Author: Rick E

March 9, 2006
Governor Shingo Mimura
Governor’s Office

1-1-1 Nagashima, Aomori City
Aomori Prefecture 030-8570 Japan

Dear Governor Mimura,

We are writing to you to express our concerns about the complacency that seems to exist in Japan regarding the threat posed by the Rokkasho reprocessing plant to international efforts to limit nuclear proliferation. If you give your approval, this plant in your prefecture may start active testing as early as the end of this month — a test that will ultimately separate over 4 tons of plutonium from spent fuel, enough to make more than 500 Nagasaki-type bombs.

One example of this complacency can be observed in the February 14 letter sent by Ambassador Ryozo Kato to six US Congress members, including Edward Markey of Massachusetts, in response to their letter expressing concerns about the implications for nuclear weapons proliferation of the planned startup of the Rokkasho plant. The Ambassador’s letter states, “In addition, Japan has been taking the unique technical measure of producing a mixed oxide of plutonium and uranium at the Rokkasho plant in order to ensure that a pure plutonium oxide substance will not be available,” implying that somehow this mixed oxide is very different from plutonium oxide and is extremely difficult to turn into bomb materials.

It is true that the US and Japan agreed to introduce this measure for the Tokai reprocessing plant, but the measure does not actually provide significant proliferation resistance relative to plutonium oxide. This is reflected in the safeguards procedures of the International Atomic Energy Agency (IAEA), which are no different for a plant producing mixed-oxide than for a plant producing plutonium oxide.

Regarding this, one of us, Dr. Edwin Lyman, presented a letter for you to Mr. Yoichiro Sakuraba, director of Resources and Energy Department, at a meeting on Feb. 24 saying:

“The Japanese government has said that the RRP will not pose a security threat because it will not produce separated plutonium but instead a 50-50 mixture of plutonium and uranium. However, such a mixture would be directly usable in nuclear weapons. In addition, this mixture is no more radioactive or difficult to handle than separated plutonium. For this reason, the International Atomic Energy Agency considers this material to be as useful as separated plutonium for making nuclear weapons, and as vulnerable as separated plutonium to diversion or theft

Before authorizing the startup of the RRP, you should request that the Japanese Government provide a detailed technical explanation as to why this MOX mixture will be significantly less useful in nuclear weapons than pure plutonium oxide. If it cannot provide a technically sound explanation, you should not allow the RRP to begin operation.”

Mr. Sakuraba said that he had never heard about the IAEA guidance which treats MOX mixtures and Pu oxides in the same way. He was given a copy of the relevant pages of the IAEA Safeguards Glossary (1987 version) in Japanese for your reference. The translation was done under the supervision of former Science and Technology Agency of Japan. (The minor revisions in the current, 2001, version do not affect our conclusion on this issue.)

When asked to explain the government position on the discrepancy of the statement made in the letter to Markey et.al and the IAEA guidance in a meeting with Dr. Lyman held on February 21, Mr. Yasuyoshi Komizo, Director of International Nuclear Energy and Science Department, Ministry of Foreign Affairs declined to do so, saying he was not a technical expert. Mr. Komizo, who has served as special assistant to Dr. ElBaradei, Secretary General of the IAEA, also refused to promise to give a written answer of the Japanese government to Lyman and the Congress members at a later date.

It is quite unfortunate that the Japanese government continues to give this kind of misinformation to you, your staff, and the people of Aomori Prefecture on such an important issue and refuse to give any technical justification for the assertion that the MOX mixture is less of a concern for proliferation than plutonium oxide.

Let us repeat here again: Before authorizing the startup of the RRP, you should request that the Japanese Government provide a detailed technical explanation as to why this MOX mixture will be significantly less useful than pure plutonium oxide for proliferant states or terrorists seeking to acquire nuclear weapons. If it cannot provide a technically sound explanation, you should not allow the RRP to begin operation. Otherwise, your decision to start active testing at the RRP will be based on a highly inaccurate and dangerously incomplete assessment of its proliferation risk.”

One of us, Dr. KANG Jungmin, will be in Aomori Prefecture on March 10-11 and would be happy to meet you and your staff to give you further information on this and other related issues.

Yours sincerely,

Dr. Edwin S. Lyman
Senior Staff Scientist
Union of Concerned Scientists

Dr. Jungmin Kang
Independent Nuclear Policy Analyst

Dr. Frank von Hippel
Professor of Public and International Affairs, Princeton University

Dr. Edwin S. Lyman
Senior Staff Scientist
Union of Concerned Scientists
March 3, 2006

1. MOX Fuel Relocation During LOCAs

The planned use of MOX (pluthermal) fuel in the Genkai-3 reactor in Saga Prefecture will be well outside the existing commercial experience base for MOX fuel with regard to plutonium concentration and fuel burnup. Saga Prefecture acknowledges this, but asserts that even in the absence of commercial data for the regime to which the fuel will be exposed, sufficient experimental data exists and analytical tools are reliable enough to make accurate safety assessments.

This assertion is not justified. While there is a very small quantity of experimental data on the performance of MOX fuel during normal operating conditions at high burnup, there is a huge gap in data on the behavior of MOX fuel under accident conditions. For some accidents that could result in severe consequences, experimental data does not exist to properly validate the codes used to assess the performance of MOX fuel. For example, the phenomenon of fuel relocation during a loss-of-coolant accident (LOCA) is not well understood for MOX fuel. Fuel relocation is the slumping of the fuel column that may occur following the clad ballooning stage of a LOCA. This slumping causes an increase in decay heat in the ballooned region, which may cause the peak clad temperature (PCT) to exceed safe limits during a LOCA.

Saga prefecture’s February 7, 2006 document, “Safety Issues Concerning the Pluthermal Program for Genkai Nuclear Power Plant Unit 3″, does not address fuel relocation. This new finding should be taken into account.

The French nuclear safety organization IRSN has argued that the relocation phenomenon may be more severe for MOX fuel than for high-burnup uranium fuel because the amount of RIM-like (high porosity) material that is generated during MOX irradiation is believed to be greater than the amount of RIM material generated in uranium fuel at a similar rod-averaged burnup. The reason for this is that in high-burnup uranium fuel, the RIM structure only occurs at the outer periphery of uranium fuel pellets, whereas in MOX fuel it also develops in the plutonium-rich clusters that occur in the MOX fuel generated by the MIMAS process, because of the high local burnups that occur in the plutonium-rich clusters. Since the clusters themselves are distributed across the entire pellet cross-section, MOX pellets have a greater area that is exposed to high local burnups and becomes porous than uranium pellets.

In a LOCA, it has been demonstrated that the rapid heating of the fuel pellets results in stresses that cause RIM-like regions to crack and crumble. This produces a powdery material that can collapse and fill the ballooned area of the clad. To the extent that MOX fuel has more RIM-like material than uranium fuel, the relocation effect may be more severe than in uranium fuel.

However, the existing experimental database, while suggestive, is not adequate to make quantitative estimates of the relative severity of the fuel relocation effects for MOX and uranium fuel. For this reason, IRSN proposed in 2003 to conduct a new series of experiments in the Ph?bus reactor to test this effect. However, despite appeals to the U.S. NRC, IRSN was unable to secure financial support for these tests, and neither IRSN nor any other organization has been able to do these experiments. As a result, computer codes used to simulate LOCAs in a reactor with MOX fuel in the core cannot accurately model the potential relocation effect, and therefore cannot conclusively demonstrate the safety of MOX fuel during LOCAs.

The inability of current codes to adequately simulate LOCA performance for fuels outside of the existing experimental database, such as high-burnup fuel, MOX fuel and fuels with newer cladding types such as M5 has become clear during a series of experiments conducted at Argonne National Laboratory in the U.S. over the last few years. Integral LOCA tests on high-burnup uranium fuel have revealed that clad embrittlement occurs at lower clad oxidation thickness than was previously thought, which means that current LOCA regulations are not adequately protective for high-burnup fuel. One must expect that similar surprises will occur for MOX fuel, whether at conventional burnups or the high burnups that are planned for Genkai-3. Therefore, there is an urgent need to confirm that existing LOCA regulations are adequate for new fuels such as MOX.

With respect to MOX fuel performance under ordinary operating conditions, it should be noted that in the experimental MOX fuel program in the United States, the NRC required that data be obtained from the prototype irradiation of MOX lead test assemblies (LTAs) as a prerequisite to approval of full-scale MOX use. The goal of the LTA testing is to observe fuel behavior under irradiation conditions representative of those that would be encountered during the full-scale program. The LTAs used the same design, and were fabricated with the same materials and processes, as the fuel that would be used in the full-scale program. The LTAs are being irradiated to the same burnups that would be encountered during the full-scale program in one of the actual reactors where use of MOX fuel has been proposed. The LTAs will then undergo destructive analysis in hot cells. There has been no comparable activity in Japan. There was limited LTA testing in two reactors in Japan (neither of which was Genkai-3), but not with fuel at the concentration planned for Genkai-3 or to the burnup planned for Genkai-3.

Therefore, Saga Prefecture does not have a sound technical basis to conclude that existing safety margins in the Genkai-3 reactor will be adequate in the event of a LOCA if MOX fuel is used. Also, adequate data does not exist about the performance of MOX fuel during normal operating conditions in a prototypical reactor environment. Consequently, Saga Prefecture should not give its consent for the use of MOX fuel in Genkai-3 unless integral tests are conducted with high-burnup MOX fuel under simulated LOCA conditions to assess the impact of fuel relocation and other MOX-related phenomena on safety margins, and such tests show that the relocation effect will not cause such margins to be exceeded. If, however, these tests indicate that the margins will be exceeded, then obviously MOX use cannot proceed unless the emergency core cooling systems at Genkai-3 undergo appropriate upgrades.

Without doing these tests separately, the use of MOX fuel in Genkai-3 itself must be regarded as an experiment. This means that the citizens of Saga Prefecture and neighboring prefectures that could be affected by an accident at Genkai-3 are being treated like guinea pigs in this experiment by the Japanese government.

The NRC’s decision to go ahead with MOX LTA loading was partially based on the fact that only four assemblies were involved and therefore the risk would be limited.

2. The Potential for Large Radiological Releases from a MOX-fueled

Reactor

Saga Prefecture maintains that the frequency of a severe accident that could result in containment rupture and large radiological release has been calculated for Genkai-3 and found to be one in seventy million years. As a result, Saga concludes that this type of event is something that realistically cannot be considered to occur.

This is a very important point, because of the fact that in the event of such an accident, the consequences would be much more severe if MOX fuel were in the core. For example, my calculations indicate that the number of cancer fatalities resulting from such an accident would double for a core with one-quarter core MOX fuel substituting for uranium fuel. Thus it is crucial that this type of accident be taken very seriously.

However, Saga Prefecture’s conclusion that it is not necessary to consider such an accident is unjustified. First, it is well known that the absolute frequency calculated by probabilistic risk assessment has a high degree of uncertainty, and it is not appropriate to provide the results of the central value of the calculation without providing the uncertainty bands.

Obviously, the use of MOX in Genkai-3 will increase the risk to the public from a severe accident, so the magnitude of this increase should be assessed. The U.S. requires evaluation of the consequences of severe accidents, even if they are very unlikely to occur. Also, the NRC now has a policy that if a change to a reactor license could increase the risk to the public from severe accidents, this change must be evaluated, and if the increase in risk is too great, the change will not be allowed.

Finally, even if large radiological releases from Genkai-3 are improbable as the result of an accident, they can be induced by a terrorist attack. In fact, the result of actual testing of security forces at reactors in the U.S. found that even with very good security, it is possible that terrorists could attack a plant and do enough damage to cause a meltdown and a containment failure. In the case of Japan, it is likely that terrorists would be more inclined to attack a reactor that has MOX fuel in the core because of the greater consequences of such an attack. Therefore, security should be significantly increased at any reactor using MOX, such as Genkai-3. Saga Prefecture has given no indication that such an increase has taken place. As a result, the potential for a terrorist attack to cause grave consequences at Genkai-3 after MOX fuel is loaded must be taken far more seriously than Saga Prefecture appears to be doing.

3. Limitations on the Commercial Use of MOX in France

Saga Prefecture states that the reason why France has not attempted to use MOX fuel in its 1300 MWe reactors, but only in some of its 900 MWe reactors, was that only the 900 MWe reactors were needed to absorb the supply of plutonium resulting from the reprocessing of French spent fuel. However, this ignores the fact that France has accumulated a surplus of nearly 50 metric tons of plutonium that remains unused. In fact, the French plutonium surplus continues to increase, rising from 44.2 MT at the end of 2000 to 48.8 MT at the end of 2004, according to France’s declarations of plutonium holdings to the IAEA. Therefore, the plutonium demand does not match the supply in France. Moreover, France does not now reprocess its spent MOX fuel, which would further increase the plutonium supply.

The real reason why France is not planning to use MOX in its 1300 MWe reactors (or in all of its 900 MWe reactors) appears to be the inconvenience resulting from the burnup limitations imposed on MOX fuel relative to uranium fuel, as well as complications associated with the transportation and storage of spent MOX fuel. As a result, according to a recent article in a trade publication, “EDF wants to maintain more flexibility in its current reactor fleet by concentrating MOX use in certain reactors” (Ann MacLachlan, “MELOX on path to new capacity expansion, targets Japan, EDF,” NuclearFuel, February 27, 2005).

Union of Concerned Scientists
Washington Office
1707 H St NW, Suite 600
Washington, DC 20006-3962

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References:

A. Mailliat and J.C. M?lis, IRSN, “PHEBUS STLOC Meeting” with NRC Staff (October 23, 2003). It is on the NRC ADAMS site.

V. Guillard, C. Grandjean, S. Bourdon and P. Chatelard, “Use of CATHARE2 Reactor Calculations to Anticipate Research Needs,” SEGFSM Topical Meeting on LOCA Issues, Argonne National Laboratory, slides at 8-9 (May 25-26, 2004).

“Blue Ridge Environmental Defense League’s Proposed Findings of Fact and Conclusions of Law regarding BREDL Contention I”, August 6, 2004. US Nuclear Regulatory Commission Before the Atomic Safety and Licensing Board. Docket Nos. 50-413-OLA 50-414-OLA.

“Prefiled Written Testimony of Dr. Edwin S. Lyman Regarding Contention I”, July 1, 2004. US Nuclear Regulatory Commission Before the Atomic Safety and Licensing Board. Docket Nos. 50-413-OLA 50-414-OLA.

“Rebuttal Testimony of Dr. Edwin S. Lyman Regarding BREDL Contention I”, US Nuclear Regulatory Commission Before the Atomic Safety and Licensing Board. Docket Nos. 50-413-OLA 50-414-OLA.

(Unofficial translation by Green Action)

This document analyses 8 areas concerning safety of MOX fuel use. It presents arguments of both anti and pro MOX sides, and gives Saga Prefecture’s conclusions. For all items, Saga Prefecture agrees with the pro MOX argument.

The 8 areas:

1. Control of Reactor

(1) Efficacy of Control Rods and Boron

(2) Concerning Self-regulating characteristics

(3) Characteristics of Output Distribution

2. Safety of the Fuel

(1) Melting Point of Fuel

(2) Internal Pressure of Fuel (Plutonium Spots)

3. Experience with MOX Fuel Performance

(1) Experience concerning Plutonium Enrichment Levels and Burn Up

4. Radioactive Dose During Normal Operation

(1) Worker Dose

5. Effects Due to Accidents

(1) Possibility of Reactor Containment Vessel Rupture

(2) Areas Affected as a Result of Accident

6. Spent MOX Fuel

(1) Spent Fuel Storage

7. Possibility of Terrorism

(1) Possibility of Terrorism

8. Measures Related to Earthquakes

(1) Measures Related to Earthquakes

1. CONTROL OF REACTOR

(1) Efficacy of Control Rods and Boron

PRO: (Entire text.)

When MOX fuel is used, the control efficacy of control rods and boron is reduced slightly, in other words there is a tendency for the efficacy to be lowered.

However, under the safety licensing procedure a margin is placed over and above the capability “necessary to shut down the reactor”. Moveover, when assessing control rod efficacy, the analysis is conducted subtracting 10% from capability. Moreover, the analysis is conducted in a very conservative manner by which it is postulated that one control rod will not work. It has been confirmed that the criteria is met even under these conditions. Therefore, there is no problem with safety since the necessary conditions to shut the reactor down safely are met with plenty of margin.

Also, vis-a-vis boron, it has been confirmed that the reactor can be shut down safely even after taking into consideration the unique characteristics of MOX fuel.

PREFECTURE:

[ Prefecture states ” ‘the ability necessary to shut down the reactor under all manner of reactor operating conditions and anomalous situations’ has been considered.”]

(2) Concerning Self-Regulating Characteristics

PREFECTURE: (Entire response.)

Concerning self-regulating characteristics, the characteristic of maintaining the reactor at steady output levels is enhanced with MOX fuel as compared with uranium fuel. This is a positive characteristic for safety. If and when conditions arise in which reactor output (power) starts to increase for some reason, the ability to autonomously lower output is enhanced even without the operation of control rods.

On the other hand, if and when the temperature of the reactor is lowered for reasons such as low temperature coolant water mistakenly entering (the reactor), although the characteristic to autonomously increase output is enhanced, analyses have been undertaken to take these conditions under consideration. We understand and are convinced that even under these conditions the control rods and boron will safely shut down the reactor as indicated in (1).

(3) Characteristics of Output Distribution

PREFECTURE: (Entire response.)

The issue is whether fuel damage might occur where output is highest.

According to the plans, MOX fuel with lower plutonium enrichment will be used in assemblies where output can easily become high. In other words by placing MOX fuel rods which burn less in these areas, this will even out output.

Moreover, analyses have been conducted for the MOX fuel rods which will have the highest output. Safety of this fuel has been confirmed and therefore we understand and are convinced that safety can be ensured.

2. SAFETY OF THE FUEL

(1) Melting Point of fuel

PRO: (Entire Text)

The melting point of MOX fuel pellet when the temperature in the center of the fuel rod becomes the severest is, with maximum enrichment of 13%wt approximately 2720 degrees C. This is approximately 70 degrees lower than uranium fuel. Compared to this the melting point of the MOX fuel pellet is approximately 1820 degrees under normal output and under abnormal conditions the maximum temperature is approximately 2280 degrees. There is plenty of safety margin and therefore no safety problem.

PREFECTURE: (Entire text)

Even when taking into consideration abnormal conditions, there is approximately 440 degrees C difference between the highest temperature of the fuel and the fuel’s melting point. Therefore we understand and are convinced that safety can be maintained.

On the other hand, fuel melted during the 1979 Three Mile Island accident. However, this occurred when human error involving mistaken operation of the equipment coincided with break-down of equipment. Since then, based on the experience gained from the accident, countermeasures to maintain safety have been put in place such as changes in design of facility, regulatory guidelines, operational management etc. and we understand and are convinced that safety can now be ensured.

(2) Internal Pressure of Fuel (Plutonium Spots)

PRO: (Entire text.)

With regards to fuel rod design, considering the possibility of increased release of fission gases, by taking the countermeasurr of reducing helium gas pressure in the fuel rod as compared to uranium fuel, it is confirmed that the fuel rod internal pressure standard is met.

With regard to plutonium spots, as a result of experimental results under conditions more severe than could be thought to occur realistically, it has been confirmed that it is not necessary to pay special consideration to the effects of fuel damage.

PREFECTURE: (Entire text.)

The original gas pressure in the fuel rods has been reduced taking into consideration increase in the release of fission gases. As a result, it has been confirmed that the fuel rod pressure meets the standard.

Also, as a result of experiments using fuel with plutonium spots larger than can be thought to be realistically possible, it has been confirmed that the effects of fuel damage do not have to be specially taken into consideration. Therefore we understand and are convinced that safety will be ensured.

3. EXPERIENCE WITH MOX FUEL PERFORMANCE

(1) Experience concerning Plutonium Enrichment Levels and Burn Up

ANTI:

There is no commercial experience with 9% Pu (assembly average), and Pu fissile enrichment of maximum 8% (pellet). These are figures for Genkai Unit 3 pluthermal. Even France’s experience is with 900 megawatt reactors and not 1180 megawatt like Genkai. There is data regarding fissile gas build up with high burn up fuel.

PRO: (Entire text)

There is lots of experience in German reactors (1000 megawatt size). Also Germany already has experience with maximum burn up of 50,000 MWd/t.

There have been many experiments and analyses including for high enrichment and burn-up. We have undertaken safety analyses and examination taking into consideration changes to conduct of fuel rod/boron, reduction of melting point of the fuel, characteristics of output distribution, and other changes that could be thought to occur.

Even though there is no experience in commercial reactors, the reliability of analytical methods with experiments etc has been confirmed and therefore it is possible to make accurate assessments.

There is data with high burn up fuel in which the amount of fissile gases shot up, but this is because it was high burn up fuel and not because the fuel was MOX.

PREFECTURE: (Entire Text)

There is experience of burning plutonium in commercial reactors [referring to plutonium created in reactors burning uranium fuel], and based on experiments and analyses conducted in Japan and abroad, we understand and agree that the analyses has been undertaken regarding enrichment and burn up of MOX fuel for use at Genkai Unit 3.

As for no reactor experience in France over 900 megawatt, this is because the amount of plutonium coming out of reprocessing and the capacity of the 900 megawatt reactors in France are almost the same [almost same supply/demand], and therefore it has been judged that there is no need to implement MOX use in reactors larger than 900 megawatt in France.

5. EFFECTS DUE TO ACCIDENT

(1) Possibility of Reactor Containment Vessel Rupture

PRO: (Entire text.)

A safety assessment of the frequency of a reactor containment vessel rupture has been undertaken for Genkai Nuclear Power Plant Unit 3 using probabilistic safety assessment. The frequency is once in 70 million years. This is substantially lower than the IAEA international target value of “once in 100,000 years” and is something that realistically cannot be considered to occur.

PREFECTURE: (Entire text.)

The possibility of a reactor containment vessel rupture occurring at Genkai Unit 3 is, having taken into consideration the probability of each type of equipment breaking down, human error, etc., assessed to be once in 70 million years. Although the figure is not zero, considering the fact that the risk of using scientific technology cannot be zero, the probability is substantially small and we understand and are convinced that it cannot be considered to occur realistically.

(2)Areas Affected as a Result of Accident

PRO:

[States the boiling point of plutonium dioxide is high (approximately 3230 degrees C)…no big change in noble gases and iodine release with MOX fuel….plutonium intake through respiration is almost totally improbable…even with the Chernobyl accident, damage from plutonium has not been confirmed.]

PREFECTURE: (Entire text.)

If MOX fuel is used, there is more plutonium in the reactor than if uranium fuel is used. Also, if plutonium is respired, it is confirmed that the toxicity is especially high.

However, it is difficult for plutonium to become a vapor, and also, there are multiple barriers to keep radioactive materials inside the power plant, and therefore it is almost unthinkable that plutonium would be released to the external environment. Therefore we understand and are convinced that the effects due to radioactive materials going outside of the nuclear power plant are no different from uranium fuel.

There is talk that, “if one wants to hypothesize an accident, any accident could be hypothesized”. For example it is assessed that the probability of the reactor containment vessel rupturing is once in 70 million years. Although this is not zero, when considering that the risk of using scientific technology cannot be zero, the probability is substantially small and we understand and are convinced that it cannot be considered to occur realistically.

7. POSSIBILITY OF TERRORISM

(1) Possibility of Terrorism

PRO: (Entire text.)

Although the possibility of a terrorist attach on a nuclear power plant is not zero, it is difficult to think that it will become easier to be subject to a terrorist attach just because MOX fuel use is being implemented. The security at nuclear power plants is greater than at general facilities and the building itself is more solid. Many other facilities beside nuclear power plants could be considered to be targets for terrorist attach.

Although there cannot be sweeping mention regarding the kind of damage that might or might not occur or the degree of damage if a nuclear power plant were to come under a missile attach, considering the fact nuclear power plants are built to withstand earthquakes, and from the aspect of shielding, it is a solid building with plenty of strength and thickness, and has considerable resistance toward attack from the outside.

[Diagram titled “Attach from the Outside” indicates thickness of concrete walls etc, various barriers, statement saying “under abnormal conditions, the reactor is designed to immediately stop automatically.” Boxed in text: “We consider that terrorist activity or military attach from a foreign country is an issue which necessitates broad-based measures from the standpoint of national security.”]

PREFECTURE: (Entire text.)

Although the possibility of a terrorist attach on a nuclear power plant cannot be considered to be zero, it is not that there will be any changes to such things as the security and precautionary preparedness and the facilities construction and structural strength, and therefore we understand and are convinced that it will be difficult to think that the possibility of being attached will increase in any big way.

Even if the pluthermal program is not implemented, terrorist attachs etc. of nuclear power plants is a threat and we believe that it is necessary to make all sorts of diplomatic and political efforts to reduce their possibility.

On the other hand, the government has established a national emergency law, and also the prefecture this January 20th (2006) drew up the “Saga Prefecture National Citizens Protection Plan” to deal with any situations that might arise so that the safety of prefectural citizens can be secured and every effort is being undertaken among related agencies to cooperate and establish a system to deal with this matter.

End

PDF Version

Japan Atomic Energy Commission Accepts Faulty Plutonium Utilization Plan of Japanese Electric Utilities

3 February 2006

Dr. Mohamed ElBaradei
Director General,
International Atomic Energy Agency
IAEA Secretariat
Headquarters Offices
A-1400 Vienna, Austria

IAEA Board of Directors
c/o Ambassador Yukiya Amano
Chairperson,
IAEA Board of Directors
Permanent Mission of Japan to the International Organizations in Vienna
Andromeda Tower, Donau-City Strasse 6, A-1220
Vienna, Austria

　

Dear Director General ElBaradei and IAEA Board of Governors:

In our Petition of 5 January and follow-up letter of 11 January, we urged the IAEA Secretariat and Board of Governors to quickly take appropriate action before active testing begins at Japan’s Rokkasho reprocessing plant and plutonium is accumulated. This was to ensure that Japan does not breach its international commitment made to the IAEA in 1997 which pledged that “plutonium beyond the amount required to implement the program is not to be held, i.e. the principle of no surplus plutonium.”

The Federation of Electric Power Companies (FEPCO) of Japan published its “Utilization Plan for Plutonium Recovered at Rokkasho Reprocessing Plant”*1 on 6 January, the day after we sent our petition to you. The Japan Atomic Energy Commission (JAEC) considered the plan and announced its response on 24 January.*2

JAEC’s 24 January response is at variance with the commitment made by the Japanese government in 1997. This is because the FEPCO Plan announced on 6 January does not meet the conditions stipulated in the JAEC Decision of 5 August 2003, the “Basic Principles for the Utilization of Plutonium in Japan.”*3 The Basic Principles were issued to meet Japan’s commitment to transparency and “no surplus plutonium.”

According to the 2003 JAEC Decision, “The uses of plutonium should specify the quantities of plutonium involved, the places where plutonium will be used, approximate time of start [of] using plutonium, and an approximate period of time required to use the material.”

The 6 January FEPCO Plan fails to meet the “Basic Principles” of the 2003 JAEC Decision:

• Head of FEPCO, Tokyo Electric, does not say which plant will use the plutonium, yet states that it will consume the plutonium.
• None of the nuclear power plants specified under the FEPCO Plan has approval from local authorities to use plutonium (MOX) fuel.
• Moreover, the Plan includes nuclear power plants for which the utilities have not yet even applied to local authorities for approval.
• The Plan also includes the Ohma “full-MOX” nuclear power plant which does not exist and for which no reactor installation license has been granted.
• The approximate start date for plutonium use is not listed.
• There is no clear indication of by when the plutonium will have been used up.
• The FEPCO Plan is supposed to be about obtaining permission to separate plutonium at Rokkasho and is accordingly titled, “Utilization Plan for Plutonium Recovered at Rokkasho Reprocessing Plant (Fiscal years 2005-2006). The title, however, is misleading since in small print the Plan says, “There are cases where the amount of plutonium to be used includes plutonium recovered overseas.”

In the recent 24 January response, the JAEC effectively admits the FEPCO Plan does not meet JAEC’s Basic Principles, by saying that companies have “not yet reached the stage of producing detailed utilization plans…” Nevertheless it responded that the Plan was appropriate.

A table comparing key elements of Japanese / JAEC documents from 1997, 2003, and 24 January 2006 is appended to this letter.

It appears that, on the strength of JAEC’s response, active testing could begin around April at Japan Nuclear Fuel Limited’s (JNFL) Rokkasho reprocessing plant. The plant would then begin to separate plutonium from spent nuclear fuel. On the basis of JNFL’s reprocessing schedule and FEPCO’s 6 January plutonium utilization plan, it is clear that Japan’s inventory of separated plutonium will grow rapidly.

Our calculations indicate that implementation of current plans for reprocessing at Rokkasho would result in approximately 35 tons surplus plutonium in Japan by 2012.*4 (2012 is the earliest date plutonium separated at Rokkasho could be used.)

Since there are also no concrete plans to consume the 43 tons of plutonium Japan has already accumulated in Europe and Japan (37.4 tons in Europe and 5.7 in Japan*5), Japanese surplus plutonium may total 78 tons by 2012. This is comparable to the US military inventory (including military excess) of 99.5 tons of separated plutonium, and the UK military and civilian inventory of 77.8 tons.*6

Judging from announcements by power companies to date, little if any of the 37 tons of plutonium currently held in Europe will be used before 2012. The pluthermal plans -using plutonium uranium MOX fuel in thermal reactors- of the two largest power companies Tokyo Electric and Kansai Electric are in disarray. Local and prefectural consent was withdrawn for Tokyo Electric’s plans and Kansai Electric reiterated on 31 January that “concrete pluthermal plans are undecided and we continue to not be in a state for discussing the matter.”*7 Only four of the smaller power companies have announced plans to use plutonium before 2012, and none of them has yet obtained the consent of local and prefectural authorities.

It is worth noting the historic unreliability of Japanese electric utilities’ (FEPCO) plans concerning plutonium consumption. In June 1993 preceding start-up of THORP (UK), Japanese electric utilities took out full-page advertisements in all major UK newspapers stating that they needed the plutonium THORP would separate.*8 To this day, however, not a single gram of plutonium has been consumed. A week preceding the 1993 Japanese electric utilities’ advertisement, our organizations predicted that THORP’s operation would result in approximately 39 tons of surplus Japanese plutonium in Europe by 2005,*9 and a total 70 tons of surplus Japanese plutonium by 2010.*10 Our predictions are right on track.

The continued lack of transparency concerning when and where Japan will consume its plutonium for electricity generation is highly disturbing.

We contend that plutonium stocks are a proliferation risk in themselves, regardless of the current intentions of the Japanese government. They undermine international efforts to stem the drift toward nuclear proliferation.

JAEC’s recent judgment shows that it does not fully comprehend the nuclear proliferation implications and transparency problems of beginning active tests at Rokkasho.*11 *12 The JAEC’s failure to live up to its commitment to “no surplus plutonium” threatens to undermine international confidence in Japan’s oft-repeated claim that the development and utilization of nuclear energy in Japan “is strictly limited to peaceful purposes.”

We therefore urge the IAEA to discuss this matter and to inform the Japanese government that it is not appropriate to begin active tests at Rokkasho.

Yours sincerely,

Hideyuki Ban (Co-Director)
Citizens’ Nuclear Information Center (CNIC)
3F Kotobuki Bldg., 1-58-15 Higashi-nakano
Nakano-ku, Tokyo, 164-0003, Japan
Phone: +81 3 5330 9520

Aileen Mioko Smith (Director)
Green Action
Suite 103, 22-75, Tanaka Sekiden-cho
Sakyo-ku Kyoto, 606-8203, Japan
Phone: +81 75 701 7223

Atsuko Nogawa (Nuclear Campaigner)
Greenpeace Japan
N F bldg. 2F 8-13-11 Nishi-Shinjuku
Shinjuku, Tokyo, 160-0023, Japan
Phone: +81 3 5338 9800

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Enclosures:

Citizens’ Nuclear Information Center, Green Action, Greenpeace Japan, Chart: “Comparison of 3 Japanese Government / Atomic Energy Commission (JAEC) Decisions Regarding the Use of Plutonium,” compiled 3 February 2006. Available at: http://www.greenaction-japan.org/modules/wordpress0/index.php?p=34

Japanese Government, Letter to the IAEA: “Plutonium Utilization Plan of Japan,” December 1997. Available at: http://www.iaea.org/Publications/Documents/Infcircs/1998/infcirc549a1.pdf

Atomic Energy Commission of Japan, Decision: “Basic Principles for the Utilization of Plutonium in Japan” (Provisional Translation), 5 August 2003. (Personal translation by or for then JAEC commissioner Tetsuya Endo. Sent by JAEC to Green Action.)

Federation of Electric Power Companies of Japan (FEPCO), “Utilization Plan for Plutonium Recovered at Rokkasho Reprocessing Plant (Fiscal 2005-2006),” 6 January 2006. (CNIC translation.)Available at: http://cnic.jp/english/topics/cycle/MOX/pluplanFEPCO6Jan06.html

Japan Atomic Energy Commission (JAEC), “Appropriateness of the Purpose of Use Specified in the Plutonium Utilization Plans Announced by Electric Power Companies et al,” 24 January 2006. (CNIC translation.)

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*1. Federation of Electric Power Companies of Japan (FEPCO), “Utilization Plan for Plutonium Recovered at Rokkasho Reprocessing Plant (Fiscal 2005-2006),” 6 January 2006. English translation by Citizens’ Nuclear Information Center available at: http://cnic.jp/english/topics/cycle/MOX/pluplanFEPCO6Jan06.html

*2. Japan Atomic Energy Commission (JAEC), “Appropriateness of the Purpose of Use Specified in the Plutonium Utilization Plans Announced by Electric Power Companies et al,” 24 January 2006. (Translation by Citizens’ Nuclear Information Center.)

*3. Atomic Energy Commission of Japan, Decision: “Basic Principles for the Utilization of Plutonium in Japan,” 5 August 2003. (The English is a personal translation by or for then JAEC commissioner Tetsuya Endo.) Green Action has been told by JAEC that it understands commissioner Endo sent the English translation to the IAEA.

*4. Based on JNFL’s 1 September 2005 announcement regarding the amount of spent fuel to be separated from FY2005 – FY2012.

*5: Japan Atomic Energy Commission 2005 plutonium inventory figures.

Available at: http://aec.jst.go.jp/jicst/NC/iinkai/teirei/siryo2005/siryo34/tei-si34.htm (In Japanese.)

*6. Institute for Science and International Security, Global Stocks of Nuclear Explosive Materials: Summary Tables and Charts (July 12, 2005, Revised September 7, 2005), Table 2, Plutonium and HEU Holdings by Country, end 2003 in tonnes.

*7. Statement made to Green Action and Mihama-no-Kai by Kansai Electric on 31 January 2006.

*8. The Ten Japanese Electric Power Companies, “Let’s be clear about it. The ten Japanese utility companies want THORP.” Full page advertisement in major UK newspapers including The Times (23 June 1993).

*9. Japanese Citizens Concerned About Plutonium, “Why Start THORP If Japan Has No Use For It Anymore?” Advertisement in UK parliament’s House Magazine (14 June 1993.) Signers include Jinzaburo Takagi then director of CNIC and Aileen Mioko Smith, director of Green Action.

*10. Letter dated 15 June 1993 to UK Prime Minister John Major from Aileen Mioko Smith (director of Green Action [former organization name Plutonium Action Network – Kyoto]), Yurika Ayukawa (director for International Relations, Citizens’ Nuclear Information Center), and Consumers’ Union of Japan. Letter states, “Japan’s plutonium utilization programme is severely behind schedule. Major problems and chronic delays in the programme will result in an approximate 70 tonne (70,000 kg) gap between actual demand and supply of Japanese plutonium by the year 2010 if current supplies continue.”

*11. “A Call on Japan to Strengthen the NPT by Indefinitely Postponing Operation of the Rokkasho Spent Fuel Reprocessing Plant.” (May 5, 2005) Statement by 27 eminent scientists, former policy makers and analysts, including four Nobel laureates in physics and two former US Secretaries of Defense. They said, “At a time when the nonproliferation regime is facing its greatest challenge, Japan should not proceed with its current plans for the start-up of the Rokkasho reprocessing plant.” See press release and statement on the following page: http://www.ucsusa.org/news/press_release/japanese-plutonium-program-threatens-nonproliferation-regime-warn-nobel-laureates-and-other-experts.html

*12. Letter sent to the Japanese Ambassador by six Democrat members of the US Congress calling on Japan “to suspend plans to conduct active testing of Rokkasho…as part of a global initiative to reduce world-wide stockpiles of weapons-usable fissile materials.”

See press release and letter on the following page: http://markey.house.gov/index.php?option=content&task=view&id=1088&Itemid=125

PDF Version

Comparison of 3 Japan Government/Atomic Energy Commission (JAEC) Decisions Regarding the Use of Plutonium

Compiled: 3 February 2006

Compiled by Citizens’ Nuclear Information Center (CNIC), Green Action, and Greenpeace Japan

1997	2003	2006
Japanese government’s December 1997 Letter to the IAEA “Plutonium Utilization Plan of Japan” (INFCIRC/549/Add. 1 31 March 1998) Section 2, Enhancing the Transparency of the Nuclear Fuel Cycle Program (English original) The nuclear fuel cycle is promoted based on the principle that plutonium beyond the amount required to implement the program is not to be held, i.e. the principle of no surplus plutonium. Nuclear materials are also strictly managed, so as not to give rise to any international doubts concerning nuclear proliferation. Japan intends to ensure transparency of the plutonium utilization program through these efforts. Projections of plutonium supply and demand in Japan through 2010 have been published by the AEC, as appropriate, based on the progress of related programs, in order to demonstrate that the nuclear fuel cycle program follows the principle of no surplus plutonium.	JAEC’s 5 August 2003 Decision “Basic Principles for the Utilization of Plutonium in Japan” (Provisional translation by JAEC commission) (Footnote Japan has made an important pledge to the international community to utilize plutonium solely for peaceful purposes. However, in order to avoid doubts both at home and abroad about the utilization of such a sensitive substance, it is important that Japan should achieve enhanced transparency regarding the utilization of plutonium and thereby gain an improved understanding of the nation as well as the international community. To this end, AEC has laid down the principle of not holding surplus plutonium, i.e. for no specific purpose… With the commercial operation of the Rokkasho Reprocessing Plant, a large amount of plutonium will be separated and recovered. Accordingly, AEC considers it necessary to define the purposes for which this plutonium will be used and thereby to achieve further transparency as to the anticipated utilization of the substance. Electric power companies will be required to announce every year plans for the utilization of plutonium before separating plutonium, setting forth the names of owners of plutonium, the amount of plutonium in their possession, and the purposes for which plutonium will be used. The uses of plutonium should specify the quantities of plutonium involved, the places where plutonium will be used, approximate time of start [of] using plutonium, and an approximate period of time required to use the material. Moreover, in order to achieve enhanced transparency, electric power companies should provide details of the uses as the actual plans progress.	JAEC’s 24 January 2006 Decision “Appropriateness of the Purpose of Use Specified in the Plutonium Utilization Plans Announced by Electric Power Companies et al” (CNIC translation) In August 2003 AEC promulgated the decision ‘Basic Principles for the Utilization of Plutonium in Japan’ (’Basic Principles’). This showed that Japan’s concept is that in addition to publishing information on the status of plutonium management, in order to further enhance transparency, as a uniquely Japanese measure, companies must publish a plutonium utilization plan showing the purpose of use, before they can separate plutonium at the Rokkasho reprocessing plant. Until now, considering the experience accumulated in Japan and overseas, detailed decisions about the end use of plutonium recovered at reprocessing plants and the time of use may come after the plutonium has been stored for quite a while. However, regarding the recovery within Japan by civilian companies of the sensitive substance plutonium, even if companies have not yet reached the stage of producing detailed utilization plans, since by each year clarifying the plutonium utilization plan, including the plan for the plutonium to be recovered the following year, the most recently published utilization plans will step by step become more and more detailed, AEC believes this to be appropriate from the point of view of maintaining a high level of transparency regarding utilization… We expect electric power companies, under appropriate risk management, in accordance with progress made, from the next fiscal year to make positive efforts to make their utilization plans more detailed. Further, where circumstances arise, as a result of the progress status of plu-thermal plans and the operational status of the Rokkasho reprocessing plant, which might affect utilization plans, we expect electric power companies to review the utilization plans announced this time, based on the ‘Basic Principles.’

(Emphasis ours.)

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The English translation of the JAEC 5 August 2003 Decision was provided to Green Action by JAEC. It is a personal translation by or for then JAEC commissioner Endo. Green Action has been told by JAEC that it understands the translation was sent by commissioner Endo to the IAEA.

[Contact: Aileen Mioko Smith Tel: +81 90 3620 9251]

24 January 2006 (Kyoto, Japan)—The Japan Atomic Energy Commission headed by Shunsuke Kondo today approved Japanese utilities’ Plutonium Utilization Plan released earlier this month. Japanese NGOs lambasted as “fiction” the utilities’ fiscal 2005 and 2006 plans which say 1.6 tons of plutonium will be consumed in Japanese nuclear reactors as MOX (mixed plutonium uranium oxide) fuel.

None of the nuclear power plants specified under the Plan has approval from local authorities to use the plutonium. Tokyo Electric which heads the Federation of Electric Power Companies could not name which plants would use the plutonium, yet says it will consume it. Nuclear power plants where consent from local authorities had not been applied for are included in the Plan. The Ohma “full-MOX” nuclear power plant which does not exist and does not have a reactor installation license is also included in the Plan as consuming plutonium.

Utilities were required under a Japan Atomic Energy Commission (JAEC) decision issued in August 2003 to state which reactors would use what amount of plutonium from which date and by when before they would be allowed to separate out the plutonium at the Rokkasho reprocessing plant in Aomori.

Aileen Mioko Smith, director of Green Action stated,” Japan today betrayed its 1997 pledge to the IAEA not to stockpile plutonium that isn’t required for implementing Japan’s nuclear program. This is totally unacceptable. The JAEC today also betrayed its own directive which said utilities must present concrete plans for consuming plutonium before they separated it out at Rokkasho. It’s clear this whole thing is driven in a frenzy to start up Rokkasho.”

In December of 1997, the Japanese government had pledged to the IAEA that it was committed to transparency in its nuclear fuel cycle program and that its program would be promoted “based on the principle that plutonium beyond the amount required to implement the program is not to be held, i.e. the principle of no surplus plutonium”.

(Available at: http://www.iaea.org/Publications/Documents/Infcircs/1998/infcirc549a1.pdf)

Furthermore, a fundamental technical problem exists. Japan lacks the capability to turn any plutonium produced at Rokkasho into MOX fuel. There is only a government “expectation” that a MOX fuel fabrication plant be fully operational by fiscal 2012.

Moreover, a massive cache of Japanese plutonium already exists: thirty-seven tons sit in Europe. Japan’s Framework for Nuclear Energy Policy issued in October 2005 gives priority to the consump-tion of this plutonium in Europe over any produced at Rokkasho.

Japan originally made its “no surplus” pledge in the interests of nuclear non-proliferation and disarmament. Japan has now reneged on its international commitment amidst heightened political tension around disarmament and non-proliferation in North East Asia, and during its term as Chair of the IAEA Board of Governors.

[18 January 2006]

PDF version (472KB)

Japan’s 1997 Pledge

The government of Japan made a written and unequivocal pledge to the International Atomic Energy Agency (IAEA) in December 1997 to uphold the “principle of no surplus plutonium.”*1

To honor this commitment, the Japan Atomic Energy Commission issued a Decision on 5 August 2003*2 which specified that electric utilities present concrete plans for utilizing plutonium before separating it from spent nuclear fuel at the Rokkasho reprocessing plant.

On 6 January 2006, the Federation of Electric Power Companies released its “Plutonium Utilization Plan.”*3 The Plan, however, does not comply with the specifications set forth by the Atomic Energy Commission.

Defects of the Plan Released by the Federation of Electric Power Companies (FEPCO):

• None of the nuclear power plants specified under the plan has approval from the local authorities to use plutonium (MOX) fuel
• Tokyo Electric, head of FEPCO, does not specify in which plant it will use the plutonium, yet says it will consume it
• Nuclear power plants where consent from local authorities have not been applied for are included
• The Ohma “full-MOX” nuclear power plant which does not exist and does not have a reactor installation license is included

Will the AEC Approve the FEPCO Plan?

If the AEC approves the FEPCO Plan, surplus plutonium with nowhere to go will pile up at the Rokkasho reprocessing plant.

In the rush to start the Rokkasho reprocessing plant, will the Atomic Energy Commission trash its own 2003 Decision, rubber-stamp the Federation of Electric Power Companies’ Plan, and renege on Japan’s commitment to the IAEA and to the international community?

Or, will the AEC honor Japan’s commitment to not produce surplus plutonium.

The eyes of the world are watching.

Citizens’ Nuclear Information Center (CNIC)
3F Kotobuki Bldg., 1-58-15 Higashi-nakano
Nakano-ku, Tokyo, 164-0003, Japan
Phone: +81 3 5330 9520

Green Action
Suite 103, 22-75, Tanaka Sekiden-cho
Sakyo-ku Kyoto, 606-8203, Japan
Phone: +81 75 701 7223

Greenpeace Japan
N F bldg. 2F 8-13-11 Nishi-Shinjuku
Shinjuku, Tokyo, 160-0023, Japan
Phone: +81 3 5338 9800

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*1 Available at http://www.iaea.org/Publications/Documents/Infcircs/1998/infcirc549a1.pdf

*2 Available (in Japanese) at: http://aec.jst.go.jp/jicst/NC/iinkai/teirei/siryo2003/kettei/kettei030805.pdf

*3 Available (in English translation) at: http://cnic.jp/english/topics/cycle/MOX/pluplanFEPCO6Jan06.html

[Joint letter sent from Green Action, Citizens’ Nuclear Information Center, and Greenpeace Japan]

Director General Mohamed ElBaradei
International Atomic Energy Agency
IAEA Secretariat
Headquarters Offices
A-1400 Vienna, Austria

Re: ROKKASHO REPROCESSING PLANT AND JAPANESE ELECTRIC UTILITIES’ PLUTONIUM UTILIZATION PLANS

Dear Director General ElBaradei:

On 5 January 2006 we sent you a petition urging you to ensure that Japan does not breach its international commitment to the principle of “no surplus plutonium” and to quickly take appropriate action before active testing begins at Rokkasho and plutonium is accumulated. The following day the Federation of Electric Power Companies of Japan (FEPCO) published its Plutonium Utilization Plan.

Attached please find a media briefing we issued today. It is a critique of the plutonium utilization plans of Japanese electric utilities. It addresses the concern that the Japan Atomic Energy Commission (JAEC) may be approving these plans later this month in order to start “active testing” at the Rokkasho reprocessing plant.

While some of the numbers in the latest Plutonium Utilization Plan are slightly different from those previously released, the plan confirms the basic substance of our petition. We therefore reiterate our appeal for the IAEA Secretariat and Board of Governors to immediately discuss this matter and quickly take appropriate action.

Sincerely yours,

Aileen Mioko Smith
Director, Green Action

cc: IAEA Board of Governors

CONTACT:
Aileen Mioko Smith, Green Action (Director)
+ 81 75 701 7223 or 090 3620 9251 (Cell)

Philip White, Citizens’ Nuclear Information Center (International Liaison)
+ 81 3 5330 9520

Atsuko Nogawa, Greenpeace Japan (Nuclear Campaigner)
+ 81 3 5338 9800

11 January 2006 (2nd edition)

Japanese NGOs Label Electric Utility Plutonium Utilization Plan “Fiction” Concern Raised that Atomic Energy Commission may Rubber-Stamp Plan

Japanese NGOs yesterday released a scathing critique*1 of the Plutonium Utilization Plan issued by the Federation of Electric Power Companies (FEPCO) on 6 January, dubbing the plan as “fiction” and pointing out that it does not comply with specifications stipulated by the Japanese Atomic Energy Commission (JAEC) in 2003.

At this time there is concern JAEC may approve this plan as early as mid-month in order to start “active testing” at the Rokkasho Reprocessing Plant.*2 Regional and local authorities’ opposition to the plan is expected.

Rushing to Start “Active Tests” at Rokkasho Reprocessing Plant

The Plutonium Utilization Plan covers the use of plutonium fuel, known as MOX fuel, in nuclear power plants*3 operated by Japan’s electric power companies. However, none of the reactors slated under the plan have received consent from local authorities to consume the material.

In February 1997, the government of Japan made a written commitment to the International Atomic Energy Agency (IAEA) to uphold the “principle of no surplus plutonium”. Based on this, JAEC issued a decision on 5 August 2003 stipulating that electric utilities must state the amount, location, starting date, and length of time required to consume MOX fuel before spent nuclear fuel can be reprocessed to extract plutonium at the Rokkasho reprocessing plant.

The plan issued by FEPCO falls far short of this requirement. There is concern that JAEC will rubber-stamp it in the rush to start “active testing” at the Rokkasho reprocessing plant. Active testing is currently scheduled to begin in February. During the active tests the Rokkasho Reprocessing Plant will extract plutonium from spent fuel for the first time. According to the plan, 1.6 tons of plutonium will be extracted during fiscal years 2005 and 2006, enough for 200 Nagasaki type nuclear bombs.

Plan will Increase Plutonium Stockpile in Japan

This plan ignores the plutonium that Japan already possesses. Japan already has a surplus of 43.1 tons of plutonium (37.4 tons held in Europe and 5.7 tons held in Japan). The plutonium surplus continues to grow, despite the 1997 “no surplus plutonium” pledge.

An earlier Plutonium Utilization Plan, relating to plutonium held overseas, was submitted to the IAEA in December 1997. The plan, along with the “no surplus plutonium” commitment, was published in IAEA INFCIRC/549/Add.1, 31 March 1998. No MOX fuel has been used in Japan’s nuclear power plants in accordance with this 1997 plan because it foundered.

NGOs point out that the latest FEPCO plan is simply a copy-and-paste job of the 1997 plan. Under the former plan, utilities were to consume MOX fuel at 16 to 18 reactors. The number of reactors slated this time is identical to the 1997 plan, but the latest plan relates to plutonium separated in Japan at the Rokkasho reprocessing plant. No explanation is given regarding the overseas plutonium, so it must be assumed that separating more plutonium now will add to the existing surplus. (Japan’s “Framework for Nuclear Energy Policy” issued October 2005 by the JAEC gives priority to the consumption of the plutonium in Europe over any produced at Rokkasho.*4)

Plan Fails to Provide Required Information

The plan fails to provide the minimum information required by JAEC’s 2003 decision.

It effectively says nothing about the time of commencement, or the time required to use the plutonium. It says that the plutonium will be used “in and after 2012″. However, this is just a statement of the obvious. Plutonium extracted at Rokkasho is to be fabricated into MOX fuel at the MOX Fuel Fabrication Plant, but this plant has not been built and is only “expected” to commence operation by 2012*5. Apparently the time required to use the plutonium is just calculated on the basis of the number of reactors and their power output. There is no indication of by when all the plutonium will be used.

Regarding the location, reactors where the plutonium will be used are identified for only six companies: Kansai Electric, Kyushu Electric, Shikoku Electric, Chugoku Electric, Chubu Electric and Japan Atomic Power Company. The remaining four companies fail to specify which reactors will be used: Tokyo Electric, Hokuriku Electric, Tohoku Electric and Hokkaido Electric. Due to local opposition and past scandals, Kansai Electric and Tokyo Electric were forced to refer to the need to recover public trust before their plans can be implemented.

No company has obtained the prior consent of the prefectural or local governments except Kansai Electric and three have not even applied for prior consent. Previously granted consent was withdrawn by Niigata and Fukushima Prefectures (Tokyo Electric). Kansai Electric states it is not in the position to proceed with the Pluthermal (MOX fuel use) program at this time due to the 2004 Mihama nuclear power plant accident.

Regarding the amount to be used by each company, some plutonium is to be allocated to companies which will have no spent fuel reprocessed in fiscal 2005 and 2006. This will put pressure on these companies to proceed with Pluthermal plans, even thought they are not ready to do so.

Plutonium is also allocated to the non-existent Ohma Nuclear Power Plant. Ohma is still under review for a nuclear reactor installation license. It is still not certain Ohma will be built. Not surprisingly, no date is specified for plutonium use at Ohma.

Japan’s Atomic Energy Commission Must Not Accept Plan

Clearly FEPCO’s latest Plutonium Utilization Plan is not based on reality. The purpose of the plan is simply to enable the Rokkasho reprocessing plant to start “active tests” in February.

JAEC should uphold its own 2003 decision and state clearly that the plan is inappropriate. It should declare that “active tests” cannot begin at Rokkasho.

English translation of FEPCO’s Plutonium Utilization Plan chart issued 6 January 2006 is available at: http://cnic.jp/english/topics/cycle/MOX/pluplanFEPCO6Jan06.html

See also previous petition and briefing sent to the International Atomic Energy Agency on 5 January 2006
available at: http://www.greenaction-japan.org/modules/wordpress0/index.php?p=27
Briefing at: http://www.greenaction-japan.org/modules/wordpress0/index.php?p=28

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FOOTNOTES:

*1. On 10 January, twenty-five NGOs from Fukushima, Niigata, Fukui prefectures, Tokyo and Kansai metropolitan areas, and Kyushu issued a critique on FEPCO’s Plutonium Utilization Plan. Available in Japanese at: http://www.greenpeace.or.jp/campaign/nuclear/documents/doc060110.pdf

*2. The Rokkasho Reprocessing plant located in Aomori Prefecture, Japan is under construction and currently undergoing uranium commissioning. The plant has the capacity to reprocess 800 tons/HM of spent nuclear fuel a year. At full capacity, Rokkasho is capable of separating approximately 8 tons of plutonium annually.

*3. The use of plutonium fuel in light water reactors (’thermal’ reactors as opposed to ‘fast’ reactors) is called ‘pluthermal’. The fuel is made from a mixed oxide of plutonium and uranium, commonly referred to as MOX.

*4. Japan Atomic Energy Commission, “Framework for Nuclear Energy Policy”, 14 October 2005, p.11.

*5: Ibid., p. 34.

PDF Download
[Compiled 5 January 2006 by Green Action]

Statements on Rokkasho, Surplus Plutonium and MOX Fuel

Fukushima governor Eisaku Sato’s statement to the Japan Atomic Energy Commission about the Rokkasho reprocessing plant and surplus plutonium:

“Why rush to operate a new reprocessing facility when there is still no solution for disposing the 40 tons of plutonium Japan already possesses?”

Submission to Public Comment on draft of “Framework for Nuclear Energy Policy”, August 2005

—–

Of the 430 tons of spent nuclear fuel to be reprocessed during the active testing scheduled to start at the Rokkasho reprocessing plant in February, 310 tons belong to the two largest electric utilities in Japan – 170 tons from Tokyo Electric and 140 tons from Kansai Electric. Neither utility, however, can consume the plutonium that will be produced at Rokkasho.

All seventeen Tokyo Electric nuclear power plants are located in two prefectures, Niigata and Fukushima. As a result of public opposition andTokyo Electric’s safety data falsification in 2002, both prefectures withdrew authorization for MOX fuel use. Their opposition remains adamant.

Niigata Governor Hirohiko Izumida:

“The Pluthermal (MOX fuel utilization) issue is not even at a stage for discussion. It would be deplorable and damage the trust of the public and Niigata regional authorities if the Kashiwazaki-Kariwa nuclear power plant site were to be included in plutonium utilization plans and announced to the public.”

Excerpt from December 2005 letter submitted to Tokyo Electric president Tsunehisa Katsumata.
Source: Kyodo

“Niigata Governor Lodges Warning to Tokyo Electric Regarding Pluthermal (MOX utilization) Plans”
26 December, 2005

“In the middle of all of this, we have heard that the Kashiwazaki-Kariwa nuclear power plant site is being listed in the company’s Plutonium Utilization Plans….It is deplorable* that the Atomic Energy Commission is calling for public release of plutonium utilization plans at this time… We petition your committee that you understand this situation in our prefecture and take it into consideration in some manner.”

Excerpt from letter etter submitted to Shunsuke Kondo, Chair, Japan Atomic Energy Commission
27 December 2005

Fukushima Governor Eisaku Sato:

“I do not care what Tokyo Electric says. It is inconceivable that MOX fuel utilization takes place in this prefecture. I believe that Tokyo Electric understands the (prefecture’s) position.”

Excerpt from governor’s regular monthly press conference
26 December 2005

Source: Fukushima Minyu Newspaper (Morning News)

“Pluthermal (MOX fuel utilization) Inconceivable”
27 December 2005

“The governor, in giving his reasons, referred to the statement he had made during the September 2002 prefectural legislative session in which he stated, ﾔPrior consent (for MOX fuel utilization) has been withdrawn because the necessary conditions for granting it have collapsed.’ This statement by the governor was made after revelations in August (2002) that Tokyo Electric had concealed problems at its nuclear power plants. The governor (also) referred to the prefectural legislative assembly’s resolution in opposition and stated, ﾔWe have decided not to have the program implemented in our prefecture in accordance with the collective will of our citizens.’”

Excerpt from the Fukushima Minyu Newspaper article

“Pluthermal (MOX fuel utilization) Inconceivable”
27 December 2005

Meanwhile, due to the 2004 accident at Kansai Electric’s Mihama nuclear power plant, the utility itself admits implementing the MOX program is at present impossible.

Kansai Electric on MOX Program Status:

“At present we are concentrating fully on Mihama Unit 3 post-accident measures and are therefore not in the position to consider MOX fuel use.”

Kansai Electric
Osaka Headquarters
20 October 2005 (Repeated 20 December 2005)

[Informal English translation of news articles and statements are by Green Action.]

Status of Light Water Reactors using MOX Fuel in Japan

No electric utility in Japan has the go-ahead to consume MOX fuel.

Tables detailing the status for light water reactors using MOX fuel are available in English at:

”Japanese Nuclear Power Companies’ Pluthermal* Plans”

http://cnic.jp/english/topics/cycle/MOX/pluthermplans.html.

The tables have been compiled by Kakujoho (http://kakujoho.net/e/index.html) from publicly available documents and translated into English by Citizens’ Nuclear Information Center.

* In Japan, the program to use MOX (plutonium-urainum mixed oxide) fuel in light water reactors is called the “pluthernmal” program.

Green Action
Suite 103, 22-75, Tanaka Sekiden-cho, Sakyo-ku Kyoto, 606-8203, Japan
Phone: +81 75 701 7223 Facsimile: +81 75 702 1952 Email: amsmith@gol.com www.greenaction-japan.org