Dear Mr. Mendonca:
Following are Serious Texans Against Nuclear Dumping's (STAND
of Amarillo, Texas) comments on the Public Consultation for the
BNFL Sellafield MOX Plant.
MOX proposals in the United States are directly linked to
European MOX programs, and BNFL has in the past
inappropriately, and inaccurately used a "swords to plowshares"
argument to lobby for MOX in the U.S.A. After reviewing BNFL's
environmental and fiscal record, STAND is convinced that the
Sellafield MOX plant will fall far short of BNFL's wishful claims,
much as the THORP reprocessing plant has been a boondoggle.
The Sellafield MOX Plant and THORP are international issues. All
of the MOX fuel (at this time) is targeted for overseas shipments,
as no UK Nuclear Reactors are licensed to use MOX, or have
expressed a desire to use MOX. A decision to license the MOX
facility will have adverse impacts on the already heavily polluted
waters of the Irish Sea and the North Atlantic, and will lead to
plutonium proliferation worldwide.
Furthermore, BNFL has failed to operate its Demonstration MOX
Plant at Sellafield in a safe manner in the past five years.
Thank you for this opportunity to comment.
COMMENTS ON THE PROPOSED OPERATION
OF THE SELLAFIELD MOX PLANT
From:
Institute for Resource and Security Studies
27 Ellsworth Avenue, Cambridge, Massachusetts 02139, USA
July 1999
1. Introduction
These comments respond to a consultation document published on behalf of the Secretary of State for the Environment, Transport and the Regions and the Minister of Agriculture, Fisheries and Food (the Ministers). The consultation document solicits views on the economic case for the Sellafield MOX plant, but also notes that wider issues are relevant. It quotes a determination by the Environment Agency that "major developments at Sellafield are national and international matters...."
The Institute for Resource and Security Studies (IRSS) submits these comments on its own behalf, as a contribution to public debate. The comments were prepared by Gordon Thompson.
2. Scope of these comments
These comments are not limited to the economics of the Sellafield MOX plant, but also address wider issues of international security. Operation of the plant cannot be justified if it creates significant adverse impacts on international security.
Here, IRSS takes a broad-brush approach to some of the major issues associated with the Sellafield MOX plant. Our comments reflect IRSS's extensive experience with issues of this kind. Each comment can be supported by analysis and a large body of literature.
3. MOX fuel and international security
The use of MOX fuel is intensely controversial. This controversy arises for good reasons. MOX fuel is a technological option at the conjunction of two major problems of international security: (i) preventing the threatened or actual use of nuclear weapons; and (ii) providing a supply of energy in a manner consistent with sustainable development. One must ask: does the use of MOX fuel help or hinder the solution of these problems?
Plutonium and nuclear weapons proliferation
MOX fuel is part of a fuel cycle in which plutonium is separated from spent reactor fuel. While plutonium remains in the spent fuel, it is comparatively inaccessible, due to the presence of highly radioactive fission products. After separation, plutonium is managed as a liquid (nitrate) or solid (oxide). In these forms it is readily accessible and can be fabricated into the fissile component of a nuclear weapon. After incorporation into fresh MOX fuel, plutonium is somewhat less accessible but is not accompanied by fission products; it can, therefore, be re-separated by comparatively simple processes.
For several decades, informed observers have been concerned that plutonium separation will encourage the proliferation of nuclear weapons. Plausible scenarios exist for the diversion of kilogram quantities of plutonium at various points in the fuel cycle, and there is no longer any dispute that a nuclear weapon can be made from commercial-grade plutonium. Thus, plutonium separation poses a direct threat of nuclear weapons proliferation, either by states or by sub-state actors. In addition, plutonium separation poses an indirect threat of nuclear proliferation, which can occur at a larger scale.
The indirect threat arises through at least four mechanisms. First, plutonium separation in states such as Britain creates a precedent of legitimacy, thereby facilitating the acquisition of plutonium by governments whose true purpose in acquiring the plutonium is to deploy, or threaten to deploy, nuclear weapons. Second, plutonium separation creates large stocks of accessible plutonium (e.g., in Germany and Japan) that could support the rapid deployment of new, large nuclear arsenals at times of world instability, potentially exacerbating that instability through a positive feedback effect. Third, ongoing separation of civil plutonium can encourage complacency about the poorly secured stocks of plutonium and highly-enriched uranium in the ex-USSR. Fourth, small-scale diversion of separated plutonium for weapons use, or the threat of such diversion, could influence decisions by governments to expand, retain or acquire nuclear arsenals.
Fortunately, the worldwide scale of plutonium separation is smaller than was envisioned in previous decades, when governments planned to deploy breeder reactors. Nevertheless, tonnes of plutonium are separated annually, while only a few kilograms are needed for a nuclear weapon. British and French reprocessing plants perform much of the separation.
Other security implications of plutonium separation
The potential for diversion of plutonium from separated stocks of plutonium or from MOX fuel creates a need for measures to hinder diversion. Measures that are taken include secrecy, deception, close oversight of relevant personnel, provision of armed guards, and containment, surveillance and accounting measures. Some of these measures have significant adverse impacts on civil liberties and political culture.
If diverted by a sub-state actor (e.g., a terrorist group), separated plutonium could be used to make a nuclear weapon, perhaps of comparatively low explosive yield. Alternatively, plutonium could be employed in a radiological weapon. If used, such a radiological weapon could require evacuation of the surrounding population and the implementation of difficult decontamination measures. Through the actual or threatened use of a nuclear or radiological weapon, a sub-state actor who is skilled in psychological manipulation could generate political effects which would be very costly to the targeted state.
MOX fuel as an energy source
Supply of energy, in a manner consistent with the dictates of sustainable development, will be an important element of international security over coming decades. Thus, if MOX fuel were important as an energy source, the need for energy might offset some of the negative impacts of MOX fuel. However, it is clear that MOX fuel will not be a significant energy source during the next several decades.
Numerous studies have shown that MOX fuel is uneconomic at present uranium prices and those expected over the coming decades. No electric utility company operating in a truly competitive environment would employ MOX fuel unless a government subsidy, sufficient to offset the additional costs of MOX fuel, were in effect. Thus, the present world market for MOX fuel is an artifact of non-competitive arrangements and regulatory constraints in the electricity sectors of a handful of states. Under the pressures of international economic competition, these arrangements and constraints will play a diminishing role. There are trends toward greater competition in electricity supply in all states that might use MOX fuel. Within a few years, it is likely that the MOX fuel market, if such a market exists, will be dependent on explicit subsidies.
Why subsidise MOX fuel?
Why would governments subsidise the use of MOX fuel? From the perspective of energy supply, there is no logical reason for a subsidy. For the next several decades, nuclear reactors can operate without MOX fuel. Plutonium might have some role as a fuel in the subsequent period, but the present use of MOX fuel will do nothing to support that role.
The one logical reason that could exist for subsidising MOX fuel is to reduce existing stocks of separated plutonium, both civil and military. If plutonium is incorporated into MOX fuel which is burned and then stored, there is a net reduction in the mass of plutonium and the remaining plutonium becomes comparatively inaccessible (i.e., it is "locked up" in the spent MOX fuel). This is a desirable outcome from the perspective of nuclear weapons proliferation. However, there are alternative options for converting stocks of separated plutonium to an inaccessible form. For example, separated plutonium could be incorporated in a glass matrix (i.e., vitrified) together with highly radioactive fission products. These fission products would be obtained from stocks of liquid or calcined high-level waste held at reprocessing plants.
If governments are willing to spend money to render separated plutonium inaccessible -- by burning it as MOX fuel, vitrifying it, or in some other way -- the logical accompanying action would be to stop separating plutonium. This would be achieved by stopping the reprocessing of spent nuclear fuel. In the special case of Britain's Magnox reactors, the reactors would also be closed, because their fuel cycle cannot readily be converted to storing, rather than reprocessing, spent fuel. However, the Magnox reactors are already near the ends of their operating lifetimes.
Summary
Thus, separation of plutonium poses a direct and indirect threat of nuclear weapons proliferation, and other security threats. It thereby undermines international security. MOX fuel is part of a fuel cycle which involves plutonium separation. For the next several decades, use of MOX fuel will be uneconomic and unnecessary for energy supply. Given competitive trends in electricity supply, a future market for MOX fuel will only exist if governments provide explicit subsidies. The only logical reason to subsidise MOX fuel would be to reduce world stocks of separated plutonium, both civil and military. Such a reduction would be a desirable outcome from the perspective of international security, but use of MOX fuel is not the only option for rendering plutonium inaccessible. Moreover, any strategy for reducing stocks of separated plutonium would logically involve a halt to reprocessing.
4. Trends in nuclear proliferation
The preceding discussion shows that MOX fuel, if used within the context of continued reprocessing, will promote nuclear proliferation. Conversely, use of MOX fuel could help to curb nuclear proliferation if reprocessing is halted and MOX fuel is used as a means of converting separated stocks of plutonium to an inaccessible form. Other means of plutonium conversion, such as vitrification, are also available.
In considering the implications of these findings for operation of the Sellafield MOX plant, it is important to review the gravity of the nuclear proliferation threat and the trends in that threat. If the threat is significant and growing, then nuclear proliferation considerations should dominate decision-making about the MOX plant.
The significance of nuclear proliferation
At worst, continued nuclear proliferation could help to precipitate a nuclear war. Such a war could be localized (e.g., in South Asia) or global. The very worst case would involve use of the large nuclear arsenals that are still retained by Russia and the USA. By general agreement, even a localized nuclear war would be a disaster whose prevention should be of the highest priority for governments.
At lower levels of severity, there is a wide spectrum of potential adverse outcomes from nuclear proliferation. For example, proliferation could promote regional arms races that are politically destabilizing and expensive. Proliferation could feed a trend, which some analysts believe is already under way, for states to band together in mutually hostile blocs. Efforts by powerful states to suppress proliferation in weaker states could feed the same trend. Sub-state actors or embittered governments could conduct nuclear terrorism within powerful states. If conducted cleverly, such terrorism could stimulate the governments of powerful states to destroy the civil liberties of their own citizens in an effort to root out the terrorist threat. The prevention of these and other potential outcomes deserves a high priority.
Underlying trends
Following a comparatively promising period in the early 1990s, the trend lines of nuclear proliferation have become adverse in recent years. For example, India and Pakistan have tested nuclear weapons and seem determined to deploy nuclear arsenals. Iran is widely believed to be acquiring nuclear weapon capability. A Saudi Arabian delegation recently visited Pakistan's nuclear weapon and missile development sites. There is an active international trade in ballistic missile technology, and several governments are quietly seeking supplies of fissile material (plutonium or highly-enriched uranium).
As has been true since the Manhattan Project of the 1940s, acquiring fissile material is typically the major bottleneck in a government's plans to acquire nuclear weapon capability. Thus, a government that wants to keep open the option of deploying nuclear weapons will seek sources of fissile material. This phenomenon may be occurring in Australia, where the government is building a new research reactor although the civilian need for this reactor is questionable.
A variety of factors are responsible for the adverse trend lines. Three deserve mention here. First, the technological barriers to acquiring nuclear weapon capability are becoming lower, and could become lower still if technology and fissile material become widely available from an impoverished Russia. Second, some governments fear a breakdown in regional or global order. Third, the nuclear-armed parties to the Non-Proliferation Treaty have made it clear that they will not honor the pledge of nuclear disarmament that they made in order to secure indefinite extension of the Treaty in 1995.
NATO's promotion of nuclear proliferation
Without explicitly setting out to do so, NATO has greatly exacerbated the adverse trends in nuclear proliferation. This has occurred in three ways. First, NATO's expansion toward Russia's borders has been interpreted by Russia as a direct threat and a breach of previous assurances. In its weakened state, Russia has responded by placing greater reliance on nuclear weapons in its military planning. Second, NATO explicitly reserves the right to initiate nuclear attack. Third, NATO's bombing of Yugoslavia demonstrates a willingness to use deadly force without regard for the structure of international law that was erected after World War II.
The full aftermath of NATO's bombing will become apparent over the coming years. Already, the bombing has poisoned NATO's relations with Russia and China, and has stimulated Ukraine and Belarus to reconsider their non-nuclear status. Many observers fear that NATO has gravely weakened the international non-proliferation regime. That regime, the product of immense diplomatic effort over decades, was already under strain, as described above.
5. Britain's responsibility
As one of a handful of states that engage in large-scale separation of plutonium, Britain has a special responsibility to consider whether its plutonium activities are enhancing or undermining international security. As a leader in NATO's adoption of a policy of aggressive intervention, Britain has a further responsibility to consider whether this policy is feeding or curbing the proliferation of nuclear weapons.
Experience suggests that the British government will not exercise the needed level of responsibility in considering the operation of the Sellafield MOX plant. Nuclear policy-making in Britain has an unfortunate history of secrecy, deception and cynicism. The present consultation provides clear evidence of cynicism, by proposing that the capital cost of the MOX plant should be excluded from a determination that the plant's operation is justified on economic grounds.
A more responsible approach by the British government is needed, for quite practical reasons. Like other powerful states, Britain has a lot to lose if the world descends into nuclear-armed disorder.
6. Recommendations
- R1. Operation of the Sellafield MOX plant should not be allowed while reprocessing continues at Sellafield.
- R2. The British government should work with BNFL and other stakeholders to renegotiate BNFL's reprocessing contracts and review the Magnox fuel cycle, with the objective of ending all reprocessing at Sellafield.
- R3. Pending a halt to reprocessing at Sellafield, the MOX plant should be mothballed.
- R4. The British government should work with all major stakeholders to assess the merits of MOX fuel and other options as means for reducing stocks of separated plutonium, both civil and military.
- R5. Drawing from the assessment recommended in R4, the British government should convene an international consultation to seek consensus on policies and means for reducing stocks of separated plutonium.
- R6. If eventually placed in operation, the Sellafield MOX plant should be used solely as a means for reducing stocks of separated plutonium.
Institute for Resource and Security Studies
27 Ellsworth Avenue, Cambridge, Massachusetts 02139, USA
Phone: (617) 491-5177 Fax: (617) 491-6904
Email: irss@igc.org
NCI LETTER:
OPPOSE SECTION 302, TITLE III, OF
THE NUCLEAR WASTE POLICY AMENDMENTS ACT OF 1999
(Distributed to the Senate and key Administration members on Monday, July 19.)
Dear Senator:
We, the representatives of several arms control and non-proliferation organizations, are writing to express our strong opposition to Title
III, Section 302, of S. 1287, the "Nuclear Waste Policy Amendments Act of
1999," reported recently by the Senate Committee on Energy and Natural
Resources.
Section 302 would establish a new "Office of Spent Nuclear Fuel
Research" in the Department of Energy. While we agree that a good deal of
research and development still needs to be conducted on the disposal of nuclear
waste, we object to the misguided nuclear reprocesssing promotional
objectives of Section 302 as a wasteful misallocation of resources
toward inappropriate and
dangerous technologies and a flagrant violation of U.S.
non-proliferation
policy.
Section 302 calls for the new Office to "identify promising
technologies for the treatment, recycling, and disposal of spent nuclear
fuel and
high-level radioactive waste; conduct research and development
activities
for promising technologies," and "require research on advanced
processing
and separations." Indeed, the sponsor of the bill stated in a press
release that the new Office "should develop alternatives for future
congressional consideration, such as: reprocessing to extract uranium
and
plutonium." These efforts to promote spent-fuel reprocessing and
plutonium
separation run contrary to more than two decades of U.S.
non-proliferation
policy.
Beginning with the Ford Administration, the United States has
pursued an anti-plutonium policy. The present iteration of that policy,
advanced by
the Clinton Administration in September 1993, declares that "The United
States does not encourage the civil use of plutonium and, accordingly,
does
not itself engage in plutonium reprocessing for either nuclear power or
nuclear explosive purposes." [emphasis added] The policy further
pledged
that "the U.S. will seek to eliminate where possible the accumulation of
stockpiles of highly-enriched uranium or plutonium," as well as "explore
means to limit the stockpiling of plutonium from civil nuclear
programs."
Thus, U.S. development of new means to separate plutonium would make it
difficult or impossible to achieve these non-proliferation goals. U.S.
diplomatic efforts to discourage reprocessing in Taiwan, South Korea,
and
in other sensitive regions will completely lack credibility if the
United
States itself undertakes a large-scale reprocessing R&D program.
To make matters worse, Section 302 would "require research on
both
reactor- and accelerator-based transmutation systems." Despite the
claims
of its proponents, all transmutation schemes are essentially large-scale
spent fuel reprocessing and recycling programs. For instance, the
Accelerator Transmutation of Waste (ATW) system being pushed by the Los
Alamos National Laboratory is a slightly modified version of the defunct
Integral Fast Reactor (IFR), a metal-fueled plutonium breeder reactor.
The
system would require processing all U.S. spent fuel to separate the
plutonium and other "minor" actinides (neptunium, americium and curium)
from the vast majority of highly radioactive fission products that
provide
spent fuel with a self-protecting radiation barrier. The separated
actinides would then have to be fabricated into fuel, irradiated in
accelerator-driven spallation sources, and then repeatedly reprocessed
and
recycled. These are large-scale, bulk-handling processes which will
present costly and difficult safeguards and security challenges.
Accelerator transmutation proponents claim that their process is
"proliferation-resistant" because the spent fuel is processed using
"electrorefining," which does not separate plutonium from other
actinides
and a few rare-earth fission products. However, numerous reviews have
demonstrated that this process can be easily modified to produce
purified,
weapons-usable material. Even if the plutonium is not purified, the
residual fission product contamination is minor and would not provide an
effective barrier to diversion or theft. Finally, the minor actinides
themselves are now understood to be weapons-usable materials, so their
presence will not reduce the attractiveness of the electrorefining
product.
Finally, the new Office would "be authorized to fund
international
collaborators when they bring unique capabilities not available in the
United States and their host country is unable to provide for their
support." We are concerned that this provision would encourage, and
perhaps even subsidize, overseas reprocessing and other
plutonium-separation technologies.
As the recent Chinese espionage scandal made clear, DOE cannot
effectively safeguard even its most sensitive nuclear weapons
technologies. DOE's
record for safeguarding weapons-sensitive, civilian nuclear technology
is a
problem as well. DOE inadvertently sold an entire reprocessing plant
for
bomb-grade uranium to an Idaho scrap dealer a few years ago. In
addition,
our nation's most advanced technology to separate weapons-grade
plutonium
was supplied by DOE to Japan's civilian nuclear program earlier this
decade, in violation of U.S. law controlling the transfer of "sensitive
nuclear technology." There is no reason to believe that a new Office of
Spent Nuclear Fuel Research, explicitly mandated to assist other nations
in
plutonium separation, will prove any more effective in preventing
transfers
that would gravely threaten U.S. national security.
We urge you to reject Section 302 when you take up the nuclear
waste bill. Representatives of our organizations would be glad to meet
with you to
discuss these matters. Thank you for your attention to this urgent
matter.
Sincerely,
(contact NCI for a final copy of the letter.)
Return to July 28 Nix MOX Bulletin Board
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