Green Action Japan

Pre-Ruling Background Briefing on Sendai Nuclear Power Plant Units 1 and 2 Injunction Lawsuit

For immediate release: 22 April 2015 00:05 JST (Kyoto City/Kagoshima City)

For further information contact: Aileen Mioko Smith, Executive Director, Green Action
+81-90-3620-9251
(on site in Kagoshima City)

A 3-member panel of judges headed by chief judge Maeda will be handing down a decision at 10:00am today (22 April) at the Kagoshima District Court regarding the operation of the Sendai Nuclear Power Plant Units 1 and 2.
FFTV live from 10am: http://twitcasting.tv/fukuroufoe_tv

Background:
There are 5 super volcanoes (calderas) within a 160km of the Sendai Nuclear Power Plant. On 10 September 2014, Japan’s Nuclear Regulation Authority (NRA) granted permission of a change in reactor installation i.e. that the application for Sendai Nuclear Power Station Units 1 and 2 owned and operated by Kyushu Electric met post-Fukushima accident nuclear regulatory standards. The NRA granted permission for the Construction Plan on 18 March 2015. The last step in the permission process, the Operational Safety Program, remains to be completed.

Main issues: Earthquakes, volcanoes, and emergency evacuation plans

Earthquakes
Plaintiffs:
Since 2005, measurements which surpassed the reactors’ basic earthquake ground motion have occurred 5 times at a total of 4 reactor sites in Japan.

The basic earthquake ground motion estimation, calculated from the length of faults and other factors, is based on the average picture of past earthquakes i.e. data that vary from the average are not taken into consideration. Because of this, the result becomes significantly underestimated.

Basic earthquake ground motion is also based on only a limited amount of data.

Because earthquakes greater than estimated could occur at the Sendai Units 1 and 2 reactor sites, the current basic earthquake ground motion of 620 gal is too low. Because of this, there is a danger of reactor core meltdown.

The defendant Kyushu Electric:
It is not just the average picture of past earthquakes, but also special characteristics of the area which were also included in the consideration of basic earthquake ground motion for the reactor site. The possibility that the area near Sendai nuclear power plant will have an earthquake that would result in the basic earthquake ground motion being exceeded is extremely low. Even if exceeded, there is a margin of safety with the facility’s seismic resistance design. Moreover, the reactor is far from the epicenter of the Nankai Trough earthquake.

Volcanoes
Plaintiffs:
The reactors do not meet the Nuclear Regulation Authority’s Volcano Guide which states that the probability of pyroclastic flow reaching the reactor site during operation of the site (during the time nuclear fuel remains at the site) as a result of a huge (caldera) volcanic eruption must be extremely low. There are no grounds for Kyushu Electric’s assertion that the cycle for a disastrous volcano eruption is 90,000 years. The Sendai plant is surrounded by 5 calderas (super volcanoes: ring of volcanoes). Moreover, the ability to predict eruptions is known to be inadequate. This has been substantiated by volcanologists. There are no grounds for Kyushu Electric’s assertion that the probability of a caldera eruption is low.

Under the NRA guide, Kyushu Electric must meet the NRA’s Volcano Guide which requires that the utility monitor the Aira caldera, the ring of volcanoes closest to the plant, and be able to remove all the nuclear fuel from the reactor site before any volcanic eruption that would result in pyroclastic flow to the site. Kyushu Electric’s application does neither (does not show that monitoring the Aira caldera would make it possible to predict an eruption, and, there is no concrete plan which confirms that the nuclear fuel can be removed from the site before an eruption). This constitutes a violation of the NRA Volcano Guide.

The NRA’s Volcano Guide is considerably more lax than the IAEA Volcano Guide.

Kyushu Electric has also under-estimated the potential risk of volcanic ash to the facility.

The defendant Kyushu Electric:
Southern Kyushu’s cycle of huge (caldera) eruptions is very long, approximately 90,000 years. The most recent eruption was approximately 30,000 years ago. Thus the chances of a huge (caldera) eruption occurring are very low.

Eruptions can be predicted by monitoring, such as monitoring for changes in the ground. There is about 10 years leeway from the time activity is seen and an eruption. There is enough time to remove the nuclear fuel from the site after shutting the reactors down.

Emergency Evacuation Plans
Plaintiffs:
The plans do not take wind direction into consideration. Evacuation of citizens from within the 30km zone will take longer than 30 minutes. There is a danger that citizens will be exposed to radiation before they can evacuate.

There is insufficient means of transportation (buses) for people with special needs. The plans for evacuation are not realistic.

The defendant Kyushu Electric:
Evacuation will be undertaken in stages in relation to the developing situation and the distances from the site, and buses can be procured. If it becomes difficult to deal with the situation, then there will be nationwide organization to support the effort. The current evacuation plans are rational in content and the government’s emergency planning committee has approved the plan. The local authorities have made concrete emergency plans.

Download: Pre-Ruling Background Briefing on Sendai Nuclear Power Plant Units 1 and 2 Injunction Lawsuit (PDF)

Takahama Nuclear Power Plant Units 3 and 4 Injunction Ruling
-This is a pre-ruling background briefing-

For immediate release: 14 April 2015 13:00 (Kyoto City/Fukui City)
For further information contact: Aileen Mioko Smith, Executive Director, Green Action
+81-90-3620-9251
(on site at the Fukui District Court, Fukui City, Fukui Prefecture)

A 3-judge panel headed by ruling judge Hideaki Higuchi will be handing down a decision at 14:00 today at the Fukui District Court regarding the operation of the Takahama Nuclear Power Plant Units 3 and 4.

IWJ (Independent Web Journal) will be U-streaming the event from14:00 (Fukui Channel 1)
http://adieunpp.com/karisasitome.html

The Wakasa Bay region where Takahama Units 3 and 4 are located:
On 23 May 2011, the National Diet’s Upper House committee with oversight on government administration summoned 4 expert witnesses. Amongst them was Dr. Katsuhiko Ishibashi , seismologist and emeritus professor of Kobe University. When asked which nuclear power plant(s) held the highest risk next to the Hamaoka nuclear power plant (located in Shizuoka Prefecture), Dr. Ishibashi’s replied, “The entire Wakasa Bay area.”

There are 15 nuclear power reactors located along Wakasa Bay. Takahama Units 3 and 4, owned and operated by Kansai Electric, have received initial permission to restart by the Nuclear Regulation Authority (NRA) in a three-step process, and lead the restart in the Wakasa Bay area. Kansai Electric owns 11 of these reactors. Dr. Ishibashi stated, “Although such earthquakes as the Kambun Earthquake (1662) and Fukui Earthquake (1948) have occurred, this area has been a silent region. It is unmistakably an extremely dangerous area.”

Quote from ruling judge Hideaki Higuchi:
“When you alter an elevator from 12 -person occupancy to16-person occupancy, can safety be secured without radical reconstruction?

Main issues of the injunction lawsuit:
At the first court hearing of the case, Judge Higuchi (the court) requested both defendant and plaintiffs to provide clarification/proof on the following points. It is expected that the verdict will be along the lines of judging these submissions.

Clarification/Proof Requested by the Court:

• What seismic motion resistance construction was undertaken in order to address the basic earthquake ground motion being raised from 370 gal to 550 gal (this was the increase in requirement for Takahama Units 3 and 4, identical for Ohi Units 3 and 4.)
• What seismic motion resistance construction was undertaken, is scheduled to be undertaken, and the progress of this construction, in order to address the basic earthquake ground motion being raised from 550 gal to 700 gal (this is the increase in requirement for Takahama Units 3 and 4, identical for Ohi Units 3 and 4.)
• Does the cliff edge shift when raising the basic earthquake ground motion from 550 gal to 700 gal (this is the increase in requirement for Takahama Units 3 and 4, identical for Ohi Units 3 and 4.)
• What is the seismic resistance class level for the measurement equipment of the reactor vessel.
• What are the capability functions of the Seismic Isolation Building and when will the facility be put in place.

Plaintiff and defendant responses to the above issues (in Japanese)
Plaintiff:
http://adieunpp.com/karisasitome/150227junnbi6.pdf
Defendant: (Kansai Electric)
http://adieunpp.com/karisasitome/150309kandsinnkou.pdf

Other issues concerning the Takahama Units 3 and 4 reactors:
On 31 August 2014, Fukui Prefecture undertook an emergency response exercise simulating an accident occurring at the Takahama nuclear power plant. Citizens later asked Kansai Electric about the type of simulation provided for this exercise. Kansai Electric responded in September and again in November 2014 that the scenario provided responded to Fukui Prefecture request of providing a scenario for a level of accident that Fukui Prefecture could cope with because the prefecture would not be able to deal with implementation of an emergency response exercise for an accident that was too serious.

25 December 2014, Union of Kansai Governments, “Proposal Concerning Nuclear Emergency Response Measures” submitted to the Japanese government.
http://www.greenaction-japan.org/internal/141225_Kansai_Union_Proposal_on_nuclear_emergency_response_measures_E_Translation.pdf

Download: Takahama Nuclear Power Plant Units 3 and 4 Injunction Ruling -This is a pre-ruling background briefing- (PDF)

Kansai Electric’s Takahama Units 3 and 4 Restart Review
Enters Public Comment Period

First Use of Plutonium (MOX) Fuel Since Fukushima Accident Moves Ahead Without NRA Review of its Severe Accident Implications

For immediate release: 17 December 2014
Contact: Aileen Mioko Smith +81-90-3620-9251

Japan’s Nuclear Regulation Authority (NRA) today approved the first stage of the review for restart of Kansai Electric’s Takahama Units 3 and 4 located in Fukui Prefecture. If restart is approved, it will be the first reactors to use plutonium (uranium and plutonium mIxed oxide fuel: MOX fuel) since the Fukushima accident.

The Nuclear Regulatory Agency stated today that the approval process for MOX fuel at Takahama had already been completed (before the Fukushima accident) and therefore its use will not come under NRA review. Compared to conventional uranium fuel, MOX fuel lowers the safety margin of reactor operation and causes greater health damage if released to the environment. Since there is no plan for spent MOX fuel, it will remain at the reactor site.

“It is unconscionable that the NRA is not undertaking a safety assessment of MOX fuel use. If the NRA is requiring stricter standards after Fukushima, a reassessment of MOX fuel use must be undertaken. Without this, the NRA has not learnt the lessons of Fukushima, nor can Japan profess that its regulatory safety standards are “’the strictest in the world’ ” said Aileen Mioko Smith, executive director of Green Action based in Kyoto.

The Takahama reactors are unique not only because they are slated to be the first to use MOX fuel since the Fukushima accident, but because they are located quite close to large populations. The center of Kyoto City is located 60 kilometers from the Takahama plant. The population of Kyoto Prefecture within the 30km nuclear accident evacuation area is 128,500 compared to Fukui Prefecture’s 66,900 where the Takahama site is located. The entire cities of Maizuru (89,000) and Miyazu (20,300) in northern Kyoto must flee in case of a serious accident including their city hall administrations. The cultural heritage of Kyoto City is also endangered as well as Kyoto’s tourism industry which suffered economic loss after the Fukushima accident. There are 15 nuclear reactors within a 52-kilometer radius of Kyoto City’s northern city limits.

The NRA, however, refuses to address the holding of public hearing on the Takahama plant restarts in Kyoto Prefecture and states that the prefecture should go and ask Fukui if it wants to hold such meetings.

Current emergency plans to cope with an serious accident at the Takahama site are woefully inadequate including no effective plans for people with special needs, nor a decision as to where people will evacuate to within Kyoto Prefecture (Kyoto City is to accept 65,000 evacuees), and 31% of the evacuation points for Fukui and Kyoto citizens in Hyogo Prefecture do not meet legal requirements. Lake Biwa, the water serving the 14 million people of the Kansai area will be contaminated according to a study undertaken by Shiga Prefecture this year.

The NRA approval process does not include whether evacuation plans are in place to protect citizens.

Kyoto Prefecture has sought to sign a nuclear safety agreement with Kansai Electric since June 2011, but has received no positive response.

Kansai Electric’s fleet of reactors is aging, with 3 reactors over 40 years old and 4 others approaching 40 years. Although Kepco reported financial results in the black this year and there is sufficient electricity in the utility’s area, the company is pushing to restart reactors.

A public comment process will be undertaken of the NRA draft review approval. The deadline is January 16, 2015. After that Kansai Electric must receive approval for its Construction Plan and Operational Safety Program before it can restart the reactors.

There is citizen protest against restart of the Fukui Prefecture reactors. Fukui Prefecture citizens are petitioning to stop restart of all the nuclear reactors and Kansai area residents are addressing evacuation, seismic, severe accident and other issues.

Download: Kansai Electric’s Takahama Units 3 and 4 Restart Review Enters Public Comment Period (PDF)

Governor of Kagoshima Fails Fukushima Lessons:
ignores science, safety and public opinion
States operation of Sendai Nuclear Power Plant is “Unavoidable”

For immediate release: 7 November 2014
Contact: Aileen Mioko Smith +81-90-3620-9251

Governor Yuichiro Ito of Kagoshima in approving the restart of the two nuclear reactors at Sendai earlier today has failed to understand the lessons of the 2011 Fukushima Daiichi nuclear catastrophe, Green Action stated. The Kagoshima Prefectural Assembly has earlier voted to approve operations of the reactors. In the last week evidence has been made public that the reactor operator and the Nuclear Regulation Authority (NRA) are ignoring volcano risks to Sendai ; that evacuation shelters required in the event of a severe nuclear accident are in violation of the law (revised in April 2014) for emergency evacuation planning. Demands for consultation on restart by citizens throughout Kagoshima have all now been ignored.

“So desperate are Kyushu Electric, the Abe government and the Liberal Democratic Party leadership to restart the Sendai reactors, that they are willing to exert maximum leverage on Kagoshima. The Governor, by stating that restart of Sendai was “unavoidable” has mistakenly chosen, like them, to ignore the evidence of the risks restarting Sendai presents to the lives and livelihoods of the people of not just Kagoshima but a much greater geographical area. The volcano scientists who have stated that predicting eruptions in advance is not possible have spoken clearly based on their decades of experience. Yet, Kyushu Electric, NRA chair Shunichi Tanaka, and the politicians who support them are prepared to disregard these warnings and the concerns of the people of Kagoshima. The Fukushima accident was in part caused by the same arrogant disregard for nuclear safety concerns, and tragically it is being repeated once more. The Kagoshima Governor has failed to learn the lessons of Fukushima and to act to protect the interests of the people of his region,” said Aileen Mioko Smith, executive director of Green Action.

In the last week city officials of Satsumasendai City where the Sendai reactors are located, and Izumi City, Ichikikushikino City, Akune City (all within 30km from the Sendai reactors) and Minamata City in Kumamoto Prefecture where evacuees from Kagoshima are to evacuate have all confirmed to citizens groups that many of their nuclear emergency shelters are vulnerable to the impacts of tsunami’s and storm surges or landslides and that as a result they are required under the law to find safe alternatives. The emergency plans for these communities with hundreds of thousands of people are currently in violation of the Disaster Countermeasures Basic Law.

On 25 September, Kumamoto Prefecture which neighbors Kagoshima and 4 of its local authorities issued a joint petition to the Government to undertake a detailed, careful explanation to Kumamoto citizens and the prefecture regarding the NRA review and Government decisions on the Sendai plant. They also demanded that the Government issue its regulations for radiation exposure/evacuation beyond the 30km limit (the PPA standard) which are yet to be issued and undertake measures including financial measures for these areas. They also demanded that the Government undertake human and financial support for local authorities with citizens evacuating and local authorities accepting evacuees. The Government is yet to respond to any of these demands.

In the meantime, in Fukushima Prefecture, radiation levels in many areas remain higher than government set limits with no prospect for return of the population. At the time of the accident, authorities took over a month to evacuate Iitate village’s citizens despite the high radiation exposure. Kagoshima City with a population of over 600,000, is located in a similar distance away, 40km, from the Sendai reactors.

Recent polling have shown increasing demands for wider consultation on nuclear reactor restarts beyond communities that directly benefit financially from hosting power plants.

Even with approval from the full Kagoshima Prefectural Assembly and the Governor, restart of the two reactors at Sendai will not take place before 2015. The NRA has yet to complete its review of the Sendai reactor post Fukushima retrofitting plan, safety management rules and onsite inspections of the plant. Kyushu Electric’s concrete plans to comply with the NRA’s volcano guide have not been completed and made public.

Download: Governor of Kagoshima Fails Fukushima Lessons: ignores science, safety and public opinion States operation of Sendai Nuclear Power Plant is “Unavoidable”

Will Japan’s Nuclear Regulator Approve Plans to Restart Reactors Near Super Volcanoes?

[English translation]

Joint Statement Protesting: Nuclear Regulatory Authority’s Draft Approval of Sendai Nuclear Power Plant’s Conformation to New Nuclear Regulatory Standards

16 July 2014
Issued by:
The Nuclear Regulation Authority Citizen Watchdog Group
and 7 other organizations

Today, the Nuclear Regulation Authority (NRA) issued a draft report on Kyushu Electric’s Sendai Nuclear Power Plant application for restart, stating the NRA’s review found the plant conforming to the New Regulatory Standards. We strongly protest this report.

The NRA review to inspect conformation to the New Regulatory Standards does not learn from the lessons of Tokyo Electric’s Fukushima Daiichi accident, and, for the following reasons it is clearly evident that the situation is far from being able to issue such conformation to New Regulatory Standards.

1. In spite of acknowledging the warnings issued by experts that assessments on the effects of volcanoes cannot predict volcanic eruptions, the NRA review is ignoring this fact, thus violating its own Volcanic Effects Assessment Guide.
   • Although Kyushu Electric’s claim which states that the possibility is extremely small that a gigantic volcanic eruption (caldera eruption) would occur during the operation of the nuclear power plant is not substantiated with sufficient evidence, the NRA, with not a single volcano expert on its committee, without asking the opinion of experts, and with virtually no discussion, allowed this claim to pass.
   • With volcano experts stating that a huge volcanic eruption (caldera eruption) is difficult to predict, the government admitted the difficulty of being able to predict the extent and timing of such eruptions. Being able to predict the extend of the volcanic eruption and when pyroclastic flow will occur is absolutely necessary because nuclear fuel must be removed from the power plant site beforehand and because this removal takes years to complete. In spite of this, the NRA has only put monitoring in place for now, and has tossed aside this issue as an issue to be handled in the mid-term future.
2. The NRA is requiring absolutely no measures to be undertaken to prevent contaminated water from being released into the ocean and other areas in the event of a serious accident

The New Regulatory Standards require that, even though the containment has been breeched during a serious nuclear accident, countermeasures must be undertaken to limit the dispersal of radiation. Although it is stated that the New Regulatory Standards are based on lessons learnt from the Fukushima Daiichi nuclear accident, the review process completely ignored the serious situation of contaminated water emissions currently occurring at the Fukushima Daiichi plant and did not require measures be undertaken to prevent radioactive emissions from the Sendai Plant in the event of an accident.
Moreover, at the Sendai Nuclear Power Plant, 300 tons of groundwater is being pumped out daily, and when the pump equipment no longer functions in the event of a serious accident, groundwater would enter the nuclear power plant facility and mix with the contaminated coolant water that has leaked from the bottom of the containment, thus creating the danger that large quantities of contaminated water would be generated. No countermeasures have been put in place to prevent such an occurrence.

1. Measures to prevent breeching of the containment and hydrogen explosions in the event of a serious accident are inadequate—cross-checking to verify the reliability of the analysis code has not been undertaken

Kyushu Electric has a shocking plan in the event of a serious accident involving loss of coolant and loss of power. The company plans to abandon cooling of the reactor vessel and instead will switch to pooling water at the bottom of the containment vessel and having the molten fuel which has breeched the reactor vessel fall into the pooled water. The company claims that this would not lead to breech of the containment vessel nor hydrogen explosions, but its claims are only based on computerized analyses.

The accuracy of the computer code used by Kyushu Electric has been put into question. Nevertheless, the Nuclear Regulation Authority / Nuclear Regulatory Agency did not undertake a cross-check with another computer code, a procedure which is normally undertaken.

1. Seismic motion has been underestimated

The NRA did not have the method utilized for estimating the effects of a tsunami, the Takemura Method, used for estimating the earthquake motion at the Sendai Plant. The Takemura Method takes into account the special characteristic of Japanese earthquakes. If the Takemura Method had been utilized, it would have approximately doubled the earthquake motion estimation for the Sendai Plant.
Although the inadequacy of the New Regulatory Standards regarding estimation of volcanic effects became evident during the review process, as Chair of the NRA Shunichi Tanaka points out, the New Regulatory Standards do not guarantee safety.
With regards to the nuclear accident emergency preparedness plans which NRA Chair Tanaka calls “the second wheel” of a two-wheel vehicle (the other wheel being the New Regulatory Standards) the situation is as follows:

• Kagoshima Prefecture has stated it will abandon plans to evacuate people living beyond the 10-kilometer radius who require special support. It has instead forced responsibility for undertaking plans for these people upon the welfare facilities and hospitals. As a result, no plans are in place for these people. These people are being abandoned, sacrificed.
• As for the emergency preparedness plans for the general public, there is not enough capacity at the evacuation points to take in the people who have evacuated, thus no environment exists for remaining there. Also, there is a possibility that these evacuation points will be downwind. Moreover, the plans do not take into account the possibility of an earthquake, tsunami, or some other event occurring simultaneously to the nuclear accident. Plans for distributing potassium iodine are not in place. The screening points (the locations to undertake measurements and decontamination of radioactive materials) has not been established and no resolution for this is in sight. The possibility that evacuation may be required beyond a 30- kilometer radius has not been taken into consideration, etc.

Numerous issues remain problematic. An effective nuclear accident emergency preparedness plan is not in place. The greater the efforts put into making such plans concrete, the more apparent it becomes that there are great difficulties with evacuation.

The Sendai Nuclear Power Plant restart process should not be allowed to continue under these circumstances. The Nuclear Regulation Authority (NRA) should retract its review report. Restart of the Sendai Nuclear Power Plant must not proceed.

原子力規制を監視する市民の会
The Nuclear Regulation Authority Citizen Watchdog Group

反原発かごしまネット
Anti-Nuclear Kagoshima Network (ANK Net)

玄海原発プルサーマルと全基をみんなで止める裁判の会
People’s Action Against The Genkai Nuclear Power Plant

グリーン・アクション
Green Action

美浜・大飯・高浜原発に反対する大阪の会
Osaka Citizens Against the Mihama, Oi and Takahama Nuclear Power Plants (Mihama-no-Kai)

国際環境NGO FoE Japan
International Environmental NGO FoE Japan

福島老朽原発を考える会
Citizens Against Fukushima Aging Nuclear Power Plants (Fukuro-no-Kai)

Contact: The Nuclear Regulation Authority Citizen Watchdog Group
Tel: +81-90-8116-7155 (Sakagami)

Contact: (in English): Green Action
Suite 103, 22-75 Tanaka Sekiden-cho, Sakyo-ku, Kyoto 606-8203 Japan
Tel: +81-75-701-7223 Fax: +81-75-702-1952 Cell: +81-90-3620-9251 (Smith)

Download: Joint Statement Protesting Nuclear Regulatory Authority’s Draft Approval of Sendai Nuclear Power Plant’s Conformation to New Nuclear Regulatory Standards（PDF）

Japanese: 川内原発の新規制基準適合性審査　原子力規制委員会による審査書案に抗議する共同声明（PDF）