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August 13, 1999

Submission of the Nuclear Control Institute
to the Niigata MOX Consultation
Niigata Prefecture, Japan

The Nuclear Control Institute is pleased to convey the following submission to the Niigata MOX Consultation.

The Nuclear Control Institute (NCI), based in Washington, D.C., has long been concerned with safety and security problems associated with using mixed-oxide (MOX) fuel in commercial light-water nuclear reactors (LWRs).

We have conducted an analysis of safety and public health issues associated with the use of MOX fuel in LWRs, and have identified a number of serious concerns associated with this practice. Both the probability of occurrence of severe accidents and the potential public health consequences of such accidents are likely to increase when MOX fuel is substituted for low-enriched uranium (LEU) fuel.

In particular, we have done a careful calculation of the number of expected deaths from cancer that could result if a severe, loss-of-containment accident were to occur at a nuclear plant using a quarter-core of reactor-grade MOX (RG-MOX) fuel and compared that to the number of expected deaths resulting from an accident if the plant had been using only LEU fuel. We find that the number of expected cancer deaths would be more than twice as large for a plant using a quarter-core of RG-MOX. We have submitted our report both to the U.S. Nuclear Regulatory Commission (NRC) and the U.S. Department of Energy (DOE) for review. DOE later concluded that we have used our computer models in a correct manner. The report has been peer-reviewed and will be published later this year in a leading American university journal.

We are also deeply concerned about the security risks associated with the transport, handling and storage of MOX fuel at reactor sites. Long-term, on-site storage of fresh MOX fuel should be prohibited on security grounds. However, if reactors are not able to immediately load MOX fuel upon its arrival onsite, such storage will be necessary. Fresh MOX fuel lacks a radiation barrier, and if it were stolen, weapons-usable plutonium could be separated from this MOX by straightforward chemical means. According to a 1997 U.S. DOE document that discusses the security risks associated with MOX (excerpt attached), "plutonium suitable for use in weapons could be separated [from MOX] relatively quickly and easily." EdF, the French nuclear-electric utility, does not permit fresh MOX fuel to be stored at its reactor sites for more than two weeks, due to security concerns, and does not allow any dry storage of such fresh fuel.

For any storage of fresh MOX fuel, at reactor sites or elsewhere, we urge adherence to the U.S. National Academy of Science's "stored weapon standard," that is, fresh MOX fuel must be accorded the same degree of security as would an actual nuclear warhead.

We are concerned that national authorities in Japan do not fully appreciate the security risks of MOX fuel. Some of the most prominent leaders in the Japanese nuclear industry, including Ambassador Ryukichi Imai and Mr. Hiroyoshi Kurihara of the Nuclear Material Control Center in Tokyo, continue to perpetuate the dangerous myth that plutonium recovered from nuclear power reactor spent fuel (so-called "reactor-grade plutonium") cannot be used to make reliable weapons.

The ability to construct effective nuclear bombs from reactor-grade plutonium was demonstrated decades ago. Hans Blix, former director-general of the IAEA, informed our Institute in 1991 that there is "no debate" on this point in the Safeguards Department of the IAEA, and that the agency considers virtually all isotopes of plutonium, including high burn-up reactor-grade plutonium, to be usable in nuclear weapons. In June 1994, U.S. Energy Secretary Hazel O'Leary declassified further details of a 1962 test of a nuclear device using reactor-grade plutonium, which successfully produced a nuclear yield. The U.S. Department of Energy's Office of Non-Proliferation and Arms Control recently concluded that "reactor-grade plutonium is weapons-usable, whether by unsophisticated proliferators or by advanced nuclear weapons states. Theft of separated plutonium, whether weapons-grade or reactor-grade, would pose a grave security risk."

We attach the following documents in support of our contentions, and ask that they be made part of the public record of this MOX consultation.

1. A letter sent by the Nuclear Control Institute to Governor Kurita of Fukui Prefecture that describes some of our safety concerns with regard to the plan to utilize MOX fuel in the Takahama 3 and 4 pressurized-water reactors (PWRs). The letter also presents the results of a site-specific calculation of the number of additional cancer fatalities that would occur in the region adjacent to the Takahama plant following a loss-of-containment accident if one-quarter of the reactor contained reactor-grade MOX fuel instead of low-enriched uranium (LEU) fuel. Although the results in the letter are specific to PWRs, the results for boiling-water reactors (BWRs) such as Kashiwazaki-Kariwa should be similar. NCI is now carrying out calculations to estimate the public health impact in Niigata Prefecture of MOX use at the Kashiwazaki-Kariwa plant in the event of a severe accident, and we will submit these in due course.

2. The Executive Summary of the report "Public Health Consequences of Substituting Mixed-Oxide for Uranium Fuel in Light-Water Reactors," by NCI Scientific Director Dr. Edwin Lyman, the study upon which the letter to Governor Kurita was based.

3. The most recent statement of the U.S. Department of Energy, noted above, on the suitability of reactor-grade plutonium for nuclear weapons use (U.S. DOE, "Nonproliferation and Arms Control Assessment of Weapons-Usable Fissile Material Storage and Disposition," 1997, p. 37).

4. The statement of the U.S. Department of Energy, noted above, on the ease of separability of plutonium from unirradiated MOX fuel (U.S. DOE, op cit., p. 85).

We request that you review this information carefully as you undertake the important decision whether to authorize the use of MOX at Kashiwazaki-Kariwa. In our view, no amount of financial assistance from the national government will be adequate to compensate for the increased risks to both the public and the environment of Niigata Prefecture that would result from this dangerous undertaking.

Sincerely,

Paul Leventhal
President

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