December 23, 1999
H.E. Richard Leighton Bernal
Embassy of Jamaica
1520 New Hampshire Avenue NW
Washington, D.C. 20036
Impending Sea Shipment of High-Level Nuclear Waste from Europe to Japan
I am writing to you concerning sea shipment of highly radioactive nuclear waste from Europe to Japan in the hope your government will press its objections to such shipments and the manner in which they are being conducted.
An imminent shipment is expected to transit the Panama Canal early next year and will be the fifth shipment of "ultra-hazardous" nuclear waste since 1995, the third to use the Panama Canal, and the first shipment since control of the Canal has passed from the United States to Panama.
A number of vital safety, security and environmental issues concerning these shipments remain unanswered by the shipping states---Japan, Britain and France---despite having been raised by numerous en-route countries. Unresolved issues include the right of en-route states to advance notification and consultation, the absence of environmental-impact analysis in the event of an accident, and responsibility for liability and salvage. Also, the Government of the United States continues to refuse to be responsive to questions our organization has raised about the potential for and consequences of sabotage of a high-level waste shipment. Until these issues are resolved, we believe these shipments should not proceed.
Over the next 15 years, there are likely to be at least 15 to 30 nuclear waste shipments, each carrying up to 150 canisters of highly radioactive nuclear waste. In 1992 and 1993, 45 nations and territories expressed concerns about the shipment of plutonium from France to Japan. Since then, a number of governments have expressed apprehension about the potential effects of a nuclear shipping accident on their island economies and fragile ocean environment. Caribbean and Pacific island nations have repeatedly voiced their objections, as have regional associations such as CARICOM, OPANAL and the South Pacific Forum.
In an analysis of unresolved safety issues, Dr. Edwin Lyman, the Nuclear Control Institute's (NCI) scientific director, finds that in the event of a shipboard fire, or a collision and sinking at sea, the highly radioactive cargo could be rapidly dispersed because of the use of faulty stainless-steel canisters and rubber-like seals used to package and contain the waste. (This document can be found on the NCI web site at www.nci.org/ib11398.htm.) Dr. Lyman recently obtained a 1997 study from the United States Department of Energys Sandia National Laboratory which concludes that the radioactive dose from an accident involving loss of spent fuel at sea could equal that resulting from the Chernobyl accident---a veritable "floating Chernobyl."
These nuclear waste shipments and other marine transports of plutonium in various forms are inextricably tied to the history and goals of Japan's program to recover highly toxic, weapons-usable plutonium from the spent fuel of commercial nuclear power plants by means of "reprocessing." Because Japan's domestic reprocessing capability is minimal, Japan has contracted with state-owned reprocessing industries in France and Great Britain to recover plutonium from its spent fuel. Several hundred tons of Japanese spent fuel have been shipped to Europe since the 1970s. Beginning in 1992, commercial-scale shipments of plutonium, plutonium fuel and nuclear waste have been shipped back to Japan from Europe.
The severe risks of Japan's sea shipments are made all the more unacceptable by the fact that the shipments are entirely unnecessary. Japan does not need plutonium fuel or breeder reactors for energy security, and Japan does not need reprocessing or plutonium fuel for nuclear waste management. Uranium is cheap and abundant. Japan could stockpile a strategic uranium reserve containing a 50-years' supply of low-enriched or natural uranium for less than half the cost of its plutonium program. As for waste management, a geologic repository is almost certainly the ultimate destination for spent nuclear fuel, regardless of whether it has been reprocessed. Yet, lacking need and facing economic and technical obstacles, Japans plutonium bureaucracy clings to the plutonium program. We invite you to review a recent paper on our web site entitled Understanding Japans Nuclear Transports: The Plutonium Context. This paper, which I presented in October at a conference on nuclear transport sponsored by the Maritime Institute of Malaysia, provides a detailed review of the current situation. This paper can be found at www.nci.org/mmi.htm; other documents on sea transport can be found at www.nci.org/seatrans.htm.
Recent developments suggest Japan's plutonium program is encountering great difficulties and could yet be abandoned, especially if concerned governments expressed concerns about continuation of this misguided program and the shipments generated by plutonium commerce. The severe accident on September 30 at Japans Tokai fuel fabrication facility resulted from careless fabrication of fuel for Japans plutonium breeder reactor program and was thus directly linked to Japans overall plutonium program. The accident underscores the risks inherent in Japans continued allegiance to a misguided energy policy based on plutonium.
Also in September, a highly-controversial shipment of plutonium fuel arrived in Japan from British Nuclear Fuels Limited (BNFL) and Frances COGEMA. On December 16, the fuel originating from BNFL was rejected for use by Japans Ministry of International Trade and Industry as well as Kansai Electric Company (KEPCO) due to falsification of quality control data by BNFL. Subsequently, use of plutonium fuel from both BNFL and COGEMA has been suspended and the entire program has been thrown into chaos.
Finally, the nuclear-weapon potential of Japan's plutonium program should not be ignored. Nuclear-weapon experts unanimously agree that plutonium in commercial forms can be used to construct nuclear weapons. As of December 1998, Japan had acquired a stockpile of about 25 tonnes of separated plutonium, of which 5 tonnes is now in Japan. The International Atomic Energy Agency (IAEA) considers 8 kg a significant quantity for use in nuclear weapons. Thus, Japans domestic stockpile is now equivalent to hundreds of nuclear weapons and will grow considerably larger if more plutonium is shipped there from Europe.
The Nuclear Control Institute urges your Government to call for the suspension of shipments of highly radioactive nuclear waste and plutonium to Japan until the issues of concern reviewed above are resolved. Coastal nations have the right to demand a strict, mandatory code of practice as a condition for permitting such dangerous transports to proceed. Such a code should require prior notification of the shipping route, advance consultation on emergency plans, a full environmental-impact assessment, a formal liability regime, and a demonstrated salvage capability.
We would be pleased to respond to any questions you may have regarding this matter of continuing and growing concern. We thank you for your consideration of our views and request that you transmit them to your Government.