of separating plutonium in a non-nuclear weapons state.

* According to the IAEA, 8 kilograms of reactor grade plutonium is one "significant quantity", enough to make one nuclear weapon.

**Latest figure: December 2001. Quantity in 2003 is greater.

Immediate release:

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com
Contact:
Aileen Mioko Smith Mobile:
+81-90-3620-9251

We are organizations in Japan concerned with the proliferation of nuclear weapons. The Japanese people have in our collective memory the devastating effects of Hiroshima and Nagasaki. We are therefore seriously concerned with the current build-up in nuclear tensions in the Far East — the Korean Peninsula and Japan. This, more than anything, urges us to write to you today.

---

Japan has a program to use massive quantities of plutonium for civil use. In spite of there being no demand for plutonium in Japan due to a standstill in the implementation of this program, Japan is going forward with preparations to operate a huge reprocessing plant capable of separating out massive quantities of plutonium.

The Rokkasho Reprocessing Plant (800 tons HM/year) will be the first large-scale reprocessing plant located in a non-nuclear weapons state. Rokkasho, if operated, would be capable of separating 7 tons of plutonium a year.

Now is the time to stop the Rokkasho Reprocessing Plant. The plant is scheduled to begin reprocessing in 2005. Testing with depleted uranium is to begin later on this year (2003). The testing will contaminate the plant, thus furthering Japan’s commitment to reprocessing and making Rokkasho even more difficult to stop.

Japan already has a huge plutonium surplus. As of the end of 2001 there were 4.1 tons of surplus plutonium in Japan, and 32.4 tons of Japanese plutonium stockpiled at reprocessing plants in Europe (France and Britain).

Rokkasho’s plutonium was originally intended to be consumed at Japanese commercial nuclear power plants. However, the program has not been implemented. Two of the three governors of the prefectures scheduled to first use this fuel have rescinded their prior approval for the program.

In the meantime, Japan’s fast breeder reactor program — four decades under development and yet to produce but one hour of electricity in total — received a severe blow this January when a Japanese High Court revoked the original license granted by the national government for Japan’s prototype fast breeder reactor Monju.

Monju is capable of producing enough weapons-grade plutonium in two weeks to make one nuclear weapon. There are no plans to commercialize fast breeder reactor technology under Japan’s current Long-Term Program for Research, Development and Utilization of Nuclear Energy. In spite of this, the Japanese government is pressing for early restart of Monju.

Japan has a problematic track record when it comes to plutonium management.A 70 kilogram hold-up of plutonium occurred in 1994 at the Plutonium Fuel Production Facility (PFPF) during fabrication of Monju fuel with a subsequent long delay in clean up. The problem provoked the then Nagasaki mayor to state that plutonium management at the plant was "careless to the extreme".

This year an SRD (Shipper/Receiver Difference) of 206 kilograms (recently revised to 59 kilograms) of plutonium was recorded at the Tokai Reprocessing Plant (120 tons HM/year). Japanese sloppiness with plutonium management is a serious concern considering the scheduled operation of the much larger scale Rokkasho Reprocessing Plant.

We ask all nations concerned with security in Asia to immediately urge Japan not to go forward with separation of plutonium at the Rokkasho Reprocessing Plant in Aomori Prefecture, northern Japan.

We wish to thank you for your persevering efforts to rid the world of nuclear weapons, and as states party to the NPT meeting in Geneva to discuss the many critical challenges facing the non-proliiferation regime, we hope that you will consider the request stated in this appeal.

Yours sincerely,

Hideyuki BAN
Co-director
Citizens’ Nuclear Information Center

Yoko TOMIYAMA
Chairperson
Consumers Union of Japan

Aileen Mioko SMITH
Director
Green Action

Masashi KIMURA
Executive Director
Greenpeace Japan

Hideyuki KOYAMA
Director
Mihama-no-Kai (Osaka)

Daisuke SATO
Executive Director
No Nukes Asia Forum (Japan)

Satomi OBA
Director
Plutonium Action Hiroshima

Fukiko IKEJIMA
Director
Stop the Monju

Green Action

Tel: +81-75-701-7223 Fax: +81-75-702-1952 amsmith@gol.com

Plutonium Action Hiroshima

2258-14, Ichikawa, Shiraki-cho Asakita-ku, Hiroshima 739-141 Japan

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com

Plutonium Action Hiroshima
2258-14, Ichikawa, Shiraki-cho Asakita-ku, Hiroshima
739-141Japan

Comision de Poblacion, Ambiente y Desarrollo
Asamblea Legislativa
Republica de Panama

Dear Members of the Commission:

Green Action is an environmental NGO based in Kyoto, Japan which works on Japan’s plutonium program issues.

We are submitting this letter in conjunction to your deliberation of proposed legislation that would prohibit shipments of ultrahazardous nuclear cargoes through the Panama Canal. This letter addresses the fact that maritime shipments of ultrahazardous nuclear cargoes from Europe to Japan are not necessary for meeting Japan’s energy needs.

Japan at present has 53 nuclear reactors producing approximately 37% of Japan’s electric power needs, but not a single one of these reactors is dependent on maritime nuclear shipments between Europe and Japan.

The maritime shipments of HLW (high level radioactive waste) and MOX (mixed plutonium-uranium oxide) fuel are taking place only because of Japan’s plutonium program.

Japan’s plutonium program is not only not necessary for meeting Japan’s electricity demand, it is also an economic drain. In fact the chairman of Japan’s most powerful business lobby, the Japan Business Federation (Nippon Keidanren), has called on the national government to review its current nuclear energy policy that pushes use of plutonium for fuel. (Please see attached Japan Economic Newswire article dated January 27, 2003).

There is only one reactor in Japan that uses plutonium fuel to produce electric energy. (The plutonium is procured domestically and not by shipments from Europe.) This reactor is the ATR reactor Fugen. Fugen is scheduled to be shutdown permanently at the end of this month (March 2003). It will subsequently be dismantled. Apart from Fugen, there is not one single light bulb being lit in Japan by the plutonium program.

The French companies Cogema and the British company PNTL continue to attempt to mislead countries on the route of Japanese maritime nuclear shipments, making it appear as though these shipments are necessary for Japan’s energy future. Nothing can be further from the truth.

Now that the ATR program has been scrapped by the Japanese electric utilities, there are two parts of Japan’s plutonium program which remain: Japan’s FBR (fast breeder reactor) program and the use of MOX (mixed plutonium-uranium oxide) fuel in the commercial nuclear reactors currently using uranium fuel (the Pluthermal Program). Both programs are going nowhere.

Japan’s FBR program has been under development for four decades. However, to date, the program has produced only one hour of electricity. This occurred in August 1995. The electricity was produced by the prototype FBR Monju located in Fukui Prefecture. There has been no electricity produced by the FBR program since then. Monju has been shutdown since December 1995 due to a sodium leak and fire accident. There is no restart date set. There is only one other FBR in Japan called Joyo, but this reactor is experimental and cannot produce electricity.

Under Japan’s current Long Term Program for Research, Development and Utilization of Nuclear Energy, there are no plans for any further FBRs to be built.

On January 27, 2003, the Nagoya High Court ruled that the license granted for Monju by the national government was illegal. The case is now in the Supreme Court. As can be seen above, Japan’s FBR program is in total disarray.

The Pluthermal Program (use of MOX fuel), the remaining part of Japan’s plutonium program, is also currently at a complete standstill. The program was to begin in the first half of the 1990’s. Kansai Electric and Tokyo Electric were to be the first to implement the program. However, in 1999 BNFL (British Nuclear Fuels plc) was found to have falsified the quality control data for the MOX fuel to be used in the first Kansai Electric reactor in Fukui Prefecture (Takahama Unit 4). The fuel was subsequently returned to Britain in July 2002.

In September of 2002, the governors of the remaining two prefectures, Niigata and Fukushima, which were slated to be the first to use this plutonium (MOX) fuel rescinded their prior approval for the program (to be implemented at Kashiwazaki-Kariwa Unit 3 and Fukushima Unit I-3 respectively, both Tokyo Electric reactors).

As can be seen above, Pluthermal Program plans have been set back further each and every year since 1999. There are now no dates for starting the Pluthermal Program and no need for shipping MOX fuel to Japan.

Masatoshi Toyoda, former president of Japan Nuclear Fuel Limited (JNFL), the company central to Japan’s plutonium program, states in the October 2002 edition of the Japanese publication ENERGY, "Currently, the supply of uranium exceeds demand, and the price is around $50/kgU. On the other hand, reprocessing and MOX fuel fabrication fees have increased several times from prices estimated 20 years ago, and the prospect of fast breeder reactors coming into practical use has become opaque. Considering this change in the state of affairs, I believe that it goes without saying that a review of the nuclear fuel cycle should be carried out." ("Circumstances Concerning Reprocessing and Pluthermal", Energy, October 2002. Translation from the Japanese by Green Action.)

We thank you for considering our submission and we hope the above will be helpful for your deliberations.

Sincerely,

Aileen Mioko Smith
Director,Green ActionAttachment:
Japan Economic Newswire article dated January 27, 2003

About Green Action:

Green Action based in Kyoto is a Japanese NGO founded in 1991 which works to stop Japan’s plutonium program. It is co-founder of Stop the Monju (1991), the Japanese NGO working exclusively to stop Japan’s fast breeder reactor program. Green Action is also the international office for and co-founder of Stop Nuclear Waste Campaign.

Green Action has been invited by the Japanese government- the Atomic Energy Commission and the Ministry of Economy, Trade, and Industry’s Agency for Natural Resources and Energy-to give testimony at government roundtables and symposiums.Green Action is not affiliated or associated with any political party.

Japan Economic Newswire
January 27, 2003 Monday
SECTION: INTERNATIONAL NEWS
HEADLINE: Nippon Keidanren’s Okuda urges energy policy review
DATELINE: TOKYO, Jan. 27

Hiroshi Okuda, chairman of the Japan Business Federation (Nippon Keidanren), called on the government Monday to pursue energy policy changes from a long-term perspective, taking the opportunity afforded earlier in the day by a high court ruling against construction of the Monju experimental fast-breeder nuclear reactor. ‘It (the ruling) will serve as a starter (for the government) to review its energy policy centering on atomic power,’ Okuda, the head of Japan’s most powerful business lobby, told reporters. While noting that the ruling by the Nagoya High Court nullifying a 1983 government approval of the trouble-plagued reactor could be a big obstacle to energy policy in the short run, Okuda said, ‘It is necessary to look around, to see whether we will need atomic power or not in the long and medium terms.’

The government ’should think about a combination of energy sources as there have been advances in technology, like fuel cells,’ Okuda said, calling for a policy shift taking future technical innovation into consideration. The landmark decision in favor of residents seeking a halt to the operation of the nuclear reactor in Fukui Prefecture on the Sea of Japan coast has clouded plans to reactivate it, following its suspension after a massive sodium coolant leakage in 1995.

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com
Contact:
Aileen Mioko Smith Mobile:
+81-90-3620-9251

For Immediate Release: 27 January 2003
Contact: Aileen Mioko Smith
Cell: +81-90-3620-9251

Kanazawa, Japan—- Plaintiffs in Fukui Prefecture today won a lawsuit verdict against the Japanese government and the owner operator of Japan’s prototype fast breeder reactor Monju located in Fukui Prefecture. The lawsuit sought to stop the construction and operation of Monju. The epochmaking court verdict overturned a lower court ruling and is the first ever plaintiff victory addressing nuclear power in Japan. Monju had been shut since it had a sodium leak and fire accident in December 1995.

Citizens nationwide will be petitioning Prime Minister Junichiro Koizumi and Japan’s Atomic Energy Commission on 29 January in Tokyo, seeking scrapping of the entire plutonium fast breeder reactor program including Monju. 910,000 signatures have been gathered to date demanding that the government scrap Monju.

The Japanese government was working assertively to re-start the troubled reactor and in December 2002 had granted the Japan Nuclear Cycle Development Institute (JNC), the government corporation that owns and operates Monju, approval for a new post-1995 accident safety assessment. The ruling today, however, stated there were fundamental flaws in the original safety assessment made by the government. The court decision effectively guts the partially revised safety assessment that had been granted JNC.

"Today marks the beginning of the end of Japan’s fast breeder program. Monju would have to be rebuilt from the ground up if it were to meet the standards presented by the court today" said Aileen Mioko Smith, director of Green Action an environmental NGO based in Kyoto which works on stopping Japan’s plutonium program.

Ogiso Miwako, head of the Monju lawsuit plaintiff administrative office stated, "It has been a long 18 years but we have won. There is still a long fight ahead, but we have been vindicated today."

Compiled

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com

November 15, 2002

Dr. Richard Meserve
Chairman, Nuclear Regulatory Commission
Washington, D.C. 20555-0001
Facsimile: 1-301-415-1757

Dear Chairman Richard Meserve:

Re: Opposition to Issuance of Export License for Depleted Uranium to Japan’s Rokkasho Reprocessing Facility

Green Action is a Japanese NGO based in Kyoto, Japan working mainly on Japanese plutonium fuel cycle issues.

Green Action recently obtained a copy of an application to export approximately 26 tons of depleted uranium from the United States to Japan for use as test material in the test operation of Japan’s Rokkasho nuclear fuel reprocessing facility. [License Number XSOU8790, Date of Application 10/17/2002]

Green Action notes that Japan has already stockpiled more than 32 tons of plutonium in Europe for which it has demonstrated no concrete plans to consume. The Rokkasho reprocessing facility has the potential to separate 8 tons of plutonium annually, and full-scale operation of this facility will result in domestic stockpiling of large quantities of weapons-usable plutonium. Japan clearly has no demonstrable use for plutonium, and operation of Rokkasho will do nothing but greatly increase nuclear proliferation concerns in northeast Asia.

Attachment B of the above license application confirms that uranium-testing is an integral part of the start-up of the Rokkasho facility, and for this reason, we believe that the NRC and the Executive Branch of the United States Government should conduct a nuclear proliferation assessment of the impact of operation of Rokkasho prior to issuing a license to export depleted uranium to this facility.

Green Action is concerned that stockpiling of large quantities of plutonium in Japan is not only an inherent environmental and security risk in and of itself, but will also threaten world security since such a large domestic stockpile will encourage other countries to obtain or enlarge their stocks of fissile materials. Considering the enormous security risk associated with operating this facility, we believe that failure to conduct a nuclear proliferation assessment prior to issuing a license for the export of depleted uranium to Rokkasho is tantamount to the United States abdicating its responsibility concerning the management of US origin nuclear materials.

Japan’s Atomic Energy Commission which is responsible for drafting Japan’s Long-Term Program for Research, Development and Utilization of Nuclear Energy (LTP), continues to claim that plutonium utilization will go forward as planned. However, the track record of previous LTPs is dismal when it comes to plutonium utilization plans. (See table and chart in Attachment A.)

The AEC expects electric utilities to cooperate with the government to implement the programs outlined in the LTP, but there is no guarantee the electric utilities will do so. For example, in the eighth LTP finalized in 1994, the AEC proclaimed advanced thermal reactor (ATR) technology as "capable of flexibly and efficiently using plutonium and recovered uranium". However, only thirteen months after the 1994 LTP was finalized, the Federation of Electric Power Companies (FEPCO) submitted a letter to the AEC which stated, "…due to social pressure to reduce electricity costs it is no longer possible to proceed with the costly development of an ATR demonstration reactor." This letter went on to request a full-scale review of the entire ATR development program. As a result of FEPCO’s position on the ATR, all mention of the ATR program disappeared with no explanation from the ninth LTP issued by the AEC in November 2000.

In previous LTPs, plutonium utilization was to center around fast breeder reactor (FBR) technology. However, efforts to develop commercial FBRs have proven to be more difficult than originally estimated, and development plans have been put back further and further in time in every single LTP. On December 1995, a sodium leak and fire accident occurred at the Monju prototype fast breeder reactor in Fukui Prefecture. The accident and subsequent cover-up of the extent of the accident by the operator of the plant severely damaged public confidence in the entire nuclear industry and brought FBR development plans to a standstill.

With the ATR program scrapped and the FBR program at a standstill, the pluthermal program (the use of MOX fuel in light water reactors) became the key program for reducing Japan’s stockpiles of plutonium. The pluthermal program was originally scheduled to begin in 1999, and MOX fuel has been shipped from Britain and France to reactors in Fukui, Fukushima, and Niigata Prefectures. However, the program remains unimplemented due to the December 1999 BNFL MOX fuel data falsification scandal, and the May 2001 referendum in Kariwa village which resulted in a majority of residents voting against the use of MOX fuel at Tokyo Electric’s Kashiwazaki-Kariwa Unit 3 nuclear power plant. Following the September 2002 announcement that Tokyo Electric systematically concealed inspection results from government regulators, the governors of Fukushima and Niigata prefectures withdrew their advance permission for the pluthermal program. On October 9, 2002 the governor of Fukushima Prefecture called on Prime Minister Junichiro Koizumi and the national government to review the justification for the nuclear fuel cycle.

Regardless of the AEC’s advocacy of the nuclear fuel cycle, there is widespread public opposition to all plutonium utilization plans, and there is no guarantee that these plans will ever gain the consent of the Japanese public.

Given the abovementioned track record of previous LTPs, Green Action believes Japan’s AEC is incapable of providing the United States government with a convincing schedule for the timely utilization of plutonium separated in Europe and plutonium to be separated at Rokkasho. Based on the reasons outlined in this letter, we strongly urge the NRC to deny issuing a license to export this material.

Sincerely,

Aileen Mioko Smith
Director,
Green Action

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Green Action ; info@greenaction-japan.org; Modified
Phone 075 701 7223 Facsimile 075 702 1952

Interim Report

September 2002

I. Background

(How the Review came about.)

II. Concerning the Problem of "Falsification of Industry Inspections Records at Nuclear Power Plants"

"Of course the responsibility of the utilities [for having caused this situation] must be pursued vigorously, but the Japanese government’s responsibility for this situation is also extremely grave as well."

"This current problem is a problem of the national government’s constitution and disposition, conducting nuclear policy "like a bulldozer", and ‘belittling [holding in contempt] the residents where nuclear power plants are located".

"The Japanese government states, "Even though there may be slight delays as a result of the current problems, the basic plan of aiming for implementation of the pluthermal program remains unchanged." Also, "We will steadily go forward with the Pluthermal Program.’ Perhaps the national government doesn’t understand the basic nature of the current problems."

"The government is looking into the introduction of a new regulatory inspection regime —ASME-type standards. But, can this really result in effectively preventing the reoccurrence of the type of problems we are currently facing Questions remain as to whether these standards will lead to the upgrading of safety and credibility at nuclear power plants. Rather, isn’t it necessary now to take the time and undertake a careful deliberation of the issues

[Referring to the fact the government back in July had at first recognized the high marks for safety and reliability attained by the Fukushima Dai-Ichi Units 3 and 4 after their periodic safety reviews, then retracting these after the scandals erupted, the Fukushima Review states the following:]

"The government was forced into an extraordinary situation of withdrawing its approval because of the exposure of dishonest practices, and this it did without sufficient explanation as to what kind of assessment it had made to deem this judgment correct. If this is the state of affairs of the periodic safety review process which forms the basis of assuring the safety and reliability of nuclear power plants, isn’t it utterly impossible to say that the government’s inspection and assessment regime to assure safety is properly functioning"

III. Concerning "The Main Issues and Concerns"

1. Concerning the Changes in the Energy Supply-Demand Structure:

Considering the fact liberalization of the electricity market is moving forward and the supply-demand structure etc. is changing, will additional electricity-producing sites of electric utilities being built based on the assumption that electricity consumption will continue as before really be necessary

2. Concerning the Possibilities for New Sources of Energy:

The government has made the target for introducing new energy sources to be about 3% of total primary energy supply. However, isn’t it necessary to plan for an even greater increase by adopting policies to introduce each [energy source] area

3. Concerning the Decision Making Process for Formulation of Nuclear Policy:

1. Is Information Disclosure Sufficient:
   Nuclear Energy is a colossal scientific technology, its contents very difficult to understand. Also the promotion of nuclear policy relates to the issue of safety which is deeply connected to basic human rights. Because of this, the thorough disclosure of information is indispensable. However, is thorough disclosure of information taking place
2. Are the views of a wide range of the nation’s citizens being sufficiently heeded when formulating policy Rather than just listening to the views of the nation’s citizens, isn’t it necessary to create an infrastructure whereby, after supplying the nation’s citizens with sufficient information and knowledge to make their own judgments, the views of citizens are reflected when formulating nuclear policy etc.
3. Is assessment of nuclear policy being properly undertakenAfter the Monju accident, and from the point the fast breeder development plans that had been in place were revised, future plans for the utilization of plutonium have become uncertain. Wasn’t it necessary at that point to re-examine the policy of reprocessing all spent nuclear fuel
4. Where is nuclear policy actually decided
   It has been said that it is difficult for citizens to understand the decision making system for nuclear policy. Where is nuclear policy finally decided Who takes responsibility for this policy Also, nuclear policy is decided only by the bureaucracy. Isn’t it necessary instead to consider making the process democratic by having its formulation go through the legislative Diet process, etc.

4. The Position of Nuclear Energy in Overall Energy Policy

1. Is the promotion of nuclear power convincing to the nation’s citizens
2. "….While the fight to cut costs mounts, have proper countermeasures been put in place for assuring safety and undertaking the proper steps for the back-end
3. Are measures for the aging of nuclear power plants being properly undertaken
   Isn’t it necessary to undertake a drastic reconsideration of measures [countermeasures] for aging of reactors
4. What is going to happen with the outlook for disposal of high level radioactive waste Although the legislation and system for realizing a site has been established, isn’t it going to be considerably difficult to site a final repository

5. Concerning the Nuclear Fuel Cycle

1. Can it be said that the nuclear fuel cycle is at this point absolutely necessary If uranium resources can be supplied stably, is reprocessing which is undertaken in order to save on the consumption of uranium absolutely necessary
2. Will the nuclear fuel cycle not only save on resources, but will it likewise lead to a stable supply of energy
   During the Review it was pointed out that if there were no fast breeder reactors, then reprocessing once through would lead to approximately 10% of resource savings. At this level of savings, when considering the uncertainty of the costs of reprocessing and its back-end, can it really be said that reprocessing, for only this amount of resource savings, is really appropriate
3. Aren’t there problems with the cost
   The basis for the financial estimation of the cost of the nuclear fuel cycle within the backdrop of the liberalization of electricity has not, in spite of the fact it is an extremely important problem which affects the regions where nuclear power plants are located tremendously, been made sufficiently clear. Considering this, isn’t an assessment of the economic viability [of the nuclear fuel cycle difficult to make
4. What about plutonium balance
   If the Rokkasho Reprocessing Plant begins operation, will it not produce yet more surplus plutonium — considering the fact fast breeder reactor realization is nowhere in sight, construction of the full MOX nuclear reactor at Ohma in Aomori Prefecture is behind schedule, and MOX fuel implementation in light water reactors has not been realized

   …….There are concerns that even the 30 some ton quantity of plutonium from overseas reprocessing will take a considerable time to use up.
   ……Under these circumstances, the plutonium balance in the long term plan for nuclear power is no longer realistic. Can’t it be said that we can no longer say our country’s plutonium utilization is transparent. And, will there not be a possibility that anxiety will be harbored internationally due to the existence of plutonium that is ‘in surplus’ as a result of undertaking reprocessing

5. What is the possibility of the realization of a fast breeder at this time ..Currently there is no outlook for the realization of the fast breeder. Under these circumstances, is it really appropriate to continue promoting the reprocessing path
6. Does reprocessing really greatly reduce the amount of high level radioactive waste …….but it increases the volume of low level waste vastly…….etc., therefore aren’t the merits cancelled out……Isn’t it necessary to re-examine the policy of reprocessing all nuclear waste considering the problems with the cost and back end of reprocessing, the reality that there is no outlook for the fast breeder reactor, and in addition, when evaluating the overall issue of waste volumes of high level radioactive waste
7. What will happen with spent MOX fuel
   ……The chances of a second reprocessing plant becoming reality is extremely small.

6. Considering the Future of Electric Power Plant Sites

1. …… A monoculture economy…….
2. Isn’t it time to think about the future of the regions which now face the reality of the decommissioning of nuclear power plants.IV CONCLUSION[Summary in bullet point form Only parts relevant to nuclear fuel cycle translated here.]

   Especially, as far as the nuclear fuel cycle is concerned, isn’t it necessary to stop once and, moving ahead with information disclosure while undertaking a comparison between the reprocessing of all spent nuclear fuel and the options of direct disposal etc., ask the citizens of the nation what path should be taken from henceforth.
   Finally, we hope and expect that the national government will listen to our views with humility, and, based upon the rights and responsibilities bestowed upon it, carry out the responsibility of explaining the concerns and doubts we have addressed here to the citizens of the nation. We hope and expect that the government will not be bound to the past but indicate to the citizens of this nation a new nuclear energy policy in concrete form, bringing forward a nuclear power administration based on safety and security which can be understood and trusted by the citizens of this nation.

Placed on home page

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com

19 September 2002

Consultation Procedures for Citizens of Fukushima Prefecture and Others on the "Interim Report"

Administrative Office
Energy Policy Review

1. Purpose: A consultation is being undertaken to seek views on the "Interim Report" of this Energy Policy Review in order that the views of Fukushima Prefectural citizens etc. will be reflected in future energy policy [of this nation].
2. Who Can Submit: Citizens and organizations not limited to Fukushima
3. Prefecture.
4. How the "Interim Report" will be made public[Libraries, home page, through the media, etc.]
5. Consultation Period: October 1 – November 30, 2002
6. Method of Submission: Mail, fax, email : energy-g@pref.fukushima.jp
7. How Submissions Will Be Handled.

Placed on home page

Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku Kyoto 606-8203 Japan
T + 81 75 701 7223
F + 81 75 702 1952
E-mail amsmith@gol.com