October 29, 2001

The Honorable Gerhard Schroeder
Chancellor of the
Federal Republic of Germany

of Germany

Risk of Terrorism at Bavarias FRM-II Reactor

Dear Chancellor Schroeder,

We are writing in the wake of the heightened, worldwide terrorist alert triggered by the attacks of September 11, 2001 to urge you to reconsider your governments acquiescence in the proposed start-up of Bavarias FRM-II research reactor using bomb-grade uranium fuel.

The proposed bomb-grade, highly enriched uranium (HEU) fuel would be in use and storage at a civilian university that cannot be guarded like a military facility. It is highly imprudent to present such an extremely tempting target to Osama Bin Laden and other terrorists of his ilk, who have repeatedly sought to obtain this material in Europe, according to numerous authoritative reports. In light of the current terrorist threat and the feasibility of still converting the FRM-II prior to its start-up to available low-enriched uranium (LEU) fuel that is unsuitable for weapons we urge you to deny the third operating license (3.TEG) for the FRM-II on compelling national security grounds. We also ask you to announce that your government will not issue a license to operate the FRM-II until the reactor is converted to LEU fuel.

The threat posed by HEU in the hands of terrorists should be clear. Less than 25 kilograms is sufficient to construct an implosion-type atomic bomb. Twice that amount would be sufficient for a far simpler gun-type atomic bomb like that used to destroy Hiroshima. The relative ease of making a bomb with HEU was underscored by the late Luis Alvarez, a participant in the Manhattan Project, in his memoirs:

With modern weapons-grade uranium, the background neutron rate is so low that terrorists, if they had such material, would have a good chance of setting off a high-yield explosion simply by dropping one half of the material onto the other half. Most people seem unaware that if separate HEU is at hand it's a trivial job to set off a nuclear explosion . . . even a high school kid could make a bomb in short order.[1]

According to the 25 October 2001 joint declaration by Bavarias science minister, Hans Zehetmair, and the federal parliamentary undersecretary of state, Wolf-Michael Catenhusen, the FRM-II is to be started with HEU fuel of 93%-enrichment, which is even more highly enriched than the 80 to 85%-enriched fuel used in the Hiroshima atomic bomb.[2] Moreover, the reactor is currently slated to use 40 kilograms per year of HEU through 2010, meaning that as much as 360 kilograms of bomb-grade uranium would pass through the Bavarian facility. At a minimum, this amount is sufficient for 14 nuclear weapons. However, recent studies report that considerably less HEU is required for implosion-type nuclear weapons,[3] indicating that the FRM-II would use dozens of bombs worth of HEU through 2010 and that the site would at all times contain sufficient HEU for at least one nuclear weapon.

Further highlighting the terrorist threat, a study prepared for the Nuclear Control Institute by five former nuclear-weapons designers from Los Alamos National Laboratory concluded that any group sophisticated enough to obtain HEU or plutonium could put together a technical team capable of producing implosion as well as gun-type nuclear weapons.[4]

The tragic events of September 11 demonstrate that terrorists are now prepared to engage in mass destruction and mass killing and are capable of conducting sophisticated, well-coordinated operations in large numbers. The question you should ask, Mr. Chancellor, is whether the FRM-II at Garching can be defended against 19 well-armed, suicidal terrorists attacking from four different directions. That is the new threat made manifest by the terrorist attacks of September 11. If such a defense is possible, who is to pay for it and take responsibility for ensuring that it is maintained for decades to come at peak efficiency? It should be clear that the FRM-II was not designed to defend against such a large and sophisticated threat. Nor is it feasible or appropriate for a civilian university to be prepared to defend against such a threat.

The proposal in the Zehetmair/Catenhusen declaration, to start the FRM-II with 93%-enriched HEU fuel and then convert it after 2010 to 50%-enriched uranium fuel, is both too little and too late. It is too late because Germany and the rest of the civilized world cannot afford to risk another 10 years of unnecessary commerce in weapons-grade uranium, knowing that Bin Laden and his confederates are on the prowl for such uranium. It is too little because reduction to 50% enrichment is insufficient to eliminate the terrorist threat. Such material is still formally designated HEU by the International Atomic Energy Agency because uranium of this enrichment remains suitable for direct use in a nuclear weapon. The only way to ensure against the terrorist threat is to convert the FRM II to LEU, meaning to uranium that is below 20%-enrichment and thus unsuitable for direct use in weapons.

Fortunately, it is still feasible to convert the FRM-II to LEU prior to start-up, as documented in studies by both the U.S. Argonne National Laboratory and Germanys Darmstadt University.[5] The operators of the FRM-II have resisted such conversion because the required increase in the size of the fuel element and reactor core would cause some additional delay and expense. While such dubious arguments against conversion might have been tolerable prior to September 11, the new, undeniable terrorist threat now demands that security take prevalence over convenience.

To allay one other potential concern, we wish to underscore that conversion to LEU will not inhibit the quality or competitiveness of German scientific research. Both the Argonne and Darmstadt studies make clear that the FRM-II will be able to carry out the same experiments with LEU fuel as with HEU fuel. All high-power research reactors built in the West since 1978 use LEU fuel, so the FRM-II would be competing on a level playing field. Several decades ago, research reactors were built with HEU, before the proliferation and terrorism potential of this fuel were fully appreciated. But the vast majority of these reactors that require refuelings with fresh HEU fuel have since been converted to LEU.

Only four operating reactors continue to use HEU in Europe, of which one (in the Netherlands) is in the process of converting to LEU, two others (in France and Belgium) have pledged to convert to LEU as soon as feasible, and the last (in France) will probably shut down before it can be converted. Moreover, in 1995, the United States canceled a proposed HEU-fueled reactor, the Advanced Neutron Source, on grounds that the bomb-grade fuel presented "a non-proliferation policy concern."[6] In addition, new state-of-the-art research reactors under construction by France and China are both designed to use LEU fuel. In short, the worlds best neutron research will be done in the years ahead with LEU fuel not HEU fuel. For Germany now to start up an HEU-fueled FRM-II would be an embarrassing and extremely dangerous anachronism.

Mr. Chancellor, the world changed on September 11. History will judge us by how quickly we recognize and react to this fundamental change. We ask you to put security before political exigency by halting the proposed use of bomb-grade uranium in Bavaria and ordering that the FRM-II reactor must be converted to non-weapons-usable LEU fuel before the federal government will issue a final operating license.

Thank you for your consideration of this international security matter of the highest urgency.


Alan J. Kuperman Paul L. Leventhal

Senior Policy Analyst President

[1] Luis Alvarez, Adventures of a Physicist (Basic Books, 1987), p. 125.

[2] Rodney W. Jones and Mark G. McDonough with Toby Dalton and Gregory Koblentz, Tracking Nuclear Proliferation (Washington, DC: Carnegie Endowment for International Peace, 1998), p. 322.

[3] J. Carson Mark, "Some Remarks on Iraq's Possible Nuclear Weapon Capability In Light of Some Known Facts Concerning Nuclear Weapons," prepared for Nuclear Control Institute, May 16, 1991. Thomas B. Cochran and Christopher B. Paine, The Amount of Plutonium and Highly-Enriched Uranium Needed for Pure Fission Nuclear Weapons (Washington, DC: Natural Resources Defense Council, 1994).

[4] J. Carson Mark, Theodore Taylor, Eugene Eyster, William Maraman, and Jacob Wechsler, "Can Terrorists Build Nuclear Weapons?," in Paul Leventhal and Yonah Alexander, eds., Preventing Nuclear Terrorism (New York: Lexington Books, 1987).

[5] N.A. Hanan, R.S.Smith, J.E. Matos, Alternative LEU Designs for FRM-II with Power Levels of 20 - 22 MW, presented at the 22nd annual meeting on reduced enrichment for research and test reactors (RERTR), October 3-8, 1999, Budapest, Hungary. Alexander Glaser, Interdisciplinary Research Group in Science, Technology and Security (IANUS), Darmstadt University, The Conversion of Research Reactors to Low-Enriched Fuel and the Case of the FRM-II, presented at the XIIth International Summer Symposium on Science and World Affairs, August 23-31, 2001, Moscow, Russia.

[6] "DOE Facts: A New Neutron Source for the Nation," U.S. Department of Energy, February 1995, p. 1.