Risks of GNEP's Focus on Near-Term Reprocessing

TESTIMONY OF

MATTHEW BUNN

FOR THE

COMMITTEE ON ENERGY AND NATURAL RESOURCES

UNITED STATES SENATE

NOVEMBER 14, 2007

Mr. Chairman and members of the subcommittee, it is an honor to be here
today to discuss the Global Nuclear Energy Partnership (GNEP). I should
emphasize that I am expressing my own views, which should not be
attributed to Harvard University or to any committees or organizations
of which I am a member. I have been asked to focus on the proliferation
and security issues.[^1]

A key GNEP goal is to expand global reliance on nuclear energy without
increasing proliferation risks. Controlling the spread of enrichment and
reprocessing -- the technologies that make it possible to produce
nuclear bomb material -- is a critical part of achieving that objective.

Some elements of GNEP could make important contributions to reducing
proliferation risks. Unfortunately, GNEP's heavy focus on building a
commercial-scale reprocessing plant in the near term would, if accepted,
increase proliferation risks rather than decreasing them.

**Proliferation risks of near-term U.S. reprocessing**

The first set of proliferation risks that should be considered relates
to the spread of nuclear weapons-related technologies to additional
states. Since 1976, the U.S. message has been, in effect, "reprocessing
is unnecessary; we, the country with the world's largest nuclear fleet,
are not doing it, and you do not need to either." Now, with GNEP, the
message is "reprocessing is essential to the future of nuclear energy,
but we will keep the technology away from all but a few states."[^2]
This shift is likely to make it more difficult to achieve President
Bush's goal of convincing other countries not to build their own
reprocessing facilities. It has already led South Korea to express new
interest in reprocessing, and France to begin considering exports of
reprocessing plants to non-nuclear weapon states.[^3]

While it is often said that the rest of the world did not listen to us
on reprocessing, the evidence suggests the opposite. Since Japan
launched its first reprocessing plan in 1977, no other
non-nuclear-weapon state has begun reprocessing; Argentina, Belgium,
Brazil, Germany, and Italy have shut down their pilot-scale reprocessing
plants; and Taiwan and South Korea have abandoned their laboratory-scale
reprocessing efforts (both of which were associated with secret nuclear
weapons programs).[^4] Japan is now the only non-nuclear weapon state
that reprocesses spent fuel on its territory.

Department of Energy (DOE) officials respond by arguing that under GNEP,
the United States will provide assured fuel services that will reduce
countries' incentives to build their own enrichment and reprocessing
plants. That is a worthwhile objective, and as I will discuss later,
programs to take away countries' spent nuclear fuel could be a dramatic
new incentive for them to rely on the international nuclear fuel market
rather than building their own facilities. But U.S. reprocessing is
irrelevant to providing assured fresh fuel supply -- the principal focus
so far -- and if the United States or other countries are going to take
back limited quantities of spent fuel from new countries developing
nuclear energy, there is no requirement that this fuel be reprocessed.

It is important to pursue these objectives carefully, so as to follow
the dictum "first, do no harm." Ironically, the period since President
Bush's 2004 speech in which he laid down the objective of preventing the
spread of enrichment and reprocessing technologies to countries that did
not already operate such plants has seen the greatest explosion of
interest in uranium enrichment in the nuclear age, with states such as
South Africa, Argentina, Australia, Canada, Ukraine, and Belarus
suddenly expressing renewed interest. If states perceive that a new line
is to be drawn between technology "haves" and "have nots" -- a
perception that early GNEP presentations on dividing the world into
"supplier states" and "recipient states" contributed to -- they will
rush to try to ensure that they are on the "have" side of the line.

DOE officials then argue that the reprocessing approaches to be pursued
in GNEP are "proliferation resistant." But having other countries pursue
processes in the UREX+ family rather than PUREX would be only a modest
improvement. While UREX+ facilities could be designed so that modifying
them to separate pure plutonium would be moderately costly and
observable, states with UREX+ facilities would gain experience,
infrastructure, and materials that would allow them to produce plutonium
for nuclear weapons more rapidly and at less cost. For these reasons,
the State Department has publicly expressed the view that UREX+
facilities, like PUREX facilities that separate pure plutonium, must
remain "forever confined" to a small number of supplier states.[^5] That
is a challenging objective, which will be made more difficult by the
United States emphasizing the importance of reprocessing.

Similarly, non-nuclear weapon states operating pyroprocessing facilities
would gain in-depth experience with plutonium processing and metallurgy,
which would be very helpful to a nuclear weapons program. The United
States should understand that pyroprocessing is a form of reprocessing,
and the United States should oppose the spread of this technology to
additional countries just as it opposes the spread of aqueous
reprocessing technologies. Recent reports suggesting that the United
States is willing to support pyroprocessing in South Korea are
particularly troubling, as South Korea, in addition to its past
reprocessing-based nuclear weapons program, also has an agreement with
North Korea prohibiting enrichment and reprocessing on the Korean
peninsula. A South Korean move away from that agreement would likely
make elimination of North Korea's nuclear weapons program more difficult
to achieve.

Another difficulty is that these processes may make it easier for states
to divert a significant quantity of plutonium without detection by
international inspectors. Nuclear material accounting for safeguards is
already an immense challenge at traditional PUREX reprocessing plants
that separate pure plutonium, with accounting uncertainties in the range
of 1 percent at plants processing 6-10 tons of plutonium every year. By
keeping a variety of radioactive materials with the plutonium, UREX+ and
pyroprocessing approaches will make accurate nuclear material accounting
for safeguards substantially *more* difficult, forcing a greater
reliance on containment and surveillance.[^6]

A second set of proliferation issues focuses on possible theft of
plutonium by subnational groups. While reactor-grade plutonium would not
be the preferred material for making nuclear bombs, it does not require
advanced technology to make a bomb from reactor-grade plutonium: any
state or group that could make a bomb from weapon-grade plutonium could
make a bomb from reactor-grade plutonium.[^7] Despite the remarkable
progress of safeguards and security technology over the last few
decades, processing, fabricating, and transporting tons of
weapons-usable separated plutonium every year -- when even a few
kilograms is enough for a bomb -- inevitably raises greater risks than
not doing so. Indeed, while many of the stocks of civil plutonium that
have built up are well-guarded, critics have argued that some operations
in the civilian plutonium industry are potentially vulnerable to nuclear
theft.[^8]

The administration has acknowledged that the huge stockpiles of
weapons-usable separated civil plutonium built up as a result of
traditional PUREX reprocessing (now roughly equal to all world military
plutonium stockpiles combined, remarkably) "pose a growing proliferation
risk" that "simply must be dealt with." [^9]

In claiming that GNEP processes would pose lower risks, DOE officials
have repeatedly emphasized that GNEP approaches will produce "no pure
plutonium." Remarkably, DOE reports that this was the "only requirement"
the department imposed on the technologies industry could propose for
near-term construction.[^10] But "no pure plutonium" is a slogan, not an
analysis of proliferation resistance. Pure plutonium is not needed to
make a nuclear bomb.

The COEX process proposed by some for a near-term reprocessing plant,
for example, which extracts the plutonium and some of the uranium
together, poses nearly as much risk as processes that separate pure
plutonium. The uranium-plutonium mix could be used directly in a bomb,
or the plutonium could readily be separated even in a crude,
jerry-rigged glove box, using commercially available equipment and
materials.. Any state or group capable of doing the technically
challenging job of making a nuclear bomb from pure plutonium would
likely be able to do the simpler job of getting pure plutonium from a
plutonium-uranium mix without fission products. For these reasons, under
either Nuclear Regulatory Commission (NRC). or international guidelines,
such a mixture would still be considered Category I material, posing the
highest levels of security risk and requiring the highest levels of
security.[^11] When such approaches were last seriously considered in
the United States three decades ago, the Nuclear Regulatory Commission
concluded that "lowering the concentration of plutonium through blending
\[with uranium\] should not be used as a basis for reducing the level of
safeguards protection," and that the concentration of plutonium in the
blend would have to be reduced to ten percent or less -- far less than
being considered for COEX -- for the safeguards advantages to be
"significant."[^12]

For the longer term, GNEP is looking at processes such as the UREX+
family, in which the actinides and possibly some of the lanthanide
fission products would stay with the plutonium. But the processing
proposed in UREX+ still takes away the great mass of the uranium and the
vast majority of the radiation from the fission products, making it far
easier to recover plutonium from the product than from unprocessed spent
fuel. Actinides with which the plutonium would be mixed, such as
neptunium, are also potentially potent nuclear bomb materials. The
situation for pyroprocessing is different in specifics, but not in the
overall conclusion. Indeed, the plutonium-bearing materials that would
be separated from aged spent fuel in either the UREX+ process or by
pyroprocessing would not be radioactive enough to meet international
standards for being "self-protecting" against possible theft.[^13]

Proponents of reprocessing and recycling often argue that this approach
will provide a nonproliferation benefit by consuming the plutonium in
spent fuel, which would otherwise turn geologic repositories into
potential plutonium mines many hundreds or thousands of years in the
future. But the proliferation risk posed by spent fuel buried in a
safeguarded repository is already modest; if the world could be brought
to a state in which such repositories were the most significant
remaining proliferation risk, that would be cause for great celebration.
Moreover, this risk will be occurring a century or more from now, and if
there is one thing we know about the nuclear world a century hence, it
is that we know almost nothing about it. We should not increase
significant proliferation risks in the near term in order to reduce
already small and highly uncertain proliferation risks in the distant
future.[^14]

In short, all of the spent fuel processing approaches proposed for GNEP
pose higher, not lower, proliferation risks than are posed by not
processing the spent fuel at all and continuing to rely on a
once-through fuel cycle. Some of these approaches do offer modest
proliferation advantages compared to the traditional PUREX reprocessing
approach. But there are no grounds for confidence that our pursuit of
these technologies will convince other countries to phase out the PUREX
processes in which they have made large investments, particularly as
processes such as UREX+ add several complex steps and are therefore
likely to be more expensive.

Ultimately, proliferation resistance should not be judged solely on how
much material other than plutonium there may be in the product of a
particular process, or how radioactive that product might be. Rather, it
should be judged by a full life-cycle examination of how the deployment
of such technologies by some states might affect the spread of sensitive
technologies to other states; how much access to the materials,
facilities, and expertise involved in the proposed fuel cycle would
reduce the time, cost, and observability of a state nuclear weapons
program; and how the large-scale adoption of such a fuel cycle would
affect the risks of nuclear theft and nuclear terrorism around the
world.[^15]

**Security against sabotage**

Construction of a large reprocessing facility using the technologies
available now or in the near term would also be likely to increase risks
of terrorist sabotage. While such facilities could be designed and
operated with stringent anti-terrorist security measures, reducing this
risk to a modest level, transporting and processing thousands of tons of
intensely radioactive spent nuclear fuel inevitably involves more
opportunities for terrorist mischief than leaving that spent fuel in
large steel or concrete casks.

**Costs of reprocessing and recycling**

Reprocessing using technologies available now or in the near term is
likely to be substantially more expensive than direct disposal of spent
fuel.[^16] The UREX+ technology now being pursued adds a number of
complex separation steps to the traditional PUREX process, and would
likely be even more expensive. The capital cost of fast-neutron reactors
such as those proposed for GNEP has traditionally been significantly
higher than that of light-water reactors. A National Academy of Sciences
review of separations and transmutation technologies such as those
proposed for GNEP concluded that the additional cost of recycling
compared to once through for 62,000 tons of commercial spent fuel "is
likely to be no less than \$50 billion and easily could be over \$100
billion."[^17] While spent fuel management is only a small part of the
cost of nuclear energy, the proposed GNEP approach would also require
construction of a large fleet of fast reactors whose capital costs --
the key driver of nuclear energy costs -- have always been higher than
those of light-water reactors. If the capital costs of fast reactors
remained significantly higher in the future, processing all U.S. spent
fuel in this way would cost tens or hundreds of billions of dollars more
than a once-through approach. Who will pay these costs? Are we talking
about many decades of government subsidies, or onerous regulations
requiring private industry to pay for uneconomic activities?

The Boston Consulting Group study outlines the hope that if new
facilities could be built with a much larger capacity for only modestly
more money -- and would operate close to capacity throughout their
lives, something no real reprocessing plant has ever done -- the unit
costs of reprocessing might be much reduced. But the real experience of
building a plant similar to the French reprocessing plant in Japan has
been unit costs several times *higher* than those in France, not lower;
the costs of the MOX fuel plant private firms are building for DOE, also
based on French technology, are also several times *higher,* not lower,
than those of the French plants. One can argue -- correctly -- that each
of these new plants has unique problems, but why should we expect that a
new reprocessing plant in the United States would avoid similar
problems? No policy-maker should make decisions about reprocessing based
on an expectation that the costs will be similar to those projected in
the Boston Consulting Group report.

Rather than relying solely on paper analyses, one can look at the
evidence from the commercial market. The British reprocessing plant will
be closed in a few years because it cannot get enough contracts to keep
running; the French and Russian reprocessing plants are operating at far
less than capacity because of a lack of contracts; to pay the huge costs
of the Japanese reprocessing plant, Japanese utilities insisted on a
government bailout in the form of a wires charge that will increase the
price of electricity for *all* users in Japan for many years to come.
When utilities have a choice, they do not choose to reprocess their
fuel.

**Room at Yucca Mountain**

Similarly, it is by no means clear that effective nuclear waste
management and disposal in the United States will require reprocessing
and recycle. Recent studies indicate that the technical capacity of the
Yucca Mountain repository is far larger than the legislated capacity --
large enough to support a growing nuclear energy enterprise for many
decades to come.[^18] GNEP is likely to make it more difficult, rather
than easier, to get a license for Yucca Mountain, by creating
uncertainty over what, exactly, would be disposed of there, and raising
the possibility that wastes from a far larger number of reactors would
be emplaced there. If Yucca Mountain opens and begins operating
successfully -- and a repository will certainly be required whether we
continue to rely on a once-through fuel cycle or shift to a closed cycle
-- it may well be easier to get a license for using the next ridge over
for an additional repository than it will be to get political approvals
and licenses for several large reprocessing plants and dozens of fast
neutron reactors.

**What's best for the future of nuclear energy?**

Mr. Chairman, to be against near-term reprocessing is not the same as
being against nuclear power. It is precisely because I hope for a
vibrant and growing future for nuclear energy, to help cope with climate
change, that I am against near-term reprocessing. Nuclear power's future
will be best assured by making it as cheap, simple, safe, and
proliferation-resistant as possible -- and near-term reprocessing points
in the wrong direction on every count.[^19]

**Technical maturity**

Fortunately, there is no pressing need to move forward with construction
of a reprocessing plant in the United States in the near term. Dry casks
offer a safe and proven technology that makes it possible to store spent
fuel for decades at low cost. As a result, there is no need to rush to
make these decisions -- we can make these decisions more responsibly in
the decades to come, when technology has developed further and economic,
security, and political circumstances have clarified. What is needed now
is patient R&D and in-depth systems analysis, rather than a rush to
build commercial-scale facilities. As Richard Garwin has put it, by
picking winners prematurely, the proposed GNEP approach "would launch us
into a costly program that would surely cost more to do the job less
well than would a program at a more measured pace guided by a more open
process."[^20]

It would certainly not be a sign of U.S. leadership to decide now to
build a reprocessing plant little different from what France, Russia,
the United Kingdom, and Japan have already built -- to build, as one
GNEP participant put it to me, a 1975 Cadillac. Rather, it would lock
the United States in to spending many billions of dollars on decades-old
technologies whose high costs and proliferation risks are already well
known, and which are already failing to win contracts in the commercial
marketplace. The idea of sending spent fuel from decommissioned U.S.
reactors to France to be reprocessed, as DOE is reportedly
considering,[^21] has even less merit, and should be soundly rejected.
The reprocessing would cost well over a billion dollars, far more than
continuing to store this fuel where it is, and would simply add to the
multi-billion dollar problem of excess plutonium the United States
already has. DOE has correctly identified large global stockpiles of
separated plutonium as a dangerous problem; dealing with that problem by
reprocessing more plutonium is like using gasoline to put out a fire.

The recent National Academy of Sciences review has provided an excellent
discussion of just how premature it would be to build commercial-scale
facilities now, unanimously recommending against proceeding with a GNEP
program focused on near-term large-scale construction. As they
concluded: "There is no economic justification to go forward with this
program at anything approaching commercial scale. Continued research and
development are the appropriate level of activity, given the current
state of knowledge." I urge the Committee to hear from the National
Academy panel, to get the insights gained from their in-depth
examination of the GNEP program in the context of other nuclear R&D.

**Positive elements of GNEP**

As I mentioned at the outset, other elements of GNEP could be
significant steps to reduce the proliferation risks of nuclear energy.
Unfortunately, these other elements have not received comparable
emphasis and funding in the program to date.

**Fuel leasing.** First, providing assured fuel services, so that
countries have strong incentives not to build enrichment or reprocessing
plants of their own, is a potentially important idea.[^22] The current
emphasis is primarily on assured supplies of fresh nuclear fuel; while
this is an important goal, it should be recognized that the commercial
market already provides high assurance of fuel supply (except for
countries that are special cases outside of or in violation of global
nonproliferation norms, such as Iran and India). less need to build
enrichment or reprocessing fuel leasing -- that is, providing fresh fuel
to countries with a promise to take the spent fuel away -- would allow
countries to enjoy the benefits of nuclear energy without having to
build repositories. This would create a powerful new incentive for
countries starting new nuclear energy programs to rely on foreign fuel
supply rather than building enrichment and reprocessing of their own.
(Note that existing reprocessing services offered by Britain and France,
which require that the wastes be sent back to the customer, would not
have this advantage.) Moreover, widespread fuel leasing would mean that
plutonium-bearing spent fuel need not build up in countries all over the
world. There are obvious political problems with one country taking
another country's spent fuel, but we should be working to address these
problems -- as we have in the case of taking back spent research reactor
fuel. It is important to note that take-back of modest quantities of
foreign spent fuel from the small numbers of reactors likely to be build
in coming decades in new nuclear countries would not in any way require
that this fuel be reprocessed. Russia has already passed legislation
that allows it to enter the fuel leasing business, and signed a contract
with Iran that requires all of Iran's spent fuel to be shipped back to
Russia. Other countries have considered being hosts for international
waste storage facilities. It only takes one of the world's 190 countries
to agree to host an international repository (and if one country
launched such an effort successfully, others might decide to compete
with them in that highly profitable business). The country providing the
fresh fuel and the country accepting the spent fuel would not
necessarily have to be the same. The United States should be doing far
more to make this vision a reality.[^23]

**Reducing stockpiles of separated plutonium.** Second, the huge global
stocks of weapons-usable civilian separated plutonium -- now as much as
all the plutonium in all the world's nuclear weapons stockpiles -- pose
significant risks, and continue to grow. Building a reprocessing plant
or a single demonstration fast reactor in the United States will not do
much to solve that problem. The United States should be doing much more
to work with other countries to ensure that all these stockpiles are
secured to the highest practicable standards, to limit or phase out
unneeded plutonium separation where possible, and to ensure that plans
are put in place for reducing these immense stocks over time. In
particular, the Bush administration should renew the talks with Russia,
almost completed in the Clinton administration, concerning a 20-year
moratorium on plutonium separation in both countries, and should
cooperate with other countries to work out disposition paths for
plutonium stockpiles for which there is no current plan for use or
disposal.[^24]

**Small, exportable reactors.** Third, the concept that is sometimes
called a "nuclear battery" -- small reactors that might be produced in a
factory, shipped to a deployment site with their fuel already included,
generate electricity there for 10-20 years, and then be shipped back to
the factory with their spent fuel -- could make it possible to have
widespread use of nuclear energy with little spread of sensitive
materials and expertise and few proliferation risks. Within GNEP, even
the small level of funding devoted to "small and medium reactors" is
largely devoted to medium-sized reactors that could not be factory-built
in this way. GNEP should devote higher priority to R&D on nuclear
battery concepts, and particularly to approaches that might reduce their
costs -- currently the main barrier to implementing this approach.

**Advanced safeguards development.** Fourth, as the American Physical
Society has pointed out, the United States needs a major reinvestment in
safeguards and security technologies to support a new nuclear era.[^25]
DOE is taking the first steps in that direction, but much more needs to
be done.

**Recommendations**

What, then, should be done?

First, I recommend that Congress follow the bipartisan advice of the
National Commission on Energy Policy;[^26] the advice of the recent
National Academy of Sciences review of GNEP;[^27] and the advice of the
American Physical Society study of nuclear energy and
nonproliferation,[^28] by rejecting proposals to spend many billions of
dollars on near-term construction of a commercial-scale reprocessing
plant and a commercial-scale fast reactor in the United States. The
Committee would be hard-pressed to find any independent scientific or
engineering group that believes such construction is a good idea in the
near term.

Second, Congress should redirect GNEP to focus on long-term research on
(a) advanced technologies that might have the potential to overcome the
large liabilities of past reprocessing and recycling approaches; (b)
improved approaches to once-through systems; and (c) in-depth studies of
the real repository capacity likely to be available in different
scenarios and of global uranium resources. This should include a much
broader set of reactor and spent fuel processing technologies than GNEP
is currently pursuing; it would be a mistake to down-select and focus
only on technologies that could be deployed soon, when other
technologies may have more long-term promise.[^29] As improved recycling
and once-through technologies develop, we should regularly re-examine
which of them appear to offer the best combination of cost, safety,
security, proliferation-resistance, and sustainability. At the same
time, we should not allow an expansion of nuclear R&D to overwhelm R&D
on other promising energy technologies: the United States urgently needs
to undertake expanded investments in a wide range of energy R&D.

Third, Congress should increase the funding for the positive elements of
GNEP I have enumerated, and direct the administration to devote greater
attention to pushing them forward. On these points, I believe the
approach proposed by the Senate Energy and Water Appropriations
Committee is a major step in the right direction.

Fourth, Congress and the administration should work to establish
cost-effective dry cask storage approaches to address the spent fuel
storage problems and costs that have resulted from continuing Yucca
Mountain delays, including at least a small amount of centralized
storage to address problems at decommissioned reactors.[^30] Whatever
option for spent fuel disposal or processing we pursue, additional
interim storage capacity will be needed. Storing spent fuel in dry casks
leaves all options open for the future, as technology develops and
political and economic circumstances change. (Indeed, since the Yucca
Mountain repository will remain open for a century or more, even direct
disposal will leave all options open for a long time to come.) At least
some centralized storage capacity is needed to address particular needs;
whether nearly all of the spent fuel should be moved to a centralized
away-from-reactor site or site depends on a number of factors that
require further analysis. Here, too, we should not let frustration with
the current state of affairs prevent us from taking the time to get it
right: a rushed process for siting and licensing such facilities is a
recipe for public opposition and ultimate failure, adding to the long
history of failed attempts to site centralized interim storage
facilities in the United States. In a 2001 study, we provided a detailed
outline of a democratic and voluntary process for siting such
facilities, based on approaches that had been applied successfully in
siting other hazardous and unwanted facilities, and I would urge that
such an approach be followed here.[^31]

Fifth, Congress and the administration should work together to redouble
U.S. efforts to stem the spread of nuclear weapons -- resolving the
crises with Iran and North Korea, securing nuclear stockpiles around the
world, stopping black-market nuclear networks, and more.[^32]
Ultimately, this will also require reducing the demand for nuclear
weapons, in part by reducing the number, roles, and readiness of our
own.

[^1]: For a more comprehensive account of the issues surrounding
    near-term reprocessing in the United States, see Matthew Bunn,
    "Assessing the Benefits, Costs, and Risks of Near-Term Reprocessing
    and Alternatives," testimony before the Subcommittee on Energy and
    Water, Committee on Appropriations, U.S. Senate, 14 September 2006,
    available as of 12 November 2007 at www.belfercenter.org/\
    publication/3222/); see also Frank von Hippel, *Managing Spent
    Nuclear Fuel in the United States: The Illogic of Reprocessing*
    (Princeton, N.J.: International Panel on Fissile Materials, Research
    Report 3, January 2007, available as of 11 November 2007 at
    http://www.fissilematerials.org/ipfm/site_down/\
    ipfmresearchreport03.pdf ). For broader assessments of the future of
    nuclear energy that come to similar conclusions, see John Deutch and
    Ernest J. Moniz, co-chairs, *The Future of Nuclear Power: An
    Interdisciplinary MIT Study* (Cambridge, MA: Massachusetts Institute
    of Technology, 2003, available as of 12 November 2007 at
    http://web.mit.edu/nuclearpower/); and Keystone Center, *Nuclear
    Power Joint Fact-Finding* (Keystone, Colo: Keystone Center, June
    2007, available as of 12 November 2007 at
    http://www.keystone.org/spp/documents/FinalReport_NJFF6_12_2007(1).pdf).

[^2]: This formulation is adapted from Frank von Hippel, "GNEP and the
    U.S. Spent Fuel Problem," congressional staff briefing, 10 March
    2006.

[^3]: On South Korea, see, for example, Mark Hibbs, "ROK to Chart Fuel
    Cycle Policy Course Beyond 'Wait-and-See'," *NuclearFuel,* 23 April
    2007; on the French export ideas, see Ann MacLachlan, "Areva
    Dual-Track Strategy Aimed at Two Reprocessing Plants,"
    *NuclearFuel,* 3 July 2006. Areva, the state-owned French nuclear
    conglomerate, is quoted as saying that GNEP "boosted" its plans for
    exporting reprocessing plants.

[^4]: For a discussion, see von Hippel, *Managing Spent Fuel in the
    United States,* p. 20. Other than Japan, the major commercial
    reprocessing facilities in the world are in nuclear weapon states:
    France, the United Kingdom, and Russia. Since 1976, many of their
    customers (such as Germany and Sweden, among others) have joined the
    United States in abandoning reprocessing in favor of direct
    disposal. In general, the poor economics of reprocessing have driven
    decisions more than U.S. policy.

[^5]: James Timbie, U.S. Department of State, remarks to an open meeting
    of the U.S. National Academy of Sciences-Russian Academy of Sciences
    Committee on Internationalization of the Nuclear Fuel Cycle, 17
    October 2006.

[^6]: For a discussion, see Edwin S. Lyman, "The Global Nuclear Energy
    Partnership: Will it Advance Nonproliferation or Undermine It?" in
    *Proceedings of the Institute for Nuclear Materials Management
    47^th^ Annual Meeting,* Nashville, Tennessee, 16-20 July 2006
    (Northbrook, IL: INMM, 2006, available as of 11 November 2007 at
    http://www.npec-web.org/Essays/20060700-Lyman-GNEP.pdf); see also
    von Hippel, *Managing Spent Fuel in the United States,* pp. 23-24.

[^7]: For an authoritative unclassified discussion, see
    *Nonproliferation and Arms Control Assessment of Weapons-Usable
    Fissile Material Storage and Excess Plutonium Disposition
    Alternatives*, DOE/NN-0007 (Washington DC: U.S. Department of
    Energy, January 1997), pp. 38-39.

[^8]: Ronald E. Timm*, Security Assessment Report for Plutonium
    Transport in Fran*ce (Paris: Greenpeace International, 2005;
    available as of 12 November 2007 at
    www.greenpeace.fr/stop-plutonium/en/\
    TimmReportV5.pdf).

[^9]: Samuel Bodman, \"Carnegie Endowment for International Peace Moscow
    Center: Remarks as Prepared for Secretary Bodman\" (Moscow: U.S.
    Department of Energy, 16 March 2006; available at
    http://energy.gov/news/3348.htm as of 12 November 2007). This
    characterization seems oddly out of tune with the schedule of the
    administration's proposed solution, advanced burner reactors that
    will not be available in significant numbers to address this
    "growing" risk for decades. In a similar vein, the British Royal
    Society, in a 1998 report, warned that even in an advanced
    industrial state like the United Kingdom, the possibility that
    plutonium stocks might be "accessed for illicit weapons production
    is of extreme concern." The Royal Society, *Management of Separated
    Plutonium* (London: Royal Society, 1998, available as of 12 November
    2007 at http://www.royalsoc.ac.uk/displaypagedoc.asp?id=18551). The
    Royal Society renewed this warning and analyzed the options for
    action in a 2007 report. See The Royal Society, *Strategy Options
    for the UK's Separated Plutonium* (London: The Royal Society,
    September 2007, available as of 12 November 2007 at
    http://www.royalsoc.ac.uk/displaypagedoc.asp?id=27169).

[^10]: U.S. Department of Energy, Office of Nuclear Energy, "DOE
    Response to NAS-NRC Report Review of DOE's Nuclear Energy Research
    and Development Program" (Washington DC: 29 October 2007, available
    as of 11 November 2007 at
    http://www.gnep.energy.gov/pdfs/NAS_Response.pdf).

[^11]: See, for example, the categorizations in U.S. Nuclear Regulatory
    Commission, \"Part 73-Physical Protection of Plants and Materials,\"
    i*n Title 10, Code of Federal Regulatio*ns (Washington, D.C.: U.S.
    Government Printing Office; available as of 12 November 2007 at
    http://www.nrc.gov/reading-rm/doc-collections/cfr/part073/full-text.html);
    International Atomic Energy Agency*, The Physical Protection of
    Nuclear Material and Nuclear Faciliti*es, INFCIRC/225/Rev.4
    (Corrected) (Vienna: IAEA, 1999; available as of 12 November 2007 at
    http://www.iaea.or.at/Publications/Documents/Infcircs/1999/infcirc225r4c/\
    rev4_content.html). Any effort to define such a facility at only
    requiring Category II safeguards, on the basis of DOE's starkly
    different (and in important respects misguided) categorization
    guidelines, should be firmly rejected.

[^12]: Office of Nuclear Material Safety and Safeguards, U.S. Nuclear
    Regulatory Commission*, Safeguarding a Domestic Mixed Oxide Industry
    against a Hypothetical Subnational Thre*at, NUREG-0414 (Washington,
    D.C.: NRC, 1978), pp. 6.8-6.10.

[^13]: Keeping the actinides with the plutonium provides only a small
    fraction of the radiation level considered "self-protecting" by
    international standards -- 1 Sievert/hr at 1 meter, a standard that
    should itself be fundamentally reexamined in an age of suicidal
    terrorists. The lanthanide fission products have relatively short
    half-lives, and only provide substantial radiation fields if the
    spent fuel is processed fairly quickly after discharge. See Jungmin
    Kang and Frank von Hippel, "Limited Proliferation-Resistance
    Benefits From Recycling Unseparated Transuranics and Lanthanides
    From Light-Water Reactor Spent Fuel," *Science and Global Security,*
    Vol. 13, pp. 169-181, 2005, available as of 12 November 2007 at
    http://www.princeton.edu/\
    \~globsec/publications/pdf/13_3%20Kang%20vonhippel.pdf.

[^14]: For a discussion, see John P. Holdren, "Nonproliferation Aspects
    of Geologic Repositories," presented at the "International
    Conference on Geologic Repositories," October 31-November 3, 1999,
    Denver, Colorado).

[^15]: For a discussion, see Matthew Bunn, "Proliferation-Resistance
    (and Terror-Resistance) of Nuclear Energy Systems" lecture,
    Massachusetts Institute of Technology, 1 May 2006, available at
    http://www.belfercenter.org/files/proliferation_resist_lecture06.pdf
    as of 12 November 2007. For a more elaborate methodology, see
    *Evaluation Methodology for Proliferation Resistance and Physical
    Protection of Generation IV Nuclear Energy Systems* (Paris: Gen. IV
    International Forum, November 2006, available as of 12 November 2007
    at http://www.gen-4.org/Technology/horizontal/PRPPEM.pdf).

[^16]: Matthew Bunn, Steve Fetter, John P. Holdren, and Bob van der
    Zwaan, *The Economics of Reprocessing vs. Direct Disposal of Spent
    Nuclear Fuel* (Cambridge, MA: Project on Managing the Atom, Belfer
    Center for Science and International Affairs, John F. Kennedy School
    of Government, Harvard University, December 2003, available as of 12
    November 2007 at http://www.belfercenter.org/files/repro-report.pdf
    ).

[^17]: U.S. National Research Council, Committee on Separations
    Technology and Transmutation Systems, *Nuclear Wastes: Technologies
    For Separation and Transmutation* (Washington, D.C.: National
    Academy Press, 1996), p. 7. Note that these figures are expressed in
    1992 dollars; in 2006 dollars, the range would be \$66-\$133
    billion.

[^18]: *Program on Technology Innovation: Room at the Mountain --
    Analysis of the Maximum Disposal*

    *Capacity for Commercial Spent Nuclear Fuel in a Yucca Mountain
    Repository* (Palo Alto, Calif: Electric Power Research Institute,
    May 2006, available as of 12 November 2007 at
    http://www.epriweb.com/public/

    000000000001013523.pdf).

[^19]: For a similar argument that the GNEP approach "threatens to set
    back the nuclear revival," see, for example, Richard Lester, "New
    Nukes," *Issues in Science and Technology,* Summer 2006, pp. 39-46.
    For earlier discussions of this point, see, for example, John P.
    Holdren, "Improving US Energy Security and Reducing Greenhouse-Gas
    Emissions: The Role of Nuclear Energy," testimony to the
    Subcommittee on Energy and Environment, Committee on Science, U.S.
    House of Representatives, 25 July 2000, available as of 12 November
    2007 at http://www.belfercenter.org/publication/3244/.; and Matthew
    Bunn, "Enabling A Significant Future For Nuclear Power: Avoiding
    Catastrophes, Developing New Technologies, Democratizing Decisions
    -- And Staying Away From Separated Plutonium," in* Proceedings of
    Global \'99: Nuclear Technology- Bridging the Millennia*, Jackson
    Hole, Wyoming, August 30-September 2, 1999 (La Grange Park, Ill.:
    American Nuclear Society, 1999, available as of 12 November 2007 at
    www.belfercenter.org/publication/2014/).

[^20]: Richard L. Garwin, "R&D Priorities for GNEP," testimony to the
    U.S. House of Representatives, Committee on Science, Subcommittee on
    Energy, 6 April 2006, available as of 12 November 2007 at
    www.fas.org/rlg/060406-gnep.pdf.

[^21]: Jeff Beatie, "DOE Pushing to Recycle Closed Plants' Spent Fuel,"
    *Energy Daily,* 7 November 2007.

[^22]: For a useful account of such fuel assurances, see Ashton B.
    Carter and Stephen LaMontagne, "Toolbox: Containing the Nuclear Red
    Zone Threat," *The American Interest*, Vol. 1, No. 3 (Spring 2006),
    pp. 28-40.

[^23]: See discussion of such international approaches in Chapter 4 of
    Matthew Bunn et al.*, Interim Storage of Spent Nuclear Fuel: A Safe,
    Flexible, and Cost-Effective near-Term Approach to Spent Fuel
    Manageme*nt (Cambridge, Mass.: Project on Managing the Atom, Harvard
    University, and Project on Sociotechnics of Nuclear Energy, Tokyo
    University, 2001; available as of 12 November 2007 at
    http://www.belfercenter.\
    org/publication/2150/), pp. 95-116. Some of the best current work in
    both analyzing and promoting regional or international approaches to
    storage or disposal of spent fuel and nuclear waste is being done by
    the Arius consortium. Much of this work was available as of 12
    November 2007 at http://www.arius-world.org/.

[^24]: For a discussion, see Matthew Bunn and Anatoli Diakov,
    "Disposition of Excess Plutonium," in *Global Fissile Materials
    Report 2007* (Princeton, NJ: International Panel on Fissile
    Materials, October 2007, available as of 12 November 2007 at
    http://www.fissilematerials.org/ipfm/site_down/gfmr07.pdf), pp.
    33-42. The Royal Society's report, *Strategy Options for the UK's
    Separated Plutonium*, outlines approaches that could be pursued for
    the United Kingdom's huge stock of separated civilian plutonium. The
    United States should encourage all countries with military or civil
    stockpiles of excess separated plutonium to bring unneeded
    separation of plutonium to an end, undertake similar examinations of
    their options, and implement approaches to safe and secure
    disposition of these stockpiles as rapidly as practicable.

[^25]: Nuclear Energy Study Group, American Physical Society Panel on
    Public Affairs, *Nuclear Power and Proliferation Resistance:
    Securing Benefits, Limiting Risk* (Washington, D.C.: American
    Physical Society, May 2005, available as of 12 November 2007 at
    http://www.aps.org/policy/reports/popa-reports/\
    proliferation-resistance/upload/proliferation.pdf).

[^26]: National Commission on Energy Policy, *Ending the Energy
    Stalemate: A Bipartisan Strategy to Meet America's Energy
    Challenges* (Washington, D.C.: National Commission on Energy Policy,
    December 2004, available as of 12 November 2007 at
    http://www.energycommission.org/files/contentFiles/\
    report_noninteractive_44566feaabc5d.pdf ), pp. 60-61.

[^27]: Committee on Review of DOE's Nuclear Energy Research and
    Development Program, *Review of DOE's Nuclear Energy Research and
    Development Program* (Washington, D.C.: National Academy Press,
    October 2007, available as of 12 November 2007 at
    http://www.nap.edu/catalog/11998.html).

[^28]: APS, *Nuclear Power and Proliferation Resistance.*

[^29]: For a discussion, see Garwin, "R&D Priorities for GNEP." For a
    discussion of R&D that should be pursued on improved once-through
    options, see Deutch, Moniz, et al., *The Future of Nuclear Power.*

[^30]: For recent discussions, see, for example, American Physical
    Society, Nuclear Energy Study Group, *Consolidated Interim Storage
    of Commercial Spent Nuclear Fuel: A Technical and Programmatic
    Assessment* (College Park, MD: American Physical Society, February
    2007, available as of 12 November 2007 at
    http://www.aps.org/policy/reports/popa-reports/upload/Energy-2007-Report-InterimStorage.pdf
    ); National Commission on Energy Policy, *Energy Policy
    Recommendations to the President and the 110^th^ Congress*
    (Washington, D.C.: National Energy Commission, April 2007, available
    as of 12 November 2007 at
    http://energycommission.org/files/contentFiles/NCEP_Recommendations_April_2007\_\
    4656f9759c345.pdf), pp. 21-22; and Keystone Center, *Nuclear Power
    Joint Fact-Finding*, pp. 75-79.

[^31]: Bunn et al.*, Interim Storage of Spent Nuclear Fu*el, pp. 95-116.

[^32]: For a reasonable first cut at an agenda of steps to be taken, see
    George Perkovich et al.*, Universal Compliance: A Strategy for
    Nuclear Securit*y (Washington, D.C.: Carnegie Endowment for
    International Peace, 2005; available at
    http://www.carnegieendowment.org/files/UC2.FINAL3.pdf as of 13 May
    2007). For an agenda of steps to be taken specifically on preventing
    nuclear terrorism, see Matthew Bunn, *Securing the Bomb 2007*
    (Cambridge, Mass.: Project on Managing the Atom, Harvard University,
    and Nuclear Threat Initiative, September 2007, available as of 12
    November 2007 at http://www.nti.org/\
    e_research/securingthebomb07.pdf).