Contents

Chapter 1

Overview

Hitoshi Yoshioka

1. Why do an International Assessment of the Interim Report?······························ 1
1-1．Events Leading Up to the Formulation of the
Draft Nuclear Energy Policy Outline ·························································· 1
1-2．Interim Report Concerning the Nuclear Fuel Cycle Policy ························ 1
1-3．Purpose of the Review ················································································ 2
2. Organization and Activities of the ICRC ································································ 32-1. Background behind the establishment of the ICRC····································· 32-2. ICRC Members······························································································ 3
3. Characteristics of and Problems with the Interim Report ···································· 43-1. Conducting a “Comprehensive Evaluation” of the “Basic Scenarios”········· 43-2. The Conclusion to Adhere to the Current Policy ······································· 53-3. Problems with the Methodology of the Overall Assessment······················· 53-4. Problems with each of the Individual Assessment Items ···························· 7
3-5. A Summarization of the Problems ······························································· 9
4. Results of the Reviews by Overseas Panelists ························································ 94-1. Overall characteristics ··················································································· 94-2. Particular features of each individual report·············································· 10
4-2-1. Fred Barker (UK) ········································································ 10
4-2-2. Mycle Schneider (France) ·····························································11
4-2-3. Christian Küppers (Germany) ·······················································11
4-2-4. Frank von Hippel (USA) ····························································· 13
5. Assessment of the Cost of a Change of Policy ···················································· 13
5-1. Why treat the cost of a change of policy as a separate issue? ·············· 13
5-2. The Interim Report’s evaluation methodology in regard to thecost of a change of policy ······································································· 14
5-3. Errors in the long-term nuclear power plant shut down scenario ············ 14
5-4. The real problem associated with a change of policy ······························ 15
5-5. The uncounted costs of not changing policy············································· 16
6. Conclusion ················································································································· 16

Chapter 2ICRC Review

Fred Barker

1. Introduction ··············································································································· 18
2. Deficiencies in the Planning Council’s Assessment Method ········································· 18
3. Key Issues in Judgements of Scenario Performance ····················································· 19
4. Methods for Improved Assessment ·············································································· 23
5. Stakeholder Participation in Assessment ······································································ 25
6. Conclusion ················································································································· 26

Chapter 3

ICRC Review

Mycle Schneider

1. Introduction ··············································································································· 27
2. JAEC Methodology ···································································································· 27
3. Definition of the Scenarios ························································································· 28
4. Evaluation of the Scenarios························································································· 29
5. Conclusion ················································································································· 39

Chapter 4ICRC Review

Christian Küppers

1. Introduction·················································································································· 42
2. Radiological Impact of Reprocessing, Interim Storage and Final Disposal of Spent Fuel · 43
3. Safety of Reprocessing, Interim Storage and Final Disposal of Spent Fuel ······················ 46
4. Proliferation Risks Related to Separated Plutonium and Spent Fuel ································ 47
5. Overseas trends ············································································································ 49
6. Conclusion ··················································································································· 49

Chapter 5ICRC Review

Frank von Hippel

1. Introduction ··············································································································· 50
2. Domestic considerations: economics, safety and other considerations··························· 50
3. International considerations: the added danger of plutonium diversion by

would-benuclear terrorists and damage to the effort to contain the proliferation of national nuclear
fuel-cycle facilities ····································································································· 52
4. Conclusion ················································································································· 56

Appendix 1:New Nuclear Policy-Planning Council 13th Meeting Reference Paper 1.
Interim Report Concerning the Nuclear Fuel Cycle Policy, 12 November 2004 ············ 1

Appendix 2: Letter to the JAEC Chairman ················································································· 8Appendix 3: Reply from the JAEC Chairman ··············································································· 9

Chapter 1 Overview

Chapter 1
Overview
Hitoshi Yoshioka
Professor, Graduate School of Social and Cultural Studies, Kyushu University
Chair of ICRC

1. Why do an International Assessment of the Interim Report?
1-1. Events Leading Up to the Formulation of the Draft Nuclear Energy Policy Outline
In June 2004, the Cabinet Office’s Atomic Energy Commission established the New Nuclear PolicyPlanning Council with the aim of revising the Long Term Nuclear Program (Chokei)*. A review of the
Chokei is carried out approximately every five years. After a little more than a year's debate, on 28th of
July 2005, the Council published the Draft Nuclear Energy Policy Outline, and on the following day
began public comment on this document. The New Nuclear Policy-Planning Council will recommence
debate in September 2005, and there is a possibility that the Draft Nuclear Energy Policy Outline will befinalized then. It is thought that the reason why the name "Long Term Program" (Chokei) disappeared
this time was to clarify the assignment of responsibilities. The formulation of specific plans will be left up
to each individual ministry, while the Atomic Energy Commission will only be responsible forformulation of the basic policy.
[*“Chokei” is the Japanese abbreviation for the “Long-term Nuclear Program”.]
Compared with the Energy Basic Plan and the Science and Technology Basic Plan, the formulation ofwhich is required by law, the legal status of the Nuclear Energy Policy Outline is unclear. Furthermore,when the Law for Establishment of the Atomic Energy Commission was revised in 2001, Article 23,
which outlined the legal obligation of the prime minister to respect the decisions of the Atomic Energy
Commission, was deleted. Consequently, the legal authority and binding force of the Nuclear Energy
Policy Outline is unclear, but it cannot be denied that the contents of the Outline have substantive
authority over the government and also over the private sector.
The New Nuclear Policy-Planning Council, carried out a debate with regard to various fields and issues,
and by June 2005 had compiled 10 “interim reports” and “summaries of points for discussion”. These
reports express the majority opinion of the Council members. The main arguments outlined in the Draft
Nuclear Energy Policy Outline are based upon the contents of the “interim reports” and “summaries ofpoints for discussion”.

1-2. Interim Report Concerning the Nuclear Fuel Cycle Policy
During the deliberations this time, the major focus of public interest was the nuclear fuel cycle backend
policy. With construction of Japan Nuclear Fuel Ltd.’s (JNFL) Rokkasho Reprocessing Plant almost
finished, and the starting date of operations (referred to as active tests) getting closer, it was a perfect time
to stop and rethink the policy and assess whether or not it is appropriate to push forward with the spent
nuclear fuel reprocessing option. Consequently, the debate in the New Nuclear Policy-Planning Council
was being closely watched.
In principle, policy re-examination can be carried out at any time, but if this chance is lost, it is projectedthat there will be a huge cost (estimated at 1.55 trillion yen) associated with dismantling the reprocessing
plant. This is because it will have been contaminated due to operation. The cost of withdrawal will
become immense, resulting in a situation where it will be considered difficult to withdraw. That is why it
was said that if the reprocessing policy is to be re-examined, now is the time to do it.

1Chapter 1 Overview

Looking at this situation from the standpoint of the people who want to stick with the nuclear fuelreprocessing policy, the New Nuclear Policy-Planning Council represents the last big hurdle before
commencement of operations of the Rokkasho Reprocessing Plant. If the go-ahead to operate the facility
is given, the path forward will be clear. In Japan, the reprocessing of spent nuclear fuel is carried out by
the private sector, but a characteristic of Japanese policy is that private sector enterprise is strongly boundby government policy. Private sector entities have no legal obligation to abide by government policy, but
practically speaking, because of the administrative direction associated with permission for siting nuclear
power plants, power companies are left with no other option but to choose to reprocess their spent nuclear
fuel. So, for all intents and purposes, the government decision is the private sector decision.
Under these circumstances, the nuclear fuel cycle backend policy was destined to be the biggest issue inthe debate. The majority of the first 12 meetings were spent debating this issue. On 12 November 2004, as
the first of the 10 “interim reports” and “summaries of points for discussion”, the Interim Report
Concerning the Nuclear Fuel Cycle Policy (referred to below as the Interim Report) was agreed to as amajority opinion. The main points of the Interim Report were embedded as is into the Draft Nuclear
Energy Policy Outline. The gist of the argument is adherence to the historical policy and an expectation(in reality a demand) for smooth operation of the JNFL Rokkasho Reprocessing Plant.
Following the release of this report, JNFL and the Ministry for Economy Trade and Industry (METI)
immediately took action. Uranium commissioning of the Rokkasho Reprocessing Plant commenced in
December 2004 and in May 2005, the Reprocessing Fund Law* was passed and became law. In this way,even before the finalization of the Nuclear Energy Policy Outline, the Interim Report has already wielded
an immense amount of influence. Even though it is classified as a provisional Interim Report, policy isalready being forcefully carried out based on its conclusions.
[*Our abbreviated translation]

1-3. Purpose of the Review
During the debate regarding the Interim Report in the New Nuclear Policy-Planning Council, several
members of the Council, including some who are not necessarily opposed to nuclear power, expressed
many concerns about issues such as the following:
i.
ii.
iii.
iv.

the financial risk to the operators as a result of adherence to the historical policy;
the impact on the Japanese economy if this risk becomes a reality;
the risk of the imposition of an enormous public burden, due to a bail-out of the operators, orinsolvency proceedings;
the fear that the start of operations of the Rokkasho Reprocessing Plant will further undermine theinternational nuclear disarmament and nuclear non-proliferation regimes.

It was also pointed out that the least that can be said is that there is no rational reason to justify theimmediate commencement of full-scale operations of the Rokkasho Reprocessing Plant.
These concerns are well grounded. For this reason, it is necessary to re-examine the basic policy of theInterim Report prior to finalization of the Nuclear Energy Policy Outline. This is important because
continuation of the historical policy which is fixated on the implementation of spent nuclear fuelreprocessing, does not simply stop at Japan's adoption of an energy policy for the immediate future. It
also adds a future cause for concern for the Japanese economy and the daily lives of the citizen and it has
the potential to precipitate a situation that fundamentally threatens Japan's future position in theinternational community.
In order to contribute to the debate concerning such a revision, we decided, as a joint project between
Japanese and overseas nuclear power policy researchers, to carry out a scientific assessment of theInterim Report. Specifically, we carried out a professional assessment, in accordance with international

2

Chapter 1 Overview

standards, in regard to the appropriateness of the Interim Report. By introducing the results of thisassessment into Japan's policy decision-making process in real time, and by transmitting the results
widely to the international community, we hope to arouse an international climate of opinion, andcontribute to the improvement of Japan's policy. This is our main objective.
One more important goal is, by using this method of “international real-time policy assessment”, toestablish a paradigm, (an exemplary practical example) so that when important decisions concerning
Japan's nuclear and energy policy are made in the future, this method is available as an option for citizens
to pursue. When attempting to establish a new approach, it is insufficient to only explain the approachverbally. It is also necessary to present an exemplary practical example, so that the people who follow canemulate the earlier example, which in turn entrenches and improves the new approach.
The main target readers of this report are all persons connected to nuclear and energy policy decisionmaking. Of course, included in this target group is any member of the general public who has an intentionof participating in, or having an influence on, nuclear and energy policy decision-making.

2. Organization and Activities of the ICRC
2-1. Background behind the establishment of the ICRC
During the 12th meeting of the New Policy-Planning Council (held on 12 November 2004) when theInterim Report was adopted, Council member Professor Hitoshi Yoshioka of Kyushu University proposed
conducting an international review of the report. The Atomic Energy Commission didn't reject the
proposal outright, but it took no action in response to his proposal. However, the Takagi Fund for Citizen
Science had for some time, at the proposal of then Director Mycle Schneider and Executive Director
Tetsunari Iida, secured a budget allocation for a project to carry out a comparative evaluation of spent
fuel management options, including the operation of the Rokkasho Reprocessing Plant, and various spent
fuel storage options.
At this point, the Takagi Fund and the Institute for Sustainable Energy Policies (ISEP) (of which Mr. Iidais the Director) consulted together and, as a part of the Takagi Fund research project, it was decided to ask
Professor Yoshioka to work as the Chairman of an international review project. Professor Yoshioka
agreed to accept this role. The entrusted research project is divided into two projects, the “International
Critical Review Committee on the Long Term Nuclear Program” (ICRC), and the “Backend Assessment
Review” (BEAR). Overseas commission members were invited to Japan for the launching of the projectand on 29 March 2005 a kickoff meeting was held, and the project was publicly announced at a press
conference.
As for the procedures of the ICRC assessment, first the Japanese commission members proposed thebasic review subject matter and issues and between April and August 2005 the overseas commission
members each carried out an assessment review based on this framework. The Japanese commission
members then made suggestions on the overseas commission members’ reviews. At the same time, theJapanese commission members drafted an overall report (this ICRC Report) based on the contents of thefour review reports and, after receiving the consent of the overseas commission members, inserted it at
the beginning of the full report.

2-2. ICRC Members
In order to conduct an objective and critical assessment of the New Nuclear Policy-Planning Council'sInterim Report, committee members with academic ability and high theoretical and empirical skills werechosen from Japan and abroad. The people selected are all experienced and well-respected research andconsulting professionals in the nuclear energy policy field.

3Chapter 1 Overview

When selecting the committee members, a common criterion was that they be critical of the reprocessing
option, but care was taken to include both people who are opposed to and people who are not-opposed tonuclear energy. With regards to the overseas committee members, it was decided to appoint one personfrom each of the following leading atomic energy using countries: United States of America, United
Kingdom, France, and Germany.
International Critical Review Committee on the Long Term Nuclear Program (ICRC) Overseas
Panel Members:Frank von Hippel (USA)Professor of Public and International Affairs at Princeton University. Former Assistant Director for
National Security in the White House Office of Science and Technology Policy. International authority on
nuclear energy policy, whose statements have significant influence on issues not only in the U.S., butinternationally as well. He is an advocate of “Citizen Science”.
Fred Barker (United Kingdom)
Nuclear policy consultant. Member of the United Kingdom Committee on Radioactive Waste
Management (CoRWM), appointed to the committee as an independent member by the UK government.
Consultant specialising in nuclear policy analysis and stakeholder engagement.
Christian Küppers (Germany)
Deputy coordinator of the Nuclear Engineering & Plant Safety Division of the Institute for Applied
Ecology (Oeko-Institute). Member of the German Commission on Radiation Protection. He is aninternational authority on nuclear safety and radiation protection, often in cooperation with Michael Sailer(Chairman of the German Reactor Safety Commission and Deputy Director of the Oeko-Institute).
Mycle Schneider (France)
International energy and nuclear policy consultant. Advisor to the German, French and Belgian
governments on nuclear power policy. Former Director of WISE-Paris. Co-laureate of the Right
Livelihood Award (also known as the Alternative Nobel Prize) with his colleage Jinzaburo Takagi for
their joint work on plutonium issues.
International Critical Review Committee on the Long Term Nuclear Program (ICRC) Japanesepanel members:
Hitoshi Yoshioka,
Tetsunari Iida,
Yuichi Kaido,
Takeo Kikkawa,
Yo Fujimura,

Professor, Graduate School of Social and Cultural Studies, Kyushu University(Chair of ICRC)
Executive Director of Institute for Sustainable Energy Policies
LawyerProfessor, Institute of Social Science, The University of Tokyo
Assistant Professor, Graduate School of Science, Kyoto University

3. Characteristics of and Problems with the Interim Report3-1. Conducting a “Comprehensive Evaluation” of the “Basic Scenarios”
First of all, in this section we will provide an overview of the characteristics of and problems with theInterim Report. The viewpoint presented in this section represents the common view shared by theJapanese and overseas commission members. Then, in the next section, we will introduce the mainfeatures of the reviews of the four overseas members.
In the Interim Report, the following four “basic scenarios” were established:i.
reprocessing of all spent nuclear fuel (presumes the operation of a second reprocessing facility);4

Chapter 1 Overview

ii.
iii.
iv.

partial reprocessing (only the first reprocessing plant to reprocess spent fuel, interim storage
followed by direct disposal of spent fuel that exceeds reprocessing capacity);
direct disposal of all spent fuel;moratorium case (interim storage for the time being, then at sometime in the future decide between
reprocessing of all spent fuel or direct disposal of all spent fuel).

The Interim Report assumed that for those scenarios involving reprocessing, the reprocessing plant will
always operate at planned capacity (100% capacity, costs held within cost estimates). With regards tothese four scenarios, a comprehensive evaluation was carried out for the following ten issues:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)

safety assurance
energy security
environmental compatibility
economic considerations
nuclear non-proliferation
technical viabilitysocial acceptability
assurance of choice (flexibility)
issues associated with policy change
overseas trends.

The Interim Report concluded that, with regards to the nuclear fuel cycle backend policy, it was rational
to adhere to the reprocessing centered option.

3-2. The Conclusion to Adhere to the Current Policy
In addition, the Interim Report determined that the basic policy would be adherence to current policy. The
three most important points of the historical reprocessing policy are as follows.
i.

ii.

iii.

With regards to the management of spent nuclear fuel, reprocessing is considered the only
implementable option. Laws and ordinances which effectively bind private companies are firmly
maintained and legal interpretation of them by the administration is not altered. Legal measures tomake direct disposal of spent fuel possible will not proceed.
Private enterprise is expected to smoothly startup and operate the Rokkasho Reprocessing Plant.
The government will not intervene to adjust output in order to maintain balance between plutonium
supply and demand.
A mechanism will be put in place to enable private enterprise to retrieve the costs associated withreprocessing. (In this regard, the Electricity Industry Committee of METI’s Advisory Committee for
Natural Resources and Energy proposed the enactment of a Reprocessing Fund Law. The Atomic
Energy Commission gave its approval for this.)

However, there is one important change from existing policy. This is that research and development into
direct disposal was suggested on the grounds that technological development takes place in order to
respond to future uncertainties. (This is specified in the Draft Nuclear Energy Policy Outline.)

3-3. Problems with the Methodology of the Comprehensive Assessment
The Interim Report adopted an “comprehensive assessment” method based on multiple options. The
adoption of this methodology is to be commended. However, the most obvious approach, namely tochoose the best policy based on an overall policy assessment was not adopted.
Policy is something which indicates the government’s views regarding the methods of achieving a certain
goal. The government chooses as its policy the best of the various options available. The priority and5Chapter 1 Overview

weighting assigned to the various criteria and issues of assessment are determined depending on theobjectives established. Of course, the appropriateness of the policy goal itself must be examined from thepoint of view of public benefit.
As policy options, aiming to reprocess all spent nuclear fuel, or aiming to directly dispose of all spent
nuclear fuel, are policy options with specific meaning. The strategies required in order to aim for adesired state must also be included within these options. When such strategies are drawn up, of course, allde facto conditions (initial conditions, boundary conditions) concerning the backend operations, must be
taken into consideration. Among these, the six most important points are as follows:
i.
ii.

iii.
iv.

v.
vi.

Japan already holds over 40 tons of plutonium from reprocessing carried out in England and France.
There is no existing program capable of consuming huge quantities of plutonium (such as the use of
MOX fuel in light water reactors, or the fast-breeder reactor cycle program) and there is no prospectin sight of realizing such a program.
The Japanese government has publicly pledged to the international community that it will not holdsurplus plutonium.
The international nuclear disarmament and nuclear non-proliferation regime is in serious danger offalling apart and the commencement of operations at the Rokkasho Reprocessing Plant will have aneffect on this situation.
There is no prospect in sight for final disposal of the high-level radioactive waste (vitrified waste)
which results from reprocessing.
There is no prospect in sight for dealing with the spent MOX fuel that results from the utilization of
plutonium.

When developing a strategy, it is necessary to take into account these various de facto conditions, alongwith the uncertainties associated with reprocessing and the business risks which accompany these
uncertainties. The best policy from among those policy options that incorporate such a strategy should bechosen. Of course, what is deemed the best policy will change depending on how the various factors
governing the backend operations change in the future. However it is not possible to estimate futurechanges with a high degree of accuracy. Therefore, there are hazards associated with making a judgment
about the best option and it is necessary to include many disclaimers in regard to future uncertainties.
When future generations retrospectively assess today's policies, they will also scrutinize whether or notconsideration of the uncertainties was appropriate.
However the Interim Report completely bypassed the above mentioned comprehensive policy evaluationand instead did something that is similar but not the same. It presented abstract “project implementation
scenarios” under the name of “basic scenarios”, which take into consideration neither policy goals, nor defacto conditions, nor project uncertainties, nor the risks associated with them, then conducted acomprehensive evaluation of these scenarios. This effectively became a “general comparative
assessment” between the reprocessing and direct disposal methods. (Actually, it is also inadequate as a“general comparative assessment”. A symbolic proof of this is the addition of the cost of a change ofpolicy to the issues for assessment. In a general comparative assessment, a smuggling of initial conditions
cannot be done. A partial, methodologically eclectic assessment was carried out so as to obtain a resultthat is advantageous to adhering to the pro-reprocessing policy.)
The fatal defect which resulted from employing this methodology was that an assessment of someselectable policies was bypassed and the policy which was considered to be the best by the great majorityof people was left out of the options from the outset. That option was as follows: regardless of the routetaken in future, put a freeze on reprocessing until progress is made in consuming the existing plutonium
from reprocessing in Britain and France. (If this policy option had been adopted, a situation similar to themoratorium case in the Interim Report might or might not have been attained. Generally speaking, justbecause a policy option aiming for a certain condition is adopted, it does not necessarily follow that the“basic scenario” corresponding to that condition will be realized. Rather, it would not be surprising if thecorrelation between the two were low.)6

Chapter 1 Overview

Abruptly, from the general comparative assessment of the two methods, a conclusion which completely
adheres to current policy, was derived as a realistic policy choice. Even supposing that one arrives at theconclusion that the reprocessing option is in general a better choice, it is still a big logical jump to getfrom there to a conclusion which entirely affirms the current policy. Is it not necessary to carry out acareful assessment from the point of view of the public benefit for each and every policy?

3-4. Problems with each of the Individual Assessment Items
The scenario assessment in the Interim Report is effectively a comparison of the reprocessing and direct
disposal methods. However, it is not necessarily possible to conduct a simple comparison of the strengths
and weaknesses of these two methods. Therefore, for each issue assessed (nuclear non-proliferation,
safety, energy security, economics, environmental compatibility, etc), depending on which assessment
criteria are employed and which criteria are prioritized, the result of the assessment of the advantages anddisadvantages of the two methods will change greatly. In this context, it must be said that the balance of
the assessment criteria used in the Interim Report was seriously distorted. An overall characteristic wasthat those perspectives which where advantageous for reprocessing were emphasized, while those whichwere disadvantageous were either not taken into consideration or were downplayed. With regards todirect disposal, there was a pronounced tendency to take the opposite approach. The real weaknesses ofreprocessing were considered to be of no significance. On the other hand, imagination was employed tothe utmost when listing the weaknesses of direct disposal, while no opposite point of view was provided.
The assessment problems of each individual item are concisely listed below.
(i) Nuclear Non-Proliferation
The Interim Report concludes that as long as appropriate safeguards and measures to protect nuclear
material are adopted, there is no significant difference between reprocessing and direct disposal. In otherwords, they assume that the rules will be strictly followed, and find reprocessing and direct disposal to beequal. However, it is clear that the proliferation risk brought about by the separation of plutonium(reprocessing) places a further burden on nuclear material management, so the grounds for determining
them to be equal is obscure.

(ii) Safety Assurance
Following the same line of argument, the Interim Report judged both scenarios to be equal. However, it
inappropriately assumed that there could not be a severe accident at the reprocessing plant, or that an
accident could not occur at one of the various facilities associated with the reprocessing plant (forexample, an accident involving a leak of high-level liquid waste). Also, this approach is inappropriate
with regards to radiation exposure and radioactive leaks during normal operations, because it is not in
keeping with the spirit of the ALARA principle (As Low As Reasonably Achievable). Daily releases ofradioactivity from nuclear reprocessing plants are thousands of times greater than those of nuclear power
plants [see STOA Report].
(iii) Energy Security
The Interim Report only considered uranium resource savings in concluding that the reprocessing
scenario was superior. However, for decades to come, it is hard to imagine a situation where uranium will
become difficult to obtain due to shortage of supply. Even if this is assumed, a comparative assessment of
the effectiveness of other alternative countermeasures (such as increasing a uranium reserve) should havebeen carried out, so the grounds for the Interim Report’s conclusion are obscure here too. The Interim
Report also ignored the management risk which will result from the heavy economic burden of
reprocessing and the consequential risk of unstable electricity supply.

(iv) Economic Considerations
The Interim Report found the direct disposal scenario to be superior for this item. The results ofcalculations of backend related costs for the 59 year period to the year 2060 were that the scenario

7Chapter 1 Overview

involving reprocessing of all spent fuel would cost 1.6 yen/kWh, while the scenario involving direct
disposal of all spent nuclear fuel would cost between 0.9 and 1.1 yen/kWh. The ratio of the two scenarios
was between 1.5 and 1.8. Of all the assessments carried out, this was the most quantitative analysis andthe only analysis to yield a well-founded result. However, by accentuating the cost of a change of policy(where full spent fuel storage pools lead to the stoppage of nuclear power plants), the Interim Report drew
the conclusion that the direct disposal option was not necessarily superior. But the grounds for thisconclusion were extremely weak. The Interim Report completely ignored the extremely high economic
uncertainties of the reprocessing option (accidents etc., supply balance adjustment, changes in theinternational political situation, changes in public opinion, and so on) and the management risks whichaccompany these uncertainties. When a concrete policy for action is decided, it is essential that these
uncertainties and management risks be taken sufficiently into consideration. However, in a projectassessment of abstract, fanciful business plans under the name of "basic scenarios", such factors falloutside the scope of consideration.
(v) Environmental Compatibility
The Interim Report pointed to the compactness of the high-level waste repository site and argued thatsince plutonium reutilization would be a method of "recycling", as such it would be highly compatible
with the goal of achieving a closed-loop economy*. On this basis the Interim Report found the
reprocessing scenario to be superior. On the one hand, it strongly emphasized that risks associated withfinal waste disposal are greatly reduced by removing the plutonium, even though in reality the effect ofremoving plutonium is not very great. On the other hand, it concluded that emissions of radioactivity(during regular operations, and during accidents) are of no significance. The fact that huge amounts of
low and intermediate level waste are generated as a result of reprocessing and the dismantling of associatedfacilities was also not taken into consideration. With regards to spent MOX fuel, the Interim Report
assumed that it could be reprocessed and reused over and over again without problem, but noconsideration was given to the effects of its strong radioactive toxicity and its degrading plutonium quality.
[* ‘Closed-loop economy’ is one possible translation of the Japanese term ‘junkangata shakai’, but there
is no completely satisfactory translation. It is a uniquely Japanese term, which refers to a society where
the environmental impact due to waste is kept to a minimum. In Japanese bureaucratic parlance it iscommonly translated as ‘recycling-based society’. Promoting recycling is certainly one of the means, but
if one takes into consideration the fact that recycling doesn't always result in a reduced environmental
burden, it is a misleading translation.](vi) Flexibility (Assurance of Choice)
The Interim Report made the assumption that, because reprocessing leaves open the possibility for future
development, a fundamental quality of reprocessing is that it provides flexibility of choice. In addition, it
took the view that by proceeding with reprocessing, the current technological infrastructure andinternational understanding (previously obtained agreement) in regard to Japan's reprocessing
operations will be maintained. For these reasons it found reprocessing to be superior. However, as noted
above, the Interim Report suggested that research and development into direct disposal should be carriedout in order to respond to future uncertainties. It is therefore difficult to comprehend why the conclusionthat adherence to the reprocessing option is highly flexible was not adopted consistently throughout thereport.
In addition to the above, the Interim Report also carried out investigations in regard to “technicalviability” and “social acceptability”. An acknowledgment of “overseas trends” was also included. The
overall conclusion was that the reprocessing scenario was superior to the direct disposal scenario. In orderto reach this conclusion, it is necessary to apply a weighting to each of the individual items, but this was
not done. Admittedly, given that the Interim Report judged that direct disposal was inferior under every
criterion (putting to one side the validity of that assessment), regardless of the weighting applied, thesame conclusion would have been reached.

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3-5. A Summarization of the Problems
As indicated above, the Interim Report, contains serious flaws in both the logical structure and in theassessment of the individual items. This is the conclusion of the international assessment carried out by
Japanese and overseas experts. The suggestion that foreigners are unable to assess the Japanese case isfundamentally not applicable. This is because the reasoning of the Interim Report pays almost no
attention to the peculiarities of the Japanese situation. The style of debate developed in the report isessentially universal.

4. Results of the reviews by overseas panelists
4-1. Overall characteristics
In this section the overall characteristics of the review by the four overseas panelists, along with thecharacteristics of each of their individual reports, will be briefly introduced. All of the panelists, withrespect to their special fields of expertise, provided a broader and deeper analysis and evaluation than wasoffered in the brief overview in the previous section. Each in his own different words identified a general
problem with the Interim Report. This was the lack of clarity in regard to the evaluation criteria and thelack of any clear weighting system for the ten issues evaluated. The Interim Report’s evaluation criteria
for the ten issues are not in themselves particularly complicated. The reason why they were criticized inthis way is that the Interim Report emphasized those issues which are favorable for reprocessing andignored or downplayed those issues which are unfavorable for reprocessing. As a result, the priority of theissues for evaluation is difficult to understand in any systematic way. The Interim Report used these
unbalanced evaluation criteria to draw the conclusion that reprocessing is superior. However, because of
the low reliability of the evaluation method, all of the overseas panelists judged that the reliability of theconclusion was extremely low.
In regard to the evaluation of each individual issue, the overseas panelists made many similar comments
to those made by the Japanese panelists and also to the comments made by those members of the New
Nuclear Policy-Planning Council who were critical of the reprocessing option. This confirmed andstrengthened our own understanding.
The overseas panelists’ reviews contained very critical comments on three of the issues: safety,
environmental compatibility and non-proliferation. On the other hand, there was little discussion of thecost of a change of policy. Also there wasn’t much discussion about energy security. To some extent thisreflects the peculiar realities of Japan. However, more importantly, from an international perspective, it
might have been quite unbelievable for them that the Japanese government would decide to use plutonium
on the basis of this type of reasoning.
Below are some of the important points made by more than one of the panelists.
In regard to safety, the Interim Report made no mention of the fact that highly active liquid waste at
reprocessing facilities in both the UK and France has accumulated beyond the quantity predicted. This isdue to the fact that the reprocessing plants and the vitrification facilities have not operated smoothly. The
panelists pointed out that this is a very serious problem.
In regard to environmental compatibility, for the full reprocessing scenario the Interim Report only
considered the glass canisters from reprocessing spent uranium fuel. The effect of the radioactivity andthe heat generation of spent MOX fuel were completely ignored. The overseas panelists assumed thatsince an evaluation of the scenarios was carried out for the Interim Report, obviously a life cycle
assessment for the reprocessing scenarios must also have been carried out, including an assessment of theenvironmental compatibility conditions of the spent fuel from plutonium-containing MOX fuel. They
raised questions about concluding that reprocessing was superior without conducting such an assessment.
The unsoundness of the evaluation of the scenarios was clearly demonstrated in regard to this point.

9Chapter 1 Overview

Besides these points, they also raised questions about the Interim Report’s emphasis on Japan’s lack oftechnical know-how in regard to direct disposal, despite the fact that there are countries which havechosen the direct disposal option. This point was repeated to a surprising degree in the Interim Reportunder such issues as ‘safety assurance’ and ‘technical viability’.
The overseas panelists’ comments also showed their great interest in the international problem of nuclear
proliferation. The Interim Report stated that on this issue there was no significant difference between
reprocessing and direct disposal. However, the overseas panelists made several incisive criticisms of thisview. They pointed out that, in regard to preventing proliferation, totally different scales in time (present
and distant future) and space (surface facilities for handling plutonium and sub-surface disposal facilities)
were conflated. The point was made that the so-called ‘plutonium mine’ problem identified for the direct
disposal option also applies to the disposal of glass canisters. The overseas panelists also noted the grave
implications of Japan’s choice for international peace.

4-2. Particular features of each individual report4-2-1. Fred Barker (UK)Mr. Barker welcomed the fact that the New Nuclear Policy-Planning Council developed several futurescenarios for the management of spent fuel and evaluated a broad range of issues, both technical andsocial. However, because the evaluation method itself was not sufficiently robust or rigorous, heconcluded that it did not produce a reliable policy decision.
Mr. Barker pointed out that an overall problem with the evaluation method is that two obvious analyses
were not carried out. First, there was no sensitivity testing, for example of the effect on the relative meritsof each scenario of changes in quantitative conditions, such as energy supply and demand. Second, there
was no systematic analysis of the implications of changes in key assumptions (‘what if’ analysis), forexample, failure of reprocessing and vitrification facilities to operate smoothly, as has occurred in theUK .
In his review he gave specific examples of how each issue evaluated in the Interim Report was evaluatedfrom a very narrow point of view. In particular, he cited the situation in the UK, where a large quantity ofhighly active liquid waste has accumulated at the commercial scale reprocessing plant in Sellafield due inpart to difficulties with the vitrification facility. This has become a matter of considerable regulatory
concern. It is a major failure of the Interim Report that this important safety issue was not considered.
The lack of balance in the discussions carried out by the New Nuclear Policy-Planning Council can beseen throughout the Interim Report. Problems which have actually occurred as a result of reprocessing
were mentioned above, but the Interim Report treated them as if they were insignificant. On the other
hand, the reduction in the ‘inherent radioactive harm’ as a result of extracting the plutonium from thefinal waste was emphasized as evidence of the superiority of reprocessing. This argument has beenaround for a long time. However, in regard to geological disposal, it is recognized by people in the
nuclear energy field that the important issue is the mobility of the radioactive isotopes. Therefore, theproblem for safe disposal is isotopes other than plutonium. Reducing the level of radioactivity byremoving the plutonium does not translate directly into increased safety in terms of reduced radiologicaldose. Mr. Barker also indicated that there may be little difference between disposal of glass canisters anddirect disposal in regard to the level of safety.
In regard to the cost of a change of policy, he said that, in the case where the reprocessing plant is notoperated, including the cost of building replacement thermal power plants is an extreme scenario. In a
more realistic scenario, new interim storage facilities could be built to avoid nuclear power plant closures.
He also said that the money already invested in the construction of the reprocessing plant should betreated as a sunk cost and should not be included in the cost of a change of policy.

10Chapter 1 Overview

Mr. Barker did not attempt to refute the conclusion that reprocessing is superior. He provided aconstructive assessment. The nuclear fuel cycle is an issue with sharp divisions between those for andagainst. He recommended that the scenarios to be evaluated and the evaluation criteria, which he critiquedin his review, should be improved. He said it is desirable that a policy decision should be informed byanalytical methods such as numerically weighted multi-criteria assessment and strengthened
implementation analysis. The view of people with different points of view should be obtained andassessed through stakeholder participation, as is being done in the UK.
4-2-2. Mycle Schneider (France)
Mr. Schneider investigated in detail the unbalanced, one-sided nature of the evaluation criteria for all of
the ten issues evaluated in the Interim Report. His report overlaps with those of the other panelists, but Mr.
Schneider emphasized in particular the gaps in the Interim Report from the perspective of safety andsecurity in the context of terrorism, such as the September 11, 2001 attack in the US.
The Interim Report emphasized the 10-20% uranium saving resulting from reprocessing. However, Mr.
Schneider presented the reality in his own country, France, which is the world leader in the commercial
use of plutonium and where in 2004 nuclear power accounted for 78% of electricity supply. However,nuclear power plants supplied only 42% of commercial primary energy use in France and only 17.5% of
final energy use. The use of plutonium in light water reactors accounts for about 10% of that, so
plutonium is of only marginal significance to France’s energy supply, providing only 1% to 2% of the final
energy consumed in the country. Mr. Schneider pointed out that it would be quite possible to replace it inways with lower associated economic and social costs. It is still the case that 71% of France’s final energy
consumption is covered by fossil fuels and that both these and uranium are imported. Furthermore, hequestioned why Japan should be in a rush to start up a reprocessing plant, given that the 40 tons ofplutonium already owned by Japan is equal to the amount consumed by France over 25 years.
Mr. Schneider pointed out the ineffectiveness of reprocessing for energy security, given that fast breeder
reactors have failed worldwide. He also emphasized that throughout the world in recent years therecognition that acceptance of nuclear power is increased if plutonium is not used has been gaining
strength, even among proponents of nuclear energy.
The Interim Report said that in the case of direct disposal, because the final waste contains plutonium, it
is more difficult to find disposal sites. Mr. Schneider questioned the basis for this claim, pointing out thatthe strongest opposition worldwide has been to facilities which handle plutonium, such as reprocessing
facilities. The Interim Report said that if a policy decision is postponed and temporary storage iscontinued, local residents will fear that a final repository will not be found and interim storage facilities
will become semi-permanent facilities. Consequently, it is difficult to find interim storage sites. Mr.
Schneider’s response was that the role of the operators and local and federal authorities is precisely toresolve this mistrust.
Mr. Schneider is well versed in the circumstances of nuclear energy in Japan. He provided a detailed
analysis of each issue for evaluation. He emphasized that, considering the Japanese public’s great mistrust
towards nuclear energy, to choose to use plutonium on the basis of the unbalanced arguments provided in
the Interim Report would do nothing to reduce that public distrust.
4-2-3. Christian Küppers (Germany)
Mr. Küppers focused principally on three of the Interim Report’s issues for evaluation: safety assurance,
environmental compatibility and nuclear non-proliferation. From these perspectives, he concluded that
reprocessing is the least desirable and that direct disposal is the most desirable choice. He argued

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powerfully for the opposite conclusion to the Interim Report on the grounds that the Interim Report waswrong to ignore;

i.
ii.
iii.
iv.
v.

radiation doses below the dose limits established by the International Commission on RadiologicalProtection (ICRP);
the possibility that accidents beyond the design basis might occur;
differences in the number and kind of facilities where major accidents could occur;
the physical limits of safeguards;
appropriate weighting of the different evaluation criteria.

Mr. Küppers’s conclusion is not based on a comprehensive analysis of all the issues for evaluation, so it isdebatable whether it can be accepted as is. However, his review is a good example of how the conclusion
reached from an evaluation of the scenarios can change as a result of the choice and weighting of criteria.
The Interim Report concluded that there is no significant difference between reprocessing and direct
disposal in regard to safety and nuclear non-proliferation and that reprocessing is superior to direct
disposal in regard to environmental compatibility. However, Mr. Küppers (along with all the otheroverseas panelists) concluded that direct disposal is far superior on all these issues. Thus, it is not possible
to deduce that reprocessing is the superior option in the simplistic fashion of the Interim Report. It isnecessary to redo the assessment, fairly evaluating each criterion and giving appropriate weightings to thedifferent criteria. Mr. Küppers’s arguments are briefly summarized below.
Regarding safety assurance, of course nuclear energy facilities must fulfill the required safety standards,
but that doesn’t amount to a guarantee of safety. There is a big difference between the reprocessing pathand the direct disposal path with respect to the risk of a disastrous accident and the risk of worker
exposure to radiation. In the reprocessing path, reprocessing plants, which discharge at least four ordersof magnitude more radioactivity than nuclear reactors, and MOX fuel fabrication plants, which result in
two orders of magnitude higher radiation exposure for workers than uranium fuel fabrication plants, will
be operated. Compared to the direct disposal path, in which the radioactive materials are sealed in the
spent fuel through interim storage to final disposal, in the reprocessing path there are many scenarios inwhich large quantities of radioactivity may be released. The reprocessing path entails great risk ofradiation exposure to workers and to the general public. Although the dose during normal operations of a
reprocessing plant may be lower than natural radiation and the ICRP limits, the exposure of the publicshould be kept as low as reasonably achievable. Therefore, it is a mistake to argue that there is nodifference between direct disposal and reprocessing.
In regard to compatibility with a ‘closed-loop economy’, Mr. Küppers points out that after reprocessing
the volume of radioactive waste is larger than before, but only a negligible part of the radioactivity in the
spent fuel is separated for reuse. Also the heat generation and radioactivity of the spent MOX fuel is very
great, so it is absolutely wrong to say that reducing the quantity of resources used and waste produced,
reusing and recycling create a closed-loop economy and that reprocessing is consistent with thisphilosophy.
From the perspective of nuclear proliferation, a problem for reprocessing and MOX fuel fabrication plants
is that international safeguards, designed to prevent theft of plutonium and its diversion to nuclear
weapons, cannot function effectively. This is a physical limitation of safeguards-based inspections. Whenmanaging the quantity of plutonium on the basis of ‘countable items’, for example spent fuel assemblies,
the error is small. However, in ‘bulk-handling facilities’ like reprocessing plants and MOX fuelfabrication plants, where plutonium is handled in great amounts in free-flowing separated form,
unavoidably the measurement error far exceeds the quantity required to produce a nuclear weapon. The
Interim Report downplays these practical risks. It gives the same weight to the risk of plutonium being
dug up from a geological repository in the far distant future, when plutonium and nuclear weapons may
have lost the military importance that they now have, as to the real and present above ground risk. In thisfuture scenario it assumes, completely unrealistically, that this massive operation could be carried out
unnoticed. Mr. Küppers is very sceptical of this comparison.

12Chapter 1 Overview

4-2-4. Frank von Hippel (USA)Mr. von Hippel provided examples to precisely and concisely illustrate the one-sided nature of the Interim
Report’s evaluation. He expressed great concern regarding the safety of the reprocessing plant. Also, fromthe standpoint of an overseas panelist, he placed great importance on the problem of proliferation, arguingthat the start-up of the Rokkasho Reprocessing Plant is not just a domestic issue but also an international
issue. The first problem is that it makes it easier for terrorists to get hold of plutonium. As he points out,
“plutonium separated anywhere is a potential threat to cities everywhere”. The second problem is that, at
a time when countries suspected of being a proliferation concern are making moves to build nuclear fuelcycle facilities, Japan’s example undercuts ongoing international efforts to resist this growing trend.
Mr. von Hippel pointed to serious problems with the Interim Report’s argument that the proliferation risk
associated with reprocessing is of the same level as the risk associated with direct disposal. The
proliferation risk associated with direct disposal is that in hundreds of years’ time terrorists might raid thespent fuel repository a few hundred meters underground and steal the plutonium. This plutonium would
have to be extracted from the strongly gamma-emitting spent fuel inside metal containers, each weighingtens of tons. Mr. von Hippel argues that, if there are central governments hundreds or thousands of years
in the future, “they ought to be able to keep terrorist groups from recovering plutonium from a central
nuclear-waste repository hundreds of meters underground much more easily than a government today
could prevent the theft of plutonium in surface storage, processing or transport.” Terrorists can approach
MOX fuel without heavy shielding from gamma rays. This is a definitive difference between the
scenarios. The Interim Report said that once the gamma radiation has decreased, between a few hundred
and a few tens of thousands of years from now, the spent fuel repositories in the direct disposal scenario
will become ideal plutonium mines for terrorists. However, Mr. von Hippel points out that there will also
be significant quantities of plutonium in the glass canisters produced in the reprocessing scenario. If the
reprocessing plant operates for forty years, enough plutonium for 400 nuclear weapons will accumulate in
the material buried with the glass canisters. Furthermore, he warns, “if plutonium is still being separating
and recycled in that distant future, it will still be more difficult to protect on the surface than the dilute
plutonium stored in a few national repositories under hundreds of meters of rock.”
The large-scale use of plutonium extracted through reprocessing will indicate to other countries that Japan
has gained the nuclear-weapons option. Consequently, proceeding with reprocessing in Japan provides ajustification for other countries which say that all countries have the right to their own nuclear fuel-cycle
plants. In support of this position, Mr. von Hippel cited the example of statements made to him by highlevel Iranian officials. He concluded that if Japan, the only country thus far to have cities devastated by
nuclear bombs and the home to the world’s leading nuclear disarmament movement, decides to use
plutonium, it will have a huge impact on other countries and will do severe damage to the international
nonproliferation regime.

5. Assessment of the cost of a change of policy
5-1. Why treat the cost of a change of policy as a separate issue?
The four overseas panelists discussed the issues of nuclear non-proliferation and safety in detail, but there
were relatively few critical remarks regarding the other issues (security of supply, cost of a change ofpolicy, etc.).
As in Japan, in Europe and in the US, common sense dictates that due economic compensation should be
provided in a situation where freezing or terminating the reprocessing option would have a large impact
on the local economy. However, the Interim Report argued that freezing or terminating the reprocessing
option would rapidly lead to a deadlock in the management of spent nuclear fuel; that there was a highpossibility that this in turn would cause the majority of nuclear power plants to cease operating long-term;
and that the cost of constructing and operating replacement thermal power plants should be included in
the cost of a change of policy. This story line was probably all a bit too far-fetched for not only to
Japanese Panelists, but also the European and US panelists. It was difficult for us to come to terms with

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the fact that the Interim Report was seriously arguing this case and that this argument permeated theoverall assessment.
Nevertheless, this issue played an important role in the deliberations of Japan’s New Nuclear PolicyPlanning Council. Furthermore, the costs the Interim Report links to a policy change are quite large. To
the extent possible, people associated with Japan’s nuclear industry wanted to avoid these costs. It could
be interpreted to be a major motivation for their support for sticking with the existing policy. For thatreason it was judged necessary that the Japanese panelists provide a separate analysis for this one issue.
The issue is discussed below.

5-2. The Interim Report’s evaluation methodology in regard to the cost of a change ofpolicyThe Interim Report assumes that if the current reprocessing policy were frozen or changed, there would
be no further increase in spent fuel storage capacity (onsite storage and interim storage) and the 1,000
tons of spent nuclear fuel already accepted by the Rokkasho Reprocessing Plant would be returned to the
nuclear power plants where it originated.
As a result, it was assumed that the spent fuel storage pools established at the nuclear power plants would
fill up one by one, and, one by one, the nuclear power plants would shut down. The view of the Interim
Report was that there was a high probability that this would happen. Even in the most favorable case there
would be no extra storage capacity until 2015, while in unfavorable circumstances this situation would
continue until 2020.
As a result, almost all nuclear power plants would cease operating. The Interim Report judges that thecost of this would be between 11 trillion and 22 trillion yen (for replacement thermal power plants andincreased use of existing thermal plants).
Furthermore, in addition to the above costs, the Interim Report included the cost of construction anddismantling of the Rokkasho Reprocessing Plant (a little less than 3 trillion yen) in the total cost. This is arelatively low figure compared to the above amount, but it is nevertheless huge and it gives the reader the
impression that a change of policy would entail a huge economic burden.

5-3. Errors in the long-term nuclear power plant shut down scenario
However, it is inappropriate to include the cost of construction and dismantling of the Rokkasho
Reprocessing Plant (a little less than 3 trillion yen in total) in the total cost. The construction cost has
already been invested and the cost of dismantling is an unavoidable cost. These are not costs which will
be incurred in future as a consequence of a change of policy. These are sunk costs. In fact, there would beconsiderable savings linked to policy change if it occurs before the plant goes into active testing and gets
plutonium contaminated.
In addition, the long-term nuclear power plant shut down scenario contains the following three errors.
1. Even if reprocessing proceeds, in the case of accidents, or due to adjustments in the plutonium supply
and demand balance, there is still the risk of a long-term shut down of the Rokkasho Reprocessing
Plant, or that it will be forced to operate for an extended period of time at low capacity. In such cases
the same risks as those discussed above arise, so there should be no great difference between
proceeding with reprocessing and freezing or changing the existing policy. However, no consideration
is given to this in the Interim Report.
2. Long-term dry storage of spent nuclear fuel has relatively few safety problems compared to other typesof nuclear facilities. Therefore, from the perspective of protection from risks to life and health, it

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Chapter 1 Overview

should be easier to find a site for this type of facility than for other nuclear facilities. The idea that it
would take even longer to find a site for such a facility than for a nuclear power plant (that in the mostfavorable case there would be no progress for 10 years) is unreasonable. For example, in Germany
since July 2005 spent fuel shipments to reprocessing plants are totally banned, and all spent nuclear
fuel is stored at on-site dry storage facilities. We are told that gaining the acceptance of the local
communities was not particularly problematic.
3. A long-term stoppage of the majority of nuclear power plants as a result of the overflow problem ofspent fuel storage pools would be a serious situation for all concerned. The consequence would be thatthe whole nuclear power system (including the nuclear fuel cycle system) would be seen as high risk
and inadequate in regard to security of supply. It would lose the support of the market and of thegeneral public and be faced with extinction.
However, this is not a risk associated solely with a change of policy. It is a risk that could also easily reemerge in association with repeated accidents, or with adjustments to the plutonium demand and supply
balance. So if there is any reality in this scenario, it is because nuclear power by nature entails high risk of
cost escalation and is inferior in regard to security of supply. Nuclear power is having enough problems
surviving in a liberalized electricity market. It is quite likely that it will disappear as a result of natural
selection. Moreover, if lots of replacement thermal power plants were built, they would take away thedemand for existing nuclear power plants which had been closed for a long period of time. One would
predict that they would be shut down permanently.
Consequently, the long-term nuclear power plant shut down scenario is not realistic. If it ever began tohappen, there is a strong possibility that it would develop into an organized nuclear phase-out scenario.

5-4. The real problem associated with a change of policy
Despite the fact that the above scenario is not realistic, the fact that it was given prominence in theInterim Report suggests that the ‘real costs of a change of policy’ associated with putting a freeze on
reprocessing are considerable. These ‘real costs of a change of policy’ are not costs of a type which the
public will pay. They are costs which people associated with the nuclear power industry will have to pay.
Of course, some of them will be passed on to the public, but the consequences primarily will concern
companies and institutions directly associated with the nuclear power industry.
The greatest of these ‘real costs of a change of policy’ is that people associated with the nuclear powerindustry will lose some of their special privileges. Even if reprocessing is not cancelled, just frozen for awhile, the impact could be significant. The continued existence not just of reprocessing itself, but also of
related businesses and of businesses which were approved on the assumption that reprocessing would
become problematic. One such example is research and development into fast breeder reactor cycle
technology. Furthermore, by freezing reprocessing, the sense of the whole nuclear power industry as anindustry with poor development potential could be strengthened, or at least there is a high probability that
this impression will be conveyed to the public. It is felt that there is a danger that the whole nuclear powerindustry could incur significant damage this way. This damage would not only be felt by people directly
involved in the nuclear power industry, but by all people with a vested interest in the nuclear powerindustry.
Another important ‘real cost of a change of policy’ relates to the fact that the existing policy is propped
up through the alignment of the vested interests of a large number of people. Changing this will arouseconflicts between these people. There is a strong possibility that constructing a stable new community ofinterests will be a slow process. There will be many associated risks and costs.
For example, the power companies signed a safety agreement with Aomori Prefecture regarding its
acceptance of spent fuel on the assumption that the spent fuel would be reprocessed. If they breach thisagreement, consultations will be demanded regarding return of this spent fuel and they will lose the15Chapter 1 Overview

temporary destination for their spent fuel. It is appropriate to take the view that this will not cause spent
fuel pools to overflow and the majority of Japan’s nuclear power plants to close down long-term, but it istrue that power companies will be faced with a major problem. There is a high risk that they will have to
pay various costs in the short term, even if they would save considerable funds in the future. As for thegovernment, it is highly likely that as a result of a change of policy it will be forced to reallocate staff andbudgets. Furthermore, if the policy change is carried out against the will of the power companies, it ispossible that they, as the owners of the Rokkasho Reprocessing Plant, will claim damages from thegovernment. Local districts that are economically and budgetary heavily dependent on the nuclear fuelcycle will not be able to look forward to the tax income that would have arisen from the operation of the
reprocessing plant. They would be forced to drastically change their local development plans. They would
demand preventative action and claim compensation, so it is understandable that no one wants to change
this rigid status quo.
However, the Japan Atomic Energy Commission should not keep postponing a change of policy indeference to vested interests. It should decide on the best policy from the perspective of the public good.
It should also devise policy measures adequate to ameliorate regional economic difficulties.

5-5. The uncounted costs of not changing policy
In evaluating the scenarios, if the cost of a change of policy is considered, but the cost of not changing
policies is not considered, then clearly the evaluation is unbalanced. Most significant in this regard are thefinancial costs and the increased risk thereof. In regard to reprocessing, a huge investment has alreadybeen made in the Rokkasho Reprocessing Plant, including construction costs of 2.19 billion yen.
However, if it is decided to proceed with the reprocessing option, there will be huge costs to pay in future,including the cost of constructing and operating a MOX fuel fabrication facility. If a second reprocessing
plant is constructed, the costs will escalate further. Furthermore the Interim Report estimates that the
reprocessing option will be much more expensive than the direct disposal option. However, this estimate
is based on the assumption that the Rokkasho Reprocessing Plant will operate perfectly at full capacity.
The risk that it might not achieve this for one reason or another is not considered at all.
If that risk becomes a reality, besides the fact that reprocessing will come to a standstill, the unit cost of
reprocessing will escalate. There is a real possibility that this will put pressure on the management of thepower companies. This will stimulate action from investors and influence financial markets. The impact
could even ripple through the entire Japanese economy. If the financial difficulties become long-term,
reprocessing will be abandoned. There is also the possibility that the public will have to pay the hugebankruptcy costs.
Some members of the New Nuclear Policy-Planning Council repeatedly demanded that an assessment bemade of the uncertainties associated with reprocessing and the management risks and the financial risk to
the public that these entail. However, in contrast to the cost of a change of policy, this was almost totally
ignored. The two cases should have been compared from the perspective of public benefit.

6. Conclusion
Given that in the past the back end of the nuclear fuel cycle had been completely excluded from policy
debate, the fact that this Interim Report considered placing a freeze on reprocessing and direct disposal aspolicy options could be seen as a step forward. It was also laudable that the Interim Report acknowledgedthat economic analysis showed that direct disposal is much more economic than reprocessing. However,in regard to the other judgments made, there were serious deficiencies both in logical structure and in theevaluation of individual issues. Consequently, it failed to prove that, from the point of view of publicbenefit, the existing policy regarding the reprocessing of spent fuel is the best policy. The report of theinternational assessment panel proves that the Interim Report was a failure in this regard.

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Chapter 1 Overview

Overall, this report confirms that both overseas and Japanese panelists shared the same basic
understanding, the overseas panelists identifying the same problems as the Japanese panelists. In
particular, both agreed that the Interim Report based its decision on a very crude evaluation.
The main aim of the International Committee was to investigate the appropriateness of the Interim Report,
rather than to propose an alternative policy. The latter is the job of a sister group, known as the BEAR
Group. This group is working in parallel with the International Committee. Many of the members of theInternational Committee are also participating in, or cooperating with the BEAR Group.
The conclusion that can be drawn from the International Committee’s investigation is that the Atomic
Energy Commission should re-evaluate the policy on the back end of the nuclear fuel cycle articulated inits draft Nuclear Policy Outline. It should demand that Japan Nuclear Fuel Ltd. put a freeze on operations
at the Rokkasho Reprocessing Plant, while it conducts an investigation, based on correct methodology, todiscover what is the appropriate policy option.
If the Atomic Energy Commission conducts this investigation itself, it will be necessary for a new council
to be chosen, with membership that can debate for and against the current policy in a holistic andbalanced fashion, under a neutral chairperson with a neutral secretariat.
If the Atomic Energy Commission is unable to establish an appropriate policy decision-making forum,
the government should take responsibility for establishing a new decision-making forum, in an
organization other than the Atomic Energy Commission, to conduct a new review. This review should not
focus narrowly on nuclear energy policy, but should investigate nuclear energy policy, including the backend of the nuclear fuel cycle, in the context of the entire energy policy framework.

17

Chapter 2 ICRC Review - Fred Barker

Chapter 2
ICRC REVIEWFred Barker,
Independent Nuclear Policy Analyst (UK), Member of the International Critical Review Committee
on the Long Term Nuclear Program (ICRC).

1. Introduction
This paper is a contribution to the international review of the interim decision of the New Nuclear Policy
Planning Council on nuclear fuel cycle policy in Japan.
In preparing the paper, the author has used the translation of the Planning Council’s Interim Report by the
Citizens’ Nuclear Information Centre (CNIC)1. The author has also had the benefit of discussions withmembers of the ICRC and its secretariat during a visit to Japan at the end of March, 2005.
The paper has the following structure:-

Section 2: Deficiencies in the Planning Council’s Assessment Method
Section 3: Key Issues in Judgements of Scenario Performance
Section 4: Methods for Improved Assessment
Section 5: Stakeholder Participation in Assessment
Section 6: Conclusions

2. Deficiencies in the Planning Council’s Assessment Method
In principle, two central features of the Planning Council’s approach to assessment are to be welcomed:••

the development of scenarios2 which encompass a wide range of possible spent fuel management
futures; andthe identification of assessment criteria that encompass a broad range of relevant technical and social
issues.

However, as far as the author can judge from available material, this promising start is not built upon todevelop a robust and rigorous assessment method. In particular:a). There is an insufficiently systematic and rigorous approach to judging scenario performanceagainst criteria
As outlined in Section 3, many of the evaluations against specific criterion are open to criticism, with aneed for a more robust and rigorous approach.
1

CNIC [Internet]. Translation of the AEC Planning Council’s Interim Report Concerning the Nuclear Fuel Cycle
Policy. [updated 12 November 2004]. Available from:http://cnic.jp/english/topics/policy/chokei/longterminterim.html. (Also attached at the end of this report).
2
The four scenarios are: 1 reprocess all spent fuel; 2 reprocess spent fuel, but direct dispose of the quantity which
exceeds the capacity of the Rokkasho reprocessing plant; 3 direct dispose of all spent fuel; and 4 store spent fuel anddecide in the future whether to reprocess or dispose.

18Chapter 2 ICRC Review - Fred Barkerb.) There is no formal assessment of the relative importance of the different criteria
It is not immediately obvious whether the Planning Council considers all criteria to be equally important,or whether it is making implicit assumptions that some criteria are more important than others. The
Planning Council’s views and reasoning about the relative importance of different criteria should be madeexplicit, as should the impact of these views on the overall assessment.

c). There is no attempt to undertake any sensitivity testing to explore how varying assumptions
and judgements might impact on the overall assessment
For example, the assessment is based on an official reference case for the total electricity generated by
nuclear power between 2000 and 2060. However, it is possible to envisage different plausible energy
futures with varying contributions from nuclear power. A comprehensive approach would explore thepotential impact of different energy futures on the assessment of spent fuel management scenarios. In
addition, a more formal assessment method (see Section 4) would allow the impact of varying judgementsof (i) scenario performance against criteria and (ii) the relative importance of criteria to be explored.

d). There is no systematic attempt to analyse ‘what if’ questions across the scenarios
Although this is done to a degree for direct disposal scenarios, there appears to be very little analysis of
the implications of the failure to meet key assumptions in reprocessing scenarios. Obvious examples of‘what if’ questions relate to poor reprocessing or vitrification plant performance. A systematic analysis ofsuch questions can help inform more robust decision-making (see Section 4).

3. Key Issues in Judgements of Scenario Performance
The following examples support the argument that many of the Planning Council’s evaluations ofscenario performance against specific criterion are insufficiently rigorous.

3-1. ‘Safety Assurance’
Although a serious safety issue, there is no discussion in the Interim Report about the hazards associatedwith the accumulation of highly active liquid (HAL) waste from reprocessing. This accumulation could
occur if the performance of vitrification plant did not meet expectations, as has been the case in the UK
where the accumulation of HAL at Sellafield has been a matter of considerable regulatory concern.
In particular, in February 2000, the UK Nuclear Installations Inspectorate (NII) announced that it was
requiring BNFL to reduce stocks of HAL to a ‘buffer volume’ by around 2015. This was because the NII
believes:“that there has to be a demonstrable reduction in potential hazard (and hence risk) by
reducing the amount of HLW stored as Highly Active Liquor and that the around 2015
date must therefore be achieved, as any shortfall will be publicly unacceptable.”3
The lack of consideration of the safety implications of the potential accumulation of highly mobile, longlived radioactive material, is a significant omission in the Interim Report.

3

NII, ‘The Storage of Liquid High Level Waste at BNFL Sellafield’, 2000, p1. In January 2001, the NII formalised
its requirements for HAL stock reduction by issuing BNFL with a ‘Specification’, Health and Safety Executive,‘HSE Enforces Waste Reductions at Sellafield’, Press Release, 31 January 2001.

19

Chapter 2 ICRC Review - Fred Barker

3-2. ‘Energy Security’
The Interim Report considers energy security largely in terms of the impact of the scenarios on the supplyof uranium. This is a very limited and narrow way of looking at energy security issues.
In the UK in the 1990s, attention focussed on how most effectively to enhance diversity in electricity
supply as a response to unpredictability in the costs, technical performance, risks and environmental
impacts associated with any single electricity source. In general, the argument goes, the greater thevariety, balance and disparity of electricity generation sources within a supply system, the more diverse,and secure, is that electricity system4.
The converse argument is that the more an electricity supply system relies on a single source of electricity
supply, whether it be coal, nuclear or a specific type of renewable power, the less diverse and ultimately
less secure is that system. It follows that any steps that perpetuate over-reliance on particular electricity
sources is arguably contributing to reduced energy security.
It has been argued that this is particularly the case with over-reliance on nuclear power:“The two most serious accidents of recent years (Three Mile Island and Chernobyl)
provide evidence of the contagious effect of a nuclear accident. An accident anywhereaffects nuclear power almost everywhere. Given the strength of public reaction toaccidents and feared accidents .., introducing more nuclear power into an electricity supply
system may well reduce security. Although the primary fuel may appear to be available,
there is a constant danger that, because of events at home or abroad, future building might
be deferred, some existing capacity might be shutdown or derated, and stricter regulation
might lead to high costs.”5

3-3. ‘Environmental Compatibility’
The Interim Report appears to make the argument that reprocessing is advantageous on environmental
grounds because of the reduced toxicity of HLW compared with spent fuel, particularly over time. The
implication appears to be that the removal of plutonium from the HLW stream significantly improves
repository safety. Once again, this is a limited and narrow approach to assessment of an important issue
in the comparison of scenarios.
One starting point for a more complete assessment is acknowledgement that the long-term safety of deep
geological disposal depends on the immobilisation of radioactivity. Then, as has been pointed out:
“Studies of plutonium mobilisation suggest that it will not move far out of the near-field of the repository
under most conditions. Removing plutonium does not therefore bring great improvements to long-term
safety, which is determined more by the prevalence of nuclides like neptunium-237, technetium-99 andiodine-129. These occur in the same amounts in spent fuel and reprocessing waste.”6This position is supported in an appraisal from the IAEA. This shows that in terms of (a) the delay
between disposal and the start of dispersal of nuclides from a deep repository and (b) the rate of dispersal
4‘Variety’ represents the number of electricity sources in a portfolio. ‘Balance’ takes into account the relative
magnitudes of the contributions of the different sources. ‘Disparity’ involves consideration of factors such as thegeographical origins of fuel supplies, the firms involved in trading fuels or operating stations, the vendors involvedin supplying equipment, and the different regulatory and political issues invoked by different electricity sources.
For further discussion see, A Stirling. 1994. New Nuclear Investment and Electricity Portfolio Diversity. COLA
Nuclear Review Submission Volume 5.
5
C Robinson. 1990. Reviewing Nuclear Power in Prospects for Nuclear Power in the UK and Europe. SEEDS.
Discussion Paper. 53p.
6
F Berkhout. 1997. Reprocessing and the Environment in Energy and Security, No 2.

20

Chapter 2 ICRC Review - Fred Barker

into the environment, a range of nuclides are likely to have a far more significant radiological impact thanplutonium7. Overall, although highlighting that a complete and detailed safety assessment is not yet
possible, the IAEA appraisal concludes that:“For the direct disposal of spent fuel, the order of magnitude of the individual doses to the public are notexpected to be significantly different from the impacts from disposing of high level reprocessing waste.”
A number of factors complicate this picture of broad comparability:••

Firstly, reprocessing generates significant quantities of plutonium contaminated Intermediate
Level Waste (ILW), introducing additional concerns about the mobility of plutonium in a
repository containing such wastes. These concerns arise from the formation and mobility ofcolloids (very fine suspended particles). In the UK, it is thought that the organic material
contained in ILW can enhance the production of colloids8.
Secondly, the recycling of plutonium in MOX could increase the quantity of more mobile
actinides, such as neptunium-237 that are consigned to a repository9.

The Interim Report also suggests that the space required for the deep disposal of VHLW is between a half
and two thirds of that for the disposal of spent fuel. The basis for this suggestion should be explored in
more detail. For VHLW and spent fuel, required repository volume is largely determined by the heat
outputs of the wastes. The Interim Report’s suggestion therefore appears to be linked to a view that theheat output of VHLW is typically two thirds that from spent fuel.
In addition, it should be noted that the Interim Report does not appear to consider VHLW from
reprocessing spent MOX fuel in this assessment. This VHLW requires more repository volume due to its
higher heat output than VHLW from uranium fuel. Taking into account the volume of VHLW from spent
MOX fuel and ILW produced during reprocessing, the overall repository volume required for
reprocessing wastes is unlikely to be significantly smaller than for the equivalent amount of spent fuel10.

3-4. Nuclear non-proliferation
The Interim Report argues that there is no significant difference between the scenarios in terms of nonproliferation. The basis for this position appears to be that the short-term storage of MOX powder and the
deep disposal of spent fuel would both be required to meet internationally agreed monitoring and physicalprotection systems. However, this type of argument is weak because it is premised on the assumptions
that these systems will provide equivalent levels of protection for each scenario, and that they will beapplied consistently and work effectively over time (i.e. that they will not breakdown).
A more thorough and rigorous analysis would assess the resistance of the different scenarios to the mainclasses of proliferation and terrorist threats, including ‘host nation breakout’11 , theft for a proliferant
nation or for a sub-national group, and terrorist attack. Resistance to these threats arises not only fromengineered and institutional protection systems, but also from the intrinsic properties of the forms ofplutonium. A full assessment would consider the intrinsic properties of the forms of plutonium material

7

IAEA. 1997. Nuclear Fuel Cycle and Reactor Strategies: Adjusting to New Realities. Proceedings of anInternational Symposium Table V. 216p.
8
Following the Public Inquiry into the siting of a Rock Characterisation Facility in the UK, it was accepted thatfurther research was required on this issue, C S McDonald, ‘Cumbria County Council: Appeal by UK Nirex Ltd’,
Report of the Inquiry Inspector, 1997, paras 6c.60, 6C.65 and 6C.185-188.
9
C Kueppers, M Sailor. 1994. The MOX Industry or the Civilian Use of Plutonium. IPPNW report Table 7/1, 64p.
10
Where separated plutonium is recycled as MOX fuel, account should also be taken on the reprocessing side of theneed to dispose of spent MOX fuel. As this is likely to have a heat output of 2-3 times higher than conventional
spent fuel, it will require a correspondingly greater repository volume.
11
Where a country holding the plutonium containing material decides to recover it for use in nuclear weapons.

21Chapter 2 ICRC Review - Fred Barker

at different stages within a scenario, and how resistant the material form is to theft, plutonium separation,and hostile attack.
The Committee on International Security and Arms Control (CISAC) of the US National Academy of
Sciences has assessed the relative importance of a range of ‘intrinsic barriers’ to host nation breakout andtheft, when analysing which plutonium forms could be considered to meet the so-called ‘Spent FuelStandard’12. These intrinsic barriers include:•••

Barriers to theft: the mass and bulk of the item13, concentration of plutonium in the item, radiation
hazard, technical difficulty of part separation of plutonium from the item on site, and thermal,
chemical and nuclear signatures aiding detection.
Barriers to separation: technical difficulty of disassembly, technical difficulty of dissolution andseparation, quantity of material to be processed, hazards to separators, signatures aiding detection.
Barriers to use: deviation of isotopic composition from ‘weapons grade’.

In principle, it would be possible to build upon this type of approach to develop a more complete analysisof the proliferation resistance of each scenario.

3-5. Extra cost in reversing reprocessing policy
The Interim Report refers to the results of some basic cost comparisons of the four scenarios that werecarried out by the Secretariat to the Planning Council. These cost comparisons are based on a ‘greenfield’
analysis, which assumes all new facilities (and no sunk costs). The Interim Report then outlines theresults of further work that estimates the costs involved in reversing the current reprocessing policy.
The basic cost comparisons are contained in a translation provided by the CNIC 14 . Table 6 in thetranslation presents the results in terms of unit costs in yen/kWh. For Back End costs alone, the unit costfor scenario 1 (all reprocessing) is estimated at 0.94 yen/kWh and for scenario 3 (all direct disposal) at
0.33 – 0.46 yen/kWh. In other words, the costs of reprocessing and disposal of the resulting radioactive
wastes are estimated as around 2-3 times higher than the costs of storage and direct disposal of spent fuel.
This estimate is consistent with the results of a critical review of an OECD/NEA assessment of theeconomics of the nuclear fuel cycle15, which was co-authored by the current author. This critical review(the ‘Sadnicki et al report’) explained how - based on a ‘greenfield’ analysis - the OECD/NEA reportfound reprocessing to be twice as expensive as interim storage and direct disposal, even using
assumptions heavily biassed towards the reprocessing case. Examination of more plausible assumptions
indicated that reprocessing was up to three times more expensive than direct disposal.
The Sadnicki et al report pointed out that this dramatic difference in costs raised the possibility that aswitch from reprocessing in THORP to storage and direct disposal could actually offer financial benefits.
The report went on to estimate the future cash flows involved, focussing on the important case of the
spent fuel from German reactors that was to be reprocessed in THORP. It estimated that savings could bemade by switching to storage and direct disposal.
12

CISAC. 2000. The Spent Fuel Standard for the Disposition of Excess Weapon Plutonium: Application to Current
DOE Options.
CISAC argued that judgements about compliance with the SFS should depend only on the intrinsic properties of the
final plutonium form, not on the extent of engineered and institutional protection.
13
CISAC defined an item as the “smallest embodiment of the final plutonium form that could be removed from astorage facility without a degree of on-site physical processing (cutting, blasting etc) likely to be impractical foranybody but the host state”.
14
CNIC [Internet]. New Nuclear Policy-Planning Council: Costings for Direct Disposal of Spent Nuclear Fuel.
Available from: http://cnic.jp/english/topics/policy/chokei/disposalcost.html.
15
The OECD/NEA assessment is contained in “The Economics of the Nuclear Fuel Cycle”, 1994. The criticalreview is contained in M Sadnicki, F Barker and G MacKerron. 1999. THORP: The Case for Contract
Renegotiation. Friends of the Earth. pp7-12.

22Chapter 2 ICRC Review - Fred Barker

The Sadnicki et al report argues that the correct approach to estimating the costs of reversing a
reprocessing policy is to undertake a ‘future economic analysis’16. In this type of analysis the pattern of
all cash flows over future years is evaluated, including capital, operating and decommissioning costs, andpayments for the provision of products or services. This approach does not therefore take into accountpast costs and payments, which are considered sunk.
For the current review, the key questions then become: is the Interim Report’s approach to estimating thecosts of reversing reprocessing policy based on an assessment of future cash flows alone? And, if so, arereasonable assumptions made for all the main activities that have to be costed?
Although limitations of time and source material do not allow a detailed assessment of these questions,two points of concern arise immediately. Firstly, it appears that the Interim Report’s finding that extra
costs would arise from reversing reprocessing is based on an analysis that includes a figure of 2440
billion yen invested in Rokkasho. If this money has already been spent, it should be considered as sunkcosts and should not be included in the analysis.
Secondly, the Interim Report assumes that the reversal of policy would result in the shutting down ofnuclear power plants (as spent fuel storage facilities become full), with their replacement by new fossil
powered stations. The costs of new stations are then included in the analysis. However, it is questionable
that the analysis should be based on such an extreme scenario, when it seems plausible that despite thehurdles to doing so, new interim storage facilities could be built to avoid nuclear power station closures.
The costs of additional storage facilities should then be included, rather than the costs of new stations.
These two changes alone could make a significant impact on whether financial benefits or costs are
estimated to arise from a change in policy.

4. Methods for Improved Assessment
Section 2 outlined a number of deficiencies in the Planning Council’s assessment method. These weresummarised as:••••

An insufficiently systematic and rigorous approach to judging scenario performance against
criteria
No formal assessment of the relative importance of the different criteria
No attempt to undertake any sensitivity testing to explore how varying assumptions andjudgements might impact on the overall assessment
No systematic attempt to analyse ‘what if’ questions across the scenarios

These deficiencies suggest that the Planning Council’s approach would benefit from the use of moreformal decision-aiding tools. Two potentially helpful methods are outlined below.

4-1. Multi-Criteria Assessment
The first tool that could in principle enable a more robust and rigorous assessment is ‘Multi-Criteria
Assessment’ (MCA). The main steps in a MCA are normally:
1. identify the decision context, aims and starting assumptions.
2. identify and characterize the options that will be assessed.
3. identify the criteria against which the options will be assessed.

16

Sadnicki et al. 1999. pp57-60.

23Chapter 2 ICRC Review - Fred Barker

4. evaluate the performance of each option against each criterion (leading, for example, to theallocation of numerical ‘scores’).
5. assign ‘weights’ to each of the criteria to reflect their relative importance.
6. combine the weights and scores for each of the options to derive overall values.
7. conduct a sensitivity analysis of the results to changes in scores and weights.
8. discuss the results and their implications for decision-making.
In a sense, the Planning Council has gone part of the way through a MCA by identifying scenarios andassessment criteria, and carrying out a fairly rudimentary evaluation of scenario performance against
criteria (steps ii-iv). In principle, it would be possible to extend and develop the Planning Council’s
assessment by adopting a more formal MCA approach.
It should be noted that there are many ways of undertaking a MCA, depending on the aims of theassessment, and the availability of time, resources, data and analytical skills. All MCA approaches follow
the basic steps, but differ, for example, in how they ‘score’ option performance, ‘weight’ criteria,
combine weights and scores, and facilitate sensitivity testing. Various software packages are available toassist with these steps. In the UK, detailed guidance is available on how to undertake and make the bestuse of MCA for the appraisal of policy and other decisions17.
Using an MCA method does not however provide a panacea18. Care has to be taken to avoid a number of
pitfalls associated, for example, with a lack of clarity about when value judgements are being made, or
placing too much emphasis on the numerical outputs from combining scores and weights. Nonetheless,
MCA does offer advantages over less formal forms of assessment. These include:
•
•
•
•
•
•

a systematic approach that enables the basis for judgements to be visible, documented andcapable of presentation to outside audiences;
the inclusion of appropriate specialist knowledge, particularly in identifying the metrics and datathat can be used to inform judgements of option performance against criteria;
the inclusion of a wide range of stakeholder perspectives in reaching judgements about scores andcriteria weighting;an approach that allows uncertainties and differences of view to be identified, documented andaddressed through systematic and comprehensive sensitivity testing;an approach that enables large amounts of complex information to be handled in a consistentway; andan iterative approach, allowing steps in assessment to be re-visited and revised as appropriate in
the light of further information or discussion.

4-2. Implementation Analysis
In his detailed assessment of decision-making about THORP in the UK19, Walker argues that decisions
about major technological developments should be subject to a test of achievability that might be termedan ‘implementation analysis’. For Walker, the purpose would be to make transparent:

17

J Dodgson, M Spackman, A Pearman and L Phillips. 2001. DTLR Multi-Criteria Analysis Manula. Office of the
Deputy Prime Minister. A more accessible introduction to MCA can be found in G Butler, C McCombie and A
Pearman. 2004. Review of Options Assessment Methodologies and their Possible Relevance to the CoRWM
Process. IDM18
18
See, for example, A. Stirling. 1995. The Nirex Multi-Attribute Decision Analysis, Proof of Evidence to the RockCharacterisation Facility Public Inquiry. This sets out the disputes that can arise around the application of an MCA
method.
19
W Walker. 1999. Nuclear Entrapment: THORP and the Politics of Commitment. Institute for Public Policy
Research.

24

Chapter 2 ICRC Review - Fred Barker•••

the actions and activities (current and future) entailed when a given proposal is put into effect;
the plans (or options) that have been developed or are being developed in regard to those actions
and activities; andthe status of those plans in terms of acceptance and implementation.

Walker argues that such an analysis would help decision-makers and stakeholders:• to form judgements about the probability that the claimed outcomes can be achieved;• identify areas where special difficulties and risks might emerge;• gain a better understanding of the commitments that are being entered into;• make explicit the additional actions that will be required of governments so as to realise
proposal;• help identify the important “what if” questions; and• enable a full comparison of the relative merits of the alternatives.

the

The application of this sort of analysis to the ‘back end’ of the fuel cycle has much to recommend it.
Indeed, there would be merit in applying it systematically to each of the scenarios identified in the Interim
Report. In addition to helping decision makers develop a clear understanding of the risks, commitments
and required actions (and consequent actions) in different courses of action, it would highlight the need to
avoid ‘all or nothing’ policies, and the strategic value of flexibility in spent fuel management.

5. Stakeholder Participation in Assessment
There is increasing recognition internationally that decision-making in controversial policy areas can be
improved by engaging with stakeholders with a wide range of perspectives and knowledge.
In the UK, there are a number of examples of programmes of stakeholder engagement, intended to inform
decision-making at policy, strategic, or operational levels. These include:•

Committee on Radioactive Waste Management (CoRWM): this independent committee has been set
up to advise the UK Government on long-term approaches to the management of radioactive wastes
and materials. The Committee has its own budget to commission specialist papers, and to organise
public and stakeholder engagement. The Committee is proposing a short-list of options that include
various forms of long-term interim storage, and/or shallow or geological disposal. The Committee isdeveloping plans for assessing these options using a participative form of MCA20. It is due to makerecommendations to the UK Government in July 2006.

•

BNFL sponsored National Dialogue: this ran from 1998 to 2004 and involved key stakeholder groups,
including industry regulators, local government officials, trade unionists and environmentalists. The
Dialogue was facilitated by an independent third party called The Environment Council and produced
a variety of detailed reports that have encouraged BNFL to work on contingency plans and alternative
approaches21. In the process of producing these reports, a number of formal decision-aiding tools
were used, including MCA and ‘Strategic Action Planning’22.

20

CoRWM. 2005. How should the UK manage radioactive waste? 2nd Consultation Document. Section 2. See also
www.corwm.org.uk.[Internet]
21
Environmental council [Internet]. BNFL National Dialogue Reports. Available from: http://www.the-environmentcouncil.org.uk/templates/mn_template.asp?id=221.
22
Strategic Action Planning can be seen as a form of implementation analysis. See the basic introduction in G
Butler, C McCombie and A Pearman. 2004. Review of Options Assessment Methodologies and their Possible
Relevance to the CoRWM Process. IDM18.

25

Chapter 2 ICRC Review - Fred Barker•

Dounreay Best Practicable Environmental Option (BPEO) Consultation: the UKAEA has beendeveloping the use of participative BPEOs around the Dounreay site in North Scotland as an aid todecision-making on site clean-up and decommissioning. These participative BPEOs are based on aform of MCA23.

If the Planning Council’s assessment were to be developed and extended using the decision-aiding
methods outlined in Section 4, there would be a strong case for involving representatives from key
stakeholder groups. A participative form of MCA would, for example, allow uncertainties anddifferences of view in performance scoring and criteria weighting to be identified and addressed throughsensitivity testing, and for joint discussion of the implications for decision-making.

6. Conclusions
This review has argued that there is a wide range of deficiencies in the Planning Council’s assessment. In
particular, there is:••••

An insufficiently systematic and rigorous approach to judging scenario performance against
criteria
No formal assessment of the relative importance of the different criteria
No attempt to undertake any sensitivity testing to explore how varying assumptions andjudgements might impact on the overall assessment
No systematic attempt to analyse ‘what if’ questions across the scenarios.

The review has illustrated how many of the Planning Council’s evaluations of scenario performanceagainst specific criterion are open to criticism, and require a more robust and rigorous approach. This isargued to be the case with regard to evaluation against the criteria of ‘safety assurance’, ‘energy security’,‘environmental compatibility’, ‘nuclear non-proliferation’, and ‘cost in reversing reprocessing policy’.
The deficiencies in the Planning Council’s approach suggest that it would benefit from the use of moreformal decision-aiding tools. Two potentially helpful methods are outlined in the review: Multi-Criteria
Assessment and Implementation Analysis.
Finally, the review suggests that if the Planning Council’s assessment were to be developed and improved
using these sorts of methods, then there would be added benefit from involving representatives of key
stakeholder groups in the assessment. This should result in more robust analysis and improved decisionmaking.

23

Entec UK Ltd. 2004. Particles Best Practicable Environmental Option Public Consultation: Review of the
Proposed Consultation Process. and Faulkland Associates. 2004. Evaluation of the Dounreay BPEO Stakeholder
Programme: Main Report, C2014 R01-1.

26

Chapter 3 ICRC Review - Mycle Schneider

Chapter 3
ICRC REVIEW
Mycle Schneider,
Independent Nuclear Policy Analyst (France), Member of the International Critical Review
Committee on the Long Term Nuclear Program (ICRC).

1. Introduction
In November 2004 the Japan Atomic Energy Commission (JAEC) has released its Interim Report
Concerning the Nuclear Fuel Cycle Policy (hereafter the Interim Report)1. After requests from membersof a JAEC working group to get the document officially reviewed by international experts remained vain,
the establishment of the International Critical Review Committee on the Long Term Nuclear Program(ICRC) was initiated. The present paper is part of the ICRC analysis process.
It should be clearly stated that neither the mandate of the ICRC nor its resources are designed to prepare
its own in depth analysis of possible futures of the Japanese nuclear power program. The ICRC, as its
name suggests, has been established to provide an external, independent view on the coherence and natureof the JAEC Interim Report.

2. JAEC Methodology
The Interim Report lacks a clear explanation of the applied methodology. The reader would like to haveprecise understanding of the mandate, the definition of the role of the various actors 2 (secretariat,
composition of working groups, external experts) and the justification of their selection. The rules of theinteraction between the various actors and members of the public also remain unexplained. Effective anddemocratic stakeholder involvement is excluded if the public is merely invited to listen but occasions tovoice opinions that have to be taken into account are not provided for.
The Interim Report states, that, “if the deliberations of the Technical Investigation Subcommittee arecounted, 18 meetings were held over a total of 45 hours.” In order to appreciate the work accomplished it
would be helpful to know how many person-days of research and analysis work has been carried out
under the auspices of JAEC and by whom prior to the editing of the report.
It is also unclear by what mechanism the elements of information and analysis provided by external
experts were to be taken into account in the process. Analysis and comments offered by independent
experts have neither been reflected in the Interim Report nor have they been visibly refuted.
Overall, it is not transparent for the reader of the Interim Report why JAEC reached the conclusions it hasreached. Most of the statements are not backed up by arguments nor by scientific references. It is not a
1

CNIC [Internet]. Translation of the AEC Planning Council’s Interim Report Concerning the Nuclear Fuel Cycle
Policy. [updated 12 November 2004]. Available from:http://cnic.jp/english/topics/policy/chokei/longterminterim.html. (Also attached at the end of this report). The author
is not in a position to judge whether other elements of information have been made available by JAEC in Japanese
language.
2
In a letter to the JAEC Chairman dated 4 March 04, the author has expressed concern about possible conflict ofinterest in the case of JAEC secretariat staff that is at the same time on the pay-role of the nuclear industry (seeAppendix 2). In his reply dated 19 March 04, the JAEC Chairman simply indicated that the JAEC secretariat “iscomposed of government employees, who act under the obligation of the National Public Service Law” (seeAppendix 3).

27

Chapter 3 ICRC Review - Mycle Schneider

problem if JAEC reaches different conclusions from other authors as long as those conclusions are backed
up by a transparent and solid chain of argumentation. This is not the case in the Interim Report.
In addition, there are areas where additional in depth research is urgently needed – in particular relating tosafety and security aspects that derive from a post-911 perspective – but that have not been mentioned in
the Interim Report. In a recent testimony in the US House of Representatives, Matthew Bunn, SeniorResearch Associate at the University of Harvard’s Belfer Center for Science and International Affairs,
who is also lead author of a major study into spent fuel management options3 stated: “No complete lifecycle study of the safety and terrorism risks of reprocessing and recycling compared to those of direct
disposal has yet been done by disinterested parties. But it seems clear that extensive processing ofintensely radioactive spent fuel using volatile chemicals presents more opportunities for release ofradionuclides than does leaving spent fuel untouched in thick metal or concrete casks.”4
JAEC has chosen a number of spent fuel management scenarios that do not reflect the entire spectrum ofissues involved. The underlying rationale for the selection and definition of these scenarios remains
obscure (see next point for further discussion of the scenarios). Certain options have been ruled out fromthe start. For example, the four selected scenarios have not been compared to one or several nuclear
phase-out scenarios. If JAEC is convinced that the nuclear options are clearly favourable over nonnuclear options, the explicit comparison of the entire range of options would help decision makers and the
public to understand the reasoning.

3. Definition of the Scenarios
The definition of the scenarios is essential to the evaluation of possible policy options. In the following
part, possible shortcomings of the scenario definitions are discussed.

Scenario 1: “Reprocess spent fuel after storing it for an appropriate period of time”.
Scenario 1 seems to suggest the reprocessing of all spent fuel. This is technically and economicallydifficult and seems practically impossible. Since the amount of spent fuel currently discharged annually
already reaches a higher tonnage than the design throughput of the Rokkasho plant, the scenario implies
the building of a second reprocessing plant.
However, there will always be some spent fuel to be disposed of in the end. In particular, if the
reprocessing option suggests the reuse of the separated plutonium in the form of Light Water Reactor(LWR) MOX fuel, at least some spent MOX fuel will have to be disposed of at some point, even in thehighly unlikely case of multi-recycling. While the reprocessing of MOX has been technicallydemonstrated, currently there is no utility in the world that seriously considers reprocessing spent MOX.
The quality and fissile content of the plutonium degrades during the use in the reactor. Therefore the
incentive to extract plutonium further decreases after a MOX passage in the reactor from any point ofview (energy, toxicity, economics etc.).
In the evaluation sheet of the scenarios, JAEC indicates a certain volume of spent MOX fuel in Scenario 2.
It is unclear why this would apply to Scenario 2 and not to Scenario 1.

3

Matthew Bunn et al. 2001. Interim Storage of Spent Nuclear Fuel - A Safe, Flexible, and Cost-Effective NearTerm Approach to Spent Fuel Management. A Joint Report from the Harvard University Project on Managing theAtom and the University of Tokyo Project on Sociotechnics of Nuclear Energy.
Available from: http://bcsia.ksg.harvard.edu/BCSIA_content/documents/spentfuel.pdf
4Matthew Bunn. 2005. The Case Against a Near-Term Decision to Reprocess Spent Nuclear Fuel in the UnitedStates. Testimony for the Subcommittee on Energy, Committee on Science, US House of Representatives 2005.

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The scenario does not specify what shall happen to the over 40 tons of already separated Japanese
plutonium. However, it seems logical that Japan demonstrates a way how to deal with such a large
amount of plutonium – the quantity corresponds to the total amount of plutonium that has been absorbed
in the French fast breeder reactor and LWR MOX programs over a 25 year period (1973-1998) – before adecision on the separation of further amounts of plutonium is taken or even put into practice.
Alternatives to plutonium reintroduction into reactors, in particular the management as radioactive waste,
either in glass or ceramic form, are not presented and do not seem to have been evaluated.
The scenario assumes that all intermediate and high-level wastes from reprocessing would be smoothly
conditioned and brought to final storage. It does not envisage any technical difficulties neither potential
evolution of technical specification and therefore the potential need to review the waste management
schemes. This is of particular interest to already generated waste forms, including from overseas
reprocessing operations. 5 As for spent fuel and plutonium, a number of different management anddisposal routes are to be envisaged.

Scenario 2: “Reprocess spent fuel, but directly dispose of that quantity which exceeds
reprocessing capacity.”This scenario explicitly takes into account the fact that current reprocessing capacity is not sufficient inorder to handle the current or foreseeable spent fuel output of the Japanese nuclear power plants. It also
explicitly envisages the direct disposal of spent MOX fuel. Otherwise, comments on Scenario 1 apply.

Scenario 3: “Directly dispose of spent fuel”.
Supposedly Scenario 3 designates what usually is called the “once through” option. This means that noneof the spent fuel that is not currently under reprocessing contract abroad would be reprocessed.6 While thescenario does not explicit what would happen to the existing already separated plutonium, it would allow
for the option not to generate any MOX fuel and bring existing plutonium stocks under a waste
management scheme. However, no indication is given as to what the management of existing waste
streams would look like.

Scenario 4: “Store spent fuel for the time being and at some time in the future choose whether
to reprocess it or directly dispose of it.”In the short and medium term, Scenario 3 and 4 do not seem to present significant differences. However,
the report does not clarify what are the main implications envisaged. Essentially, the question is to what
extent the interim spent fuel storage management would be altered under the two scenarios. This is not
specified in the Interim Report.

4. Evaluation of the Scenarios
The JAEC states to have carried out a “comprehensive evaluation” of the four scenarios. In order to do
this it has established 10 criteria: (1) safety assurance, (2) energy security, (3) environmental
compatibility, (4) economic considerations, (5) nuclear non-proliferation, (6) technical viability, (7) social
5

In France, for example, it is illegal to store foreign nuclear waste. It would therefore be simplistic to assume that
there will be a swap of intermediate level and “old” conditioned waste (bitumen, concrete) for a smaller volume ofadditional high level waste.
6
All of the fuel under contract with the French company COGEMA has been reprocessed already. The remaining
spent fuel to be processed at BNFL’s Sellafield facility is unknown. After the detection of a significant spill at the
Sellafield THORP plant, it is not excluded anymore that the facility will remain shut down permanently. Whatshould happen in that case to foreign yet unreprocessed fuel remains unclear. A German utility has definitely
renounced a shipment to Sellafield that was contracted and already scheduled for the month of June 05.

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acceptability, (8) assurance of choice, (9) issues associated with policy change, (10) overseas trends.
JAEC has broken down the criteria into the following four categories:
Category I: Prior conditions, which are essential to the viability of the scenarios, such as safety assurance
and technical viability;
Category II: Factors, which can be used to compare the policy significance of the scenarios, such asenergy security, environmental compatibility, economic considerations, nuclear non-proliferation, andoverseas trends;
Category III: Practical, restrictions such as social acceptability (problems finding a site) and issues
associated with a change of policy; andCategory IV: Assurance of choice, that is adaptability in the light of future uncertainty associated withthe scenarios.
The Interim Report does not clarify whether the criteria have been looked at under lifecycle analysis
conditions that include all necessary activities at and between all of the necessary facilities. This isparticularly relevant for safety and security issues linked to transports. There are great differences
between the scenarios as to the need for particularly problematic shipments (eventually separated
plutonium 7 , fresh MOX fuel, spent fuel). Key issues concerning strategic choices in spent fuelmanagement strategies are not addressed. Those include wet versus dry storage, centralised versus
decentralised storage, away-from-reactor (AFR) versus on-site storage.
While each single criteria stipulated by JAEC could and should be discussed, there seem to be at least two
major lacking criteria:••

the level of security and possibility to protect against terrorism and its effects;
the compatibility of a plutonium economy under all circumstances with the requirements of afunctioning democracy.

Also, not only the definition of each qualitative criterion is insufficient but it is unclear how they areweighted against each other. For example, how is the choice to be made between an option that increases
energy security but is less proliferation proof and an option that provides the opposite qualities? How doyou weigh an option that is higher risk for 50 years but lower risk after 1,000 years versus another that islower risk for 500 years, but higher risk after 1,000 years? The Intermediate Report does not ask leavealone answer these fundamental questions.

Category I: Criteria (1): Safety Assurance
The sentence “almost no possibility that a difference between the scenarios will arise in regard to safetyassurance” does not have a single reference. There are dozens of major reports that have discussed safetyissues linked to plutonium separation and use versus non-reprocessing options in great detail and lengthand have come to significantly different results.8
7

Unforeseen plutonium shipments might be seen necessary in the case of the lack of expected performance of MOX
fuel fabrication facilities. Following repeated delays in MOX fabrication, the Sellafield MOX plant subcontracted
MOX fabrication to the French company COGEMA, which used plutonium of other origin. The equivalent quantityof plutonium will eventually have to be shipped from the UK to France.
8
In particular see Matthew Bunn et al.
The author has been involved in several major projects on the plutonium economy including:a) Mycle Schneider et al. 2001. Possible toxic effects from the nuclear reprocessing plants at Sellafield (UK) andCap de La Hague (France), commissioned by the Scientific and Technological Option Assessment (STOA)
programme at the European Parliament. WISE-Paris. 154 p.
Also see: http://www.wise-paris.org/english/stoa_en.html

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Chapter 3 ICRC Review - Mycle Schneider

One has to differentiate between safety under normal operating and under accidental conditions. The
reprocessing scenarios demand the transformation of a solid waste form – the spent fuel assemblies –
subsequently into liquid and oxide form. It is obvious that the physical-chemical condition of thematerials involved has potentially a great impact on the relative safety of plant operators and the
population.
One major study, the “STOA Report9”, concludes on releases from La Hague, the French site that houses
the reference plant for the Rokkasho reprocessing facility:“Releases of radioactivity from La Hague to the environment are several orders of magnitude larger thanreleases from a nuclear reactor. Releases of some radionuclides have decreased in the past while liquidand gaseous discharges of other key radionuclides have increased significantly. A further group ofradionuclides is not being measured in effluents. Increases of radioactive releases from La Hague in the
1990s and expected future discharges are in violation of obligations under the OSPAR Convention.”
During a European Parliament hearing on 12 March 2002, Margot Wallström, then European
Commissioner for the Environment, told the parliamentarians that the analysis of the discharge data in the« STOA Report » was "found to be consistent" with data collected by Commission services.
JAEC states that “the point has been made that scenarios 1 and 2, which involve reprocessing, require
more facilities to handle spent fuel than the other scenarios, and therefore could entail a higher release ofradioactivity into the environment. However, the exposure doses resulting from these releases will be low
and well within the regulatory limits. They will also be much lower than exposure from natural radiation.
The reference to exposure from natural radiation is misleading. Background radiation is not without harm.
Currently available radiation models indicate that there is no threshold for health impact from low levelsof radiation. In other words, current knowledge indicates that people exposed to background radiation
experience health detriment equivalent to the level of exposure, without any level being considered assafe. In the case of a country like France this means that the relative risk of exposure to backgroundradiation corresponds to several thousand lethal cancer cases every year.
A recent large study10 on over 400,000 workers from 15 countries indicates a significant risk increase
through radiation exposure including in very small doses: “Overall, on the basis of our central risk
estimates, we estimate that 1-2% of deaths from cancer (including leukaemia) among workers in thiscohort may be attributable to radiation. This assessment actually increases the risk estimate that iscurrently underlying the international radiation protection regime.
In addition to exposure from normal operating conditions, the “STOA Report” concludes on the accident
hazard in the case of La Hague:“Past accidents at La Hague include at least one accident that led to population doses
significantly exceeding EU limits. Accidents are estimated to be responsible of 36% of theleukaemia risk level for the 0-24 year age category around the La Hague site. The hazard
potential of the La Hague spent fuel stores is very large. The accidental release of afraction of the caesium inventory in the cooling pools could cause up to 1.5 million fatal
cancers.”11b) Jinzaburo Takagi (Dir.), Mycle Schneider (Ass. Dir.) et al. 1997. Comprehensive Social Impact Assessment of
MOX Use in Light Water Reactors. Final report of the International MOX Assessment. Citizen Nuclear Information
Center (CNIC), Tokyo, Japan. English, Japanese and Russian editions, 335p.
Also see: http://cnic.jp/english/topics/cycle/MOX/ima/
9
see Mycle Schneider et al.
10
Elizabeth Cardis (dir.) et al. 2005 .Risk of cancer after low doses of ionising radiation: retrospective cohort study
in 15 countries. British Medical Journal: 331:77.
11
see Mycle Schneider et al.

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Similar consequences, or worse, are to be envisaged under a terrorist attack scenario. 12 Under nonreprocessing schemes there are many ways to avoid large spent fuel inventories in pools.
If JAEC does disregard the findings of international assessments it should explain in detail why and what
the own statements are based on, so as to allow for detailed analysis and debate.

Category I: Criteria (6): Technical Viability
While it is true that the reprocessing and vitrification technologies have been fully developed, until today
it proves complex and difficult to implement. The lack of operability of the Sellafield vitrification
facilities lead to the regulator required shut-down of the THORP reprocessing plant in the past. The
current post-accidental situation after a serious Level-3 incident in the THORP clarification cell is anotherindicator of the complexity of the system. As of the end of 2004, La Hague – and this is much less wellknown – as well as the Sellafield site had 1,000 m 3 or more high active waste in liquid form stored on thesite. This liquid, easily dispersable, contains on each site several dozen times the amount of cesium-137
released during the Chernobyl accident that accounts for about three quarters of its radiological impact. A
high active liquor backlog of such a size had never been planned. It is several times larger, in both cases,
than envisaged on design basis. It is very surprising therefore that JAEC seems to consider that the
problem is solved.
The Interim Report estimates that “there is a lack of accumulated technical knowledge on which to judge
the suitability of direct disposal in the Japanese disposal environment”. That is certainly true. However, it
is unclear, why JAEC considers it “by contrast” to the reprocessing option. In fact, the final disposal
problem remains in the case of vitrified waste. In addition, while the plutonium path inherently leads toseveral different waste streams (vitrified high-level waste, cemented and bitumen intermediate level waste,solid, gaseous and liquid low level waste) that considerably increase the complexity of the waste
management compared to Scenarios 3 and 4 that induce a solid high active waste (the spent fuel) andminor quantities of low level radioactive waste in the case of wet storage (which can be prevented
through adoption of a dry storage option).

Category II: Criteria (2): Energy Security
Historically the question of energy security has been an important argument used in favour of nuclear
power in Japan, just as in France. JAEC states that scenarios 1 and 2 have “the effect of reducing theamount of uranium required by between 10% and 20%”. Since plutonium can be reintroduced into
reactors replacing a certain amount of uranium, the principle of that statement is theoretically obvious,
even if one can discuss the figures. However, while Japanese spent fuel has been reprocessed for almost
30 years (in Japan since 1977), no plutonium has so far been reintroduced into an LWR and little into fast
breeder reactors. As stated above, the current amount of already separated Japanese plutonium
corresponds to the quantity that has been reused in breeders and LWRs in France over a 25-year period.
Energy security should not be measured in mere terms of additional primary energy content. In thisrespect, the Interim Report fundamentally lacks the identification many and discussion of most possible
alternatives to the separation and use of plutonium. As a matter of supply security, should be integrated
into the consideration, for example, the potential of:••

Enrichment tailings: the waste from the process of uranium enrichment still contains considerable
amounts of fissile uranium-235 that could be separated at low cost if justified by high uranium
prices;The build-up of a strategic uranium reserve;13

12

Following the 7 July 05 London terrorist attacks up to 5,000 “non-essential” Sellafield workers were told to stayat home for four days after the site that houses the UK’s plutonium facilities went on “amber alert” although the site
was said to be at no specific risk.
13
See for example Paul Leventhal, Steven Dolly. 1995. A Japanese Strategic Uranium Reserve: A Safe and32

Chapter 3 ICRC Review - Mycle Schneider

•
•
•
•
•

Uranium extraction from seawater;
Uranium separation from phosphate mining activities;
Increase in uranium fuel burn-up to levels difficult to achieve with plutonium fuels;
Thorium resources;
Finally, a whole range of non-nuclear energy services options (efficiency, CHP, renewables14,etc.) that could be combined with Scenarios 3 and/or 4 in order to increase supply security.

The Intermediate Report refers to the first point and states that a view was held that “a comprehensive
assessment should consider, in addition to reprocessing, reducing the concentration of the tailings. It
seems like a quite obvious case of “cart-before-horse” to consider reprocessing before the efficient
implementation of an already practiced industrial activity, which is uranium isotope separation orenrichment. The Intermediate Report further notes that “in response to this view it was pointed out thatthe superiority of scenario 1 becomes much more pronounced if the fast breeder is established, so the path
towards implementation of the fast breeder should be made clearer.” The argumentation is identical to the
one that has led to the conceptualisation of the first generation of breeder reactors, including the Monju
reactor that has been consuming rather than generating electricity over the past 10 years.
Considerations on supply security must take into account historical experiences in Japan and in othercountries. The devastating failures of the fast breeder programs in Europe and the US have led to thesubsequent abandoning (or eternal moratoria) of reprocessing programs in most of the European countries.
In the UK, one of the two only countries that operate commercial reprocessing plants, there is now open
debate about the question whether to restart the THORP facility, currently shut down for an indefinite
period of time after the detection of a major leak. The internal BNFL inspection report on the incident
notes: “This event has demonstrated that despite high quality construction, serious faults can occur within
THORP which breach primary containment. Given the history of such events so far, it seems likely that
there will remain a significant chance of further plant failures occurring in the future even with thecomprehensive implementation of the recommendations in this report.”15 Under those circumstances apotential strategic dependency on a scheme to produce a difficult-to-use primary energy material seems aquestionable way to take care of the legitimate concern of supply security.
In addition, nuclear power only provides electricity, while the energy consumption of any given society ismainly non-electric. The role of an energy source should be examined according to its potential to cover
the energy service needs of a given society. In France, for example, in 2004 nuclear power plants supplied
78% of the electricity, but just 42% of commercial primary energy and only 17.5% of the final energy
consumed in the country. The plutonium fuel loaded into 20 French reactors (max. one third of the core)
generates 8%-10% of the nuclear electricity in the country.16 In other words, plutonium fuels provide
between 1% and 2% of the final energy consumed in France. The contribution of plutonium to “supply
security” is not only marginal, it is irrelevant since it can easily and cheaply be substituted by a number ofother options. At the same time, 71% of French final energy is still being provided by fossil fuels (oil, gas,coal). All of the French uranium and all of the fossil fuels are imported.
Finally, supply security has to take into account other parameters like flexibility, security and systemrobustness that are not reflected in the parameters used in the Intermediate Report on this specificcriterion.

Economic Alternative to Plutonium. Science & Global Security: Vol.5. pp1-31.
See for example Marc Fioravanti. 1999. Wind Power Versus Plutonium: An Examination of Wind Energy
Potential and a Comparison of Offshore Wind Energy to Plutonium Use in Japan. prepared for the Institute forEnergy and Environmental Research. Available from: http://www.ieer.org/reports/wind/summrec.html/.
15
BNFL. 2005. Fractured Pipe With Loss of Primary Containment in the THORP Feed Clarification Cell. Board of
Inquiry Report.
16
The quantity of plutonium absorbed in the French MOX program corresponds to the output of one of the two
reprocessing lines at La Hague and is equivalent to the expected throughput of the Rokkasho plant.
14

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Category II: Criteria (3): Environmental Compatibility
In the scenario evaluation, the JAEC Secretariat is noted as stating: “Reprocessing aims to recover andreuse resources and thus reduce waste. Reducing the quantity of resources used and waste produced,
reusing and recycling create a closed-loop economy. Reprocessing is consistent with this philosophy.”
The Secretariat correctly states that reprocessing aims to recover and reuse resources. Unfortunately, thisis the theory, not the practice. Hardly any of the recovered Japanese plutonium has been reused. On thecontrary, it is quite likely that, to date, the overall lifecycle analysis of Japanese plutonium separation anduse would result in a negative energy balance.
There is no other “closed loop” industry that would be permitted to emit as many pollutants, in quantityand quality, to the environment than the plutonium industry. Furthermore, the statement that reprocessing
is “reducing the quantity of (…) waste produced” is factually wrong.
The Intermediate Report states: “The volume of high-level waste would be reduced to between 30% and
40% and the space required to bury it would be reduced to between a half and two thirds of that if the
spent fuel had been disposed of directly. Therefore, this scenario is superior.” It would be interesting to
see the underlying calculations to this affirmation. Other comparative calculations on waste generation
get to significantly different results.17 Under all circumstances, it is indispensable to appropriately address
the following issues in the evaluation:•

There is no incentive to reprocess MOX fuel. Spent MOX fuel has to be either cooled much
longer prior to final disposal than uranium fuel (roughly an additional 100 years, according to a
scenario by the French utility EDF) or it needs a much larger final storage volume (four times thevolume of uranium fuel, as envisaged by JAEC itself) because of the much higher heat output.

•

Waste volumes are not limited to high-level wastes. Significant amounts of intermediate level
wastes arise in the reprocessing scheme that don’t even exist in the once-through path. In addition,
large amounts of low level wastes are generated and either discharged into the environment orconditioned as solid waste. Volumes are particularly significant in the case of decommissioning
wastes from the reprocessing plant. In volume terms it is obvious that reprocessing entails thegeneration of a significant larger quantity of waste than the once-through option.

Category II: Criteria (4): Economic Considerations
The following economic criteria have been spelled out in the Intermediate Report:•••

How should differences in economic merit be measured?
In regard to economic merit, from the point of view of the burden on households, how does thiscompare with recycling of such things as cars, electrical appliances and general industrial items?
What is the difference in the cost of the nuclear fuel cycle in terms of the cost of production ofelectricity?

While the first question has not been explicitly answered in the Intermediate Report, the two other criteria
are heavily biased and set out from the start to lower significance of the economic advantage of the oncethrough options over the plutonium fuel scenarios. The question is altered implicitly from what is themost economic option in the framework of a global cost-benefit analysis to what could Japaneseelectricity and taxpayers afford to pay for. Comparisons with consumer goods like cars and refrigerators
are grossly misleading. The impact of an individual given consumer good and its recycling, the level ofindividual taxpayers’ choice and the level of intergenerational consequences of a given practice are by no17

see Yves Marignac, Xavier Coeytaux. 2002. Volumes de déchets radioactifs à vie longue associés à la gestion du
combustible usé (colis / barrières ouvragées). WISE-Paris.

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Chapter 3 ICRC Review - Mycle Schneidermeans comparable. While JAEC clearly admits that Scenario 1 is the most expensive one, it does notclarify what system lifecycle analysis based cost-benefit evaluation actually looks like.
As the author has pointed out in his presentation to JAEC on 2 March 04, even if Rokkasho did operate
for 40 years with an unlikely load factor of 100%, the cost per gram of separated plutonium (based on
TEPCO’s 40 year plutonium economy cost estimate) would be 40 times the current price of gold. At thesame time, the British and French owners of dozens of tons of plutonium attribute into their official
accounts a zero value to their plutonium stocks. It is unclear why the Japanese electricity customer andtaxpayer should pay an exceptionally large sum of money for a substance that is considered worthless inthe countries that hold the world’s largest stocks of the same substance.
In fact, one might wonder, whether Japan has approached the European plutonium stockholders in order
to inquire under what conditions they would transfer those stocks to Japan and what the outcome would
have been. It is quite likely that, independent of any strategic and security considerations, the European
plutonium stockholders would actually pay the Japanese counterpart to take over responsibility for the
awkward material.
JAEC does not seem to pay attention to the relative level of economic risk. A large number of additional
facilities obviously induce a larger potential for construction delays, incidents and accidents duringbuilding and operation and therefore disruption of economic income. Japan Nuclear Fuel Ltd. (JNFL)
announced on 28 March 05 that Rokkasho is now scheduled to start-up in May 2007, another 10 months
later than expected. The construction cost estimate was increased yet another time by 2.3% to reach ¥2.19 trillion. Already in 2004, the start-up had been delayed by a full year, following the discovery ofdefective quality-control measures on welds in the spent fuel pools18. As a result, “tens of kilometres of
welding have to be re-examined in detail”, noted the nuclear department of the French embassy inTokyo.19 In other words, the cost figures that have been taken into account in the Intermediate Report are
already obsolete a few months after its publication.
The latest THORP accident is another good illustration of high economic risk in the plutonium industry.
THORP was expected to contribute about a quarter to the Nuclear Decommissioning Agency’s £ 2.2
billion annual budget. This is now jeopardized. Besides the loss of income, the accident will entail either
significant repair costs or will leave the plant with a significantly reduced nominal capacity. The costs are
in any case adding up to several hundred million pounds sterling.

Category II: Criteria (5): Nuclear Non-Proliferation
There are essentially two primary materials for a nuclear explosive device: highly enriched uranium (likein the case of the Hiroshima bomb) and plutonium (like in the Nagasaki bomb). The Intermediate Reportstates that “when conducting reprocessing, in order to avoid giving rise to international concerns about
nuclear proliferation and nuclear terror, it is necessary to create strict, internationally agreed safeguards
and measures for the protection of nuclear materials”. It is unclear to what extent JAEC considers thatbeyond the existing national and international safeguards regime it considers it necessary “to create”
additional or different safeguards and physical protection measures.
The Intermediate Report states that “in the case of scenario 1, so that pure plutonium oxide doesn't exist
at the reprocessing plant, uranium nitrate and plutonium nitrate solutions are combined to make MOX
powder (mixed oxide powder)”. If at any point in time, Japan decided to legally withdraw from the
Nuclear Non-Proliferation Treaty because it intended to produce nuclear weapons, it would be technicallyno problem to add a chemical unit that allows for the transformation of plutonium nitrate into plutonium
metal that can be used directly in nuclear weapons. In other words, the existence of a large-scale
plutonium separation plant – a situation that does not exist in any other non-nuclear weapons state –18

A number of serious potential implications of the incident have been raised by Yves Marignac, John Large. 2004.
Submission to the Inquiry Committee on Rokkasho Reprocessing Plant Comprehensive Inspection.
19
Service nucléaire. 2004. Ambassade de France au Japon, La situation du nucléaire a Japon. MINEFI

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makes Japan a latent nuclear weapons state. The country would be technically within months rather than
within years of a significant nuclear weapons capability.
The perception of international observers of the original nuclear weapons taboo has changed remarkably
over the last ten years or so. A paper on nuclear weapons and Japan published by the Federation ofAmerican Scientists20 concludes:“Japan's nuclear power program based on reprocessed plutonium has aroused widespread
suspicion that Japan is secretly planning to develop nuclear weapons. Japan's nuclear
technology and ambiguous nuclear inclinations have provided a considerable nuclear
potential, becoming a ‘paranuclear state’. Japan would not have material or technologicaldifficulties in making nuclear weapons. Japan has the raw materials, technology, andcapital for developing nuclear weapons. Japan could possibly produce functional nuclear
weapons in as little as a year's time. On the strength of its nuclear industry, and its
stockpile of weapons-useable plutonium, Japan in some respects considers itself, and istreated by others as, as a virtual nuclear weapons state.”
The International Atomic Energy Agency (IAEA) has recently raised the “possibility of ‘break out’ fromthe Non-Proliferation Treaty (NPT) by non-nuclear weapon States (NNWS) with advanced nuclear fuelcycle technology and/or stocks of enriched uranium or separated plutonium – intentions cannot be
verified”21.
If Japan intends to dissipate “widespread suspicion” about potential nuclear weapons ambitions 22 ,Japanese leaders will have to provide a reasonable and solid argumentation about the “raison d’être” of its
plutonium programme. JAEC has not.
The Intermediate Report states: “In the case of scenario 3, the temptation for diversion of this material
will increase in the period between hundreds and tens of thousands of years after disposal, so it will benecessary to develop and implement an efficient and effective internationally agreed monitoring andphysical protection system. When these things are taken into account, there is no significant difference
between the scenarios on the issue of non-proliferation.” JAEC again mixes timeframes that differ byorders of magnitude without applying a transparent weighing mechanism. Under all scenarios, most likely
will remain some spent fuel containing still plutonium quantities equivalent to thousands of nuclear
weapons. Depending on the geological environment, in any system of deep geological disposal efficient
safeguards are technically extremely difficult or even impossible to implement (in salt formations, forexample). However, with the monitoring difficulty also increases the access problems.
JAEC does not seem to have looked at the proliferation implications of the fact that the plutonium oxide
can be extracted chemically from the mixed oxide fuel and therefore represents a potential prime target
for subnational groups.

Category II: Criteria (10): Overseas Trends
The vast majority of spent nuclear fuel discharged from reactors worldwide is not reprocessed. The
representation in the Intermediate Report is one-sided and superficial. The Intermediate Report states that“countries with large scale nuclear power generation, such as France, Russia, China, and countries with a20

Federation of American Scientists. 2000. Nuclear Weapons Program – Japan.
Tariq Rauf. 2005. Background & Report of the Expert Group on Multilateral Approaches to the Nuclear Fuel
Cycle. presentation at the International Conference Multilateral, Technical and Organizational Approaches for the
Nuclear Fuel Cycle Aimed at Strengthening the Non-Proliferation Regime, Moscow, 13-15 July 05
22
see also David McNeill. 2005 July 31. Japan stockpiles plutonium as threat of nuclear escalation spreads acrossAsia – Hiroshima: Sixty years after the dawn of the Atomic Age, survivors look back amid fears their nation's
postwar pacifism is at risk. [natl ed]; Independent on Sunday, London.
21

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basic policy of continuing with nuclear power, or poor energy resources within their own borders arechoosing reprocessing”. The Intermediate Report omits to mention that:
•
•
•
•
•
•

France, Russia and China are nuclear weapons states;
Russia reprocessed a very limited amount of fuel in an old, particularly polluting facility and hasabandoned the construction of a commercial size facility in Krasnoyarsk23;
China does not have any commercial reprocessing facility operating and is only in the course ofbuilding a small-scale pilot plant;
France has lost all of its foreign clients for commercial reprocessing, besides a small contract for
Dutch fuel and faces now a gigantic overcapacity or the closure of one of the two reprocessing
lines;
As of 1st July 05, the shipment of spent fuel from German nuclear power plants to any
reprocessing plant is prohibited by law;
In the UK, following the most recent serious incident, subsequent to the edition of the Interim
Report, there is now open debate about the possible permanent closure of the THORP facility.

While only a small fraction of spent fuel generated in the world has been reprocessed in the past, there isa clear tendency to even more marginalise the plutonium industry in the future.
However, one current international trend is the substantial increase of the uranium price. The question iswhether this would be a lasting development and whether it could constitute a new incentive for the
separation of plutonium. The answer is no, because the price is to a large extent an artificial one and its
impact on the cost of the nuclear kWh is marginal.24 The uranium mining industry has been trying formany years to get the price back up that in 2003 was on the level of 1974, about a quarter of the peak in
1978, the time when the large scale plutonium programmes, including major overseas reprocessing
contracts were launched. Since 2000 the uranium industry has produced only about 55% of the worldconsumption, the rest being drawn from large stocks, down-blending of weapons grade uranium and there-enrichment of recycled uranium. No wonder, after several incidents in operating uranium mines anddifficulties to implement the US-Russia agreement on down-blending of weapons uranium, the uranium
price went up, “the historically low price of uranium reaching a ‘floor’ as approached or perhaps evendropped below the production costs of uranium producers”.25

Category III: Criteria (7): Social Acceptability andCriteria (9): Issues Associated With Policy Change
The current official Japanese plutonium policy is met by increasing distrust of Japanese and international
public opinions. As the Australia based Uranium Information Centre (UIC) puts it: “Public support for
nuclear power in Japan has been eroded in the last few years due to a series of accidents and scandals.”26
The sodium fire at Monju, the fire in the waste conditioning facility at Tokai and various serious cover-up
and criminal cases like the Monju video manipulation, the MOX fuel and reactor quality-control
falsification brought public trust in the Japanese nuclear industry to an all time low. Also, all these cases
had serious economic consequences. As the UIC reports, the shut down of TEPCO’s 17 reactors, some of23

The author has visited the facility, which in many publications is still listed as “under construction”. However, noactive building work has been ongoing for over 10 years and the already existing parts (basements and walls, noroofs) would certainly have to be torn down because they were exposed unprotected to Siberian weather for many
years.
24
According to French government figures, at a price of US $20/lb, the share of the natural uranium purchasecorresponds to 5% of the cost of the nuclear kWh (see Approvisionnement en matière et intérêt du recyclage
Material supplying and reprocessing-recycling benefit. by Florence Fouquet, sous-directrice de l’industrie nucléaire,
Cyrille Vincent, chef du bureau Politiques publiques et tutelles et Arnaud Locufier, adjoint au chef du bureau
Politiques publiques et tutelles, Direction générale de l’énergie et des matières premières (DGEMP), in Contrôle, n°
162, February 05
25
OECD-NEA, IAEA. 2004. Uranium 2003: Resources, Production and Demand. OECD-NEA. Paris.
26
Uranium Information Centre. 2005. Nuclear Power in Japan. Briefing Paper. 79p.

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Chapter 3 ICRC Review - Mycle Schneider

them for over two years, led to replacement power costs on average 50% higher than the official nuclear
generating costs (5.9 yen/kWh). TEPCO “expects the whole fiasco to cost it about 200 billion yen”27.
The series of accidents and scandals also eroded Japanese Prefectures’ confidence into the MOX fuel
“Pluthermal” program. The use of MOX fuel is – correctly – seen as additional risk and is even lessaccepted by public, local and regional administrations than the operation of nuclear power plants itself.
The Intermediate Report argues in favour of reprocessing because “at this stage Japan lacks accumulated
technical knowledge in regard to direct disposal that takes into account Japan's natural conditions andfinding a locality which will accept the final disposal of spent fuel, which contains plutonium, would be
expected to be much more difficult than finding a site for the final disposal of glass canisters”. At thisstage, Japan lacks accumulated knowledge and a mechanism for the selection of appropriate disposal
concepts and sites for any waste category. It would be interesting to know why JAEC expects that finding
a final disposal site for spent fuel would be “much more difficult” than in the case of vitrified high-level
waste. Are there any social studies available, any opinion polls carried out? In addition it would beinteresting to include studies on how the final disposal of MOX fuel, including five times more plutonium
than uranium fuel – inherent to any realistic reprocessing option – would be accepted as compared todirect disposal of uranium fuel.
In every country that has operated nuclear power plants and plutonium facilities the latter have caused
vastly more opposition than in the case of nuclear power plants. In fact, there is an increasing number ofnuclear industry and utilities representatives, including in France, that consider the plutonium businessharmful to the future of nuclear power. Also, no pro-nuclear government that followed the Green-Red
administration that decided in 1998 to shut down permanently the Superphénix fast breeder reactor has
ever envisaged to overturn that decision and restart the reactor or the breeder program. No other nuclear
project drew as much public and internal criticism in France than the plutonium program.
However, the idea that the disposal of high-level vitrified waste would be easier to implement in terms of
public opinion than the spent fuel direct disposal is entirely contradicted by the experience in Germany.
Massive protests accompany every single return of vitrified high-level waste from the French La Hague
plutonium factory to the German Gorleben site. Over 30,000 policemen had to protect railways, transfer
stations and storage site. This high-level opposition takes place although Gorleben so far is only aninterim storage facility and has been investigated so far only under the mining law and not under the
nuclear legislation for final disposal and while all of the reactor sites have implemented intermediate dry
store concepts without major disruption.
The Intermediate Report argues that Scenario 4 would suffer from the problem of “maintaining over along time period the technology and human resources, as well as the international understanding, inregard to Japan’s reprocessing program”. The relevance of this point largely depends on the time frame
and the significance that the country would assign after several decades to plutonium as an energy
resource or as a primary ingredient for nuclear weapons. The maintenance of competence in the nuclear
sector is not a specific issue concerning reprocessing in particular but a general problem, which has to beaddressed effectively. Concerning the “international understanding” of the Japanese plutonium program,
this could certainly only improve over the current situation.
The Intermediate Report also argues that “many interim storage facilities will become necessary (9~12sites by 2050), but because no policy decision has been made about disposal after storage, it will bedifficult for local people to remain confident regarding the 'interim' status of the facilities, so there is astrong possibility that attempts to find a site will stall and, one by one, currently operating nuclear power
plants will be forced to cease operating”. It is unclear why 9-12 sites for interim storage facilities would
be necessary. The spent fuel could be maintained in dry storage at the reactor sites as in the German caseand at an increasing number of sites in the world. It is quite possible that local people have difficulties “toremain confident” regarding the interim status of the facilities. However, it is the responsibility of
27

ibid.

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Chapter 3 ICRC Review - Mycle Schneider

operators, local and federal authorities to implement a credible policy scenario. The policy that has beenpromoted over the past three decades and that continues to be advocated by JAEC certainly lacks thathigh level of credibility. It is unclear why this should lead to premature closure of operating units.
JAEC suggests an original analysis approach in looking at the consequences that would stem from themere fact that there would be a policy change under certain scenarios in addition to looking at
advantages/disadvantages of a given scenario itself. The Intermediate Report stipulates that “there is astrong possibility that the search for a final high-level waste disposal site, which has already begun, will
be affected by the policy change and become stalled for a long period of time”. The Intermediate Report
does not elaborate on the statement, but if a policy shift is considered necessary as a result of acost/benefit analysis then it would be absurd to argue that one has drops the policy change because it
would possibly delay the implementation of a final repository scheme. This conclusion seems all the more
surprising as Japan seems decades away from the opening of a high-level waste repository anyway.

Category IV: Criteria (8): Assurance of Choice
JAEC considers that the all-reprocessing Scenario 1 is “superior” to the other scenarios “because it
maintains infrastructure for technical innovation which can respond to changes of circumstances in regard
to reprocessing (human resources, technology, knowledge, etc.), while maintaining international
understanding of Japan's reprocessing program”.
This is another example of the systematic bias in the Intermediate Report in favour of the reprocessing
option. The reprocessing option, the logical “fait accompli” scenario is presented as “superior” because of
the disproportionate and unjustified weighting of a single parameter that is maintaining competence. The
methodology of the building and operating for decades of a multi-trillion yen operation for the mere
purpose of maintaining competence is not only extremely inefficient. There are many characteristics ofthe plutonium economy that are of specific non-reversible nature including the following:••••

The invested huge amounts of capital into the infrastructure of the plutonium economy.28
The intrinsic danger of the operation of additional high-risk facilities and shipments.
The permanent exposure of concentrated large radioactive inventories and shipments to attack.
Massive discharges of radioactive and other toxic pollutants into the environment.

5. Conclusion
JAEC, in the conclusion of the Intermediate Report, narrows the four original scenarios down into two
options, “a path based on reprocessing and a path based on direct disposal”. A thorough argumentation
why the scenario variations have been abandoned at the end has not been given.
JAEC stipulates as “basic stance” for Japan’s future nuclear fuel cycle policy “to adopt the effective useof plutonium, uranium, etc. recovered by reprocessing spent fuel”. Essentially three reasons are given forthis opinion that will be commented on one by one:
1. While the reprocessing option is recognized as being more expensive under current conditions, it isjudged “superior from the perspective of 'energy security', 'environmental compatibility' and 'adaptability
to future uncertainty', etc.” It is also felt that future pressure on the uranium markets and a long term
commitment to nuclear power could even reverse the economic disadvantage of the plutonium option.
JAEC has failed to demonstrate the relative advantage of the plutonium fuel option in the area ofenvironmental protection and system flexibility. It has flatly dismissed or ignored substantial evidence for28

In this regard it would constitute a helpful illustration to calculate the comparative cost of the build-up of astrategic uranium reserve at a uranium price of US $10 /lb, an average price level that was held on the international
spot market for 15 years between 1988 and 2003.

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Chapter 3 ICRC Review - Mycle Schneider

the particular problems of the plutonium economy in these areas. JAEC has also given unjustified weight
to a theoretical minor uranium saving of 10%-20% and has ignored or downplayed numerous otheroptions that could achieve the same or better results at lower economic and social cost.
JAEC obviously vastly overstates and misrepresents the impact on “energy security” of the plutonium
economy. This is well illustrated by the analysis of the French case, the only one to have actually
implemented the scheme that is being promoted by JAEC:•

Japan has separated plutonium for over 25 years and has still not reused a single gram of the over
40 tons of stocks of the material into one of its commercial reactors. It took the French Stateutility 25 years to absorb the same quantity of plutonium into its reactor program. Considering theuncertainties and costs of its future use, it is logical that the owner – just like its British
counterpart – has allocated a zero value to its stocks in the accounts;•

In 2004 French nuclear power plants supplied 78% of the electricity, but not more than 42% ofcommercial primary energy and only 17.5% of the final energy consumed in the country. The
plutonium fuel (MOX) generates 8%-10% of the nuclear electricity in the country.29 In otherwords, plutonium fuels provide between 1% and 2% of the final energy consumed in France. At
the same time, 71% of French final energy is being provided by fossil fuels (oil, gas, coal), allwhich are imported into France just as all of the uranium.

None of this is taken into account in JAEC’s final judgement. Considering the weight JAEC seems toallocate to the energy supply issue, the explicit critical analysis of the French case should impact heavily
on the outcome of JAEC’s recommendations.
2. JAEC argues that the Japanese government and industry have heavily invested in the past in order toimplement the plutonium economy. This investment, labelled “social capital”, JAEC states “has greatvalue and should be maintained”, since Japan “has established nuclear power as a core ingredient of its
electric power generation”.
The value of that proclaimed “social capital” is highly doubtful. First of all, the definition is questionable.
JAEC defines it in terms of “technology, trust of local communities, international agreement on numerous
issues related to reprocessing”. The idea of social collective benefit is entirely missing. The plutonium
option does not provide anything more to the Japanese society than, at best, an insignificant fraction ofenergy service.
It should be clearly stated that, so far, a large share of the social cost of the Japanese plutonium programis being paid for by non-Japanese citizens since the vast majority of Japanese plutonium has been
separated at European reprocessing plants. The essential cost is being paid for by European citizens interms of the impact of the radioactive emissions of the two European reprocessing facilities into air andsea that account for over 80% of the collective dose stemming from the past use of nuclear power inEurope.
There is a great difference between technical analysis and political decision-making. JAEC seems to havegreat difficulties in separating both. Its very influential secretariat staff is co-financed by the nuclear
industry, which induces a conflict of interest unacceptable by international standards. It also makes
technical and policy based evaluations. Its role is ambiguous. Its composition is neither independent nor
representative. JAEC’s ambition seems to be limited to guarantee continuity of Japan’s nuclear policy,
not to provide analysis based policy recommendations. JAEC’s performance risks to be counterproductive by all means, and especially when it comes to public trust. While nuclear issues have always

29

The quantity of plutonium absorbed in the French MOX program corresponds to the output of one of the two
reprocessing lines at La Hague and is equivalent to the expected throughput of the Rokkasho plant.

40Chapter 3 ICRC Review - Mycle Schneider

been surrounded by the myth of “unintelligible” expert knowledge, citizens in all countries have shownthat they have an unmistaken understanding of the limits of trust in institutions.30
3. JAEC states that “in order to further nuclear power and the nuclear fuel cycle, it is essential to obtainthe understanding and support of the public”. Policy change would lead to distrust and therefore topotential difficulties in the acceptance of intermediate spent fuel storage and further operation of power
plants.
JAEC seems to be more driven by the acceptance of nuclear power than by the in depth cost-benefit
analysis of a spent fuel management option assessment. This attitude does not seem to be appropriate forthe task JAEC has been appointed for. However, it can be argued that even if JAEC’s key objective was ahigh-level of adherence to nuclear power use in Japan, the unbalanced support of the plutonium option
could turn out to be counterproductive. There is a growing pro-nuclear community internationally thatthinks that public acceptance of nuclear power would grow strongly if the plutonium economy was cut
out.31
For an international observer it is surprising that, at a time of profound public distrust in Japan, JAEC
considers that the nuclear industry’s credibility would benefit from an unmodified, literally stubborn
attitude of business-as-usual towards long-term energy policy-making.
JAEC has chosen to publish a document that repeats the erroneous visions of the 1970s that urged for the
implementation of a plutonium fuel based energy economy following sky-rocketing uranium prices inview of an expected exponential growth of nuclear energy programs that never occurred. While the errorsof the past have already lead to substantial social costs, 30 years later, it seems indispensable to take into
account not only past errors – nationally and internationally – but also new dimensions like the post-911
situation, the development of uranium resources and prices, technical developments like high burn-up
uranium fuels, smaller electricity generating units in liberalised energy markets and the unprecedented
potentials of energy efficiency and non-nuclear energy options.
The JAEC Intermediate Report appears like a document of the past. It ignores historical developments,
disregards evidence that has been submitted and seems to be heavily biased towards the perpetuation of
the status quo. It does not seem to be the appropriate basis for political decision-making in an area thatentails consequences for hundreds of generations to come.

30

In a recent poll for the French Institute for Radiation Protection and Nuclear Safety; on the question “do you trust
the French authorities on their protective actions of people in the following areas?” on radioactive waste 22.7%
answered Yes, but 46.5% said No (29.1% said More or Less). On the question of the Chernobyl fallout in France
only 9.5% said Yes but 68.2% said No (17.4% said More or Less). Source: Baromètre IRSN. – Perception desRisques et de la Sécurité.
31
One of the outspoken proponents of international restrictions and control of reprocessing activities is the Director
General of the UN’s International Atomic Energy Agency who initiated a proposal to put a number of strategic
facilities – that would include the reprocessing plant at Rokkasho - under international management, stated: “"Weshould be clear: there is no incompatibility between tightening controls over the nuclear fuel cycle and expanding
the use of peaceful nuclear technology. In fact, by reducing the risks of proliferation, we could pave the way formore widespread use of peaceful nuclear applications. Also see:
http://www.un.org/apps/news/story.asp?NewsID=14996&Cr=nuclear&Cr1=terrorism

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Chapter 4 ICRC Review - Christian Küppers

Chapter 4ICRC REVIEW
Christian Küppers,
Oeko-Institute, Darmstadt (Germany), Deputy Coordinator of the Nuclear Technology and Plant
Safety Division. Member of the International Critical Review Committee on the Long Term
Nuclear Program(ICRC).

1. Introduction
This paper is a contribution to the international review of the interim report of the New Nuclear PolicyPlanning Council on nuclear fuel cycle policy in Japan (in the following quoted as the “Interim Report”).
The Interim Report compares four scenarios how to deal with spent nuclear fuel. The scenarios differ in
the amounts of spent fuel that are reprocessed, stored for reprocessing in the future or stored for direct
final disposal.
In preparing the paper, the author has used the translation of the Planning Council’s Interim Report by the
Citizens’ Nuclear Information Centre (CNIC)1. The author has also had the benefit of discussions withmembers of the ICRC and its secretariat during a visit to Tokyo at the end of March, 2005.
The paper is focused on the aspects of the interim decision of the New Nuclear Policy-Planning Council
on nuclear fuel cycle policy in Japan that are related to high-level radioactive waste management. The
following aspects are discussed in this paper:•

Section 2.: Radiological Impact of Reprocessing, Interim Storage and Final Disposal of
Fuel•

Section 3.: Safety of Reprocessing, Interim Storage and Final Disposal of Spent Fuel•

Section 4.: Proliferation Risks Related to Separated Plutonium and Spent Fuel•

Section 5.: Overseas Trends•

Section 6.: Conclusions

Spent

These sections refer to the criteria (1) safety assurance, (3) environmental compatibility, (5) nuclear nonproliferation and (10) overseas trends in the Interim Report.
A general weakness of the arguments in the Interim Report is that there are no statements about therelative importance of the different criteria. It is not immediately obvious whether the Planning Council
considers all criteria to be equally important, or whether it is making implicit assumptions that somecriteria are more important than others. The Planning Council’s views and reasoning about the relative
importance of different criteria should be made explicit, as should the impact of these views on theoverall assessment. Probably, some of the misleading conclusions would not have been drawn by
regarding differences in the importance of the different criteria.

1

CNIC [Internet]. Translation of the AEC Planning Council’s Interim Report Concerning the Nuclear Fuel Cycle
Policy. [updated 12 November 2004]. Available from:http://cnic.jp/english/topics/policy/chokei/longterminterim.html. (Also attached at the end of this report).

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Chapter 4 ICRC Review - Christian Küppers

2. Radiological Impact of Reprocessing, Interim Storage and Final Disposal of
Spent Fuel
The Interim Report states:“The point has been made that scenarios 1 and 2, which involve reprocessing 2 , require more
facilities to handle spent fuel than the other scenarios, and therefore could entail a higher releaseof radioactivity into the environment. However, the exposure doses resulting from these releases
will be low and well within the regulatory limits. They will also be much lower than exposure fromnatural radiation. Therefore, it cannot be said that these releases represent a significant difference
between the scenarios.”
The common approach to evaluate radiation exposures from artificial sources is to discuss thejustification of the practice, the optimisation of radiation protection and the compliance with dose limits(this is the bases of the recommendations of the ICRP, e.g. ICRP-603, IAEA Basic Safety Standards4, EU
Basic Safety Standards5 and national rules).
The principle of justification means that a practice should only be adopted if its intention cannot be
achieved without or with significantly lower radiation exposure. In the case of reprocessing the intention
to use plutonium cannot be achieved without reprocessing the spent fuel.
The optimisation means that the resulting radiation exposures must be as low as reasonably achievable(ALARA principle). The statement in the Interim Report totally ignores the ALARA principle. It is
stated that the releases of radioactivity from a reprocessing facility are not significantly higher than thosefrom an interim storage and final disposal facility only on the grounds that radiation exposure is low, well
below the limits and much lower than natural exposure. Table 1 shows the limits for releases ofradioactivity of the German reprocessing facility in Wackersdorf (licensed but construction stopped in1989) and the Rokkasho reprocessing facility.
Table 1: Limits for releases of radioactivity of two reprocessing facilities (in Bq/yr)

Nuclide/group
Aerial discharges
kryptontritium
iodine-129
Liquid discharges
tritium
all beta-emitters (except tritium)
all alpha-emittersiodine-129

Reprocessing facility
Rokkasho6

Wackersdorf

3.3·1017
2·10151.3·1010

1.6·1017
1.5·1015
1.8·1091.8·1016
7·1011
9.8·1092.6·1010

3.7·1013
1.3·1010
4.4·108
1·108

2

Scenario 1: all spent fuel is reprocessed; Scenario 2: quantity of spent fuel that exceeds reprocessing capacity is
disposed.
3
International Commission on Radiological Protection. 1991. Recommendations of the International Commission
on Radiological Protection. Publication No. 60.
4International Atomic Energy Agency. 1996. International Basic Safety Standards for Protection against Ionising
Radiation and for the Safety of Radioactive Sources. IAEA Safety Series No. 115. Vienna.
5
European Union. 1996. Council Directive of the European Union Laying Down the Basic Safety Standards for theProtection of the Health of Workers and the General Public Against the Dangers Arising from Ionising Radiation.
96/29/Euratom.
6see, for example, CNIC. November 1997. Final Report of the International MOX Assessment. Comprehensive
Social Impact Assessment of MOX Use in Light Water Reactors. IMA Project, table 3-10.

43Chapter 4 ICRC Review - Christian Küppers

The data presented in Table 1 show a significant difference of the limits for releases of radioactivity for
those radionuclides that are relevant for the resulting doses to the public from the Rokkasho andWackersdorf facility. Dose-relevant radionuclides are iodine-129 and the beta-emitters (except tritium)
and alpha-emitters in waste water. The limits that were licensed for the Wackersdorf facility are much
lower than those of the Rokkasho facility, even when the annual capacities of the facilities are taken into
account (800 tHM in Rokkasho versus 500 tHM in Wackersdorf ). This means that the releases ofradioactivity to the environment from the Rokkasho reprocessing facility are not as low as reasonably
achievable and that the ALARA principle is violated. Natural radiation exposure is no adequate criterion
to compare radiation exposures in the different scenarios.
The situation at existing reprocessing facilities is as follows:•

Discharges of dose-relevant long-lived radionuclides from reprocessing facilities (including the
Rokkasho facility) are at least four orders of magnitude higher compared with nuclear power
plants7. Liquid discharges from the Sellafield plant have been reduced since the 1970s but are
still at least four orders of magnitude higher compared with real liquid discharges from nuclear
power plants.

•

There is an accumulation of long-lived radionuclides especially in the marine environment
around the reprocessing facilities that is much higher than nearby nuclear power plants8.

•Long-lived radionuclides are spread over very long distances, e.g. technetium-99 from Sellafield
is measured at different Scandinavian coasts, in Greenland etc.

Additional exposures and risks result from the following facts:•

Reprocessing causes transports of radioactive materials over long distances (from nuclear power
plant to reprocessing facility, from reprocessing facility to waste storage facilities and to fuelfabrication facilities).

•

The fabrication of MOX fuel causes enhanced radiation exposure of workers, compared tofabrication of uranium fuel 9 . In the (meanwhile decommissioned) Siemens fuel fabrication
facilities for MOX and for uranium fuel fabrication the individual and collective dose for workers
was two orders of magnitude higher per tHM of produced fuel for MOX than for uranium fuel.
Due to the difference in specific activity and inhalation dose coefficients, the standards forprotection against inhalation are roughly a million times stricter in plutonium processing than inuranium processing (related to the mass). Additionally, the dose rate from gamma radiation ishigher for plutonium than for uranium because of the americium-241-content of plutonium,
growing with the time after separation from spent fuel10.

•

The difference in specific activity and inhalation dose coefficients between plutonium anduranium also means that there is a major difference in risks to the public by possible accidents.
Such accidents can be fire or external impacts like earthquake and aircraft crash that cause arelease of relevant amounts of fuel material. The release of a defined mass of plutonium has
roughly a one million times higher radiological consequence than the release of the same amountof uranium.

7see, for example, IMA-Report, chapter 3.5.1.
this is evident by the results of activity measurements according to the related reports by the operators andauthorities; see, for example, C. Küppers and A. Benischke. 2000. Ermittlung der möglichen Strahlenexpositionen
der Bevölkerung aufgrund der Emissionen der Wiederaufarbeitungsanlagen in Sellafield und La Hague(Assessment of the potential radiation exposure of the public by radioactivity releases from the reprocessing
facilities in Sellafield and La Hague). Öko-Institut. Darmstadt. (in German).
9see, for example, IMA-Report, chapter 3.4.
10
for details, for example see, C. Küppers, M. Sailer. 1994. The MOX Industry or The Civilian Use of Plutonium –Risks and Health Effects Associated with the Production and Use of MOX. Report from the German and Belgian
Sections of The International Physicians for the Prevention of Nuclear War (IPPNW).
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Chapter 4 ICRC Review - Christian Küppers•

The use of MOX fuel in nuclear power plants can enhance the probability of incidents andaccidents in these plants. Radiation exposure can be higher after severe accidents with coredamage in MOX-fuelled reactors11. If, in a long-term view, plutonium is used as fuel in fast
breeder reactors, the special safety aspects of such reactors, due to a very high power density andthe use of liquid metals for cooling, must be taken into account.

Direct final disposal (including interim storage) has the following advantages from the perspective ofradiation protection:•

Spent fuel is stored in casks that prevent releases of radionuclides to the environment and thatgive protection even against severe impacts. The spent fuel is housed in a container of steel orcast iron with a wall thickness of 30 to 40 cm. The cask consists of a container body and a cap
system, which normally comprises two caps and different sealings for each cap. The sealing
systems for both caps should be leak-proof for more than forty years. The thick wall of thestorage cask serves as the protection against radiation as well as heavy external impacts. The
dry storage of spent fuel in casks is in large part based on passive safety features with low
failure probability. Therefore, there are very low risks by interim storage facilities incomparison to other nuclear facilities. Dry storages for spent fuel even are the nuclear facilities
with the lowest routine releases of radioactivity to the environment, whereas reprocessing
facilities cause the highest contamination of the environment among all facilities of the nuclear“fuel-cycle”.

•

In the case of reprocessing the amount of plutonium in the final disposal is reduced, but the useof plutonium as fuel causes a much higher inventory of other long-lived transuranium nuclides
in the spent fuel, the reprocessing wastes and in the final disposal (e.g. neptunium-237).
Therefore, the radiological long-term safety of a final disposal is not necessarily higher, if
plutonium is separated from spent fuel by reprocessing.

Taking into account all these aspects the conclusion is that reprocessing (and use of plutonium in fuel) is
the option with the highest radiation exposures to workers and the public. There is a significant
difference in radiation exposures and risks between the scenarios defined in the Interim Report. The
higher the quantity of reprocessed fuel in a scenario is, the higher will be the radiation exposure and risk.
The difference in radiation exposure between the scenarios is several orders of magnitude (resulting fromthe exposure by reprocessing versus the much lower exposure by nuclear power plants and the nearlyzero exposure by dry storage facilities for spent fuel), so that this difference is obviously very significant.
The oppositional statement of the Interim Report is the result of its very restricted perspective, reduced tothe question of compliance with dose limits and to the comparison with natural exposure.

3. Safety of Reprocessing, Interim Storage and Final Disposal of Spent Fuel
The Interim Report states:“In regard to ‘safety assurance’, by preparing appropriate response measures, taking into accountthe evaluation of assumed accidents based on the safety evaluation guidelines, it is possible toassure safety to the required standards. However, at this stage, Japan lacks technical knowledge
in regard to direct disposal that takes into account Japan´s natural conditions. It is necessary toaccumulate this knowledge.”
The criterion used in the Interim Report is absolutely insufficient to compare safety aspects of thedifferent scenarios. Of course, all facilities must fulfil the required safety standards, but there are
significant differences in the possibility of severe accidents beyond the requirements and theirradiological consequences.

11see, for example, IMA-Report, chapter 3.2 and 3.3

45Chapter 4 ICRC Review - Christian Küppers

The different parts of reprocessing facilities have very high inventories of radioactivity. There are storing
pools for spent fuel, storing (and vitrification) facilities for the high-active fission product solution,
storing facilities for plutonium etc. All mentioned facilities have inventories of radioactivity that aremuch higher than those of a nuclear power plant. Compared to a dry storage of spent fuel there are lots of
scenarios which cause a release of high amounts of radioactivity from a reprocessing facility (fire, severe
earthquake, terrorist attack etc.). The real problem of accidents in reprocessing facilities results from
accidents beyond the design and required standards. It was impossible to evaluate these differences to dry
storage facilities for spent fuel in the Interim Report because an insufficient criterion was used for theevaluation.
Remark to the “closed-loop economy”: The waste storage facilities at reprocessing sites are necessary forthe interim storage of the wastes from reprocessing. After reprocessing the volume of radioactive waste
is larger than before. Only a negligible part of the radioactivity in the spent fuel is separated for reuse, themajor part remains in waste that must be disposed of. Therefore, the following statement in Annex(tables) of the Interim Report is absolutely wrong: “Reducing the quantity of resources used and waste
produced, reusing and recycling create a closed-loop economy. Reprocessing is consistent with thisphilosophy.”
Regarding the final disposal there is an additional inventory of plutonium in it, if spent fuel is not
reprocessed. However, some aspects should not be ignored:•

Every final disposal for high-level radioactive waste will contain plutonium and other fissionable
material. The absolute inventory depends mainly from the number of cycles in which plutonium
is reused, considering that the quality of the plutonium (fissile part of its isotopes) is reduced withevery reuse and separation.

•

The reuse of plutonium causes additional problems in respect to the final disposal. There is asignificantly enhanced heat production in spent MOX fuel compared to spent uranium fuel andthe inventory of some long-lived transuranium nuclides grows up. The enhanced heat production
creates a need for long-term cooling. For example, spent MOX fuel elements with a burn-up of
33 GWd/tHM after about 100 years have dropped to a heat output of spent uranium fuel elementswith the same burn-up after a cooling period of 10 years12. With higher burn-up this effect grows
up and the time, when the same heat production is reached, can be several hundreds of years.
Reprocessing of spent MOX fuel cannot significantly reduce this effect, because the major part ofthe enhanced heat results from transuranium nuclides.

4. Proliferation Risks Related to Separated Plutonium and Spent Fuel
The Interim Report states, that “there is no significant difference between the scenarios on the issue of
non-proliferation”. The reasons, presented to support this conclusion, are:•In the case of reprocessing, MOX is fabricated from the separated plutonium and this is done inaccordance with technical procedures agreed with the US.

•

In the case of direct final disposal the temptation for diversion of nuclear fuel will be increased in
the period between hundreds and tens of thousands of years after disposal, so that a monitoringand physical protection system must be developed and implemented.

Due to its suitability for weapons plutonium especially must be carefully observed in order to avoid
proliferation (misuse of civil plutonium for military purposes), or at least to discover it early on. For thiscontrol the so-called safeguard measures are used. Inspectors from international organisations (IAEA andin Europe also Euratom) control the civil nuclear plants using certain methods. The methods must be
12

for details, for example see the figures in IMA-Report, chapter 5.4.1 or IPPNW-Report, chapter 7.2.

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Chapter 4 ICRC Review - Christian Küppers

adapted to the prevailing technical processes in the observed plant and to the proliferation resistance ofeach handled material containing plutonium. The isotopic composition is not considered because ofplutonium’s fundamental suitability to weapons on examination of proliferation resistance.
Safeguards can relatively easy be implemented as long as countable items containing fissile materials arehandled. Regarding fuel, this is done by measuring the fissile material content. As long as this element is
not dismantled it can be surveyed easily during handling, storage or transportation, because only themethods of containment and surveillance have to be applied. Sealed containers are, in view of safeguards,
similar countable “items” as fuel. Interim storage sites are, therefore, relatively easy to survey if
safeguard aspects were considered during construction.
One main weakness of the safeguard concept is exposed through all the so-called “bulk-handlingfacilities”. These are plants where plutonium (and other fission products) are handled in great amounts intheir free-flowing separated form, for example, reprocessing facilities and MOX fuel fabrication facilities.
As long as the plutonium is packed and kept together (e.g. in fuel assemblies), it can be accurately
counted using the methods mentioned above. If, however, material containing plutonium appears in a
non countable form (powder, solution, pellets, abrasive dust and other scrap material) accuracy is notguaranteed during counting - up to 1% inaccuracy is unavoidable with every check carried out. The
calculated material balance differs then from stock-take to stock-take. This can lead to considerable
amounts of material unaccounted for (MUF).
The IAEA states13: For item material balance areas (MBAs), MUF should be zero, and a non-zero MUF is
an indication of a problem (e.g. accounting mistakes) which should be investigated. For bulk handlingMBAs, a non-zero MUF is expected because of measurement uncertainty and the nature of processing.
The operator’s measurement uncertainties associated with each of the four material balance components
are combined with the material quantities to determine the uncertainty of the material balance.
Should there appear a MUF greater than zero, the safeguard organisations are faced with the problem of
not being able to distinguish between a real proliferation and a statistical inaccuracy. The bigger theinventory handled in a plant, the greater the inaccuracy. This in turn means that the absolute amount of
MUF which can be tolerated is greater- due to this inability to distinguish between real proliferation andinaccuracy.
Dealing with these inaccuracies, the IAEA defines a “detection probability” and a “false alarmprobability”. The detection probability is the probability, if diversion of a given amount of nuclear
material has occurred, that IAEA safeguards activities will lead to detection. The values of accountancy
detection probability currently in use are 90% for ‘high’ and 20% for ‘low’ probability levels14. False
alarm probability is the probability that statistical analysis of accountancy verification data would indicatethat an amount of nuclear material is missing when, in fact, no diversion has occurred. It is usually set at
0.05 or less, in order to minimize the number of discrepancies or false anomalies that must be
investigated15.
So-called significant quantities are used in establishing the quantity component of the IAEA inspection
goal. The quantity value currently in use for plutonium is 8 kg 16 . The combination with the above
mentioned detection probability and false alarm probability results in the fact that the amount of
plutonium diverted from a reprocessing facility with high through-put that can be detected is much higher
than the significant quantity of 8 kg, for example 50 to 100 kg.

13International Atomic Energy Agency, IAEA Safeguards Glossary, 2001 Edition, International Nuclear
Verification Series No. 3, Vienna, section 6.43.
14
IAEA Safeguards Glossary, section 3.16.
15
IAEA Safeguards Glossary, section 3.17.
16
IAEA Safeguards Glossary, section 3.14.

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Chapter 4 ICRC Review - Christian Küppers

This cannot be avoided by using “near real time accountancy (NRTA)”. This is a form of nuclear
material accountancy for bulk handling material balance areas in which itemized inventory and inventorychange data are maintained by the facility operator and made available to the IAEA on a near real timebasis so that inventory verification can be carried out and material balances can be closed more frequently
than, for example, at the time of an annual physical inventory taking by the facility operator17. However,it inevitably includes the estimation of in-process inventory by calculation because the plant operation
cannot be stopped at each time. Therefore, NRTA does not mean that the material balance data are
available nearly continuously, but for shorter time periods than one year.
Due to the fundamental problems of balancing as a measurement technique, the proliferation risk of freeflowing plutonium is high. It is therefore preferable to keep plutonium in spent fuel from the view-pointof non-proliferation. The Interim Reports referred to “internationally agreed safeguards” and“accordance with technical procedures agreed with the US” to argue that there is no major proliferation
risk associated with reprocessing spent fuel. This evaluation ignores the insufficiencies of physicalmeasurements and the inherent inaccuracy on which the safeguards are based. Obviously, these physicalfacts cannot be substituted by international agreements or agreements with the US.
Regarding plutonium in a final disposal the following facts must be considered:•

In a final disposal with irradiated fuel elements, the protective effect of the fission products
remains over very long periods. Should an interest in a clandestine military use arise after several
hundreds or thousands of years, the opening of the final disposal and salvage of the fuel elements
would still be a massive operation. Substantial radiation shielding measures would still benecessary, and the centuries-old fuel elements would still have to be manipulated by remotecontrol. Due to the extensive measures necessary, the recovery of such old irradiated fuelelements could hardly pass unnoticed. A lot of concepts exist for the monitoring of a final
disposal site, see, for example papers of the IAEA18.

•

It is highly questionable whether plutonium and nuclear weapons will still have the same militaryimportance in the more distant future than today. It is rather to be expected that the relevance of
plutonium will be that of flint stones to us, which also had a key military function several
thousand years ago.

•

The future effort required to salvage plutonium from a final repository must also be viewed incomparison to the effort required for new production. It is technically simpler to create
plutonium in a small special reactor and separate this plutonium from the fresh spent fuel than tosalvage irradiated fuel elements from a final disposal and to reprocess the salvaged elements,
which will be in a very “undefined” condition.

5. Overseas Trends
Only some short comments will be given here to the overseas trends as they are described in the Interim
Report.
The Interim Report states in its Annex (tables), that Germany, Switzerland and Belgium are examples ofcountries following scenario 2 (reprocess spent fuel, but directly dispose of that quantity which exceeds
reprocessing capacity). This is not comprehensible at all because all these countries do not operate
national reprocessing facilities (at least since a lot of years) but had spent fuel reprocessed abroad. The
decision for a phase-out of reprocessing was not drawn because of missing reprocessing capacity abroad.

17
18

IAEA Safeguards Glossary, section 6.3.
see, for example, A. Fattah. 1999. Safeguards Policy and Strategies. An IAEA Perspective for Spent Fuel inGeological Repositories. International Atomic Energy Agency (IAEA)/Department of Safeguards, EPR-55.
Vienna.

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Chapter 4 ICRC Review - Christian Küppers

The French and British reprocessing facilities can offer a lot of capacity to foreign customers. Therefore,
the classification in the Interim Report is not correct.
The evident disadvantages of reprocessing spent fuel lead to the German decision to stop the transport toreprocessing at July 1st, 2005. This was fixed in the atomic law as a result of an agreement between theGerman federal government and the German operators of nuclear power plants. Another importantchange in the atomic law was the definition of a remaining plant-specific amount of electricity that isallowed to be produced in the nuclear power plants. Meanwhile, the Christ democrats proclaimed thatthey would change the atomic law again, if they will be the winners of the next federal elections(probably taking place in autumn 2005), so that the nuclear power plants can run for a longer time-period.
But there is no wish to restart transports to reprocessing in Germany.

6. Conclusions
The main conclusions can be summarized as follows:•

The higher the quantity of reprocessed fuel in a scenario is, the higher will be the radiation
exposure of workers and the public. The difference in radiation exposure between the scenarios
is several orders of magnitude.

•

The higher the quantity of reprocessed fuel in a scenario is, the higher will be the risk resulting
from accidents. These accidents can occur at the reprocessing facility, during fabrication of
MOX fuel and during the use of the MOX fuel in a nuclear reactor.

•

The higher the quantity of reprocessed fuel in a scenario is, the higher will be the amount of
plutonium that is handled in bulk-facilities and not in an itemized status. Due to thecorresponding difficulties of possible safeguard measures this results in growing proliferation
risks.

Therefore, regarding radiation protection, safety and non-proliferation, scenario 1 (reprocessing of all
spent fuel) shows the most disadvantages and scenario 3 (direct final disposal of all spent fuel) shows themost advantages.
The different results in the evaluation by the New Nuclear Policy-Planning Council on nuclear fuel cycle
policy in Japan are due to
•
•
•
•
•

generally ignoring optimization below dose limits,
generally ignoring differences in respect to accidents beyond the design basis,
generally ignoring differences in the number and kind of facilities where such accidents can occur,
generally ignoring the physical basis and restrictions of safeguards,
abandoning the weighting of the importance of different criteria.

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Chapter 5 ICRC Review - Frank von Hippel

Chapter 5ICRC REVIEWFrank von Hippel,
Professor of Public and International Affairs, and Co-Director Program on Science and Global
Security, Princeton University. Independent Nuclear Policy Analyst (USA), Member of theInternational Critical Review Committee on the Long Term Nuclear Program (ICRC).

1. Introduction
I divide this review into two parts:
2. Domestic considerations: economics, safety and other, and3. International considerations: the added danger of plutonium diversion by would-be nuclear
terrorists and damage to the effort to contain the proliferation of national nuclear fuel-cycle
facilities.
As an international reviewer, I focus more on the latter aspects. However, I hope that my comments on
nuclear safety issues may have special value as well.

2. Domestic considerations
I divide the discussion of domestic considerations into three subsections:1. Economics,
2. Safety, and3. Other considerations.

2-1. Economics
The Interim Report1 concludes that direct disposal of 32,000 tons of spent fuel instead of reprocessing it
and recycling the plutonium it contains would save Japan about:•••

0.6 ¥/kWh of nuclear-generated electricity or
173 billion ¥ per year or
7 trillion ¥ over the 40-year operating life of the Rokkasho plant.

Comment. This is the only part of the report that contains significant analysis. I agree with its
conclusion that the reprocessing/recycle option would be extraordinarily costly.

2-2. Safety
The Interim Report dismisses concerns about a possible accidental or terrorist dispersal of radioactivity
from Rokkasho, stating without analysis that the risks to the Japanese population would be no greaterfrom reprocessing than from direct disposal of spent fuel.
1

CNIC [Internet]. Translation of the AEC Planning Council’s Interim Report Concerning the Nuclear Fuel Cycle
Policy. [updated 12 November 2004]. Available from:http://cnic.jp/english/topics/policy/chokei/longterminterim.html. (Also attached at the end of this report).

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Chapter 5 ICRC Review - Frank von Hippel

Comment. Most of the danger from spent fuel occurs while it is still in the spent-fuel storage pools
associated with the reactors from which it has been discharged. 2 The risks from reprocessing andplutonium recycle therefore are additive, not alternative to most of the safety risk from unreprocessed
spent-fuel.
In 2000, the twenty one radioactive-waste tanks at the United Kingdom’s THORP facility contained about
185 Mega-Curies (MCi) of 30-year halflife cesium-137, almost 100 times as much as was released by the
Chernobyl accident.3 The amount of 30-year halflife strontium-90 would have been about the same. The
UK Nuclear Installations Inspectorate expressed concern about the possibility of hydrogen or red oil
explosions occurring in these tanks and dispersing some of their contents.4 An explosion in a radioactive
waste tank in the Soviet Union’s RT-1 reprocessing plant in the Urals ejected about 0.5 MCi of strontium90 and caused the long-term evacuation of 1000 km2.5 The economic damages from hypothetical releasesof 3.5 and 35 MCi of Cs-137 from 5 U.S. reactor sites have been estimated at $100-400 billion.6 The riskof accidental or deliberate dispersal into the atmosphere of liquid high-level waste therefore deserves
serious consideration.
Potential large releases of plutonium-oxide aerosol from storage at the reprocessing plant, from theplutonium-fuel fabrication plant or during transport in between must also be considered. Eight thousand
kilograms of plutonium oxide powder would be processed annually at Rokkasho and it is likely that amuch larger quantity would be stored there. The accidental dispersal of only 10 kilograms of plutoniumoxide aerosol 30 kilometers upwind from Seattle would cause hundreds to thousands of additional cancer
deaths.7

2-3. Other considerations
The Interim Report concludes that the huge economic costs, the safety issues, and the security andnonproliferation objections to plutonium recycle that I discuss below in the section on international
considerations are outweighed by the following considerations:i.

The lack of experience with the direct disposal of spent fuel.

Comment. Japan and the world nuclear industry lack experience also with the disposal of the high-level
vitrified waste generated by reprocessing, and the transuranic waste from the fabrication of fuelcontaining plutonium and the decommissioning of the reprocessing and fuel-fabrication facilities. The
issues raised by all these radioactive-waste disposal problems have much in common. Therefore, thisconsideration does not weigh for reprocessing.
ii. The problem of maintaining the technology base and human skills required for
reprocessing if the Rokkasho reprocessing plant and plutonium-fuel fabrication facility are
not operated.

2

Robert Alvarez, Jan Beyea, Klaus Janberg, Jungmin Kang, Ed Lyman, Alliston MacFarlane, Gordon Thompson,and Frank N. von Hippel. 2003. Reducing the hazards from stored spent power-reactor fuel in the United States.
Science & Global Security 11. 1p.
3
Gordon Thompson. 2000. High-level radioactive liquid waste at Sellafield: An updated review by Institute for
Resource and Security Issues. p. 6. Available from: http://www.irss-usa.org/pages/enpubsum2.html.
42000. The storage of liquid high level waste at BNFL Sellafield: An updated review of safety, HM Nuclear
Installations Inspectorate. pp. 37-40.
5Thomas Cochran, Robert Norris and Oleg Bukharin. 1995. Making the Russian bomb: From Stalin to Yeltsin.
Westview. pp. 109-113.
6
Jan Beyea, Ed Lyman and Frank von Hippel. 2004. Damages from a major release of 137Cs into the atmosphere of
the United States. Science & Global Security 12, p125.
7
Steve Fetter and Frank von Hippel. 1990. The hazard from plutonium dispersal from nuclear-warhead accidents.
Science & Global Security 2. p21.

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Chapter 5 ICRC Review - Frank von Hippel

Comment. Japan developed its current expertise in reprocessing and mixed-oxide fuel fabrication
without operating the Rokkasho plant. If these capabilities are needed in fifty or a hundred years,
Japan’s nuclear-power R&D community could devise programs to preserve and restore them at a cost far
less than 170 billion ¥ per year operating cost of the Rokkasho plant. The benefit of embarking on
reprocessing for this reason is therefore is far outweighed by the costs.
iii. The 10-20 percent uranium resource savings that would result from recycling plutonium
recovered by reprocessing.
Comment. At the average uranium price paid by U.S. reactor operators in 2004 ($33 per kilogram8) Japan
could replace the annual savings of 800-1600 tonnes of natural uranium that would result from
reprocessing and recycling plutonium (and possibly uranium) for a few percent of the cost of operating
the Rokkasho plant. Therefore, this benefit would be far outweighed by the costs.
Uranium savings are not an argument for operating Rokkasho now, however, because the plutonium
separated at Rokkasho would not be used until the 40 tons of separated plutonium that Japan has alreadystockpiled have been recycled. This is not likely to have been accomplished in less than 15 years.
Furthermore, if Japan chooses direct disposal as its spent-fuel policy and changes its mind later, the fuelvalue of the plutonium and uranium in today’s spent fuel will still be available for recovery until a final
decision is made to close Japan’s first radioactive waste repository, many decades in the future.
iv. The problem of finding interim storage sites.
Comment. Vitrified high-level waste also requires interim storage until geological disposal becomes
available. Aomori Prefecture has agreed to provide interim storage for Japan’s foreign and domestic
high-level reprocessing waste at the Rokkasho plant for up to 50 years. It will also store for decades
most of the plutonium that will be recovered there. Thus the Aomori Prefecture has already agreed tosupply interim storage for Japan’s spent fuel for decades -- only in the form of separated radioactive
materials instead of the mixture in spent fuel.
Why would the prefecture not accept the lower risks of interim storage of the intact, self-protecting spent
fuel if the same tax revenues and number of jobs were guaranteed? Has this formulation of the question
been discussed with the leadership of the prefecture?

3. International considerations
As my comments above suggest, the arguments being made in the Interim Report for the operation of the
Rokkasho reprocessing plant evaporate under close and critical inspection. At the same time, the safetyissues relating to the storage and processing of liquid high-level waste and plutonium oxide have not beenaddressed seriously.
If these were the only issues, however, the debate over the operation of Rokkasho would be a domestic
matter for Japan. What makes it an issue of international concern is the risk of plutonium diversion toterrorists and the impact of Japan’s example on the current effort to stem the spread of nuclear fuel-cycle
facilities to countries of proliferation concern. Plutonium separated anywhere is a potential threat tocities everywhere.9
8Energy Information Administration. 2004. Uranium Marketing Annual Report. 2004 Edition.
Japanese reprocessing advocates often argue that power-reactor plutonium, unlike weapon-grade plutonium,
cannot be made into a nuclear weapon. This is despite repeated briefings to the contrary from U.S. nuclear-weapon
952Chapter 5 ICRC Review - Frank von Hippel

In the remainder of this review, I therefore discuss the Interim Report’s treatment of the diversion andproliferation costs of operating the Rokkasho plant and sketch out some of the issues that should havebeen analyzed but were not.

3-1. Risks of plutonium diversion
The Interim Report states that the increased risk of diversion of plutonium due to plutonium separation in
reprocessing is offset by the danger that plutonium could be mined from buried spent fuel hundreds or
thousand of years in the future.
Comment. This is a problematic comparison because no one can predict the type of society that will exist
so far in the future. If there are central governments, they ought to be able to keep terrorist groups fromrecovering plutonium from a central nuclear-waste repository hundreds of meters underground much
more easily than a government today could prevent the theft of plutonium in surface storage, processing
or transport.
On the surface, diversion resistance comes from two sources:i.

The physical characteristics of a plutonium-containing material, andii. Added barriers (guards, barriers, intrusion alarms, etc.)
і. Inherent diversion resistance. The interim report does not and cannot claim that stealing the 8 kg of
plutonium that the IAEA considers sufficient to make a crude nuclear explosive, and the 8 kg ofuranium diluent in the Rokkasho reprocessing plant product10 would be as difficult as stealing two
half-ton spent-fuel assemblies containing the same amount of plutonium.
The gamma field around an unshielded spent fuel assembly, 20 years after discharge from a reactor,
would deliver a lethal dose one meter away in 15 minutes.11 A cask weighing tens of tons therefore
would be required to provide shielding during transport, and the mechanical and chemical separation of
the plutonium from the fission products would have to be carried out behind heavy shielding -- i.e. in an
improvised reprocessing plant. This makes quite implausible the idea of terrorist theft and reprocessingof spent fuel.
In contrast, the plutonium-uranium oxide mix produced by the Rokkasho reprocessing plant could betransported in lightweight airtight containers.
Similarly, a unirradiated mixed-oxide (MOX) fueldesigners. The technical issues relate to the effects of the higher concentrations of Pu-238 and Pu-240 in powerreactor plutonium. Because of its short half-life, Pu-238 generates heat. A kg of power-reactor plutonium
generates decay heat at a rate of about 20 Watts per kg vs. about 2 Watts/kg for weapon-grade plutonium. Inside athick insulating blanket of high-explosive such as in the Nagasaki bomb design, the plutonium would eventuallyheat up to a level where the high-explosive would start to decompose. However, for safety reasons, the Nagasaki
design had the plutonium inserted not long before detonation. This would also avoid the overheating problem. Pu240 is problematic because it releases neutrons by spontaneous fission that could start the fission chain-reaction
before the imploded plutonium reached its maximum supercriticality. This would reduce the yield of a Nagasakibomb design but the lowest yield expected from that design would still be equivalent to about 1000 tons of chemical
explosive, J. Carson Mark. 1993. Explosive properties of reactor-grade plutonium. Science & Global Security 4.
111p. The yields of modern weapon designs are not sensitive to pre-initiation of the chain reaction.
10
Uranium/Plutonium Mixed Oxide: Safety in Regard to Fuel Fabrication Facility, Safety Check Investigation
Committee Report. 2002. Outline of raw material type and product fuel type. 13p. Table 3.
11
W.R. Lloyd, M.K. Sheaffer, and W.G. Sutcliffe. 1994. Dose Rate Estimates from Irradiated Light-Water-Reactor
Fuel Assemblies in Air. Lawrence Livermore National Laboratory. UCRL--ID-115199. Five Sieverts (500 rem) is amedian lethal dose.

53Chapter 5 ICRC Review - Frank von Hippel

assembly containing 30+ kg of plutonium could be placed in the back of a truck without shielding. In
both cases the plutonium could be separated later in an unshielded glove box.
ii. Added barriers to diversion. The risks of theft of separated plutonium and MOX fuel are reduced by
the addition of physical barriers, access controls, intrusion sensors, and guards. The U.S. spends
almost a billion dollars per year on such protections for its military plutonium and high-enricheduranium. Major shortcomings have been identified, however, that make this material vulnerable totheft.12 Such vulnerabilities are typical of added barriers. Physical self-protection is much morereliable.
The Interim Report points out that the self-protection of spent fuel will die down “in the period between
hundreds and tens of thousands of years” and hence “it will be necessary to develop and implement anefficient and effective internationally agreed monitoring and physical protection system.” The concern
is that spent fuel repositories could become “plutonium mines.”
The Interim Report ignores, however, the fact that the buried wastes from reprocessing and MOX fuelfabrication also will contain significant quantities of plutonium. On the order of one percent of theplutonium in the spent fuel ends up in the waste. In 40 years one percent of the 8,000 kg/yr plutonium
output of the Rokkasho plant would mount up to enough material for 400 nuclear weapons.
There is also about 2% as much Americum-243 as plutonium in spent fuel. If the spent fuel isreprocessed, the Am-243 is to be buried with the vitrified high-level waste., It decays with a 7400-year
half-life into plutonium-239.
Of course, if plutonium is still being separating and recycled in that distant future, it will still be more difficult toprotect on the surface than the dilute plutonium stored in a few national repositories under hundreds of meters ofrock.

3-2. Effect of Japan’s decision upon the proliferation of national fuel-cycles
The Nuclear Policy-planning Commission dismisses with a meaningless sentence the entire issue of the
impact on the international nonproliferation effort of a Japanese decision to separate hundreds of tons
more plutonium:“each country is making a choice between reprocessing and direct disposal in response to geologicalfactors, resource factors, scale of nuclear power generation, and cost competitiveness.”“Resource factors” are irrelevant to the operation of Rokkasho any time in the next decades, however.
And, as the Interim Report acknowledges, reprocessing and plutonium recycle are not cost competitive
with direct disposal.
The current global concern about Iran’s acquisition of a nominally civilian but inherently dual-use fuelcycle facilities indicates, however, that the proliferation of such facilities is also a major internationalsecurity issue.
In the case of reprocessing, it is easy to see that a country that has only spent fuel is much further frompossessing nuclear weapons than an otherwise identical country that has a large stockpile of separated
plutonium.
Consider a scenario in which the governments of these two hypothetical countries both decide one daythat they wish to make nuclear weapons. The government that does not have separated plutonium or a
12

See e.g. U.S. nuclear weapons complex [Internet]: Homeland security opportunities, Project on Government
Oversight. May 2005. Available from: http://www.pogo.org/p/homeland/ho-050301-consolidation.html.

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reprocessing plant will require a considerable amount of time to build a reprocessing plant and begin to
separate plutonium from its spent fuel. This could give time for domestic anti-nuclear-weapon groups
and allied governments to persuade the government to change its mind. This is, in fact, what happened ina number of countries, including Sweden in the late 1960s, and Argentina and Brazil in the 1980s andearly 1990s.
Japan, of course, is different. Even without putting Rokkasho into operation, Japan already has over 5
tons of separated plutonium, enough to make 600 first-generation nuclear weapons because of its previous
reprocessing activities at Tokai Mura and early imports from the U.S. and perhaps other countries.
The Interim Report does not even consider, however, the fact that Japan’s example, as the only nonnuclear-weapon state with a reprocessing facility, undercuts ongoing international efforts to discourage
the proliferation of nuclear fuel-cycle facilities.
Recently, I participated in a two-day discussion of Iran’s nuclear program with a high-level group of
Iranians in Vienna. Repeatedly, the Iranians insisted on their country’s “inherent right” under the
Nonproliferation Treaty to acquire enrichment technology. Repeatedly the Iranians asked why theircountry should not acquire the same technology as Japan.
When I responded that acquiring thetechnology would put Iran in a position to very quickly acquire a nuclear weapon. The response was,“Why should not Iran have a nuclear-weapons option like Japan? All we want is the option. Don’t
worry, we won’t use it!”I have had similar discussions with nuclear analysts in Brazil, South Korea
and other countries.
The IAEA Director General has proposed multilateral fuel-cycle facilities as an alternative theproliferation of national enrichment and reprocessing plants. 13 The issue mostly concerns enrichment
plants, which are required by today’s nuclear power plants. Reprocessing plants are neither required nor
even economic. In any case, this option is not discussed in the Interim Report.
I criticize my own Government frequently these days for policies that undercut the nonproliferation
regime.14 In this case, Japan too would set a terrible example by insisting on operating a facility that isdesigned to produce annually enough separated plutonium to make 1000 nuclear weapons. As thediscussion above shows, Japan has no justification whatsoever for doing this. Its example therefore
undercuts those who would challenge the justification of fuel-cycle plants in other countries and urge
those countries to explore alternatives such as interim spent-fuel storage.
What makes the situation even more extreme in this case is that the Government of Japan proposes toviolate its own commitment to “the principle of no surplus plutonium.”15 It is proposing to launch theoperation of a huge domestic reprocessing plant at a time when it already has a stockpile of 40 tons ofseparated plutonium that it has not yet been able to recycle.
These considerations have put theimportance of delaying operation of the Rokkasho plant near the top of the international nonproliferation
agenda.16

13

See , IAEA. 2005. Multilateral approaches to the nuclear fuel cycle: Expert group report submitted to the Director
General of the International Atomic Energy Agency. INFCIRC 640.
14
See e.g. Steve Fetter and Frank N. von Hippel. 2005. U.S. Reprocessing? Still unnecessary, uneconomic and risky.
Arms Control Today. (in press).
15
See Japan’s submission to the IAEA, “Plutonium utilization plan of Japan,” attached to InfCirc/549, Add. 1,
March 31, 1998 on the IAEA’s web site.
16
See “A call on Japan to strengthen the NPT by indefinitely postponing operation of the Rokkasho Spent Fuel
Reprocessing Plant,” released by the Union of Concerned Scientists at the Nonproliferation Treaty Review
Conference, May 5, 2005. The 28 prominent scientists who were the first signatories include four winners of the
Physics Nobel Prize and Joseph Rotblat, who was awarded the Nobel Peace Prize because of his life-long work fornuclear disarmament starting with his resignation from Los Alamos after the defeat of the Nazis, Available from:http://www.ucsusa.org/global_security/nuclear_terrorism/page.cfm?pageID=1765.

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Chapter 5 ICRC Review - Frank von Hippel

If it is impossible to get Japan, the only country thus far to have cities devastated by nuclear bombs andthe home to the world’s leading nuclear disarmament movement, to set a good example, what basis isthere for hope that other countries will behave responsibly?

4. Conclusion
I can find no basis in the Nuclear Policy-Planning Council’s interim report for its conclusion that thebenefits of operating the Rokkasho plant and recycling the recovered plutonium would exceed the costs.
To the contrary:••••

The cited benefits are minor or nonexistent;
The financial cost to Japan would be huge;
The increased risks of radioactive contamination within Japan and of nuclear terrorism to all
countries would be significant; andThe damage to the international nonproliferation regime could be severe.

In contrast, if Japan postponed the operation of Rokkasho for at least a decade -- or even for the durationof the 5-year moratorium called for by IAEA Director General ElBaradei -- that action would give hopeto nuclear nonproliferation and disarmament advocates worldwide.

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Appendix 1
New Nuclear Policy-Planning Council
13th Meeting
Reference Paper 1

Interim Report Concerning the Nuclear Fuel Cycle Policy
12 November 2004
Japan Atomic Energy Commission
New Nuclear Policy-Planning Council

1. Proceedings to Date
The Japan Atomic Energy Commission's (AEC) New Nuclear Policy-Planning Council (PlanningCouncil) was established on 15 June 2004 with the aim of bringing together by mid 2005 Japan's'new long-term program for the research, development and utilization of nuclear energy'. The firstmeeting was held on June 21. The Planning Council decided to commence by intensively studying
the topic of most interest to its members, namely the nuclear fuel cycle policy. Including the firstmeeting, 12 meetings were held over a total of 30 hours. (If the deliberations of the Technical
Investigation Subcommittee are counted, 18 meetings were held over a total of 45 hours.)
In regard to the future direction of the nuclear fuel cycle policy, deliberations on how to deal withspent nuclear fuel considered the following 4 basic scenarios:
Scenario 1: Reprocess spent fuel after storing it for an appropriate period of time [CNIC's note: i.e.
reprocess all spent fuel];
Scenario 2: Reprocess spent fuel, but directly dispose of that quantity which exceeds reprocessing
capacity [CNIC's note: i.e. reprocess to the capacity of the Rokkasho Reprocessing Plant, which iscurrently undergoing uranium tests, and dispose of the rest by deep burial without reprocessing];
Scenario 3: Directly dispose of spent fuel [CNIC's note: i.e. all spent fuel];
Scenario 4: Store spent fuel for the time being and at some time in the future choose whether toreprocess it or directly dispose of it.
A comprehensive evaluation of these scenarios was carried out against the following criteria: (1)safety assurance, (2) energy security, (3) environmental compatibility, (4) economic considerations,(5) nuclear non-proliferation, (6) technical viability, (7) social acceptability, (8) assurance of choice,(9) issues associated with policy change, (10) overseas trends.
The evaluation was based on the reference case in the Advisory Committee for Natural Resources
and Energy's 2030 Energy Supply and Demand Forecast. Under this case the total electricity
generated by nuclear power between 2000 and 2060 is assumed to be around 25 billion kWh.
(Generation capacity from nuclear power is expected to increase before stabilizing at 58 GW from
2030.)

1

Appendix 1
AEC established a Technical Investigation Subcommittee within the Planning Council to carry out
technical investigations, in order to make an assessment of the economics of the scenarios. So far
this subcommittee has met 6 times for a total of 15 hours to consider expert technical issues. It
calculated the costs associated with the direct disposal of spent fuel, the costs of the nuclear fuelcycles associated with the above 4 scenarios, and other matters necessary for the evaluation.

2. Assessment of the Basic Scenarios
The results of the evaluation of the 4 scenarios, considered against the various criteria, are shown in
the appendix. [CNIC has added its comments to this appendix.] The evaluation criteria can be
broken down into the following 4 categories: (1) prior conditions which are essential to the viabilityof the scenarios, such as safety assurance and technical viability; (2) factors which can be used tocompare the policy significance of the scenarios, such as energy security, environmental
compatibility, economic considerations, nuclear non-proliferation, and overseas trends; (3) practical
restrictions such as social acceptability (problems finding a site) and issues associated with a changeof policy; and (4) assurance of choice, that is adaptability in the light of future uncertainty associatedwith the scenarios. An outline of the evaluation of each basic scenario is presented below in terms ofthese 4 categories.
(1) Evaluation of prior conditions which are essential to the viability of the scenarios* In regard to 'safety assurance', by preparing appropriate response measures, taking into account theevaluation of assumed accidents based on the safety evaluation guidelines, it is possible to assure
safety to the required standards. However, at this stage, Japan lacks technical knowledge in regard to
direct disposal that takes into account Japan's natural conditions. It is necessary to accumulate thisknowledge. The point has been made that scenarios 1 and 2, which involve reprocessing, require
more facilities to handle spent fuel than the other scenarios, and therefore could entail a higher
release of radioactivity into the environment. However, the exposure doses resulting from these
releases will be low and well within the regulatory limits. They will also be much lower than
exposure from natural radiation. Therefore, it cannot be said that these releases represent asignificant difference between the scenarios.
* In regard to 'technical viability', reprocessing technology is being scaled-up, reflecting pastexperience with the technology; the system for glass canister (high level waste left after
reprocessing) disposal has been prepared and the implementing organization made clear, andtechnical knowledge is being continually improved. By contrast, there is a lack of accumulated
technical knowledge on which to judge the suitability of direct disposal in the Japanese disposal
environment. Therefore, scenario 1 presents fewest technological problems. In regard to scenario 4,
due to the fact that technological choices will be postponed for a long period of time, there will be
problems associated with the need to continue to make investments to maintain a technology baseand human skills that may never be used.
(2) Evaluation of factors which can be used to compare the policy significance of the scenarios* At current uranium prices and with the current level of technological knowledge, scenario 1 is theleast 'economic' of the scenarios. However, (1) from the point of view of 'energy security (stabilityof supply, resource conservation)', it has the effect of reducing the amount of uranium required by2

Appendix 1
between 10% and 20%; (2) from the point of view of 'environmental compatibility', by not directly
disposing of the spent fuel with the uranium and plutonium contained therein, by reprocessing the
spent fuel and extracting that uranium and plutonium, and by dealing with this uranium andplutonium by [re]using it, the inherent radioactive harm from the high level waste (glass canisters)
after 1,000 years has elapsed will be one eighth of that if the spent fuel had been disposed of directly.
The volume of high level waste would be reduced to between 30% and 40% and the space required
to bury it would be reduced to between a half and two thirds of that if the spent fuel had been
disposed of directly. Therefore, this scenario is superior. It is highly compatible with the closed-loop
economy objectives of using resources as effectively as possible, and reducing waste to the greatest
extent possible. Furthermore, if the fast breeder cycle is implemented, the superiority of this
scenario is even more marked. Moreover, if the costs associated with a change of policy are
considered, it is not unlikely that it will also cease to be less economic.
Against this argument was the view that, at a stage when the fast breeder has not been implemented,
in pursuing a method of achieving the effect of uranium conservation, a comprehensive assessment
should consider, in addition to reprocessing, reducing the concentration of the tailings (the uranium
left after the process of enriching natural uranium). It has been pointed out that this would have thesame uranium conservation effect as reprocessing, but at a reduced cost. In response to this view it
was pointed out that the superiority of scenario 1 becomes much more pronounced if the fast breeder
is established, so the path towards implementation of the fast breeder should be made clearer.
* At current uranium prices and with the current level of technological knowledge, the nuclear fuelcycle cost of scenario 3 was calculated to be 0.5-0.7 yen per kWh cheaper, so from that angle
scenario 1 is superior. However, because usable plutonium will be buried instead of being placed
under human control, this scenario is inferior to scenario 1 from the point of view 'energy security'and 'environmental compatibility'. Moreover, if the costs associated with a change of policy are
considered, it is not unlikely that it will also cease to be more economic. The point was made thatconsidering the fact that, with a view to realizing a closed-loop economy, large costs are incurred inorder to recycle industrial goods1, it will be possible to gain the public's understanding for the extra
0.5-0.7 yen per kWh required for the nuclear fuel cycle of scenario 1, given that this scenario issuperior from the point of view of 'environmental compatibility'.
[Note 1: The cost of recycling industrial goods per item is 13,000 yen for automobiles, 4,830 yen forrefrigerators, and 3,675 yen for air conditioners, whereas the difference in the nuclear fuel cycle
costs would be 600-840 yen per year per household, which represents 1% of annual electricity costs(72,000 yen). For the average office building the difference would be 70,000-90,000 yen per year,
being 1% of annual electricity costs (6,500,000 yen).]* In regard to 'non-proliferation', when conducting reprocessing, in order to avoid giving rise tointernational concerns about nuclear proliferation and nuclear terror, it is necessary to create strict,internationally agreed safeguards and measures for the protection of nuclear materials. In the case of
scenario 1, so that pure plutonium oxide doesn't exist at the reprocessing plant, uranium nitrate andplutonium nitrate solutions are combined to make MOX powder (mixed oxide powder). This is toimplement Japan's promise to the international community and is done in accordance with technicalprocedures agreed with the US. In the case of scenario 3, the temptation for diversion of thismaterial will increase in the period between hundreds and tens of thousands of years after disposal,
so it will be necessary to develop and implement an efficient and effective internationally agreed

3Appendix 1
monitoring and physical protection system. When these things are taken into account, there is no
significant difference between the scenarios on the issue of non-proliferation.
* In regard to 'international trends', each country is making a choice between reprocessing and direct
disposal in response to geological factors, resource factors, scale of nuclear power generation, andcost competitiveness. The overall trend shows that countries with small scale nuclear power
generation, or which have made a policy decision to exit from nuclear power generation, such as
Finland, Sweden, Germany and Belgium, and countries with abundant energy resources within theirown borders, such as the US and Canada, are choosing direct disposal, while countries with large
scale nuclear power generation, such as France, Russia, China, and countries with a basic policy ofcontinuing with nuclear power, or with poor energy resources within their own borders are choosing
reprocessing. However even the US, which has chosen direct disposal, in order to continue to use
nuclear power in future, because it judges that it is important keep to a minimum the increase in
number and size of disposal sites for the high level waste that accompanies nuclear power, hasbegun research into advanced reprocessing technology to assist with this problem.
* Scenarios 2 and 4 have strengths and weaknesses similar to scenario 1 in regard to thereprocessing component and similar to scenario 3 in regard to the direct disposal component.
(3) Evaluation of practical restrictions* Scenario 1 is no different from the current policy, however scenario 3 involves a policy change.
For this reason, (i) at this stage Japan lacks accumulated technical knowledge in regard to direct
disposal that takes into account Japan's natural conditions and finding a locality which will accept
the final disposal of spent fuel, which contains plutonium, would be expected to be much moredifficult than finding a site for the final disposal of glass canisters; (ii) it will be necessary to rebuild
the trust of regions with proposed sites, which until now have assumed reprocessing would proceed.
This will take time. During that time, the removal of spent fuel from nuclear power plants and thecreation of interim storage facilities will stagnate. There is a strong possibility that, one by one,currently operating nuclear power plants will be forced to cease operating. These are issues
connected to 'problems finding a site' and 'issues associated with a change of policy'.
* In the case of scenario 4, (i) there is the problem of maintaining over a long time period thetechnology and human resources, as well as the international understanding, in regard to Japan's
reprocessing program; (ii) many interim storage facilities will become necessary (9~12 sites by2050), but because no policy decision has been made about disposal after storage, it will be difficult
for local people to remain confident regarding the 'interim' status of the facilities, so there is a strong
possibility that attempts to find a site will stall and, one by one, currently operating nuclear power
plants will be forced to cease operating; (iii) there is a strong possibility that the search for a final
high level waste disposal site, which has already begun, will be affected by the policy change andbecome stalled for a long period of time. These are issues connected to 'problems finding a site' and'issues associated with a change of policy'.
(4) Evaluation from the perspective of assurance of choice ('adaptability to future uncertainty')
There is uncertainty in regard to the direction of future socioeconomic developments, such as the
direction of technological development and the international situation, so, while Japan is strong, it isdesirable to advance projects and investment that will assure 'adaptability to future uncertainty'.

4Appendix 1
From this perspective scenario 1 is superior to the other scenarios in regard to 'adaptability to future
uncertainty', because it maintains infrastructure for technical innovation which can respond tochanges of circumstances in regard to reprocessing (human resources, technology, knowledge, etc.),
while maintaining international understanding of Japan's reprocessing program. However, it waspointed out that, since it is difficult to change direction with scenarios that involve facilities which
require large investments, such as reprocessing facilities, due to the time required to recover theinvestment, these scenarios are more rigid than the other scenarios, and therefore, if projects arepromoted in accordance with these scenarios, research should also proceed into technologies
required for options other than reprocessing. On the other hand, scenario 4, because it maintains
adaptability and postpones to the future the decision about the direction that should be taken,
logically should be adaptable to future uncertainty. In practice, however, by not undertaking any
projects for a long period of time, it will face problems maintaining infrastructure and international
understanding.

3. Basic thinking regarding Japan's future nuclear fuel cycle policy
The basic thinking regarding nuclear fuel cycles which would make each of these basic scenarios
possible can be condensed into a path based on reprocessing and a path based on direct disposal.
The Planning Council considered which of these two options, taking into account the evaluation
already carried out of the 4 basic scenarios (discussed in section 2 above), is suitable to become
Japan's future nuclear fuel cycle policy.
The result of our deliberations to date - the basic stance regarding Japan's future nuclear fuel cycle
policy, the basic policy direction for the time being, and the way forward for the future - arediscussed below.
(1) Basic stanceIn order to promote Japan's nuclear power generation, it is necessary to make a comprehensive
assessment: to assure not only the most economic outcome, but also to assure energy security andadaptability in the face of future uncertainty and to pursue a closed-loop economy. From thisperspective, striving as far as is reasonable to use nuclear fuel resources effectively, assuring 'safety','non-proliferation' and 'environmental compatibility', while also taking into account 'economic
considerations, our basic stance is to adopt the effective use of plutonium, uranium, etc. recoveredby reprocessing spent fuel.
The main reasons for selecting this basic policy stance are as follows.
At the current price of uranium and level of technical knowledge, if the cost of a change of policy is
not taken into account, the reprocessing option is less 'economic' than the direct disposal option.
However, it is superior from the perspective of 'energy security', 'environmental compatibility' and'adaptability to future uncertainty', etc.. When the policy significance is compared, bearing in mind
that there might be supply and demand pressures on uranium in future, and considering that nuclear
power will be a core ingredient of Japan's electric power generation for the long term, taking acomprehensive view the reprocessing option is recognized as superior.

5Appendix 1
Both government and private companies have undertaken activities and accumulated social capital(technology, trust of local communities, international agreement on numerous issues related toreprocessing) over a long period of time with the aim of bringing to fruition the nuclear fuel cycle.
Japan has established nuclear power as a core ingredient of its electric power generation. In order tocontinue to use nuclear energy over the long term and enjoy the superior 'energy security','environmental compatibility' and 'adaptability to future uncertainty' that it offers, introducing
technological advances as appropriate, this social capital has great value and should be maintained.
In order to further nuclear power and the nuclear fuel cycle, it is essential to obtain theunderstanding and support of the public. If a change of policy were made from the reprocessing
option to the direct disposal option, due to the fact that it is essential to maintain the trust of theregions where facilities are located, the government and private companies would have to makeevery effort to rebuild that trust. That would be expected to take time. During that time removal of
spent fuel from nuclear power plants would become problematic. A situation can be imagined where,
one by one, power plants have to cease operating and progress in the search for sites forintermediate storage facilities and for final disposal might cease.
During deliberations about the basic thinking, the view was expressed that the direct disposal option
should be chosen on the grounds that it is superior to the reprocessing option, not just from the pointof view of 'economic considerations', but also from the point of view of 'safety' and 'nonproliferation'. In the assessment of the basic scenarios, it was judged that there is no significant
difference between the two options from the point of view of 'safety' and 'non-proliferation' if thedesign, construction and operation of the facilities is carried out in accordance with the safety
standards established by the government and if strict, internationally agreed safeguards andmeasures for the protection of nuclear materials are in place. However, bearing in mind that theabove view was expressed, both the government and companies, when implementing the project,must ensure transparency within Japan and internationally. As well as ensuring the implementationof safety and safeguards measures etc., they should periodically reassess the appropriateness of theseregulations and the technical standards related to their application.
A view was presented that a policy allowing private companies to choose either reprocessing or
direct disposal should be adopted. However, even if the government decided to change its policy to
one of leaving it up to the company to choose, despite the fact that any benefits would notmaterialize for some time, the government's administrative expenses, including for technologicaldevelopment activities, would increase, and concerns about interim storage facilities would emerge,causing problems finding a site. The problems would be similar to scenario 4, so this was judged not
to be an option for consideration.
(2) Basic policy direction for the time being
For the time being, to the extent of the reprocessing capacity that will become available, spent fuelwill be reprocessed, and the spent fuel generated in excess of this capacity will be placed in interim
storage. Consideration of what to do with the spent fuel placed in interim storage will commence
around 2010, and be based on the track record of the Rokkasho Reprocessing Plant, progress inresearch and development relating to the fast breeder reactor and reprocessing, international
developments in relation to nuclear non-proliferation, and so on. Consideration of this matter will bebased on the basic stance and will pay regard to flexibility. A decision will be made in plenty of6Appendix 1
time to construct and commence operations at the necessary facilities before the Rokkasho
Reprocessing Plant ceases operation.
The government should, in accordance with the basic policy, put in place the necessary research anddevelopment system, make economic arrangements to cover expenses, take sincere steps to ensure
safety and non-proliferation, and, in order to develop mutual understanding with the public and theregions where facilities are located, proceed steadily with public hearings and provision of
information. In particular, still greater efforts are required to advance the pluthermal program and tofind sites for interim storage facilities.
It is hoped that private companies will, in accordance with the basic stance, take responsibility foradvancing the nuclear fuel cycle, based on the steps taken by the government, bearing in mind theneed to ensure safety and trust and to improve the economics of the project. In particular, in regard
to the Rokkasho Reprocessing Plant, it is hoped that they will ensure the smooth operation of theplant by thoroughly securing safe and stable operations, by undertaking thorough risk management
for the project, including preparing measures to deal with problems that arise, and by thoroughaccountability to the local community through risk communication.
In order to promote thorough transparency in regard to the use of plutonium, companies should
publish their plans for the use of plutonium before it is separated. It is appropriate that they clarify
the purpose of use, by providing estimates of the quantity to be used, the place where it is to be used,
when use will commence and for how long the use will continue. It is hoped that companies will
carry this out sincerely, by providing more and more detailed information as the project proceeds.
Due to the fact that, over the long-term, there are many uncertainties in regard to technologicaldevelopment, the international situation, etc., both government and private companies, separately
and cooperatively, should conduct research as necessary in order to be able to respond to future
uncertainties.
(3) Way forward for the future
From now on, via reviews of the progress of the existing long term plan, this Planning Council willconsider the future direction of policies which, based on this basic policy, are necessary in order toadvance the nuclear fuel cycle policy: the fast breeder reactor; improvement of light water reactors;
technological development of fuel cycle technology etc.; the system for ensuring transparency of thepeaceful use of plutonium; the system of public hearings and provision of information to the public;
the advancement of the management and disposal of radioactive waste (how to deal with waste
returned from overseas and transuranic waste, etc.); the system for the research which is needed inorder to be able to respond to future uncertainties; etc..
CNIC (This document is translated by CNIC)
Citizens' Nuclear Information Center
TEL.03-5330-9520
FAX.03-5330-9530

7Appendix 2
Mycle Schneider Consulting
45, allée des deux cèdres

Tél: 01 69 83 23 79

91210 Draveil (Paris)

Fax: 01 69 40 98 75

Francee-mail: mycle@wanadoo.fr

Open LettertoShunsuke KONDO
Chairman of the Japan Atomic Energy Commission
3-1-1 Kasumigaseki
Chiyoda-ku 100-8970
Japan
Paris, 12 March 04
Sir,
Thank you very much again for the invitation to give evidence to the Japan Atomic Energy Commission in
the framework of its reappraisal of the Atomic Energy Long-Term Plan.
Please, however, allow me to express my deep concern over the following issue.
In a recent paper, the Atomic Energy Commission stressed the significance of “democratic management” inthe pursuance of peaceful nuclear research and use: “We, the Atomic Energy Commission, fulfil our
responsibility incessantly recalling this principle (…)”. The document also states that “the Commission itself
shall continually conduct policy evaluations and reappraisals, taking into consideration the most recent
information and state of affairs so that the possibility of attaining overall objectives stipulated in the Atomic
Energy Basic Law is not impaired.”1
It is in this context that the Commission is organising public hearings, including evidence given byindependent experts like myself. However, I have learned that at least part of the Atomic Energy
Commission’s Secretariat is carried out by officials who are receiving a salary by the Commission while arealso on the payroll of the private nuclear industry. Asked whether this situation would not constitute a case ofConflict of Interest, one of the members of the Commission’s secretariat answered: “May be.”I consider it a very serious case of Conflict of Interest, if members of the Atomic Energy Commission’s
Secretariat are simultaneously receiving salaries by the Commission and by the nuclear industry. Such asituation would certainly severely damage the Commission’s credibility as independent State body acting inan exemplary democratic manner in collective public interest.
I would be grateful if you could share with me your thoughts on this serious matter.
Thank you very much for your attention.
Sincerely,

Mycle Schneider
1

Atomic Energy Commission of Japan, New Year Policy Statement, January 6, 20048

Appendix 3

19 March 04
Dear Mr. Schneider,

I appreciate your presentation at our 5th Public Hearing on March 2, 2004.
Par your letter on the conflict of interest dated March 4, I would like to make the following points clear toyou.
(1) The mission of the Atomic Energy Commission is to act as a guardian of principles and objectives set in
the Atomic Energy Basic Low, deliberate the long term program of research, development and utilization of
atomic energy, review the relevant actions taken by various stakeholders along the program, and make advice
them, if necessary. Commissioners are the government officer appointed by the Prime Minister with theapproval of the Diet and endeavor to accomplish the mission impartially.
(2) The Commission makes any decision collectively though the Commission and the Commissioners receive
various secretariat services from the Commission’s Secretariat which is under the supervision of the
Chairman. The Secretariat is composed of national government employees, who act under the obligation of
the National Public Service Law.
As you indicated that your letter is an open letter to us, I would like to ask the Secretariat to put your letterwith this response on the Opinion Corner of our Web page. If you have any serious problem on thistreatment, please let me know it at your earliest convenience.
Thank you again for your kind service to us.
Sincerely
Shunsuke Kondo
Chairman9