Green Action Japan

Frédéric Patalagoity,
President and Managing Director
AREVA Japan
Urban Toranomon, Bldg. 5F
1-16-4 Toranomon, Minato-ku
Tokyo 105-0001
Japan

July 21, 2016

Dear Frédéric Patalagoity,

We are writing to you to express our disappointment and concerns over the use of AREVA produced MOX fuel in Japanese nuclear power plants.

As you know we wrote to you on January 28^th of this year to request details over the quality of plutonium mixed oxide fuel supplied to Japan, specifically Kansai Electric. We have yet to receive a response to this letter (also attached to this letter).

As you will be aware the Ikata 3 reactor is due to restart operations shortly. Sixteen assemblies of MOX fuel supplied by AREVA in 2009 (as part of 21 assembly delivery) have been loaded into the reactor. As with the fuel supplied to Takahama, there are major doubts over the safety of the MOX fuel about to be used in Ikata, including quality control issues related to the thermal stability of the fuel.

We are alarmed by the lack of transparency over issues of fundamental nuclear safety demonstrated by AREVA’s lack of response.  At a time of unprecedented crisis for the global business operations of AREVA, failure to provide information that is in the public interest and that of nuclear safety is both unacceptable and poor business practice. Once again we calling on AREVA to release immediately the actual quality control data for MOX fuel assemblies supplied to both Kansai Electric’s  Takahama 3&4 reactors, and Shikoku Electric’s  Ikata 3 reactor.

Yours sincerely,
Shaun Burnie
Senior Nuclear Specialist,
Greenpeace Germany

Aileen Mioko Smith
Executive Director,
Green Action
Kyoto

Hideyuki Ban
Co-Director,
Citizens’ Nuclear Information Center
Tokyo

Hideyuki Koyama
Director,
Osaka Citizens Against the Mihama, Ohi and Takahama Nuclear Power Plants (Mihama-no-Kai)
Osaka

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PDF: Letter to AREVA Japan Calling for Disclosure of MOX Fuel Quality Control Data, 2016-07-21

日本語訳

Frédéric Patalagoity,
President and Managing Director
AREVA Japan
Urban Toranomon, Bld 5F 1-16-4
Toranomon, Minato-ku
Tokyo 105-0001
Japan

January 28th 2016

Dear Frédéric Patalagoity,

We are writing to you to outline our concerns with the production standards, quality control and, ultimately, safety of AREVA plutonium MOX fuel produced for Japanese utilities. Specifically the planned use of 30 MOX assemblies in the Takahama reactor units 3&4, owned by Kansai Electric.

As you will be aware it is fifteen years since the poor quality control and production standards of plutonium MOX fuel was first disclosed in the case of 8 MOX fuel assemblies manufactured by the then British Nuclear Fuels Limited (BNFL) at Sellafield in the UK, and delivered to the Kansai Electric reactor Takahama unit 4 in Fukui prefecture. As a result of our analysis, based on original quality control data that BNFL were forced to disclose publicly at that time, Green Action and Mihama-no-Kai filed a legal challenge. For two month both Kansai Electric and BNFL denied that the fuel had falsified quality control data. However, in December 1999, one day before the court ruling, Kansai Electric and BNFL were forced to confirm in that plutonium MOX fuel to be used in Takahama 4 contained falsified quality control data. As you know the fuel was returned to the UK and scrapped.

In 1999 and 2000 we produced analysis that showed production and quality control standards for MOX fuel produced using the MIMAS method, including at the Cogema/AREVA Melox plant, were actually of a lower standard than used by BNFL. This was used by a legal challenge to the Fukushima District court on behalf of 1000 plaintiffs in challenging the loading of 32 MOX fuel assemblies into the Fukushima Daiichi unit 3 reactor. The MOX fuel was manufactured using the MIMAS method, under a contract between Tokyo Electric and COMMOX, of which Cogema was a lead agency. While the judgement of the Fukushima District Court did not uphold the lawsuits complaint, the judgement also made clear that quality control data for the MOX fuel should be publicly disclosed. No such data was released by COMMOX in the intervening years. As a consequence of the doubts and controversy over the safety and quality of MOX fuel, Tokyo Electric were prevented from use of the 32 assemblies of MOX fuel until September 2010, six months prior to the March 2011 disaster.

You will also be aware that 28 MOX assemblies delivered to the Kashiwazaki Kariwa nuclear plant in Niigata in 2001, as a consequence of the controversy over the quality and safety of MOX fuel and the opposition of the people of Kariwa, was not loaded into unit 3 as planned. Nearly 15 years later that plutonium fuel remains unused and stored in the cooling pool at the reactor site.

As AREVA sought to restart its MOX business with Japanese utilities the issue of quality control and production standards persisted. Twelve AREVA MOX fuel assemblies, containing 552kg of plutonium were delivered to the Takahama plant in 2010, eight of which were loaded into unit 3. Our analysis at the time found that there were disagreements between AREVA and Nuclear Fuel Industries Ltd (the developer and design code verifier of the MOX fuel and contractor acting on behalf of Kansai Electric and other Japanese power companies). Specifically over the MOX fuel quality and production standards to be used for the manufacture of Japanese fuel at AREVA’s Melox fuel production plant in Marcoule, France, including for Takahama. As a result of AREVA’s production problems, and their intransigence, NFI agreed to AREVA’s insistence that a lower standard of production and quality control would be used for the production of MOX fuel, including for that produced for Kansai Electric. AREVA failed to publicly provide quality control data at this time when challenged by us in 2010.

As you know the safety implications of MOX fuel use are severe. This is made worse by significant problems with the quality control and production standards that exist at the Melox plant.

The MIMAS production technology used at Melox has a multiple problems, including in relation to a fundamental issue for MOX fuel, Thermal Stability. If the plutonium fuel pellets swell under heat alone, and as internal pressure builds up from gaseous fission products, a gas-filled pellet-cladding gap can occur. This has several nuclear safety consequences. Not least that in the event of a loss of coolant accident, the MOX fuel, which may already be fractious, would be further more likely to fragment and “relocate”. The heterogeneous fuel structure can also increase the chance that fuel rods will rupture and block coolant channels if a transient occurs, again potentially impacting cooling function of the reactor core. The reactor safety implications of not being able to sufficiently cool the reactor core fuel are obvious, not least from the meltdown of three reactors at Fukushima Daiichi in 2011. This underscores the importance of achieving the highest nuclear fuel production standards, and applying the most rigorous quality control and inspection. Neither of these are possible at the Melox plant.

The thermal stability problem that exists with Melox produced MOX fuel is but one of multiple concerns we have with plans to operate Japanese reactors with AREVA supplied fuel. The fact that five years after delivery of MOX fuel to Takahama, AREVA has made no effort to provide details on their production and quality control standards is unacceptable to the people of Japan. Already subjected to the consequences of the Fukushima Daiichi accident, the people of Japan are now confronted with the risks of the restart of the Takahama reactor units 3 and 4, to be operated with 24 assemblies and 4 assemblies of AREVA MOX fuel, containing 1,088kg and 184kg of plutonium respectively.

The failure of the Japanese Nuclear Regulation Authority (NRA) to re-assess the risks of MOX fuel use in Japan is deeply regrettable and we have challenged them on this, relying as they do on the reviews conducted by the discredited NISA. At the same time, AREVA as the manufacturer of this substandard product, has a duty to publicly disclose all relevant and original data on the quality control and production standards of its fuel that is about to be used in the Takahama reactors.

It is all the more critical that AREVA release the quality control data for the Takahama MOX fuel, as in 2010 the French nuclear safety regulator, ASN, confirmed to Greenpeace France in relation to the fuel then being shipped to Japan for use in Takahama unit 3, that, “The ASN is not involved in the quality control of production destined for Japanese utilities.” With neither French or Japanese regulators overseeing MOX fuel standards and quality control there clearly are additional major failures and risks from Kansai Electric’s plans to use AREVA MOX fuel. Without a commitment to transparency on this issue, assurances that the fuel is safe to use are meaningless.

We understand that AREVA have multiple threats and challenges to their future business prospects. Securing additional MOX business with Japanese utilities, including new MOX fuel manufacture, must rank high in your priorities given the 16,000kg of plutonium belonging to Japan currently stored in France. This will require the transport of many hundreds tons of MOX fuel from France, including that scheduled for 2016. But we would contend that a failure to put safety first and above commercial interests is in no ones interests, including those of AREVA.

Conducting a nuclear test on the people of Fukui, Kansai region and wider Japan, is never acceptable. As we approach the anniversary of the Fukushima Daiichi accident it is even more reprehensible that AREVA has so far refused to fully disclose all relevant data on its MOX production problems at Melox. We are calling on you to release immediately the actual quality control data for the 30 MOX fuel assemblies about to irradiated in the Takahama reactors.

Yours sincerely,

Shaun Burnie
Senior Nuclear Specialist,
Greenpeace Germany

Aileen Mioko Smith
Executive Director,
Green Action, Kyoto

Hideyuki Ban
Co-Director,
Citizens’ Nuclear Information 
Center
Tokyo

Hideyuki Koyama
Director,
Osaka Citizens Against the Mihama, 
Ohi and Takahama Nuclear Power Plants
(Mihama-no-Kai)
Osaka

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PDF: Letter to AREVA Japan Calling for Disclosure of MOX Fuel Quality Control Data, 2016-01-28

日本語訳

Plutonium Shipment to Depart Japan for United States – Exposes Failure Of Global Reprocessing Programs

March 22nd 2016, Tokyo…The shipment of weapons-grade plutonium at the port of Tokai, Ibaraki prefecture departing later today, exposes the failure of global plutonium reprocessing programs and the threat from current Japanese nuclear policy, five non-governmental organizations charged today.(1) The cargo of 331kg of plutonium was loaded on to the Pacific Egret, an armed British nuclear transport ship, after it arrived at Tokai at 08.00 March 21st. Armed Japanese coastguard vessels, including the Shikishima, are outside the port and are expected to escort the plutonium shipment while inside Japanese coastal waters. The shipment is being undertaken in a failed U.S. policy attempt to reduce the threat from nuclear weapons materials worldwide.
The plutonium cargo to Charleston, South Carolina, in the United States, is sufficient to make over 110 nuclear weapons. However, the plutonium stockpile remaining in Japan is sufficient for over 1800 nuclear weapons, and the nation`s total plutonium stocks of over 47,000kg– including material stored in France and the UK – is sufficient for over 9400 nuclear weapons.

For more than five decades, Japanese nuclear policy has been based on the production and use of plutonium as a nuclear fuel. However, the failure of both its breeder program and plans to use plutonium as mixed oxide (MOX) fuel in light water reactors, has led to Japan acquiring the largest stockpile of weapons usable plutonium of any non nuclear weapon state. Operation of the 2.1 trillion yen Rokkasho-mura reprocessing plant in Aomori prefecture was recently postponed for the 23rd time. The Japanese government is aiming to pass legislation in the Japanese Diet to try and secure continued financing for Rokkasho from power companies that are facing a deeply uncertain future. Plans to operate Rokkasho from 2018 mean that Japan’s plutonium stocks could rise to as much as 93,000kg of plutonium by 2025.

As a result of reprocessing at the Sellafield nuclear complex in England, including from Japanese reactor spent fuel, over 126 tons of plutonium is stored at the site with no plans for its use. Total global stocks of so-called commercial reactor-grade plutonium was 271 tons at the end of 2014. This amount far exceeds the total amount in all military programs of 140 (+/-10) tons.(2)

“The global reprocessing of spent fuel has created a plutonium nightmare that threatens nuclear weapons proliferation. The UK, France and Japan have led this disastrous program, for which there is no economic rationale,” said Martin Forwood of CORE in the UK. “The clear warning to Japan from here in the UK, which has accumulated over 120 tons of plutonium and with no ability or plans to use it commercially, is, don’t start up the Rokkasho-mura reprocessing plant – it does not solve your nuclear waste problem but makes it far worse and produces vast amounts of weapons material that is only a security and proliferation threat. It’s time to scrap Japan’s plans for further plutonium production,” said Forwood.

Two reactors, Takahama 3 and 4, owned by Kansai Electric, began operation in January and February 2016 loaded with plutonium MOX fuel, with unit 3 operating with 24 assemblies containing 1,088kg of plutonium and unit 4 with 4 assemblies containing 184kg of plutonium. Unit 4 shut down due to an electrical failure three days after start up, while unit 3 was forced to shut down on March 10thfollowing a court order. Both reactors remain shut down and are subject of a court injunction preventing operation issued by the Otsu district court, Shiga prefecture on March 9th. They are expected to be non operational for many months. Of the 26 reactors both approved and still under review by the Nuclear Regulation Authority (NRA), Ikata-3, Genkai-3 and Tomari-3 are all intended to operate with plutonium MOX fuel.

“The United States has helped create the global plutonium crisis by approving Japan’s program over decades. Dumping hundreds of kilograms of plutonium in the United States only creates the illusion that something is being done – in reality it solves nothing. With the nuclear reactor program in Japan in disarray, with no credible program for either restarting most reactors or using large amounts of this plutonium, if ever there was a time to abandon its current doomed nuclear energy policy, it is now. The U.S.-Japan Nuclear Cooperation Agreement, the basis for Japan accumulating vast stocks of weapons material, is up for re-negotiation in 2018 – approval for Japan to continue acquiring plutonium must be terminated,”said Tom Clements of Savannah River Site Watch.

The Department of Energy has no plans for final disposal of the Japanese plutonium, which will be added to the existing stockpile of 13 tons at the Savannah River Site, demonstrating that the shipment is largely a commercial dumping operation to secure funds for the beleaguered weapons material production site near Aiken, South Carolina, as pointed out by Savannah River Site Watch.

For more detailed analysis of Japan’s plutonium program and future prospects see Nuclear Proliferation in Plain Sight: Japan’s Plutonium Fuel Cycle–A Technical and Economic Failure But a Strategic Success, Japan Focus, March 2016 – apjjf.org/-shaun-burnie–frank-barnaby–tom-clements–aileen-mioko-smith–kendra-ulrich/4860/article.pdf

For further information:

Hideyuki Ban, Co-Director CNIC –+81-3-3357-3800 –www.cnic.jp/english/?p=3182

Aileen Mioko Smith – Executive Director Green Action –+81 90 3620 9251 –greenaction-japan.org/en/

Tom Clements – Director Savannah River Site Watch -+1 803 240 7268 –www.srswatch.org

Martin Forwood – CORE -+44 1229 716523 –corecumbria.co.uk

Shaun Burnie – Greenpeace Germany –+81 80 5088 3351 –www.greenpeace.org/japan/ja/campaign/energy-en/

Notes

1 – The five organizations are: Citizens Nuclear Information Center, Japan, Green Action, Kyoto, Savannah River Site Watch, CORE, UK, and Greenpeace. The Pacific Egret and its escort ship, Pacific Heron, lightly armed UK flagged vessels arrived in Kobe port from Barrow-in-Furness, England on March 4th. The Egret and Heron after departing Japan today will sail together most likely through the South Pacific to the east coast of the United States, with arrival expected in early May. The U.S. National Nuclear Security Administration’s Office of Material Management and Minimization (M3), formerly known as the Global Threat Reduction Initiative (GTRI), describes itself as a part of the U.S. national security strategy of preventing the acquisition of nuclear materials for use in weapons of mass destruction (WMDs) and other acts of terrorism. The M3 mission is to reduce vulnerable nuclear materials located primarily at civilian sites worldwide, and in the case of Japan the NNSA identified gap nuclear material (plutonium), which presents a potential threat to nonproliferation goals and may not have adequately safe and secure management options – see Environmental Assessment For Gap Material Plutonium – Transport, Receipt, And Processing, DOE/EA-2024 December 2015, energy.gov/sites/prod/files/2015/12/f27/EA-2024-FEA-2015.pdf

2 – Global Fissile Material Report 2015 – Nuclear Weapon and Fissile Material Stockpiles and Production

Eighth annual report of the International Panel on Fissile Materials, see fissilematerials.org/library/gfmr15.pdf

3 – During the March 2014 Hague Nuclear Security Summit, Prime Minister Abe and President Obama “pledged to remove and dispose of all highly-enriched uranium (HEU) and separated plutonium from the Fast Critical Assembly (FCA) at the Japan Atomic Energy Agency (JAEA) in Japan”. Their pledge involved 331kg of plutonium. The 2016 summit from March 31st – April 2nd 2016 in Washington DC, will be the last. See nis2016.orgm/articles/SB10001424052970203658804576638392537430156

Secret Plutonium Shipment Exposes Failure of Non Proliferation and Security Policy in Advance of Nuclear Security Summit and the Threat from Japanese Stockpiling Program
Armed British transport ships expected to arrive Tokai port Sunday

March 18th 2016  Tokyo…A shipment of weapons-grade plutonium scheduled to depart the port of Tokai, Ibaraki prefecture this coming weekend highlights the failure, but also the proliferation risks, of the current Japanese nuclear policy, a coalition of five non-governmental organizations warned today. A cargo of 331kg of plutonium will be loaded on to the Pacific Egret, an armed British nuclear transport ship, prior to departure under armed escort to the United States. It will be the largest shipment of separated plutonium since 1.8 tons of plutonium was delivered to Japan by controversial Akatsuki-maru in 1992. The two month voyage to the Joint Base Charleston-Weapons Station will then see the plutonium dumped at the Department of Energy Savannah River Site (SRS) in South Carolina.(1) The U.S. National Nuclear Security Administration, which is responsible for the shipment, has identified that storage in Japan poses a security risk justifying its removal.(2)
Citizen Nuclear Information Center (Japan); Green Action (Japan); Savannah River Site Watch (U.S.); CORE (England), and Greenpeace, condemn the shipment as a dangerous distraction from the major problem in Japan which is its overall nuclear energy policy, where over 9 tons of plutonium remains stockpiled and there are  plans to produce many tons more during the coming decade. The representatives of the five organizations have worked together over the past quarter century against Japan`s plutonium and nuclear fuel cycle program.

Two-hundred and thirty six kilograms of the Tokai plutonium was supplied to Japan from the UK, with 2 kilograms from France and the remainder from the U.S. for neutronic testing purposes at the Japan Atomic Energy Agency Fast Critical Assembly facility at Tokai-mura in Ibaraki. The facility has been used as a basis for Japan`s failed fast breeder reactor program, in particular the MONJU reactor. For more than five decades, Japanese nuclear policy has been based on the production and use of plutonium as a nuclear fuel. However, the failure of both its breeder program and plans to use plutonium as mixed oxide (MOX) fuel in light water reactors, has led to Japan acquiring the largest stockpile of weapons usable plutonium of any non nuclear weapon state.

For the U.S. and Japanese government, the Tokai shipment will be mistakenly hailed as demonstrating their commitment to reducing the threat from fissile materials. Both Prime Minister Abe and President Obama plan to announce the ‘success’ of the removal from Japan, at the fourth Nuclear Security Summit from March 31st-April 1st in Washington, D.C. (3), while Japan will be desperate to avoid any discussion of the proliferation and security threat posed by its plutonium fuel cycle program.
“If 331 kg of plutonium warrants removal from Japan on the grounds of its vulnerability and in the interests of securing nuclear weapons material, then there is no credible justification for Japan’s current program and future plans to increase its plutonium stockpiling. Hailing a shipment of hundreds of kilograms of plutonium as a triumph for nuclear security, while ignoring over 9 tons of the weapons material stockpiled in Japan and in a region of rising tensions, is not just a failure of nuclear non proliferation and security policy but a dangerous delusion,” said Shaun Burnie, senior nuclear specialist at Greenpeace Germany, who is currently in Japan.
In total, Japan`s current stockpile is around 46,700 kg, of which 9,528kg is located in Japan, the remaining balance being stored in France and the UK. The shipment from Tokai port will reduce its stockpile to 9,197 kg. Less than 8kg is sufficient for one nuclear weapon. While the Tokai shipment consists of weapons grade plutonium, and the vast bulk of Japan`s remaining stockpile is designated reactor-grade plutonium, from a security and non proliferation perspective there is no practical distinction and reactor-grade plutonium is capable of being used for the manufacture of nuclear weapons — a point highlighted by Shigeru Ishiba, a former Liberal Democratic Party Defense Minister, when speaking in 2011 described Japan`s nuclear energy program as “a tacit nuclear deterrent”.(4)
Two reactors, Takahama 3 and 4, owned by Kansai Electric, began operation in January and February 2016 loaded with plutonium MOX fuel, with unit 3 operating with 24 assemblies containing 1,088kg of plutonium and unit 4 with 4 assemblies containing 184kg of plutonium. Unit 4 shutdown due to an electrical failure three days after start up, while unit 3 was forced to shutdown on March 10th following a court order. Both reactors remain shutdown and are subject of a court injunction preventing operation issued by the Otsu district court, Shiga prefecture on March 9th. They are expected to be non operational for many months. Of the 26 reactors under review by the Nuclear Regulation Authority (NRA), Ikata-3, Genkai-3 and Tomari-3 are all intended to operate with plutonium MOX fuel.

“On current plans, and if ever the Rokkasho-mura reprocessing plant begins operation, Japan`s program could yield as much as 93,000kg by 2025 – most of which will remain unused. The reactor program in Japan is in crisis with no credible program for either restarting most reactors or using large amounts of this plutonium. If ever there was a time to abandon its current doomed nuclear energy policy, it is now. The Obama administration in its last year has an opportunity to step up and actively reduce the spiraling proliferation dynamic in East Asia – this should be top of the agenda in Washington instead of being ignored. The next step is to challenge the basis of the U.S.-Japan nuclear cooperation agreement which runs to 2018 – approval for Japan to continue acquiring plutonium must be reversed,” said Burnie.

The Department of Energy has no plans for final disposal of the Japanese plutonium, which will be added to the existing stockpile of 13 tons at the SRS, demonstrating that the shipment is largely a commercial dumping operation to secure funds for the beleaguered weapons material production site near Aiken, South Carolina, as pointed out by Savannah River Site Watch.
For more detailed analysis of Japan’s plutonium program and future prospects see Nuclear Proliferation in Plain Sight:Japan’s Plutonium Fuel Cycle–A Technical and Economic Failure But a Strategic Success, Japan Focus, March 2016.

For further information:
Hideyuki Ban, Co-Director CNIC –+81-3-3357-3800-http://www.cnic.jp/english/?p=3182
Aileen Mioko Smith – Executive Director Green Action –+81 90 3620 9251–http://greenaction-japan.org/en/
Tom Clements – Director Savannah River Site Watch -+1 803 240 7268-http://www.srswatch.org
Martin Forwood – CORE -+44 1229 716523 –http://corecumbria.co.uk
Shaun Burnie – Greenpeace Germany –+81 80 5088 335
http://www.greenpeace.org/japan/ja/campaign/energy-en/

Notes
1 – The Pacific Egret and its escort ship Pacific Heron are lightly armed UK flagged vessels and arrived in Kobe port from Barrow-in-Furness, England on March 4th. The Egret docked in Tokai for pre-transport logistics last week. Both ships after departing Tokai port will sail together most likely through the South Pacific to the east coast of the United States.
2- The U.S. National Nuclear Security Administration’s Office of Material Management and Minimization (M3), formerly known as the Global Threat Reduction Initiative (GTRI), describes itself as a part of the U.S. national security strategy of preventing the acquisition of nuclear materials for use in weapons of mass destruction (WMDs) and other acts of terrorism. The M3 mission is to reduce vulnerable nuclear materials located primarily at civilian sites worldwide, and in the case of Japan the NNSA identified gap nuclear material (plutonium), which presents a potential threat to nonproliferation goals and may not have adequately safe and secure management options – see Environmental Assessment For Gap Material Plutonium – Transport, Receipt, And Processing, DOE/EA-2024 December 2015, http://energy.gov/sites/prod/files/2015/12/f27/EA-2024-FEA-2015.pdf
3 – During the March 2014 Hague Nuclear Security Summit, Prime Minister Abe and President Obama “pledged to remove and dispose of all highly-enriched uranium (HEU) and separated plutonium from the Fast Critical Assembly (FCA) at the Japan Atomic Energy Agency (JAEA) in Japan”. Their pledge involved 331kg of plutonium. The 2016 summit will be the last. See http://nis2016.org
4- “In Japan, Provocative Case for Staying Nuclear — Some Say Bombs’ Potential as Deterrent Argues for Keeping Power Plants Online”, Wall Street Journal, October 28, 2011, http://www.wsj.com/articles/SB10001424052970203658804576638392537430156

Download:Imminent Plutonium Shipment Exposes Failure of Non Proliferation, Threat of Plutonium Stockpiling (PDF)

Lessons of the Fukushima Nuclear Power Plant Have Not Been Learned
We Strongly Oppose the Restart of the Takahama Nuclear Power Plant Unit 3 Located in the Seismically Active Wakasa Bay Region of Japan

29 January 2016
Kyoto, Japan
For immediate release. Contact: Aileen Mioko Smith +81-90-3620-9251
(amsmith@greenaction-japan.org)

There are fifteen nuclear reactors located in the Wakasa Bay region of Fukui prefecture, one of the most seismically active areas among nuclear power plant sites in this earthquakeridden archipelago of Japan.

Takahama Unit 3 is being allowed to restart by Japan’s Nuclear Regulation Authority (NRA) even though it does not meet NRA stardards for evaluating seismic motion, whereby the variations from the average recorded earthquake motions of past earthquakes must be taken into consideration. The plant is not safe from earthquakes.
The NRA also approved the plant’s restart even though Kansai Electric, the owner operator, does not have plans for constructing a seismic isolation building which would act as a control center in the event of a serious accident involving an earthquake. Such a building existed at Fukushima Daiichi and is considered by Tepco to have been the lifeline for not worsening the accident.

Clearly, the lessons of the March 11, 2011’s Fukushima Daiichi accident have not been learned by the regulator and Kansai Electric.

Kenichi Oshima of Ritsumeikan University rightly points out that Kansai Electric will only break even if four reactors at Takahama and Ohi all operate with regularity. Electric prices will only come down if the very old Takahama Units 1 and 2 are allowed to operate. In other words, restarting Takahama Units 3 and 4 will actually only increase electricity rates.

On 21 January, a coalition of NGOs including Green Action met with NRA officials who confirmed that only spot checks had been undertaken to confirm regulatory compliance of Takahama Unit 3 electric cabling. This means the NRA does not know if there is adequate separation between the cables needed for back-up systems and other cables, a vital requirement for meeting the fire code. Only Takahama Units 3 and 4 and the alreadyoperating two Sendai reactors are exempt from undertaking comprehensive examinations of the electric cables. No valid explanation has been given by the NRA on why these four reactors are exempt. Lack of compliance could lead to a catastrophic accident.

Freedom of information disclosure has revealed that MOX (mixed plutonium uranium oxide) fuel to be used at Takahama Unit 3 (and subsequently other nuclear power plants) is of markedly inferior quality compared to uranium fuel normally used in reactors. The NRA has not re-assessed the MOX fuel standards created by the now-defunct NISA (the former regulator) which were created before the Fukushima Daiichi accident. MOX fuel is known to be less safe than uranium fuel. Here again, neiher the NRA nor the utilities have learned the lessons of Fukushima.

Nearly 180,000 people must evacuate from Fukui and Kyoto prefectures in the event of a serious accident at the Takahama plant. Small children near the plant remain unprotected.
Their parents must battle through congested traffic just to get potassium iodine pills. Green Action as part of a coalition of citizens in the Kansai region has made over 60 visits to cities evacuating and others which are evacuation points. We have learned there is no viable evacuation plan in place for the tens of thousands of people with special needs–inpatients and outpatient at hospitals and various facilities, those in day care, and those with handicaps living at home. When others can flee, there are no vehicles to transport these people nor medical care prepared if and when they reach the evacuation facilities. Restart of the Takahama plant is a human rights injustice toward children and those with handicaps.

As for evacuation drills, Kansai Electric confirmed back in 2014 that Fukui Prefecture asked for the accident scenario to be sent from the utility to be for a small enough accident so the prefecture’s evacuation drills could cope. All drills in the Fukui and northern Kyoto Prefecture region have been grossly inadequate. There is no consideration that there could be heavy snow or an earthquake.

The government and Kansai Electric has ignored repeated calls by the 8 prefectures and 4 cities of the Union of Kansai Governments which state since they are in the region that can be affected by a serious accident, therefore they should have consent rights when it comes to reactor restart issues.

“Restart of Takahama violates the NRA seismic safety standard. Operating a Japanese reactor without a seismic isolation emergency control room is negligence in the extreme. Tens of thousands of children including babies and those with special needs not being protected under current emergency management planning is an outright human rights violation.” said Aileen Mioko Smith, executive director of Green Action based in Kyoto.

Download: Lessons of the Fukushima Nuclear Power Plant Have Not Been Learned We Strongly Oppose the Restart of the Takahama Nuclear Power Plant Unit 3 Located in the Seismically Active Wakasa Bay Region of Japan (PDF)

Japan’s Nuclear Regulator:
We don’t know if Takahama Reactor has significant fire safety violation
Reactor due to start January 29th

January 26, 2016, Tokyo –Greenpeace and Green Action today condemned the failure of the NRA to verify that critically important electric cabling inside the Takahama reactors meet the agency’s own fire safety regulations. At a meeting held in the National Diet on January 21st, representatives of the NRA admitted under questioning from citizens and NGOs, that they simply do not know whether Takahama 3&4 reactors are in violation.(1)

Kansai Electric plans to restart Takahama 3, located on Wakasa Bay in Fukui prefecture, on January 29th.

The safety-related cabling in a reactor must be separated to ensure that in the event of fire or other singular incident, critical redundant safety systems and power supplies are not lost. If the cabling is not adequately separated – by physical distance, cabling trays, and fire barriers in accordance with regulations– this would pose a significant risk to reactor safety – including the risk of a losing cooling systems which, in worst case, could lead to a core meltdown.

The NRA has ordered all nuclear plant operators in Japan to provide reports on the status of cable separation at their reactors before the end of March – except for Takahama and Sendai.(2)

“This latest example of complete negligence by the NRA just days before the Takahama unit 3 reactor is scheduled to restart is wholly unacceptable. It’s like allowing an airliner packed with passengers to take off without knowing whether the fuel lines and the control wires are crossed. If an accident happens, the power and backup safety systems could be taken out at once, and the plane is going down. While the NRA may be content to allow the Takahama safety cables to remain in the black box, the public deserves to know what’s inside before their lives and livelihoods are put at significant risk,” said Kendra Ulrich, Senior Global Energy Campaigner, Greenpeace Japan.

In March 2015, the Nuclear Regulatory Agency provided an assurance of safety to the Union of Kansai Governments for the Takahama reactors. It told the Union that the NRA had confirmed that the utility’s policy for the reactors would ensure compliance with nuclear safety regulations. This includes the issue of electric safety cabling.(5) The Union, made up of eight prefectural governments and four cities, has challenged the restart process for the Takahama reactors; it represents 22 million people living in the greater Kansai region. They provided the same assurance to local governments in the Union, as well as Fukui prefecture.

“The fact the Japanese government, in its efforts to neutralise the mounting opposition to restart from the Union Kansai Governments, told them last March that the plant complied with their regulations shows both the level of incompetence and deception at the heart of Japan’s nuclear industry,” said Aileen Mioko Smith, Director, Green Action, Kyoto. “The NRA are clearly not being honest or transparent about what they know about this issue. When completing their overall assessment of the safety design of the Takahama reactors in August last year, did they not verify compliance with their regulations during this process? If not, why not?” said Smith.

For a detailed briefing on the Nuclear Safety and Reactor Cable Separation: http://bit.ly/1K7EhAh

Kendra Ulrich, Senior Global Energy Campaigner, Greenpeace Japan – +81-80-5088-3351
Kendra.ulrich@greenpeace.org

Aileen Mioko Smith, Director, Green Action, Kyoto – +81-90-3620-9251
amsmith@greenaction-japan.org

Notes:

1 – A coalition of NGO’s have petitioned the NRA on a ranges of safety issues at Takahama, including safety cabling. There are 14 petitioners including: Green Action, Friends of the Earth, Greenpeace Japan, and numerous local NGOs.

2 – The NRA admitted in December that it knew of at least six nuclear plants in Japan had a safety cable problems that meant they were in non compliance with their regulations – all seven reactors at Kashiwazaki-Kariwa; units 3 and 4 at Fukushima Daiini; unit 4 at Hamaoka, and Shika unit 1, Onagawa unit 3 and Higashi-dori unit 1 – for a total of 13 reactors.

3 – See Protection against Internal Fires and Explosions in the Design of Nuclear Power Plants, IAEA Safety Series, Pages 46-48, see http://wwwpub.iaea.org/MTCD/publications/PDF/Pub1186_web.pdf

4 – Fire Protection For Nuclear Power, October 2009 Revision 2, U.S. NRC Regulatory Guide 1.189 (Draft was issued as DG-1214, dated April 2009) see http://pbadupws.nrc.gov/docs/ML0925/ML092580550.pdf

5 – NRA to Union of Kansai Governments – March 27 2015, see http://www.kouiki-kansai.jp/data_upload/1427449594.pdf

–Background Briefing–
Why the Sendai Nuclear Power Plant Should Not be Operated

[Revised]
11 August 2015 (1:00pm)
For immediate release from Sendai nuclear power plant gate, Kagoshima Prefecture.

Aileen Mioko Smith
Executive Director, Green Action (Japan)
Contact: amsmith@gol.com / +81-90-3620-9251

Lack of Consideration of Potential Earthquakes Damage—In Violation of NRA Regulations
Seismologist and emeritus professor of Kobe University, Member of the Diet NAIIC (National Diet of Japan Fukushima Nuclear Accident Independent Investigation Commission), has stated that the Nuclear Regulation Authority’s Review of the Sendai Nuclear Power Plant is “careless and faulty and will invite a second Genpatsu-Shinsai (Earthquake-Nuclear Combined Disaster)”.

Ishibashi points out that the NRA’s Review violates the legal rules of the New Regulatory Requirements by approving Kyushu Electric’s restart application which neglected to fulfill the requirement that, when establishing the Standards Seismic Motion for the plant (how much earthquake motion the plant must able to withstand), all 3 types of earthquakes (1. inland crustal earthquakes, 2. interplate earthquakes and 3. oceanic intraplate earthquakes) must be considered いｎ evaluating “earthquake ground motion formulated with a hypocenter specified for each site”. For the selection of the “Earthquakes for Investigation”, Kyushu Electric ignored type 2 and 3 earthquakes, arguing that the largest earthquakes in the past in these two categories had been sufficiently distant from the Sendai Nuclear Power Plant site. The NRA approved Kyushu Electric’s application with only the type 1 earthquake considered.

The legal requirement, however, is that not only historic but future potentially significant earthquakes must be considered. Kyushu Electric did not meet this requirement when it ignored the maximum possible Nankai trough earthquake that could occur in the future (magnitude 9). The value of seismic intensity around the Sendai Plant for this type 2 earthquake as evaluated by the Study Team in the Cabinet Office is a level of intensity that would have had to be considered under the Review.

Moreover, according to the graph presented by Kyushu Electric itself, the seismic intensity of the 1909 Western Miyazaki Prefecture earthquake (type 3 earthquake) would come to magnitude 5 Upper (5+) at the Sendai Nuclear Power Plant. But, Kyushu Electric did not include this type of earthquake for consideration in its restart application.

Ishibashi notes that, “J-SHIS, the Japan Seismic Hazard Information Station, which is made public by the National Research Institute for Earth Science and Disaster Prevention), shows that both type-2 and type-3 earthquakes could register 5 Upper (5+) or greater seismic intensity around the Sendai Nuclear Power Plant.”

According to Dr. Ishibashi, what is of serious concern is that Shunichi Tanaka, the chair of the NRA appears to not grasp that NRA has violated its own regulations, and the Nuclear Regulatory Agency officials in charge of Safety Management for Earthquakes and Tsunamis have evaded answering media questions on this issue. (NRA chair’s response to media questions about Dr. Ishibashi’s concerns was, “Dr. Ishibashi may have his own views.” The NRA’s response to the public comment process for the Sendai restart Review on this issue was inadequate and did not address these violations even though they were pointed out during the process.

Emergency Evacuation Planning for Accidents is Inadequate or Non-Existent
Although the NRA states that evacuation plans (public emergency preparedness plans) are not a requirement for restarting reactors, Shunichi Tanaka is on record stating that evacuation and the regulatory requirements for restart are “two wheels on the vehicle.”

Kagoshima’s emergency management measure plans are grossly incomplete and inadequate. All Japanese nuclear emergency management plans including Kagoshima’s do not take into consideration multiple problems, such as a earthquake occurring at the same time, i.e. an earthquake causing a nuclear accident. (For regions with heavy snow in the winter, the climate factor not being taken into consideration is a major issue.)

The protection/evacuation of children, pregnant women, and evacuation of people with special needs are to be given priority, but the actual situation is the reverse with these members of the public receiving less protection than the rest of the public.

For the region surrounding the Sendai nuclear power plant, in spite of the post-Fukushima era, potassium iodide has not been distributed to children 3 years and younger even within the 5km radius of the Sendai nuclear power plant. (After citizen organizations pointed out this problem, a newspaper article ran on August 7th in the Minami Nihon Shimbun reporting that the prefecture was not considering distributing potassium iodide to elementary schools and children’s day care facilities.) Currently, children under three are to receive the potassium iodide after they evacuate. (The effectiveness of potassium iodide is reduced with time after radiation exposure.)

On 27 August, when citizen organizations met with Kagoshima Prefecture’s Public Health and Welfare Department, Pharmaceutical Administration Section, the responsible officials thought that all evacuation would take place without any radiation exposure. The officials were unaware that between the 5km and 30km zone, the government standards for radiation measurement to activate evacuation was 500 microsieverts/hour recorded on two consecutive days. Kagoshima plans for beyond 5 kilometers is to have evacuees receive potassium iodide pills at the screening locations or the locations where they have evacuated. It will take many hours to evacuate, so this is too late.

Evacuation within the 5km radius is to take place before radiation is released to the environment. It is questionable that this is feasible since the official worst case scenario has the reactor fuel starting to melt 20 minutes after start of the accident. No evacuation plans have been undertaken around the Sendai plant or any other nuclear power plant using this scenario.

Governor Yuichiro Ito is on record stating that the prefecture will not create plans in advance for evacuation of people with special needs (people in facilities such as those for disabled and senior citizens) in the zone of 10km to 30km radius because “It’s not realistic. It’s impossible anyway to have a plan that will work”. There are 272 such facilities in Kagoshima in the 10km to 30km zone. There will be no plans made in advance. Kagoshima has opted for a “ flexible plan that will be implemented according to the situation at hand.”

The national government is on record asking for evacuation plans to be put in place for those in medical and welfare facilities. Nowhere in Japan has this been completed. Some prefectures have matched facilities: which facilities evacuate to which other facilities, but none have effective plans for transporting these people with special needs (people with physical and mental health problems). Kagoshima’s plans are especially poor with only a computer data input system for the 10km to 30km zone and no decision made as to who will be responsible for assessing the situation, deciding where people will be evacuated, and organize the means of transport in the event of an accident. Those with special needs residing at home or in day care are not even included under the data input system. In spite of this the national government agreed that Kagoshima’s emergency management plans were adequate.

Under Kagoshima’s plan, those members of the public without means of transportation are to be evacuated by buses, but this is only for the some 2000 people living within the 5 kilometer zone. There is no plan for those outside this radius except for making plans with neighbors with cars.

The evacuation of those within 5km of the plant is to be undertaken by bus companies with operations within the 30 kilometer zone. However, when Green Action interviewed the bus company union of this region on 24 July , we learned that it would take a minimum of 2 to 3 hours before the buses could arrive at the site to transport the individuals, it is unclear how the people would get to the bus stops, unclear how many buses could be procured in an emergency, and, since bus companies could not force drivers to enter the zone if radiation releases had begun, it is unclear if the buses could be driven by the drivers. The union officials also made clear that bus drivers could not unilaterally decide to expose the bus vehicles to radiation since the vehicles are owned by the bus companies.

The NRA is now deliberating establishment of allowable radiation exposure standards for local/regional civil servants (there is already a standard for national government civil servants), bus and truck drivers, etc., raising permissible exposure from the general public’s permissible exposure of 1mSV/year from manmade sources. It is expected that the standard will be decided by the end of the calendar year. The Kagoshima Bus Association has signed a contract with Kagoshima Prefecture to cooperate with emergency evacuation in the event of a nuclear accident at the Sendai nuclear power plant. However, the Association is on record stating that this contract would need to be negotiated from scratch if permissible limits for bus drivers are to be increased from the current 1mSv/year.

Much of the evacuation plans of towns and cities within the 30km zone is to evacuation points heading downwind from the Sendai nuclear power plant. The main routes of evacuation is National Road Number 3. Part of the route is in a natural hazard zone prone to flooding. There are 14 areas within the towns and cities of the 30km radius evacuation zone (total population 1,375) that are designated as “isolated hamlets” by government authorities, prone to difficulties in evacuating.

No Rights to Approve/Disapprove Restart. No explanation meetings by Kyushu Electric and/or the National Government
(For more information about this issue, please contact the author.)
The “gentleman’s agreement” for the right to say yes/no to restart has only been granted to the local and prefecture authorities where the nuclear power plant is located. This is also the case nationwide. However, at the same time, it is acknowledged that in the event of a serious nuclear power accident, areas within the UPZ zone (30 kilometers) may be contaminated with radiation, and local authorities in these areas are required to establish emergency evacuation plans.

The city legislatures of Aira, Ichikikushikino, Hioki, and Akune within the Sendai plant UPZ (30 kim) zone have all issued statements/petitions seeking that public explanation meetings be undertaken about restart and evacuation issues before the plant is restarted. To date, Kyushu Electric has refused to undertake such public meetings and Kagoshima Prefecture will not ask the national government to come to Kagoshima to explain these issues to its citizens. The only meeting being considered is for the national government to come to Kagoshima to explain “the necessity of nuclear power.”

On 24 June 2014, citizens of Ichikikushikino City, located within the 30km evacuation zone of the Sendai nuclear power plant, submitted 15,464 signatures of its citizens (more than half the population of the city) to city officials. The petition opposed restart of the Sendai plant without a viable evacuation plan for its citizens. The petition was later submitted to Kagoshima Prefecture as well. The authorities have not acted on this petition.

NRA in Violation of its own Ageing Management Guide
NRA’s Ageing Reactor Management Implementation Guide states in section 3.2 “Development and Revision of the Long-Term Maintenance Management Policy” that, “The implementation period for the long-term maintenance management policy developed under Commercial Reactor Regulation, Article 82, Section 1, shall commence from the first day after the 30th year of start of operation.”
This implementation pertains to ageing nuclear reactors in outage / cold shutdown as well as reactors that are fueled and producing electricity.
The NRA, however, neglected to apply this for the Sendai nuclear power plant Unit 1 which reached its 30th year of operation on 3 July 2014.
Instead, the NRA announced on 2 July 2014, without giving a reason why it could bend its own rules, that approval and implementation of the policy would be extended. The gap occurred, among other things, because new post-Fukushima regulatory standards had not been put in place in time to implement a plan under that new regime. It is negligent of the NRA to have allowed a gap in safety requirements between NISA and NRA oversight regimes. During NISA, never had a plant’s ageing management policy not been approved before the 30th year. In comparison, no plan was in place even after Sendai Unit 1 went into its 32nd year.
On 3 July 2015, Kyushu Electric submitted its revised application for its long-term maintenance management policy (which took into consideration the basic seismic motion’s upward revision.)
The NRA had first stated that restart approval for the Sendai nuclear power plant and NRA’s approval and Kyushu Electric’s implementation of Sendai’s ageing reactor management policy beyond the 30th year were separate issues and the plan did not have to be in place when restart was approved. However, probably due to citizen organizations raising concern about this NRA position and media inquiries about this, on July 13th the NRA began examining Kyushu Electric’s application in order to approve this policy. The NRA had to examine the plan under the new, revised basic seismic motion of the plant, now raised to 620 gals. This should have be a complicated matter. However, the NRA approved the policy on August 5th.
It had became clear by July 13th that there were ageing reactor concerns at the Sendai plant. The seismic resistance analysis for the main feed water pipe system showed reduction in the pipe wall thickness (extrapolation of corrosion rates to 40 years) of 0.991 compared to the maximum allowable figure of 1.
On August 4th at a Diet office building meeting organized by citizens (including Green Action) with former prime minister Naoto KAN arranging the meeting and attending, Nuclear Regulatory Agency officials stated that they did not have any additional measurement figures concerning this important item, nor did the NRA undertake any extensive physical examination of the plant when it undertook its one on site investigation, nor was it intending to undertake any further on site investigations when deliberating the application. Moreover, when citizens pointed out that the NRA had violated its own “NRA Ageing Reactor Management Implementation Guide” when it allowed Kyushu Electric to go beyond its 30th year without implementing the long-term maintenance management policy for the Sendai plant, the Nuclear Regulatory Agency official stated, “the NRA Guide does not have to be adhered to.”
Citizens are concerned that there is uncertainty in this estimation and that reduction in the pipe wall thickness could result in pipe rupture in the event of a large earthquake. Citizens demanded that the NRA examine the issue further and establish an outside expert committee to review Kyushu Electric’s ageing reactor maintenance policy. As mentioned above, however, the NRA gave its final approval to Kyushu Electric’s policy the next day, August 5th.
On August 7th, 1973 citizens filed an administrative complaint to the NRA, protesting NRA’s approval of Kyushu Electric’s revised long-term maintenance management policy application. The complain stated that there was no indication that the NRA had, during the review of the application, looked into whether the 0.991 figure noted above was the maximum figure this equipment and others around it had registered, nor whether deviation and uncertainty had been taken into consideration. The complaint stated the NRA had not increased the number of equipment to be examined, or undertaking a detailed examination of the area where this finding (0.991) had been registered, nor obtain the opinion of outside experts. The complaint lists other items: the fact the implementation delay violated NRA’s own standards, and the fact the Ss-2 seismic motion review which had been added on in the revised application had not been undertaken although the NRA had said it would undertake this review.

Volcanoes: the NRA is Violating its Own Volcano Guide when it Approved Sendai Restart
Japan is a land of volcanoes. Kagoshima Prefecture is an active volcano area. Kyushu Electric admits that in the past there is a possibility that pyroclastic flow from a caldera eruption reached the location where the Sendai nuclear power plant is now located. Since that is the case, the NRA Volcano Guide stipulates that surveillance of volcanic activity (monitoring) be undertaken and if and when precursor activity of a caldera explosion is observed, that the reactor site be shut down and a plan created to remove all the fuel before such an eruption takes place.

The NRA’s Volcano Guide is not as stringent as the IAEA, nor has the NRA even followed its own Volcano Guide. (More details to follow.)

Download: Background Briefing: Why the Sendai Nuclear Power Plant Should Not be Operated (PDF)