July 21, 1999

The Sellafield MOX Plant Consultation
Radioactive Substances Division
Department of the Environment, Transport and the Regions
4th Floor
Ashdown House
Victoria Street
London SW1E 6DE

Dear Sir:

The harmful international consequences of authorizing the start-up of the Sellafield MOX Plant (SMP) compel us, as representatives of U.S. arms-control, non-proliferation, and environmental organizations, to write in strong opposition to this plan. A decision by the Government to commission this fuel-fabrication plant would result in a widening web of commerce in plutonium, an atom-bomb material, as well as a prolongation of spent-fuel reprocessing and associated environmental contamination, and an increase in all categories of toxic, radioactive waste.

We note that Euratom directives require that the benefits of operating this plant must be found to exceed the negative consequences of its operation. It should now be clear that this requirement cannot be met. Contrary to assertions by British Nuclear Fuels Ltd (BNFL), no benefits will ensue from the operation of the SMP because there is no need for the plant's product---plutonium-uranium mixed-oxide (MOX) fuel. Natural uranium is in ample supply, enough to ensure the supply of non-weapons-usable fuel in low-enriched or unenriched form for the world's nuclear power reactors for decades to come. The original assumption that uranium would be in short supply has been proven false, as the continuing decline in the price of uranium confirms. In addition, the further assumption that plutonium would be utilized in fast breeder reactors has been proven false, as the demise of the British, French and Japanese breeder programs attests.

MOX fuel is now being championed by BNFL as an alternative fuel for conventional light-water reactors. This policy, in our view, is inappropriate and dangerous. Plutonium has no legitimate place in civilian nuclear-power programs. The U.K. government understands that the plutonium in fresh MOX fuel can be separated by straightforward chemical means and be made into nuclear weapons. A country that possesses MOX fuel, therefore, must be considered to possess the essential material for manufacturing nuclear weapons. BNFL's campaign to recruit new customers for the SMP could directly contribute to nuclear proliferation in East Asia and eventually legitimate plutonium commerce in Eastern Europe and the Middle East.

Beyond the global proliferation risks, use of MOX fuel is an unattractive option for nuclear power utilities. MOX is more expensive than low-enriched uranium fuel, is more hazardous to plant workers because of its radiotoxicity, and requires greater physical protection because of the plutonium it contains. In addition, MOX fuel decreases safety margins in light-water reactors and magnifies the risk of cancer fatalities from a severe accident compared with low-enriched uranium fuel.

It should be apparent that the only real need served by the Sellafield MOX Plant is to justify continued reprocessing of spent fuel at THORP. THORP separates plutonium primarily for Japanese and German utilities, BNFL's largest foreign customers. But Germany is now actively pursuing alternatives to further reprocessing and use of MOX fuel. Japan is still officially committed to use of plutonium, but because of the mounting controversy over Japan's transport and use of this weapons-usable fuel, it is now by no means certain that Japanese utilities will sign contracts with BNFL for large-scale MOX fabrication.

If the MOX option proves non-viable in Japan for political or economic reasons, the tens of tonnes of Japanese plutonium extracted from spent fuel at THORP would have to be stockpiled there. If Japan's plutonium cannot be sent to Japan as MOX, there would be no rationale for THORP continuing to reprocess Japanese spent fuel.

Even if Japanese utilities sign contracts with BNFL for MOX fuel fabrication at the Sellafield MOX Plant, much of this MOX fuel may never leave Sellafield. This is because BNFL, in order to avoid stockpiling of MOX fuel in Japan, has announced that MOX fuel will be shipped to reactors in Japan "according to their loading schedule." At present, only two Japanese reactors are licensed for use of MOX. Given the record of delays in implementing Japan's plutonium program, it could be a decade or more before most Japanese nuclear utilities are licensed to use MOX, even assuming the MOX program eventually goes forward. Thus, MOX fuel may join the foreign spent fuel, reprocessing waste, and low- and intermediate-level nuclear waste now accumulating in storage in the U.K.

Germany's situation is even more uncertain as negotiations there continue between the government and utilities over the future of Germany's nuclear power program. Although Germany has no domestic MOX fuel-fabrication facility to process plutonium extracted from spent fuel at THORP, German utilities have not yet signed up with BNFL for fabrication of MOX fuel. Indeed, the commitment of German utilities and the government alike to future use of plutonium is very much in doubt, regardless of the outcome of the debate over the future of nuclear power.

Finally, we point out that operation of the Sellafield MOX Plant will do nothing to reduce the U.K.'s own enormous stockpile of civilian plutonium because British gas reactors are unsuitable for using MOX fuel. According to the 1998 Royal Society report on plutonium, the U.K. stockpile of 66 tonnes will grow to over 100 tonnes by 2010. The House of Lords Select Committee on Science and Technology has recommended that most U.K. plutonium be declared to be waste.

In conclusion, the question of whether to authorize start-up of the Sellafield MOX plant is inextricably tied to the question of whether continued operation of THORP makes any sense, given the already large surpluses of separated plutonium and the associated problems of reprocessing waste. The U.K. now acknowledges, in response to other North Atlantic nations that participate in the OSPAR Convention to protect the marine environment, the growing danger of discharges into the sea of radioactive substances from reprocessing. The U.K. has pledged to reduce these discharges of "artificial radioactive substances" to "close to zero" even though accomplishment of this may not be feasible without shutting the reprocessing plant.

Given the proliferation risks and economic problems discussed above, and the expectation of a U.K. Government review of nuclear waste policy in the near future, we urge you not to authorize the start-up of the Sellafield MOX Plant. It is a bad bargain for the U.K., for the environment, and for nuclear nonproliferation.


Paul Leventhal     Sharon Tanzer
Nuclear Control Institute

Frank von Hippel
Princeton University
(as an individual, not for his organization)

Tom Cochran
Natural Resources Defense Council

Dan Becker
Sierra Club

Tom Zamora Collina
Union of Concerned Scientists

Robert K. Musil, PhD
Physicians for Social Responsibility

Martin Butcher
British-American Security Information Council

Mary Olson
Nuclear Information and Resource Service

Linda Gunter
Safe Energy Communication Council

Dan Hirsch
Committee to Bridge the Gap

Maureen Eldridge
Alliance for Nuclear Accountability

Susan Shaer
Women's Action for New Directions

Rep. Nan Grogan Orrock
Women Legislators' Lobby

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