Green Action Japan

10 July 2006
Statement by Citizens’ Nuclear Information Center and Green Action

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Japan has opportunistically jumped on President George Bush’s Global Nuclear Energy Partnership (GNEP) bandwagon. Just when doubts were being expressed about the proliferation dangers of separating plutonium at the Rokkasho reprocessing plant in Aomori Prefecture, GNEP was like a gift from Uncle George.

The government is treating GNEP as a great opportunity to gain recognition of Japan’s unique position as the only Non Nuclear Weapons State (NNWS) member of the Non Proliferation Treaty with access to the full nuclear fuel cycle. Japan is the only NNWS with industrial scale facilities for both uranium enrichment and reprocessing of spent nuclear fuel.

The government also hopes that GNEP will provide a lifeline for Japan’s ailing nuclear industry. The nuclear research establishment can scarcely conceal its delight and nuclear manufacturers, faced with shrinking sales each year, will be only too happy to pick up any contracts that come their way. However, it is far less clear that electric power companies share this enthusiasm. They are the ones who will have to sell any electricity produced by the reactors envisaged under GNEP and they are under no illusions about the likely price.

Somewhere in all of this, the Japanese government has lost site of the fact that it is highly unlikely that GNEP could help provide the Japanese public with any substantive source of energy in any reasonable length of time.

Even if the government is not inclined to look the GNEP gift horse in the mouth, we believe that before Japan makes any firm promises and commits any money, a more balanced assessment is required. The following brief analysis highlights some major problems that the government has not addressed.

Key components of GNEP

Though the details are far from clear, GNEP promises to develop the following:

• proliferation-resistant spent nuclear fuel reprocessing technologies;
• “advanced burner reactors” that can use plutonium mixed with other radioactive wastes as fuel;
• small-scale reactors suitable for developing countries; and
• nuclear fuel supply arrangements whereby a limited number of “fuel supplier nations” provide fuel services to “user nations” which forego the right to fuel cycle technology.

Spent fuel would be returned to the supplier countries for reprocessing. This “cradle-to-grave” fuel leasing approach is supposed to reduce the risk of proliferation and reduce the radioactive waste going to geological repositories. Researchers and NGOs in the US have already debunked these promises*1, so here we restrict ourselves to stating a few of the reasons why GNEP will not achieve what it claims.

The proliferation-resistance of the proposed new reprocessing technologies is based on the idea that plutonium will not be separated in pure form. It is claimed that by including other radioactive elements (referred to variously as transuranics or actinides) in the final product their radioactivity will act as a barrier to people who might wish to divert the plutonium to nuclear weapons. However, as explained by Kang and von Hippel*2, the radioactivity of the product will be well below the level the International Atomic Energy Agency considers to be “self-protecting”. Hence, these new reprocessing technologies cannot be said to be proliferation-resistant. GNEP offers no solution to the proliferation problems of reprocessing. Rather, by highlighting the dangers of the separation process currently used, the so-called “PUREX” process, GNEP confirms that the Rokkasho reprocessing plant is dangerous from the perspective of nuclear proliferation.

The proposed advanced burner reactors and small-scale reactors don’t exist yet and there are huge technological, safety and economic obstacles to be overcome. They will not be commercially viable for decades, if ever, and in the meantime the plutonium stockpile and the radioactive waste mountain continue to grow.

As for the idea of establishing a group of authorized fuel supplier nations (the US Department of Energy referred to them as a “consortium”, but a more honest label would be a “cartel”), it is hard to believe that the rest of the world will willingly subject itself to eternal dependence on a handful of privileged countries.

Japan’s offer of cooperation

Clearly GNEP is far from being a practical proposal promising a solution to the current pressing problems associated with nuclear energy and the nuclear fuel cycle. Nevertheless, the Japanese government is falling over backwards to appear supportive. A May 5th Ministry of Education, Culture, Sports, Science and Technology document*3 outlined five areas of research and development cooperation:

1. joint collaboration on the design of a US nuclear recycling facility.
2. joint development of FR/FBR fuel utilizing Joyo and Monju.
3. joint development of structural material for streamlined, compact reactors.
4. joint development of major components (such as steam generator) for sodium-cooled reactors.
5. joint development of safeguards concepts for nuclear fuel recycling facility based on Japan’s experience.

(Note: The English translation includes “FR/FBR” in item 2, although no corresponding words appear in the Japanese version.)

Japan is already doing research in all of these areas. Rather than offering anything new, the government is hoping to gain recognition for its existing programs and to be part of the action in the massive long-term spending program that GNEP will entail. However, besides being very expensive and totally impractical, GNEP has other features which will inevitably prove to be indigestible for Japan.

The issue that will attract the broadest opposition is the “cradle-to-grave” approach to fuel supply. GNEP envisages fuel supplier nations taking back the spent fuel, reprocessing it and burning the plutonium and minor actinides in advanced burner reactors. Japan does not now have the capacity to reprocess all the spent fuel from its own nuclear reactors and it is stretching the imagination to think that it will ever have the capacity to reprocess spent fuel from overseas. However, even if the capacity problem could be solved, prefectural and local governments are unlikely to agree to accept spent nuclear fuel from overseas. GNEP is vague about what will happen to the waste from reprocessing foreign spent fuel, but it implies that the fuel supplier nations will also end up providing the final waste repositories. Given the difficulty of finding a repository for Japan’s own high-level waste, it is inconceivable that there will be any volunteers to accept foreign waste.

Anticipating this problem, the Japanese government has already indicated that it will not take back spent fuel from overseas. This undermines Japan’s aspirations to the status of “fuel supplier nation”. We believe GNEP’s chances of success are zero in any case, but when aspiring fuel supplier nations pick and choose in this way, GNEP is exposed for the fraud that it is.

Japan is promoting its fast breeder reactor program as an area of potential GNEP cooperation. There is an inherent contradiction in this. GNEP does not propose the use of fast breeder reactors. It talks about fast burner reactors. Breeder reactors are designed to “breed” plutonium in a blanket of uranium around the core. The plutonium produced in this way is “super weapons grade”, because of the very high percentage of the isotope of plutonium-239. Breeder reactors are therefore completely incompatible with non-proliferation. Other than the breeding component, the basic technology for fast breeders and fast burners is the same, but if GNEP is really set up to address proliferation concerns, the Japanese government will have to abandon its dream of nuclear power based on breeder reactors.

The government’s offer of cooperation involving the sodium-cooled fast reactors Joyo and Monju, both of which were designed to be breeder reactors, is a good illustration of the cynical way it is approaching GNEP. No doubt it hopes the US will relent and expand the scope of GNEP to include breeders. It would have been encouraged by President Bush’s remarks at a press conference during Prime Minister Koizumi’s recent visit to the US:

“We discussed…our contributions to some research and development that will help speed up fast breeder reactors and new types of reprocessing so that we can help deal with the cost of globalization when it comes to energy…” (White House, 29 June 2006)

The President might not understand the difference between “fast burner reactors”, as originally proposed for GNEP, and “fast breeder reactors”. However, if he does, then his comment is an early indication that Japan’s involvement in GNEP, far from strengthening the non-proliferation system, is more likely to further undermine any spurious non-proliferation claims that might be made for GNEP.

There are also other ways in which Japan’s involvement in GNEP will undermine the non-proliferation system. The Non Proliferation Treaty (NPT) enshrines discrimination between Nuclear Weapons States (NWS) and Non Nuclear Weapons States (NNWS). Japan adds a further level of discrimination between nuclear fuel cycle states (NFCS) and non nuclear fuel cycle states (NNFCS). Japan’s involvement in GNEP will reinforce this discrimination. However, as Mohamed ElBaradei has repeatedly pointed out, the discrimination between NWS and NNWS is unsustainable. Likewise, discrimination between NFCS and NNFCS will be unsustainable. Japan’s defacto status as a NFCS is already generating envy overseas and experts have warned that operation of the Rokkasho reprocessing plant could undermine international efforts to discourage other countries from building their own reprocessing and enrichment facilities. The whole framework of GNEP ignores these basic obstacles.

Costs

Japan’s nuclear fuel cycle program has been under development in the name of “energy independence” for half a century. Where has it gotten Japan? Despite spending several trillion yen (tens of billions of dollars) of ratepayer and taxpayer money, closing the Japanese fuel cycle has been an economic failure and a detriment to public safety.

Japan’s Rokkasho reprocessing plant, located in Aomori Prefecture in the north of Japan, is now undergoing “active testing” leading up to commercial operation scheduled for August 2007. The plant is slated to separate plutonium from spent nuclear fuel for use in Japan’s nuclear reactors. At a cost of 2.3 trillion yen (about 20 billion U.S. dollars) to ratepayers, it is said to be the most expensive plant ever built in the history of the world. The Japanese government and utilities estimate that the total bill for choosing the reprocessing option and operating the Rokkasho reprocessing plant will be 19 trillion yen*4 (about $160 billion U.S.), far more than disposing without reprocessing. Critics say it will cost far more. A second reprocessing plant will be needed for the spent fuel that Rokkasho cannot handle. This is estimated to raise costs to 43 trillion yen (about $375 billion U.S.).

Other parts of the nuclear fuel cycle program fare no better. Scheduled to have started in 1999, the use of mixed plutonium-uranium oxide (MOX) fuel in commercial nuclear reactors is yet to begin. With the exception of minor testing undertaken years ago, the program has to date produced no electricity. The third pillar of Japan’s nuclear fuel cycle program is its fast breeder reactor program, which after 50 years of development has produced a grand total of 1 hour of electricity. Future prospects appear no brighter. The government’s current nuclear energy policy has the fast breeder commercialized by 2050, an astonishing 70 years behind the original schedule set in 1961.

With a record like this, one would have thought that, rather than jumping on the GNEP bandwagon, the Japanese government would be looking for a way out of its nuclear fuel cycle program. Pursuing the elusive dream of “closed” nuclear fuel cycles, such as those promised by GNEP, will mire Japan and the US in a quagmire of higher nuclear power costs, increased plutonium surplus, and snowballing nuclear waste headaches.

Conclusion

GNEP will not reduce the risk of nuclear proliferation. It will not reduce the burden of radioactive waste produced by nuclear power plants. Nor will it contribute to meeting the world’s energy demand. The money wasted on GNEP would be far better spent on sustainable alternatives to fossil fuels and nuclear power.

The PUREX process of separating plutonium from spent nuclear fuel, used at the Rokkasho reprocessing plant, gives rise to serious proliferation risks. Likewise, there are serious proliferation risks associated with fast breeder reactors, including the Monju prototype fast breeder reactor. These risks are in addition to the safety and radioactive waste risks associated with the Rokkasho reprocessing plant and Monju.

The Japanese government is not in a position to make a substantial contribution to GNEP’s purported aims. Rather, the government’s offer to cooperate with GNEP is opportunistic, cynical, and impractical. Like its contribution to the “coalition of the willing” in Iraq, its contribution to GNEP will be purely symbolic.

Demands

1. The Japanese government should withdraw its opportunistic, cynical, and impractical offer to cooperate with GNEP and engage in a public debate about the proliferation, safety and radioactive waste problems arising from its nuclear fuel cycle policies. Unlike the deliberations of the Atomic Energy Commission’s Nuclear Policy-Planning Council, which led to the production of the Framework for Nuclear Energy Policy, a process should be established in which serious problems are debated honestly and scientifically. Conclusions should not be reached on the basis of pre-rigged numbers on committees, but on the basis of the merits of the arguments.
2. Active testing of the Rokkasho reprocessing plant should be stopped.
3. Japan’s fast breeder program, including moves to restart the Monju prototype fast breeder reactor, should be stopped.

Hideyuki BAN
Co-Director,
Citizens’ Nuclear Information Center

Aileen Mioko Smith
Director,
Green Action

Contacts:
Aileen Mioko Smith (Director, Green Action) 81-75-701-7223
Hideyuki Ban (Co-Director, CNIC) 81-3-5330-9520
Philip White (International Liaison Officer, CNIC) 81-3-5330-95220

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*1. The following is a selection of references debunking the claims of GNEP (including articles published before GNEP was announced).

“Nuclear Terrorism and Nuclear Reactors, Extracting Plutonium from Nuclear Reactor Spent Fuel Would Increase Risk of Terrorists Acquiring Nuclear Weapons and Exacerbate Nuclear Waste Problem”, Union of Concerned Scientists

“The limited proliferation-resistance benefits of the nuclear fuel cycles being researched by the Department of Energy’s Advanced Fuel Cycle Initiative,” June 08, 2005, by Jungmin Kang and Frank von Hippel, Program on Science and Global Security, Princeton University

“Is U.S. Reprocessing Worth The Risk?” Arms Control Today, Steve Fetter and Frank N. von Hippel, September 2005

“Fast Reactors: Unsafe, Uneconomical, and Unable to Resolve the Problems of Nuclear Power”, Public Citizen

The Nuclear Alchemy Gamble: An Assessment of Transmutation as a Nuclear Waste Management Strategy, Institute for Energy and Environmental Research, August 25, 2000
summary available at “Waste Transmutation: The Nuclear Alchemy Gamble”

*2 Ibid., Kang and von Hippel

*3 “MEXT’s Proposal of Cooperation areas in GNEP”, Ministry of Education, Culture, Sports, Science and Technology, May 5, 2006

*4 “Japanese Nuclear Industry’s Back End Costs”

“In November [2003] the Federation of Electric Power Companies of Japan　stated that total back-end costs amount to about 19 trillion yen (18.8　trillion). This includes the construction, operation, repair, dismantling and waste management of Rokkasho Reprocessing Plant, plus the MOX plant and the transport, storage and disposal of radioactive waste returned from overseas…The total cost calculations for the plant are based on it operating for 40 years from 2006 then taking 32 years to dismantle. In total, the Rokkasho Reprocessing Plant alone consumes 11 trillion yen, or 60% of the total back-end costs.”）

10 July 2006
Japan's nuclear fuel cycle program has been under development since 1956. Despite several trillion yen (tens of billions of dollars) of ratepayer and taxpayer money spent, the program fails to provide any electricity to the public.

Japan's nuclear fuel cycle program is comprised of the development of fast breeder reactor technology, use of mixed (plutonium and uranium) oxide fuel in commercial nuclear power plants, and reprocessing of spent nuclear fuel. None of these have attained commercial-scale use.

The Fast Breeder Reactor Program

Japan's fast breeder reactor (FBR) program begun under Japan's Long-Term Program for Research, Development and Utilization of Nuclear Energy (LTP) was originally scheduled to attain commercialization in the 1970's. So far the date for commercialization has been postponed 7 times. Present plans under the Framework for Nuclear Energy Policy is to “strive for the commercial use of FBRs from around 2050,“ a 70-year delay from the original plan.1

The fast breeder reactor development program has so far produced only one hour of electricity. This occurred on August 29,1995 when Monju, the prototype fast breeder reactor (located in Fukui prefecture) generated electricity for an hour at 5% output.2 Monju had a sodium leak and fire accident 3 months later on December 8, 1995 and has been shutdown since then. The reactor is being refurbished and re-start is scheduled for spring of 2008.

To date about 1 trillion yen (about $9 billion U.S.) of taxpayer and ratepayer money has been spent on the fast breeder reactor development program.

No design or site has been selected for the demonstration fast breeder reactor.

Year of LTP Planned date of Commercial Implementation of FBR

1956———-
1961———-1970's
1967———-1985-90
1972———-1985-95
1978———-1995-2005
1982———-Around 2010
1987———-Around 2020's – 2030's
1994———-By around 2030
2000———-(No date specified)
20053———From around 2050

Japan's Mox Fuel Program For Lwr's

Scheduled to have started in 1999, the use of mixed plutonium-uranium oxide (MOX) fuel in commercial nuclear reactors (light water reactors) is yet to begin. With the exception of minor testing undertaken years ago, the program has to date produced no electricity.

There is considerable opposition to the MOX program both locally and nationally. In 2002 the governors of Fukushima and Niigata prefectures rescinded their prior approval for MOX fuel use at Tokyo Electric's nuclear power plants in their prefectures. Kansai Electric, the second largest utility in Japan has failed twice to go forward with its program, once due to a scandal in 1999 involving quality control data falsification by the British MOX fuel fabricator BNFL, and a second time in 2004, due to rupture of a secondary steam pipe at the utility's Mihama Unit 2 nuclear power plant involving death and injury of workers.

So far, only two prefectures are approving use of MOX fuel.

Commercial Scale Reprocessing

Japan's Rokkasho reprocessing plant, located in Aomori Prefecture in the north of Japan, is now undergoing “active testing“ leading up to commercial operation scheduled for August 2007. The plant is slated to separate plutonium from spent nuclear fuel for use in Japan's nuclear reactors. At a cost of 2.3 trillion yen (about 20 billion U.S.) to ratepayers, it is said to be the most expensive plant ever built in the history of the world.

Choosing the reprocessing option and operating the Rokkasho reprocessing plant will cost 19 trillion yen (about $160 billion U.S.), far more than disposing without reprocessing.4 Critics say it will cost far more.

A second reprocessing plant will be needed for the spent fuel that Rokkasho cannot handle. This is estimated to raise costs to 43 trillion yen (about $375 billion U.S.).

Continuing the reprocessing program will mire Japan in a quagmire of higher nuclear power costs, increased plutonium surplus, and snowballing nuclear waste headaches.

Rokkasho's operation constitutes a violation of Japan's 1997 pledge to the IAEA not to accumulate a plutonium surplus.5 Japan already has over 42 tons of separated plutonium stockpiled in Europe and Japan, so any additional plutonium separated at Rokkasho is not needed and will continue to accumulate on site for years.

Public Opposition And Safety Concerns

Besides the problem of nuclear proliferation, Japan's nuclear program poses a safety and environmental problem.

In Fukui prefecture where the Monju prototype reactor is located, primarily out of safety concerns, nearly a quarter of the region's population has signed a petition seeking that the reactor never be operated again.

According to a survey by Aomori prefecture where the Rokkasho reprocessing plant is located, 81.6% of its population is uneasy (feels anxious about the nuclear fuel cycle and nuclear power facilities in the prefecture.6

Aomori is a major agricultural and marine products producer. In February of this year the prefecture announced that radiation levels in the region's rice will rise to twice the present background level with Rokkasho reprocessing plant operation. Levels in seaweed would increase 2000 times. Major supermarkets in central Japan have said they won't buy the products even if contamination levels are low.

Repeated technical bungling by Rokkasho's owner-operator, Japan Nuclear Fuel, Ltd. since the start of testing, has resulted in the Japanese government, the Aomori governor, and the Aomori legislature coming down hard on the company. A special legislative session will be held shortly, solely on JNFL-generated woes.

In Iwate prefecture just south of Aomori, 15 municipalities have petitioned Aomori prefecture because of safety and environmental concerns about the Rokkasho reprocessing plant.

There is considerable citizen opposition to the MOX fuel utilization plan in LWRs. One of the issues involves safety concerns about Japanese utilities intending to load one-quarter of the core with MOX fuel to high burn up levels without undergoing testing at the same or equivalent reactors.

Of the four significant nuclear accidents in Japan during the past decade, three–including one that required evacuation of the public–were at nuclear fuel cycle facilities. In short, the nuclear fuel cycle is giving a bad name to Japan's entire nuclear power program.

Economic

According to its current balance sheet, the owner operator of the Rokkasho reprocessing plant, Japan Nuclear Fuel, Ltd. is 2.5 trillion yen (about $10 billion U.S.) in debt.7

Can Japan Cooperate In GNEP?

GNEP could have a significant impact on Japan's fuel cycle policy, and raises serious questions about the proliferation risks associated with Japan’s fuel cycle program. For example, the reprocessing used at Rokkasho is considered a proliferation risk under GNEP. GNEP also appears to recognize the proliferation risks associated with the fast “breeder“ reactors that Japan is developing as well. The technology breeds weapons-grade plutonium as it operates.

GNEP proposes that “fuel supplier states“ will reprocess other countries' spent fuel, but Japan does not have the capacity to reprocess all its own spent fuel, let alone take on any fuel from overseas. Since the Japanese government cannot even secure a site for Japanese highly radioactive reprocessing waste, even if the domestic reprocessing capacity problem were solved, Japanese prefectures and local governments will oppose the import of foreign fuel.

GENP also has serious implications the financially strained Japanese electric utilities can ill afford. The Japanese government is not in a position to make a substantial contribution to GNEP's purported aims. Like its contribution to the “coalition of the willing“ in Iraq, its contribution to GNEP will be purely symbolic— a house of cards.

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Footnotes

1.

Framework for Nuclear Energy Policy (Tentative Translation), October 11, 2005, Japan Atomic Energy Commission, p.29.

2.

PNC, August 29, 1995.

3.

The Long Term Program for Research, Development and Utilization of Nuclear Energy was renamed the framework for nuclear Energy Policy in 2005.

4.

The 19 trillion yen cost was submitted by the Federation of Electric Power Companies (FEPCO) to the Subcommittee to Study Costs and other Issues of the Electricity Industry Committee of the Advisory Committee for Natural Resources and Energy. (2005). It is the amount required to operate the Rokkasho reprocessing plant for 40 years, including MOX manufacture. The Rokkasho reprocessing plant is to reprocess 32,000 tons of spent nuclear fuel. A second reprocessing plant is not taken into account in this cost calculation. Consideration of a second reprocessing plant is scheduled to begin in 2010. Operations are scheduled to begin before the current Rokkasho reprocessing plant stops in 2045. Size and amount to be reprocessed is not yet decided.

5.

Statement submitted by the Japanese -government to the IAEA. In 1997.

6.

Poll undertaken by Aomori prefecture September 25 – October 14, 2003.

7.

JNFL financial report of assets and liabilities, March 31, 2006.

[Translated from Japanese] [March 13, 2006]

To: Mr. Toshihiro Nikai
Minister of Economy, Trade and Industry

As stated in the enclosed 9 March letter from Dr. Edwin Lyman (Union of Concerned Scientists) and Professor Frank von Hippel (Princeton University) to Aomori Governor Shingo Mimura, there are points that cannot be supported by facts in the explanation given by the Japanese Government to the six US Democratic members of Congress including Edward Markey, and to Aomori Prefecture. This concerns the international implications for nuclear proliferation of the Rokkasho reprocessing plant. I therefore request that you take the following action before beginning active tests at the plant:

1. Provide a detailed technical account of why METI believes that MOX is far less useable for making nuclear weapons than pure plutonium oxide.
2. Show in graph form the year-by-year accumulated plutonium inventory at the Rokasho reprocessing in order to explain how the plutonium that is to be accumulated.if and when its separation begins will be consumed based on the power companies’ utilization plans.
3. Explain how Japan justifies the logical inconsistency of commencing reprocessing at Rokkasho using the PUREX method which has nuclear proliferatoion risks, while supporting GNEP which is critical of the PUREX method. The Global Nuclear Energy Partnership (GNEP) initiative maintains that since the PUREX (plutonium-uranium extraction) reprocessing method (the method used at the Rokkasho reprocessing plant) is accompanied by high nuclear proliferation risks, it aims to develop new methods including UREX plus (uranium extraction +) .

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Jungmin KANG, Ph.D.
Independent Nuclear Policy Analyst (August 2002 -Present). Advisor on nuclear energy policy, PresidentialCommission on Sustainable Development, Republic of Korea. Visiting Research Fellow at Princeton University (1999-2000). Associate of Nautilus Institute.

130-dong, 504-ho
Seoul National University
Shilim-dong, Kwanak-go
Seoul 151-742
Republic of Korea

[Translated from Japanese] [March 13, 2006]

METI officials responded along the following lines to the demands of Dr. Kang and five Japanese organizations. They promised to consider providing a written response to demands 1 through 3.

Response to 1:

Mr. Shinichi Mizumoto, Planning Officer (responsible for international nuclear energy issues), Nuclear Energy Policy Division, Agency for Natural Resources and Energy, METI:

The MOX issue is only one aspect of the holistic measures which consist of safeguards, physical protection, etc. We object to it being taken up independently. Since precautions are taken to prevent theft, I cannot respond to the question regarding the different degree of concern between MOX and plutonium oxide in the case of theft. Since we ensure that it won’t be stolen, the question “what if it is stolen” doesn’t arise. We do not have any arguments against the views in the IAEA Safeguards Glossary.
http://www-pub.iaea.org/MTCD/publications/PDF/nvs-3-cd/PDF/NVS3_prn.pdf

Response to 2:

Mr. Takuto Miyamoto, Chief Official, Nuclear Fuel Cycle Industry Division, Agency for Natural Resources and Energy, METI:

It is up to the companies to decide whether they will first use the plutonium held in Europe or the plutonium separated at Rokkasho. This is not something for the government to dictate. The concept of surplus plutonium is not a quantitative one.

[The question was posed, “METI would not call the plutonium surplus even if it increases to 100 tons, or 200 tons, or 300 tons, as the power companies say they will use it eventually?”]

As long as there is a utilization plan, it is not surplus. But this shouldn’t be interpreted to mean that it would not be considered surplus even if it reached 10,000 tons.

Response to 3:

Mr. Shinichi Mizumoto, Planning Officer (responsible for international nuclear energy issues), Nuclear Energy Policy Division, Agency for Natural Resources and Energy, METI:

Japan is also doing research into new reprocessing technologies, so there is no inconsistency.

Response regarding the reply to Congressman Markey, et al.:

Mr. Shinichi Mizumoto, Planning Officer (responsible for international nuclear energy issues), Nuclear Energy Policy Division, Agency for Natural Resources and Energy, METI:

The Ambassador has replied to Congressman Markey, et al. You have therefore addressed your demands to the wrong place.

[Akira Kawasaki, Co-Director of Peace Boat, who attended the meeting with METI stated the Ambassador’s reply was not considered adequate. (Peace Boat is one of the five organizations having submitted the demands to METI.)]

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Translated by Kakujoho, Green Action, and Citizens’ Nuclear Information Center.

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.