Proliferation Resistance and Safety Concerns over North Korean LWRs
January 29, 2001
Mr. Desaix Anderson Executive
Korean Peninsula Energy Development Organization
Dear Mr. Anderson:
Thank you for your response of January 12 to my letter about the Korean Peninsula Energy Development Organization’s (KEDO) light-water reactor (LWR) project. Your letter raises further concerns on the points I raised with you: (1) the capability of the LWRs KEDO is building for North Korea to produce large quantities of plutonium useful for weapons and (2) the inability of the nuclear plants to meet the essential safety requirements that KEDO has advertised it will meet.
In view of the plutonium production potential of the LWRs, I objected to the term "proliferation resistant" used by KEDO. To say, as you do, that the term is appropriate because it was agreed to by KEDO’s Executive Board is entirely to beg the question. Each LWR’s capacity for production of plutonium - all of which can be used for weapons - is larger than that of all the "frozen" North Korean reactors. Moreover, each LWR will also produce large quantities of essentially weapons grade plutonium.
On the question of safety you say the nuclear units will be built to standards of the United States Nuclear Regulatory Commission. But can KEDO really meet those standards? Consider one prominent safety issue: the provision of off-site power during an accident. The U.S. standard - I refer you to section 8.2 of the NRC Standard Review Plan (NUREG-0800) for nuclear power reactors - requires that the grid supplying the offsite power to a reactor maintain stability in the face of a sudden reactor shutdown. That situation does not obtain in North Korea because its grid electric generating capacity is not much larger than that of the nuclear plant itself. You say that North Korea will deal with this by "increasing its overall power generation capacity." To accomplish this they would have to add conventional generation capacity several times that of the LWRs. Surely, that cannot be a serious proposal - it would be the tail wagging the dog.
Finally, you contend that "there is no reason the DPRK cannot get the necessary insurance coverage as long as they can demonstrate their capability to operate the plants safely." Yet, even your own analysis of KEDO’s safety approach admits that KEDO is only responsible for the safety of the plant’s construction. The safe operation of the reactors will be controlled by North Korea’s State Nuclear Safety Regulatory Commission, whose independence your own analysis describes as being unclear "considering the DPRK’s government structure." Moreover, this agency’s experience and training in advanced light water reactor operation is virtually nil. Given these circumstances it is not surprising that the project has not gotten insurance coverage and recently lost the participation of a key U.S. vendor, General Electric.
My original point was that KEDO cannot claim the project is safe and proliferation resistant. I have carefully read your response. Unfortunately, there is nothing in it sufficient to alter that conclusion.
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January 12, 2001
Dear Mr. Sokolski:
I am writing in response to your letter dated December 19, 2000, concerning the Korean Peninsula Energy Development Organization’s (KEDO) light-water reactor (LWR) project. You have outlined a broad range of concerns with the LWR project to which I feel obliged to respond.
You expressed concern regarding KEDO’s use of the term “proliferation resistant” to describe the LWRs being supplied to the Democratic People’s Republic of Korea (DPRK). This was a term agreed by KEDO’s Executive Board members ö European Union,
Japan, Republic of Korea, and the United States ö based on technical and operation al considerations. Please also bear in mind that there are non-proliferation milestones in the Agreed Framework and in subsequent agreements with the DPRK. Thus, before delivery of key nuclear components by KEDO, the DPRK must come into full compliance with its safeguards agreements with the International Atomic Energy Agency of the United Nations (IAEA).
I disagree with your statement that work on these reactors is not being carried out in accordance with international standards of nuclear and conventional safety. Safety, both conventional and nuclear, is our first priority. Through its unique Nuclear Safety Confirmation System (NSCS), KEDO will abide by its commitment to assure that the design, manufacture, construction, testing, and commissioning of the LWR plants is in conformance with nuclear safety and regulatory codes and standards equivalent to that of the IAEA and the United States.
With respect to your observations about the DPRK nuclear operator and regulator, KEDO can, on the basis of its ongoing contacts with the two DPRK organizations concerned, testify that each takes its responsibilities extremely seriously. Additional information on the NSCS and the KEDO’s interactions with the KPRK nuclear operator and regulator can be found in the article, KEDO’s nuclear safety approach, published in the January issue of the American Nuclear Society’s Nuclear News. A copy of the article is attached for your information.
Regarding the issue of off-site power, it is indeed a requirement that the DPRK provide a stable supply of electricity for commissioning of the two LWR plants, including adequate power for safe shutdown. The DPRK has developed long-term plans for upgrading its electricity sector, which include increasing its overall power generation capacity. Ultimately, safety is maintained because the DPRK must meet off-site power system interface requirements, based on United States Nuclear Regulatory Commission standards, before KEDO will supply nuclear fuel and conduct commissioning tests. Based on these conditions, there are no operational safety issues related to off-site power.
Lastly, I would like to address the issue of nuclear liability insurance for the project. KEDO incorporated measures in its agreements with the DPRK to ensure that adequate liability protection and legal and financial mechanisms are available for meeting claims related to the LWR plants. Based on discussions with international insurance
brokers, there is no reason the DPRK cannot get the necessary insurance coverage as long as they can demonstrate their capability to operate the plants safely.
As you can see, KEDO takes its responsibilities very seriously and will continue to commit itself to ensuring that the LWR project is implemented in the safest manner possible.
Finally, please not that the full name of our organization is the Korean Peninsula Energy Development Organization, not the Korean Energy Development Organization as you wrote in your letter.
Desaix Anderson Executive Director
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December 19, 2000
Mr. Desaix Anderson
The Korean Energy Development Organization
600 Third Ave., 12th Floor
New York, NY 10016
Dear Mr. Anderson:
I want to thank you again for allowing me to attend the Korean Energy Development Organization’s (KEDO’s) annual conference this fall. I thought that the free exchange with your staff regarding the nuclear reactor project’s safety and proliferation resistance was particularly useful. In this spirit, I would like to bring to your attention two statements on your organization’s website (http://www.kedo.org) about the KEDO LWRs that need correcting.
The first is that the KEDO-supplied light water reactors (LWRs) are "proliferation resistant". We all know that LWRs make less plutonium per megawatt than the reactors North Korea operated and had under construction. But because the LWRs are so much bigger--nearly ten times the power output of all the reactors it was planning to build (and nearly 400 times that of the reactor North Korea operated) -- the two modern reactors KEDO is supplying could produce twice as many bombs worth of material as the reactors Pyongyang had under construction. This size factor more than overwhelms any anti-proliferation advantages these LWRs might have had in other circumstances.
Moreover, not only is all the plutonium usable for bombs, but the two proposed reactors will, in fact, produce so-called "weapons-grade" material during initial commercial operation. Attached is an analysis done by the Lawrence Livermore US national nuclear weapons laboratory (see below). As this chart makes clear, after the first 15 months of operation, that is, at the end of the first commercial fuel cycle, each of the light water reactors KEDO is supplying would produce about 330 kilograms of plutonium (of which nearly 85 percent would be plutonium 239) --essentially weapons grade and enough for about 75 bombs. What more would North Korea need?
The second KEDO website statement that bears correcting is the one that work on the two reactors is being conducted in a manner that "meets or exceeds international standards of nuclear and conventional safety." In fact, these reactors cannot meet U.S. safety requirements for the reactors’ electric power systems. To protect against accidents, the U.S. Nuclear Regulatory Commission (NRC) requires a reliable source of off-site power to cover the possibility that the reactors’ emergency diesels fail. As you and I discussed before, such reliable offsite power cannot be supplied by North Korea’s grid. That would be true even if North Korea’s transmission system is upgraded, because the total generation capacity of North Korea’s grid is simply too small. Let me add that there are also critical safety concerns regarding the competence and independence of North Korea’s nuclear operators and regulators, who will take orders from a regime whose dedication to safety is open to doubt. Finally, it does not help that there is insufficient nuclear liability insurance for the project.
I would urge you to take another look at KEDO’s website, and to adequately qualify the statements about "proliferation resistance" and nuclear safety. I would be happy to discuss these points with you further.
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Fission Energy and Systems Safety Program
Lawrence Livermore National Laboratory
Light-Water Reactor Fueling Handling and Spent Fuel Characteristics
ROK "Standard" LWR
- 177 Fuel Assemblies (76 MT U, 41772 fuel rods)
- Equilibrium Core Characteristics:
- enrichment: 3.37%
- cycle length: 18 months (45 MWd/kg)
- core change: one-third
- Beginning of Life Core Characteristics:
- A zone: 1.4%
- B zone: 2.37-2.87%
- C zone: 2.87-3.37%
- cycle length:
- cycles 1&2: 15 months (12, 25 MWd/kg)
- cycles 3: 18 months (42 MWd/kg)
- 330 kg Puf
Due to technical difficulties we were unable to post the chart from Lawrence Livermore Laboratory.