September 12, 2000
Prof. Gert Weisskirchen
Speaker, Committee on Foreign Affairs
Social Democratic Party
[Letter sent to several SPD members of the German Bundestag]
Opposition to Export of Siemens MOX Plant to Russia
Dear Professor Weisskirchen:
I am writing to you in connection with your party's impending consideration of the German Government's plan to export the unfinished Siemens mixed-oxide ("MOX") fuel plant to Russia, where it would be used to turn excess Russian weapons plutonium into power reactor fuel.
The Nuclear Control Institute is an independent, non-profit, research and advocacy center that concentrates on military and civilian plutonium policy issues. We are strongly opposed to this plan on the basis of important security and safety concerns. These concerns relate to the vulnerability of the warhead plutonium to theft and diversion, and to the increased probability and consequences of a severe accident in which this MOX fuel is used to replace some or all of the conventional fuel in Russia's VVER nuclear reactors.
If implemented, the plan to use recovered warhead plutonium as an ingredient in nuclear reactor fuel would increase security risks associated with the processing, transport, and use of this weapons material. Despite the efforts of the U.S. Department of Energy and the U.S. national laboratories, fissile material in Russia remains inadequately protected and vulnerable to insider and outsider threats because of weak material control and accounting procedures. Instead of removing weapons-usable nuclear material from circulation, the "MOX" plan would involve more processing and transport than would the other disposal option---"immobilization" of the plutonium in highly radioactive waste.
In addition, the MOX plan would lead to significant additional hazards in the event of a severe accident at a nuclear power plant operating with MOX fuel rather than with a full core of conventional low-enriched uranium. We calculate that an increase of 25 per cent in latent cancer fatalities would result from such an accident with warhead-plutonium MOX fuel. Even this alarming consequence would be magnified further because of Russia's plan to mix reactor-grade plutonium, a more toxic form, into this fuel for the purpose of concealing the original isotopic composition of the military plutonium. Our analysis has found that Russia's VVER reactors require major safety upgrades if they are to use MOX fuel. Any use of MOX in Russia will increase the radiation effects to which Germany could be exposed in the event of a severe reactor accident in Russia.
The objective of transforming warhead plutonium into a form not immediately usable in nuclear weapons is worthy, but the MOX plan is the wrong way to proceed. Given real-world concerns about the adequacy of security and safety measures in Russia, we believe it foolhardy to export a MOX fabrication plant to Russia. Fabrication and use of MOX fuel has been rejected as too dangerous to pursue in Germany; the wherewithal to pursue such a program in Russia should not now be transferred by Germany. There is a strong German national interest in rejecting this transfer: the consequences of nuclear theft or nuclear accidents in Russia do not respect national frontiers, including Germany's. Use of plutonium should now be minimized and eliminated, not expanded.
We wish to underscore that disposition of excess military plutonium does not depend upon use of MOX fuel because this mission can be accomplished by immobilizing the plutonium in highly radioactive, glassified waste for direct disposal---a process known as vitrification. We do not favor an alternative approach of turning warhead plutonium into "bad" or "sub-spec" MOX pellets, for insertion in highly radioactive, spent fuel assemblies. Bad MOX would have to be fabricated in a MOX plant, such as the Hanau facility, and the plant could be modified later on to fabricate "good" MOX suitable for use in reactors.
The best approach, we believe, is to serve the cause of both nuclear non-proliferation and nuclear disarmament by laying the Siemens MOX plant to rest, once and for all. This plant should not be allowed to be resuscitated to provide the basis for a plutonium fuel program in Russia. If approved for export, the Siemens MOX plant will play a key role in establishing a plutonium fuel cycle in Russia, a key objective of which is construction of new plutonium "breeder" reactors, beginning with a new reactor designated BN-800.
Thus, for non-proliferation reasons, as well as the important safety dividend of avoiding use of plutonium fuel in reactors, NCI strongly opposes the MOX approach to military plutonium disposition. We appeal for your party's leadership to attain this objective by rejecting the proposed export of the Siemens MOX plant to Russia, as well as any funding necessary to export the facility.
Thank you for your consideration of these views. We ask that you share this letter with your SPD colleagues.