{"id":9321,"date":"2026-08-10T11:37:47","date_gmt":"2026-08-10T02:37:47","guid":{"rendered":"https:\/\/cnic.jp\/english\/?p=9321"},"modified":"2026-08-10T11:37:51","modified_gmt":"2026-08-10T02:37:51","slug":"participation-in-the-nuclear-power-subcommittee-part-21-they-cannot-turn-back-time-decisions-on-nuclear-power-action-guideline-revisions","status":"publish","type":"post","link":"https:\/\/cnic.jp\/english\/?p=9321","title":{"rendered":"Participation in the Nuclear Power Subcommittee, Part 21 &#8211; They Cannot Turn Back Time: Decisions on Nuclear Power Action Guideline Revisions"},"content":{"rendered":"\n<p style=\"text-align: left;\"><strong>\u00a0<\/strong>By Matsukubo Hajime<\/p>\n<p style=\"text-align: left;\">\u00a0<\/p>\n<p style=\"text-align: left;\">On June 5, 2026, the Nuclear Power Subcommittee held its 49<sup>th<\/sup> session. The theme was to review proposed revisions in the \u201cFuture Direction of Nuclear Power Policy and Action Guidelines,\u201d which had been the subject of discussions four times since June 2025. As Japan\u2019s press has reported, it is overwhelmingly oriented toward promoting nuclear expansion, including construction of up to 14 new\/replacement\u00a0nuclear power plants (NPPs). It marks a major milestone in Japan\u2019s nuclear policy in the aftermath of the nuclear accident at the Fukushima Daiichi Nuclear Power Station (NPS), which was operated by Tokyo Electric Power Co. (TEPCO).<\/p>\n<p style=\"text-align: left;\">We had thus far received one-sided explanations from the Secretariat and business operators, and no presentations criticizing the document in the discussions. I therefore spoke up, taking more than 10 minutes, although remarks from Subcommittee members are supposed to be limited to four minutes.<sup>1)<\/sup> The Nuclear Power Subcommittee (consisting of 18 regular members plus three expert members) is composed primarily of nuclear facility operators, the nuclear industry and its stakeholders, the financial institutions that provide their financing, and nuclear engineering researchers, so it is doubtful that the remarks of other Subcommittee members like myself will change their views. However, I do not believe that a solely one-sided debate would have any value in cultivating a sound public opinion.<\/p>\n<p style=\"text-align: left;\">Most Subcommittee members expressed enthusiastic agreement with the content of the proposed revisions, saying they were glad the long-awaited numerical targets had finally been presented. Asano Kenji of the Central Research Institute of Electric Power, on the other hand, said he thought more support from the government was needed.<\/p>\n<p style=\"text-align: left;\">Let\u2019s have a look at some of their remarks:<\/p>\n<p style=\"text-align: left;\">\u201cA loan system that leverages the creditworthiness of the government is important, but increasing borrowing would be insufficient by itself to support decisions to invest in nuclear power.\u201d<\/p>\n<p style=\"text-align: left;\">\u201cIn our liberalized electricity market, nuclear power is one of the riskiest assets in Japan for power producers.\u201d<\/p>\n<p style=\"text-align: left;\">\u201cVarious risks exist at multiple levels, including initial investments exceeding 1 trillion yen, construction review periods spanning more than a decade, sunk costs that generate no income until operation begins, backfitting due to regulatory changes, long-term back-end risks, a nuclear compensation system that is based on infinite liability, and the difficulty of obtaining local agreement.\u201d<\/p>\n<p style=\"text-align: left;\">\u201cGiven the competitive environment power generation companies find themselves in under current conditions, they have very little motivation to dare to take this risk in their balance sheets.\u201d<\/p>\n<p style=\"text-align: left;\">\u201cClearly, the government should share the risks that the private sector cannot handle alone, such as cost fluctuations during the construction period, regulatory changes, back-end risks, and risks under the Nuclear Damage Compensation Facilitation Corporation Act, so that businesses can find the motivation to invest in nuclear facilities.\u201d<\/p>\n<p style=\"text-align: left;\">All of these remarks assume and assert a need for investment in nuclear power. It makes me wonder once again what purpose they have for promoting nuclear power.<\/p>\n<p style=\"text-align: left;\">The Subcommittee were seeking to give complete discretion to the chairman to make revisions to the draft amendments on their behalf, but Murakami Chisato of the Nippon Association of Consumer Specialists objected, as did I. However, since the overwhelming majority of Subcommittee members strongly favor the promotion of nuclear power, the proposed amendments were sent out by e-mail to the members at the start of the following week on June 9, and solicitation of public comments began from the June 10 (continuing until July 9). Therefore, I would like to point out the problems in this document.<\/p>\n<ol style=\"text-align: left;\">\n<li><strong>Target Number for New NPP Construction<\/strong><\/li>\n<\/ol>\n<p style=\"text-align: left;\">The proposed revision here reads, \u201cBased on certain assumptions about the need in the future for reconstruction of old NPPs, there will be a need for about 220 to 550 million kilowatts (kW) (about 2 to 5 reactors) to be reconstructed by the 2040s and about 1,270 to 1,600 million kW (about 11-14 reactors) by the 2050s, inclusive of those built by the 2040s.\u201d<\/p>\n<p style=\"text-align: left;\">How were these figures arrived at? \u00a0The proposed revision states as follows:\u00a0The 7<sup>th<\/sup> Strategic Energy Plan, promulgated in 2025, set the ratio of nuclear power at 20 percent of the power supply, with the ratio of renewable energy at 40 to 50 percent. In FY 2022, power generation stood at about 1 trillion kWh in Japan, with NPPs accounting for 5.6 percent and renewables, 21.8 percent. In the 2040s, Japan\u2019s power generation is expected to reach 1.1 to 1.2 trillion kWh. If NPPs are to supply 20 percent of that, the capacity they will need can be calculated as (1.1~1.2 trillion kWh \u00d7 0.2) \u00f7 (24 h \u00d7 365 days \u00d7 facility utilization rate). In the calculation they assume a facility utilization rate of 70 percent, so the answer is 35.88 to 39.14 million kWh. On the other hand, if the operating period for NPPs is set at 60 years, and the Oma, Shimane 3 and TEPCO Higashidori NPPs, which are under construction, start operations around 2030, the total installed NPP capacity will be about 23.1 million kW, so the discrepancy would be as much as 16 million kW. Note that the term \u201creconstruction\u201d is used because electric power companies are choosing to build the same number of new NPPs as those they are decommissioning, so it is essentially nothing but renewal or expansion of existing facilities.<\/p>\n<p style=\"text-align: left;\">To achieve the government\u2019s assumption that nuclear power will supply 20 percent of Japan\u2019s electricity demand in 2040, it will be necessary to have around 37 million kW of NPPs operating (assuming a facility utilization rate of 70 percent). The total installed capacity of the 36 NPPs that are not being decommissioned happens to be 37.22 million kW, so it would require all of Japan\u2019s remaining NPPs to be restarted to achieve this goal.<\/p>\n<p style=\"text-align: left;\">Such a goal is completely unrealistic, but assuming it is adopted, there are two problems with it. The first is that no consideration at all has been given to the introduction in 2025 of a system for excluding long-term idling periods from the operating period in accordance with the nuclear operators\u2019 requests. Assuming the periods an NPP is idled are all excluded from the operating period, the installed capacity in 2040 would be 37.22 million kW and in 2050 it would be 33.85 million kW. There would be no shortage of installed capacity in 2040, and even in 2050 the shortfall would be a mere 2 to 5 million kW. The Ministry of Economy, Trade and Industry (METI) has explained that this system has just been introduced and has not been taken into account yet because there have been no cases yet in which operating periods were extended, but since it is a system the business operators themselves have requested, it is ridiculous to think they won\u2019t use it. The second problem is the facility utilization rate. The proposed revision states, \u201cEfforts to extend the operation cycle, introduce more maintenance during operation and implement periodic inspections more efficiently, together with increased NPP safety, will help maintain and increase the facility utilization rate.\u201d It indicates a policy to extend the operating period between inspections from the previous 13 months to 15 months. Improving the equipment utilization rate would reduce the required facility capacity. Assuming it were raised to 80 percent, the required capacity would be 31.39 to 34.25 million kW, and if it were 90 percent, it would be 27.9 to 30.44 million kW.<\/p>\n<p style=\"text-align: left;\">What these two points have in common is that they both fail to take into account the effect of these policies in reducing the needed installed capacity, and assume the effect is zero. This amounts to contradictions within the same policy document. One struggles to understand why they are doing this.<\/p>\n<p style=\"text-align: left;\">Here, I want to take a look back at the 3<sup>rd<\/sup> Strategic Energy Plan of 2010. The policies at that time indicated a goal by 2030 of \u201cestablishing new NPPs (at least 14 units) and boosting the facility utilization rate (to about 90%) under the strict condition that safety is ensured, while gaining the understanding and trust of the people, including residents of the areas where the NPPs are to be located.\u201d Note that the outlook at that time for electricity demand in 2030 was 1.02 trillion kWh, with nuclear energy supplying 53 percent and renewable energy, 21 percent. It is interesting that while conditions have changed drastically, the 14-unit figure remains the same. What a shame they cannot turn back time.<\/p>\n<ol style=\"text-align: left;\" start=\"2\">\n<li><strong>The Handling of the Fukushima Daiichi Nuclear Accident<\/strong><\/li>\n<\/ol>\n<p style=\"text-align: left;\">The proposed revisions start off with reflections on the Fukushima Daiichi NPS nuclear accident, explaining the measures taken by Japan\u2019s government and others involved. This is not the sort of matter, however, that can be mentioned simply as a regrettable happenstance in a report entitled Nuclear Action Guidelines. The government has promised the local community repeatedly that the decommissioning work would be completed by 2051. Well, they have 25 years left. The problem isn\u2019t just that there is no sign of decommissioning in progress. The 8 trillion yen TEPCO set aside for decommissioning will go no further than debris removal, and with no funds left for anything past that, this is an extremely big problem regarding nuclear policy.<\/p>\n<p style=\"text-align: left;\">The Atomic Mechanics Society estimates that approximately 7.8 million tons of low-level radioactive waste will be generated by the decommissioning of the Fukushima Daiichi NPS. Normally, when a nuclear reactor is decommissioned, only about 9,000 tons of low-level waste is generated, so this is more than 800 times the normal amount of waste. While they haven\u2019t even found a place yet to dispose the low-level radioactive waste generated by normal reactor decommissioning, just where do they intend to dispose of such an enormous amount of waste? The cost of disposing the low-level radioactive waste generated by the decommissioning of just one typical reactor is about 25 billion yen in terms of present value, so the cost of disposing the low-level radioactive waste alone from the Fukushima Daiichi NPS would come to more than 22 trillion yen. Added to the current 8 trillion yen estimate, this by itself comes to about 30 trillion yen. Of course, there will be other costs added to this, too. It is going to be necessary to spend the enormous sum of at least 30 trillion yen over the next 25 years. This is a matter of having to clean up after a disaster that was brought about by policies that promoted nuclear power. Until we can talk over this matter seriously, nobody should be discussing more promotion policies.<\/p>\n<ol style=\"text-align: left;\" start=\"3\">\n<li><strong>Voluntary Safety Enhancement and the Evisceration of Regulations<\/strong><\/li>\n<\/ol>\n<p style=\"text-align: left;\">The proposed revisions indicate a policy of \u201cimprovement\u201d with respect to \u201ccases of inappropriate behavior.\u201d They say, \u201cThe government and business operators will work with a wide range of stakeholders to reform safety management, not only to meet regulations, but also to improve safety continuously. In addition, they will strive to improve quality assurance activities and organizational management throughout the industry, taking into account cases of inappropriate behavior involving the formulation of standard ground motion that have occurred in the past.\u201d To promote resumed operations and the development of next-generation innovative reactors, on the other hand, the government intends to \u201cstrive to foster a common understanding with the regulatory authorities\u201d and further, \u201cto engage in dialogue with the regulatory authorities to increase the transparency and predictability of the permitting and approval processes.\u201d<\/p>\n<p style=\"text-align: left;\">Prior to now, voluntary measures have been taken, such as making improvements in response to scandals\u2014which continue to be repeated. Japan\u2019s regulators are considering penalizing the operators, but if the purpose is to prevent accidents from being repeated, it is against the persons determining utilization policy that severe penalties ought to be introduced, Rather than that, though, the regulatory side is being called on to foster a \u201ccommon understanding.\u201d In other words, the industry side wants to dictate the orientation of the inspections. If the lesson learned from the Fukushima Daiichi nuclear accident is that regulation and promotion need to be separated from each other, just presenting such a policy is inappropriate in itself.<\/p>\n<ol style=\"text-align: left;\" start=\"4\">\n<li><strong>Shifting the Burden to the Public Called \u2018a Better Business Environment\u2019<\/strong><\/li>\n<\/ol>\n<p style=\"text-align: left;\">The proposed revisions say that \u201cthe government will conduct a comprehensive review of the nuclear compensation system, taking into account the perspectives of minimizing the burden on citizens, ensuring the transparency of nuclear businesses and evaluating improvements in safety.\u201d They seem to be basing this on the argument that liability for nuclear damages should be limited from the standpoint of promoting nuclear power. However, if no accidents are ever to happen again thanks to improved safety, there would be no need to bear unlimited responsibility in the case of the non-existing accidents. In fact, METI explained at a meeting of the Working Group on Verification of Power Generation Cost that the various measures that had been taken had reduced the frequency of severe accidents to once in 12,000 reactor-years. They are, in fact, just assuming that almost no accidents will occur. On the other hand, the Action Guidelines require that \u201cthe disaster prevention system be enhanced, assuming a complex disaster combining a large-scale natural disaster with a nuclear disaster.\u201d<\/p>\n<p style=\"text-align: left;\">No change has been made in the amount of compensation for nuclear-related damages, which was 120 billion yen both before and after the accident. Moreover, some of the costs of compensation for the Fukushima Daiichi nuclear accident have been passed along to customers by adding a consignment fee for this cost, which was intended originally to be borne by the nuclear operators. They put priority on talk of immunity while fobbing off both the risks and the costs onto the citizens.<\/p>\n<ol style=\"text-align: left;\" start=\"5\">\n<li><strong>Promoting Clearance<\/strong><\/li>\n<\/ol>\n<p style=\"text-align: left;\">The revised proposal provides for \u201cpromoting activities for cultivating understanding with a view to the free release of objects targeted for clearance, along with organization of a recycling business, including local government officials in Fukui Prefecture, for cooperation and collaboration\u201d to help decommissioning proceed. \u201cClearance objects\u201d include radioactive substances, but since they consist of scrap metal or discarded concrete and have radioactivity of less than 100 Bq\/kg from cesium, it is thought that they do not need to be handled as radioactive substances. The recycling business under consideration in Fukui Prefecture will be a centralized clearance processing business, for example, carrying out decontamination, melting and other processing, to prepare the materials for clearance (returning secondary wastes with higher concentrations to the nuclear operators). \u201cFree release\u201d of waste indicates the ability to use it as a resource without the responsibility to manage it. The businesses involved claim that these clearance objects are safe, but proximity to them entails some level of exposure, so when their free release occurs, it is conceivable that a number of them might be gathered in one place under certain circumstances, resulting in higher exposure. In addition, releases of radioactive substances into the environment during processing is expected to occur from the recycling business.<\/p>\n<p style=\"text-align: left;\">There is much more of concern that I am unable to cover due to lack of space, but it is clear just from the above that the proposed revisions have far too many issues. By all means, please submit your views on this to the public comments.<\/p>\n<hr \/>\n<p style=\"text-align: left;\"><sup>1)<\/sup>A memo on these remarks has been posted here: <a href=\"https:\/\/cnic.jp\/82113\">cnic.jp\/82113<\/a><\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><\/p>\n","protected":false},"excerpt":{"rendered":"<p>\u00a0By Matsukubo Hajime \u00a0 On June 5, 2026, the Nuclear Power Subcommittee held its 49th session. The theme was to review proposed revisions in the \u201cFuture Direction of Nuclear Power Policy and Action Guidelines,\u201d&#46;&#46;&#46;<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[22],"tags":[],"class_list":["post-9321","post","type-post","status-publish","format-standard","hentry","category-policy"],"acf":[],"_links":{"self":[{"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=\/wp\/v2\/posts\/9321","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=9321"}],"version-history":[{"count":8,"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=\/wp\/v2\/posts\/9321\/revisions"}],"predecessor-version":[{"id":9397,"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=\/wp\/v2\/posts\/9321\/revisions\/9397"}],"wp:attachment":[{"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=9321"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=9321"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/cnic.jp\/english\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=9321"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}