Open Letter to Director General Yukiya Amano, International Atomic Energy Agency (IAEA)
21 June 2018
Dear Director General Yukiya Amano,
We are writing to you in advance of a submission by the Government of Japan on its plutonium stockpiling program. It
is our understanding that the IAEA will receive by the end of this month an explanation from the Abe administration on
how Japan intends to respond to growing international criticism of its plutonium stocks, which in 2016 stood at 46,900
kilograms.1 As with its earlier commitment to maintain its plutonium stockpile to the minimum level made by the Abeadministration at the Hague Summit in 2014,2 we predict the same meaningless rhetorical commitments in June 2018.
The information to be submitted by the Japanese government will likely cite current policy, applied in 2003 and restatedin its July 2017 Basic Policy for Nuclear Energy, “not to possess plutonium without specific purpose.”3 This
notification to you is a warning that any commitment made by Japan on plutonium will once again, almost certainly, bebased on wholly unrealistic ambitions for managing its stocks of plutonium to attain equilibrium in its supply anddemand. The current crisis in the nations nuclear industry, which is certain to continue, holds no prospect for large scale
plutonium stock reduction. As you are aware, this is not a new plutonium problem only emerging in recent years.
Nearly thirty years ago we exposed the risks and threats posed by Japan’s plutonium program.4 In 1999, we wrote toyour predecessor, Mohamed ElBaradei, citing the predictable failure of Japan’s plans to utilize plutonium in the form of
Mixed Oxide Fuel (MOX) fuel both in its stalled Fast Breeder Program and in Light Water Reactors.5 At that time,
Japan’s plutonium stocks were 5,318kg held domestically, with a further 27,309kg held at reprocessing plants in the UK
and France.6 The latter had grown dramatically from 10,844 in 1992 to this higher amount in less than 7 years. At thattime there was no prospect of even this large amount of direct use weapons material being used in Japan’s LWR MOX
program. At that time we warned the Director General that there was no justification for a planned plutonium MOX
shipment to the Fukushima Daiichi unit 3 and Takahama unit 4 reactors, citing that the justification offered by theGovernment of Japan was, “false, given the lack of real demand for plutonium reactor fuel, its poor economics, as well
all the environmental, human health and the direct proliferation risks it poses.”
The inaction of the IAEA to address these issues in the 1990’s to the present has in part contributed to the current
situation which has escalated as we predicted. The current stockpile of Japan’s plutonium amounts to approximately
9,800kg held domestically, in addition to 37,100kg in Europe (20,800kg at the NDA Sellafield plant in the UK and
16,200kg at the Orano la Hague and Melox plants in France).7 This stock will increase by a further 1000kg in 2018 withtransfer to Japanese utility holdings at the Sellafield plant. The growth of any nations stockpile of fissile material is oflegitimate concern, but the case of Japan is unique, having grown from 10.8 tons to 47.9 tons in 25 years. As we urged
in 1999, a first important international step in reducing the safety and proliferation risks of plutonium worldwide, andwhich remains even more urgent today, is the immediate cessation of all weapons-usable plutonium separation and use,
whether for stated military or civil use. Ultimately, only a comprehensive fissile material treaty that ends all commercial
trade in fissile material will be sufficient to counter the threats posed by the Japanese and other nations plutonium
programs.8 We realize that as a former senior diplomat for the Government of Japan who actively promoted Japan’s
right to pursue plutonium production and MOX use, a Comprehensive Fissile Material Treaty runs counter to yourhistorical position9, but in the interests of effective non proliferation there is no alternative.

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Office of Atomic Energy Policy, “The Status Report of Plutonium Management in Japan – 2016”, 1 August, 2017, Cabinet
Office , see http://www.aec.go.jp/jicst/NC/about/kettei/170801_e.pdf; and Nikkei Asian Review, “Reducing Japan's plutonium
stockpile easier said than done”, 16 June 2018, see https://asia.nikkei.com/Economy/Reducing-Japan-s-plutonium-stockpileeasier-said-than-done
MOFA, “Joint Statement by the Leaders of Japan and the United States on Contributions to Global Minimization of Nuclear
Material”, 24 March 2014, see https://www.mofa.go.jp/dns/n_s_ne/page18e_000059.html, and Final Communique, “The Hague
Nuclear Security Summit Communiqué”, The Hague, 24 March 2014, see
https://www.consilium.europa.eu/media/23823/141885.pdf
Japan Atomic Energy Commission, “Plutonium Utilization”, October 2017, see
http://www.aec.go.jp/jicst/NC/about/kettei/kettei171003_e.pdf
New York Times, “Plutonium Shipment Leaves France for Japan”, November 1992, see
https://www.nytimes.com/1992/11/08/world/plutonium-shipment-leaves-france-for-japan.html
Nuclear Control Institute, Citizens Nuclear Information Center, Greenpeace, Green Action, “Open Letter to the Director General
Dr. Mohamed ElBaradei International Atomic Energy Agency”, Paul Leventhal, Hideyuki Ban, Aileen Mioko Smith and Shaun
Burnie, April 13, 1999, see http://www.nci.org/c/c41299.htm
Nuclear Information, “Japan's plutonium holding capacity”, 2018, see http://kakujoho.net/ndata/pu_jp.html
Opcit. Cabinet Office, August 2017.
Greenpeace, International, “Time for a Comprehensive Fissile Material Treaty”, 21 February 2006, see
http://www.greenpeace.org/archive-international/Global/international/planet-2/report/2006/4/comprehensive-fissile-material.pdf“Japan views the peaceful uses of nuclear energy as vital not only to securing a stable energy supply, but also to preserving the
global environment. States parties therefore should reaffirm that nothing in the Treaty shall be interpreted as affecting their rightto the peaceful use of nuclear energy. Japan continues its research and development efforts relating to the use of plutonium for

The Fukushima Daiichi accident, as you know, involved a partially MOX fueled reactor in unit 3. The efforts of civilsociety in Japan, opposed to the inherent reduced safety margins of MOX use, led to Tokyo Electric Power Company(TEPCO) being prevented from MOX loading in 1999 at Fukushima Daiichi as well as at the Kashiwazaki Kariwa unit
3 reactor. TEPCO finally loaded approximately 225 kg of plutonium in 28 Belgonucleaire / Cogema MOX fuelassemblies in unit 3 in August/September 2010. You are well aware of what happened less than six months later inMarch 2011.
Less acknowledged is that if TEPCO had proceeded with its MOX plans as scheduled in the 1990’s, there would
potentially have been many hundreds of tons of spent MOX fuel in the Fukushima Daiichi reactor pools, as well as in
the core fuel of units 3 and potentially at least one other reactor at the site. As the International MOX Assessment (IMA)
in 1997 detailed, the consequences of a severe accident at a MOX fueled reactor are a/ more likely, and b/ involve
greater consequences.10 These include a higher release fraction of plutonium into the environment with resultant
increased latent cancer risks. Perhaps even more consequential would have been the heightened risk of loss of cooling
function at the Fukushima Daiichi spent fuel pool(s) due to the higher heat generation of spent MOX fuel. As you alsoknow, the Atomic Energy Council (AEC) provided analysis to then Prime Minister Naoto Kan on 25th March 2011. Th
AEC analysis warned that loss of cooling function and control at the spent fuel pools at Fukushima Daiichi, would haverequired potentially the evacuation of an area 150-250km from the nuclear plant.11 Rather than the necessary evacuationof 164,000 Japanese citizens, the nation could have been confronted with having to evacuate 50 million people,
including those resident in Tokyo. As Prime Minister Kan was to say,“The future existence of Japan as a whole was at stake,” he said. “Something on that scale, an evacuation of 50
million, it would have been like a losing a huge war...We were only able to avert a 250-kilometre (160-mile)evacuation zone [around the plant] by a wafer-thin margin, thanks to the efforts of people who risked their lives.
Next time, we might not be so lucky.”12
Luck indeed played a role in preventing water levels from being reduced in spent fuel pool unit 4, but it was also theefforts of civil society to prevent TEPCO’s full scale MOX fuel program that most likely prevented the Fukushima
nuclear disaster from being cataclysmic. This recent history is important to understand in the context of the expected
communication from the Japanese government to the IAEA and the U.S. State Department later this month.13 Japan’s
plutonium MOX plans were always a dangerous fantasy – they were decades ago – and they are even more so today.
Our analysis over recent years, and to the present, indicates that Japan will fail to meet its nuclear restart target of
30GW by 2030 by a wide margin.14 Many more nuclear reactors are likely to be decommissioned in the coming years,
joining the 17 that have been declared such since 2011.15 Legal challenges are underway at most nuclear plants acrossJapan, with four reactors currently loaded with plutonium MOX fuel (though one of these, Ikata-3, is shutdown after acitizen lawsuit secured an injunction from the Hiroshima High Court in December 2017 that will run until September
2018, but with possibility of further extension from the lower court.)16
Japanese utilities have recently recommitted to operating with 16-18 reactors with plutonium MOX fuel.17 Given that it
is unlikely that even this number of reactors in total will operate in the future, this vague and meaningless statement isless to do with the reality of the crisis Japanese utilities find themselves in, but rather a token offering to theGovernment to provide weak justification for business as usual in nuclear fuel cycle policy. The Federation of Electric

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fast reactors and light-water reactors in order to develop a nuclear fuel cycle while fully complying with the IAEA safeguards
agreement, including its Additional Protocol.”, MOFA, “Statement by Ambassador Yukiya Amano, Representative of Japan at
the First Session of the Preparatory Committee for the 2005 Review Conference of the Parties to the Treaty on the NonProliferation of Nuclear Weapons April 8, 2002, New York, see https://www.mofa.go.jp/policy/un/disarmament/npt/session13.html
IMA Project Citizens' Nuclear Information Center, “Final Report of the International MOX Assessment Comprehensive Social
Impact Assessment Of Mox Use In Light Water Reactors”, J. Takagi, M. Schneider, F. Barnaby, I. Hokimoto, K. Hosokawa, C.
Kamisawa, B. Nishio, A. Rossnagel, M. Sailer, November, 1997, see
http://www.cnic.jp/english/publications/pdffiles/ima_fin_e.pdf
AEC, “Scenario and Contingency Planning of Fukushima Dai-ichi Nuclear Power Plant” Shunsuke Kondo, March 25, 2011,
released by Japanese Cabinet Office, 30 January 2012.
Daily Telegraph, “Fukushima: Tokyo was on the brink of nuclear catastrophe, admits former prime minister”, 6 March 2016,
https://www.telegraph.co.uk/news/worldnews/asia/japan/12184114/Fukushima-Tokyo-was-on-the-brink-of-nuclear-catastropheadmits-former-prime-minister.html
Asahi Shimbun, “Japan to cap plutonium stockpile to allay U.S. concerns”, 17 June 2018, see
http://www.asahi.com/ajw/articles/AJ201806170027.html

14 Greenpeace, “Reality Check: Energy Mix 2030 and Japan's Collapse in Nuclear Power Generation”, April 2015, see
https://www.greenpeace.org/japan/Global/japan/%5BFINAL%5DEN_2030Energy%20Mix_G7_2016.pdf
15 WNISR, “Permanent Closure of Ikata-2 Brings Total Shutdowns to One Third of Pre-Fukushima Capacity in Japan”, 27 March
2018, see https://www.worldnuclearreport.org/Permanent-Closure-of-Ikata-2-Brings-Total-Shutdowns-to-One-Third-of-Pre.html
16 Asahi Shimbun, “For 1st time, a high court rules against nuclear plant operations”, 13 December 2017, see
http://www.asahi.com/ajw/articles/AJ201712130050.html
17 JAIF, “FEPC Adheres to Policy of MOX Fuel Use at 16 to 18 NPPs”, 16 March 2018, see http://www.jaif.or.jp/en/fepc-adheresto-policy-of-mox-fuel-use-at-16-to-18-npps/

Power Companies (FEPC) has history on this issue, having made the same commitment more than 20 years ago in
1997.18 Neither then nor today is their pledge credible.
In addition to the four reactors that have resumed operation with partial MOX fuel cores, it is uncertain how many of
the remaining six reactors that have received MOX approval will actually restart during the next 10 years. They are all
confronted with multiple challenges, including seismic faults, as well as legal and political opposition. Of the remaining
six units, five are at high risk of never restarting, specifically Kashiwazaki Kariwa-3, Shika-1, Hamaoka-4, Tomari-3,
Onagawa-3.19 Even if they were to restart and based on past performance there is little prospect of all these reactors
attaining a one-third MOX core within the coming decade. As a consequence, if we suspend reality and take industry
commitments seriously, Japan's annual plutonium demand could in theory reach at most between 1-2 tons of plutonium
per year. This would require at least one plutonium MOX fuel shipment each year from Europe - something neverachieved in the past decades and unlikely to do so in the future. Nevertheless, even if that rate of plutonium demand
could be attained it would be sometime between 2034 and 2056 before Japan's plutonium stock in Europe was reduced
to zero. Yet even that medium term timescale is not possible. Three of the reactors currently operating with MOX fuel,Takahama-3 and 4 and Genkai-3, will surpass 40 years operation in 2024 and it is unclear whether they will operate
beyond that. A further six of MOX licensed reactors will exceed forty years by 2034. The future operation of
conventional uranium fueled nuclear reactors in Japan remains highly uncertain, but it is even more so for those seeking
to load plutonium MOX fuel, which will be strongly resisted by local populations, politicians and ourselves. One thingthat is certain, any pledge by Japan to significantly reduce its plutonium stocks through MOX use will fail, as it hasthese past decades.20
At the same time, Japan remains committed to the commercial operation of the 2.9 trillion yen ($26.37 billion)
Rokkasho-mura reprocessing plant in Aomori prefecture, with the potential to separate an additional 8000kg of
plutonium each year.21 We long considered it near impossible that the plant would operate at full capacity – primarily
for technical and design flaw reasons. The only reactor project that is relevant to Rokkasho-mura’s operation is theunder construction Ohma ABWR in Aomori prefecture. Plans to operate this reactor with a 100 percent MOX core,amounting to as much as 5 tons of plutonium, remain the last hope for Japan’s nuclear fuel cycle. Yet, the reactor
remains unfinished and subject to two lawsuits seeking its cancellation. Planned and delayed in the 1980’s, originallyplanned for operation by 2012, then 201422 its latest, but still unrealistic, schedule is for construction and possible
operation to be finished in “2023 or 2024”.23 Even its owner, J-Power, which has only operated one experimental
reactor in its history, acknowledges that, “It is still undecided about the operation start time."24 Sitting in a high seismiczone and at risk from volcanic ash eruptions, the prospects of a successful operation of this unprecedented plutonium
experiment as planned are close to zero. While J-Power and the Japanese government remain uncertain as to when theOhma plant will commence operation, the citizens and city council of Hakodate, are committed to preventing its
operation through lawsuits against the company and central government.
Any commitment made to the IAEA and the U.S. State Department by the Japanese government to only operate the
Rokkasho-mura reprocessing plant to meet legitimate plutonium demand, is a clear contradiction. The only logicalsolution is for plans for commercial operation of the plutonium plant to be suspended indefinitely, leading to eventual
decommissioning. Taking all these factors into account, there are no credible prospects for Japan to significantly reduce
its plutonium stockpiles over the coming years through MOX fuel utilization.
Inexcusably, over many decades the IAEA has provided technical support and political justification for Japan’s wholly
uneconomic and failed plutonium programs.25 To this day your Agency continues to actively promote the development
18 IAEA, “FEPCO announces MOX program for Japanese NPPs”, 1997, see
https://inis.iaea.org/search/search.aspx?orig_q=RN:29002486
19 Japan Focus, “Nuclear Proliferation in Plain Sight: Japan’s Plutonium Fuel Cycle–A Technical and Economic Failure But a
Strategic Success”, Shaun Burnie, Frank Barnaby, with Tom Clements, Aileen Mioko Smith and Kendra Ulrich, Asia Pacific
Journal, 1 March 2016, see https://apjjf.org/2016/05/Burnie.html
20 Ibid.
21 Opcit. Asahi Shimbun, 17 June 2018.
22 NucNet, “Scheduled Start-Up Of Japan’s Ohma ABWR Put Back To 2014”, 19 November 2008, see https://www.nucnet.org/allthe-news/2008/11/19/scheduled-start-up-of-japan-s-ohma-abwr-put-back-to-2014/print
23 Japan Times, “J-Power delays plan to begin operating Oma nuclear plant until 2024”, 9 September 2016, see
https://www.japantimes.co.jp/news/2016/09/09/national/j-power-delays-plan-begin-operating-oma-nuclear-plant2024/#.Wyejv1OFPOQ
24 World Nuclear News, “Further delay in completion of Ohma plant”, 12 September, 2016, see http://www.world-nuclearnews.org/NN-Further-delay-in-completion-of-Ohma-plant-1209164.html
25 Recycling of Plutonium and uranium in water reactor fuel Proceedings of a Technical Committee meeting held in Newby Bridge,
Windermere, United Kingdom, 3-7 July 1995, IAEA-TECDOC-941, see
http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/28/047/28047119.pdf; and, IAEA, “MOX fuel use as a backend option: Trends, main issues and impacts on fuel cycle management”,Fukuda, K. (International Atomic Energy Agency,
Vienna (Austria)); Choi, J.-S. (International Atomic Energy Agency, Vienna (Austria)); Shani, R. (International Atomic Energy
Agency, Vienna (Austria)); Durpel, L. van den (OECD Nuclear Energy Agency, Issy-les-Moulineaux (France)); Bertel, E.
(OECD Nuclear Energy Agency, Issy-les-Moulineaux (France)); Sartori, E. (OECD Nuclear Energy Agency, Issy-lesMoulineaux (France)), 2000, see https://inis.iaea.org/search/search.aspx?orig_q=RN:31062324;

of plutonium based plutonium fuel cycles, so called Generation IV technology, against all the historical evidence of its
failure26 and in disregard for the safety, environmental and proliferation27 implications.28 One honorable exception was
IAEA Deputy Director, William J. Dircks, who in 1992 at a meeting of the Japan Atomic Industrial Forum (JAIF)
stressed the, "urgent need to review once again our policies regarding plutonium and its use,”29 warning that the,"adverse economics of MOX fuel utilization" would result in MOX providing "little help…in dealing with surplus
plutonium." Having failed to heed this warning and those of many others, including those submitting this letter,successive Japanese governments and the IAEA have instead overseen a dramatic growth in so-called civilian but
nuclear weapons usable plutonium stocks, including those of Japan, over the past quarter of century. We have little faiththat the IAEA will act effectively this time. We would, however, be pleasantly surprised if we were to be proved wrong
and a decision was made by the IAEA to take up the call to action by the IAEA’s former Deputy Director and civilsociety which is even more relevant and urgent today than it was nearly three decades ago.
Continued inaction by the IAEA and its continued active support for Japan’s plutonium program is a willful degradationof your institutions stated duty and commitment to effective non proliferation. However, given the IAEA’s track record,
we will not be waiting for action on your part. Instead, we are confident and determined that civil society and the peopleof Japan, as in the years prior to March 2011, will act to protect our environment, health and economy from the threat offuture severe accidents from this bankrupt plutonium program, leading ultimately to a policy change and the end ofJapan’s nuclear fuel cycle program.30

Hideyuki Ban
Co-Director
Citizens' Nuclear Information Center
Akebonobashi Co-op 2F-B, 8-5 Sumiyoshi-cho,Shinjuku-ku, Tokyo, 162-0065, Japan
TEL.03-3357-3800
cnic-jp@po.iijnet.or.jp

Aileen Mioko Smith
Director
Green Action
Suite 103, 22-75 Tanaka Sekiden-cho
Sakyo-ku, Kyoto 606-8203
Japan
Tel: 81-75-701-7223
amsmith@gol.com

Shaun Burnie
Senior Nuclear Specialist
Greenpeace Germany,
Attention to Greenpeace Japan,
8 Chome−13−11 NF bldg 2F
Nishishinjuku,
Shinjuku, Tokyo 160-0023,
Japan
Tel: 49 151 643 20548
sburnie@greenpeace.org

26 IPFM, “Fast Breeder Reactor Programs: History and Status”, Research Report 8 International Panel on Fissile Materials Thomas
B. Cochran, Harold A. Feiveson, Walt Patterson, Gennadi Pshakin, M.V. Ramana, Mycle Schneider, Tatsujiro Suzuki, Frankvon Hippel, February 2010, see http://fissilematerials.org/library/rr08.pdf
27 Greenpeace International, “The Unlawful Plutonium Alliance Japan's supergrade plutonium and the role of the United States”,
Shaun Burnie and Tom Clements September, 1994, Greenpeace International, see
http://www.srswatch.org/uploads/2/7/5/8/27584045/retf_report_sept_1994.pdf, and, The New York Times, "U.S., Criticized for
Helping Japan Over Plutonium, Will Stop, October 1994, see https://www.nytimes.com/1994/09/09/world/us-criticized-forhelping-japan-over-plutonium-will-stop.html
28 IAEA, “IAEA and GIF Expand Collaboration on Innovative Reactors” April 2018, see
https://www.iaea.org/newscenter/news/iaea-and-gif-expand-collaboration-on-innovative-reactors
29 David Sanger, “Japan Is Cautioned on Plan To Store Tons of Plutonium”, New York Times, 13 April 1992, see
https://www.nytimes.com/1992/04/13/world/japan-is-cautioned-on-plan-to-store-tons-of-plutonium.html
30 CNIC, “PuPo 2017 Report: International Discussion of Japan’s Plutonium Policy ~Towards change for the future”, 17 April
2017, see http://www.cnic.jp/english/?p=3781