I wrote an answer, than came upon one intresting thing about accuracy and had to check.
It may be suboptimal, and I wouldn't recommend it, since to use it, you have to show more broadside than Nagato and your citadel isn't as low-postioned as on Gneisenau. Also, Gneisenau has more range and has built-in IFHE.
Nagato can fire 8/11 secondaries at 10 degree angle. Sinop 6/8 at 14. And Gneisenau 4/6 at 33.
Firing angles, Nagato, Sinop, Gneisenau, from Gamemodels3d. (don't look at secondary accuracy there, though, it's parsing stuff wrong)
What was unexpected for me - accuracy of 140 mm battery for all IJN BB — Nagato included — is higher than normal and similar to that of Massachusetts.
So, secondary setup for Mutsu, Nagato, Ash*taka, Amagi and Kii is more viable than at first glance. And may even be a reasonable alternative to other builds, if we don't consider armor scheme (IJN BB can be squishy), so if you try that setup - you should know what you're doing, as this is quite bold and risky. And if you go higher in line - you'll have to retrain commander to different skills.