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November 15, 2002

Dr. Richard Meserve
Chairman, Nuclear Regulatory Commission
Washington, D.C. 20555-0001
Facsimile: 1-301-415-1757

Dear Chairman Richard Meserve:

Re: Opposition to Issuance of Export License for Depleted Uranium to Japan’s Rokkasho Reprocessing Facility

Green Action is a Japanese NGO based in Kyoto, Japan working mainly on Japanese plutonium fuel cycle issues.

Green Action recently obtained a copy of an application to export approximately 26 tons of depleted uranium from the United States to Japan for use as test material in the test operation of Japan’s Rokkasho nuclear fuel reprocessing facility. [License Number XSOU8790, Date of Application 10/17/2002]

Green Action notes that Japan has already stockpiled more than 32 tons of plutonium in Europe for which it has demonstrated no concrete plans to consume. The Rokkasho reprocessing facility has the potential to separate 8 tons of plutonium annually, and full-scale operation of this facility will result in domestic stockpiling of large quantities of weapons-usable plutonium. Japan clearly has no demonstrable use for plutonium, and operation of Rokkasho will do nothing but greatly increase nuclear proliferation concerns in northeast Asia.

Attachment B of the above license application confirms that uranium-testing is an integral part of the start-up of the Rokkasho facility, and for this reason, we believe that the NRC and the Executive Branch of the United States Government should conduct a nuclear proliferation assessment of the impact of operation of Rokkasho prior to issuing a license to export depleted uranium to this facility.

Green Action is concerned that stockpiling of large quantities of plutonium in Japan is not only an inherent environmental and security risk in and of itself, but will also threaten world security since such a large domestic stockpile will encourage other countries to obtain or enlarge their stocks of fissile materials. Considering the enormous security risk associated with operating this facility, we believe that failure to conduct a nuclear proliferation assessment prior to issuing a license for the export of depleted uranium to Rokkasho is tantamount to the United States abdicating its responsibility concerning the management of US origin nuclear materials.

Japan’s Atomic Energy Commission which is responsible for drafting Japan’s Long-Term Program for Research, Development and Utilization of Nuclear Energy (LTP), continues to claim that plutonium utilization will go forward as planned. However, the track record of previous LTPs is dismal when it comes to plutonium utilization plans. (See table and chart inAttachment A.)

The AEC expects electric utilities to cooperate with the government to implement the programs outlined in the LTP, but there is no guarantee the electric utilities will do so. For example, in the eighth LTP finalized in 1994, the AEC proclaimed advanced thermal reactor (ATR) technology as “capable of flexibly and efficiently using plutonium and recovered uranium”. However, only thirteen months after the 1994 LTP was finalized, the Federation of Electric Power Companies (FEPCO) submitted a letter to the AEC which stated, “…due to social pressure to reduce electricity costs it is no longer possible to proceed with the costly development of an ATR demonstration reactor.” This letter went on to request a full-scale review of the entire ATR development program. As a result of FEPCO’s position on the ATR, all mention of the ATR program disappeared with no explanation from the ninth LTP issued by the AEC in November 2000.

In previous LTPs, plutonium utilization was to center around fast breeder reactor (FBR) technology. However, efforts to develop commercial FBRs have proven to be more difficult than originally estimated, and development plans have been put back further and further in time in every single LTP. On December 1995, a sodium leak and fire accident occurred at the Monju prototype fast breeder reactor in Fukui Prefecture. The accident and subsequent cover-up of the extent of the accident by the operator of the plant severely damaged public confidence in the entire nuclear industry and brought FBR development plans to a standstill.

With the ATR program scrapped and the FBR program at a standstill, the pluthermal program (the use of MOX fuel in light water reactors) became the key program for reducing Japan’s stockpiles of plutonium. The pluthermal program was originally scheduled to begin in 1999, and MOX fuel has been shipped from Britain and France to reactors in Fukui, Fukushima, and Niigata Prefectures. However, the program remains unimplemented due to the December 1999 BNFL MOX fuel data falsification scandal, and the May 2001 referendum in Kariwa village which resulted in a majority of residents voting against the use of MOX fuel at Tokyo Electric’s Kashiwazaki-Kariwa Unit 3 nuclear power plant. Following the September 2002 announcement that Tokyo Electric systematically concealed inspection results from government regulators, the governors of Fukushima and Niigata prefectures withdrew their advance permission for the pluthermal program. On October 9, 2002 the governor of Fukushima Prefecture called on Prime Minister Junichiro Koizumi and the national government to review the justification for the nuclear fuel cycle.

Regardless of the AEC’s advocacy of the nuclear fuel cycle, there is widespread public opposition to all plutonium utilization plans, and there is no guarantee that these plans will ever gain the consent of the Japanese public.

Given the abovementioned track record of previous LTPs, Green Action believes Japan’s AEC is incapable of providing the United States government with a convincing schedule for the timely utilization of plutonium separated in Europe and plutonium to be separated at Rokkasho. Based on the reasons outlined in this letter, we strongly urge the NRC to deny issuing a license to export this material.

Sincerely,

Aileen Mioko Smith
Director,
Green Action

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