p1Takahama 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
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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.”
2There 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 theNuclear Regulation Authority (NRA) in a three-step process, and lead the restart in theWakasa Bay area. Kansai Electric owns 11 of these reactors. Dr. Ishibashi stated, “Althoughsuch earthquakes as the Kambun Earthquake (1662) and Fukui Earthquake (1948) haveoccurred, 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 safety3
be secured without radical reconstruction?
Main issues of the injunction lawsuit:

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Dr. Katsuhiko Ishibashi is the seismologist who coined the expression Genpatsu Shinsai which means
a nuclear power plant disaster caused by an earthquake. In July 2007, after the Chuetsu-Oki
Earthquake which shook the Kashiwazaki-Kairwa nuclear power plant complex in Niigata Prefectureowned and operated by Tokyo Electric, he warned at an FCCJ (Foreign Correspondents’ Club of Japan)
press conference in Tokyo that, “this was the last warning.” He stated that unless the Japanese
government and electric utilities heeded this warning, Japan was headed for a Genpatsu Shinsai.
2This includes Fugen (Advanced Thermal Reactor), Mihama Unit 1 and Unit 2 (Kansai Electric), andTsuruga Unit 1 (Japco) which have all been shut down permanently. The spent fuel at these reactors
remain on site.
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Quote in Japanese. 裁判長：「１２人乗りエレベータを１６人乗りに変えるとき、抜本的な工事なしで安全が確保できるのか」全が確保できるのか」

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At the first court hearing of the case, Judge Higuchi (the court) requested both defendant andplaintiffs to provide clarification/proof on the following points. It is expected that the verdict willbe along the lines of judging these submissions.

Clarification/Proof Requested by the Court:ll

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What seismic motion resistance construction was undertaken in order to address thebasic earthquake ground motion being raised from 370 gal to 550 gal (this was theincrease 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 beundertaken, 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 inrequirement 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 thefacility be put in place.

Plaintiff and defendant responses to the above issues (in Japanese)
Plaintiff:
http://adieunpp.com/karisasitome/150227junnbi6.pdf
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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
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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 anemergency 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.greenactionjapan.org/internal/141225_Kansai_Union_Proposal_on_nuclear_emergency_response_meas
ures_E_Translation.pdf	  4

It does not appear to be a direct response, but this is Kansai Electric’s last submission to the court andcovers the company’s basic arguments.
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Oral response by Kansai Electric nuclear issues media section at Kansai Electric headquarters inOsaka.

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