Russian Import of Foreign Spent Fuel: Status and Policy Implications

Proceedings of the 42nd Annual Meeting of the Institute of Nuclear Materials Management,Indian Wells, California

Russian Import of Foreign Spent Fuel:
Stauts and Policy Implications

by Matthew Bunn

ABSTRACT

Russia has recently approved legislation allowing it to offer to import foreign spent fuel for storage, reprocessing, or even disposal in Russia. This represents a potentially dramatic development in the decades-long history of efforts to establish internationally collaborative approaches to management of spent fuel and nuclear wastes.

Based on a recently published study, this paper reviews the wide range of issues raised by Russia''s offer to serve as host for other countries'' spent fuel. These include: (a) safety and security (especially given Russia''s past record of inadequate management of nuclear wastes, and decaying transportation infrastructure); (b) public acceptance and civil society in Russia (polls indicated that 90% of the Russian public opposes the import plan); (c) economics (Russia may be able to earn $10-$20 billion in gross revenue from imports, and dry cask storage would cost a small fraction of that, but development of reprocessing and/or repository facilities is likely to be costly); (d) potential contribution to nonproliferation, arms reduction, and cleanup (negotiations over this import may lead to a deal on Russia''s cooperation with Iran, it may be possible to convince Russia to allocate a substantial portion of the revenue to mutually agreed projects in these areas, and such a storage site would make it possible for some utilities to avoid the proliferation hazards of reprocessing plutonium before the plutonium is needed as fuel); and (e) potential contribution to nuclear waste management (for a variety of reasons, in the long run consolidating wastes in a modest number of international facilities would be more desirable than establishing scores of national waste repositories around the world).

Most of the spent fuel Russia might import is U.S.-obligated, meaning that it cannot be shipped to Russia without U.S. approval. Thus the principal thing now standing between Russia''s Ministry of Atomic Energy and $10-$20 billion in revenue is the U.S. government''s permission. Under the Atomic Energy Act, the U.S. government cannot give its permission without a Section 123 agreement for nuclear cooperation. The negotiation of such an agreement will involve a wide range of factors, including Russia''s nuclear cooperation with Iran, reprocessing of the spent fuel, use of the revenues earned, and U.S. government attitudes toward Russian public opposition to the imports, among others. The policy issues for the U.S. government raised by the upcoming negotiation of such an agreement (especially the nonproliferation and arms reduction issues) are explored.

INTRODUCTION

Russia has recently approved legislation allowing it to offer to import foreign spent fuel for storage, reprocessing, or even disposal in Russia. Russian President Vladimir Putin signed the legislation in early July, 2001. This represents a potentially dramatic development in the decades-long history of efforts to establish internationally collaborative approaches to management of spent fuel and nuclear wastes [1].

Russia''s offer to serve as host for other countries'' spent fuel raises a complex set of safety, security, economic, political, and policy issues. Such a facility could make a substantial contribution to international security and would deserve support if:

• Effective arrangements (including independent regulation) were in place to ensure that the entire operation achieved high standards of safety and security;
• Negotiation over the project provided an opportunity to effectively resolve the proliferation risks posed by Russian nuclear cooperation with Iran, and a substantial portion of the revenues from the project were used to fund disarmament, nonproliferation, and cleanup projects that were agreed to be urgent, such as securing nuclear material and eliminating excess plutonium stockpiles;
• The project did not in any way contribute to separation of additional unneeded weapons-usable plutonium, or to Russia''s nuclear weapons program; and
• The project had gained the support of those most likely to be affected by it, through a democratic process, including giving them ample opportunity to ensure that their concerns were effectively addressed.Whether an arrangement that meets these criteria can be put in place in Russia - and what the reaction will be if a proposal advances which meets the first three criteria but not the fourth - remains to be seen.

Most of the spent fuel Russia might import is U.S.-obligated, meaning that it cannot be shipped to Russia without U.S. approval. Thus the principal thing now standing between Russia''s Ministry of Atomic Energy and $10-$20 billion in revenue is the U.S. government''s permission. Under the Atomic Energy Act, the U.S. government cannot give its permission without a Section 123 agreement for nuclear cooperation. The negotiation of such an agreement will involve a wide range of factors, including Russia''s nuclear cooperation with Iran, reprocessing of the spent fuel, use of the revenues earned, and U.S. government attitudes toward Russian public opposition to the imports, among others. The policy issues for the U.S. government raised by the upcoming negotiation of such an agreement (especially the nonproliferation and arms reduction issues) are explored.

BACKGROUND

For decades, there have been a variety of efforts to establish storage or disposal sites that would accept spent fuel and/or nuclear wastes from other countries. Such international sites pose a complex array of advantages and disadvantages, provoking a range of different views concerning their desirability. The most fundamental obstacle to establishing such an international facility has been the same for decades: finding a state that is both willing to host such a facility and suitable for doing so.

From a proliferation perspective, there could be substantial benefits to an international facility, if appropriately sited and managed, including: offering an option to utilities to manage their spent fuel without reprocessing that would separate weapons-usable plutonium before the plutonium was needed; allowing nuclear materials to be removed from countries of high proliferation risk (as has been done in recent years, for example, in Iraq, Kazakhstan, and Georgia, and is planned with North Korean spent fuel); improving transparency in spent fuel and plutonium management; and consolidating the number of geologic repositories that must be safeguarded for the long term. Moreover, in some proposals, revenue from such an operation could provide billions of dollars to finance urgent arms reduction, nonproliferation, and cleanup initiatives, from securing and reducing nuclear weapons and fissile material stockpiles to downsizing the Russian nuclear weapons complex and re-employing Russia''s nuclear weapons scientists and technicians.

STATUS OF RUSSIAN LEGISLATION

Although the Soviet Union had traditionally had spent-fuel take-back arrangements with the East bloc states whose reactors it supplied, Russia''s environmental law has prohibited import of spent fuel or nuclear waste for storage or disposal in Russia. For several years, Russia''s Ministry of Atomic Energy (MINATOM) has been seeking to amend the law to eliminate this prohibition, allowing it to pursue spent fuel storage contracts from foreign countries and spent fuel reprocessing contracts without requiring return of high-level wastes.

Three pieces of legislation have now been approved, accomplishing this change in the law. The first, an amendment to the environmental protection law, would eliminate the prohibition on importing spent fuel and nuclear waste. The second, an amendment to the atomic energy law, reportedly would establish procedures for fuel leasing operations, in which fresh fuel would be marketed to foreign customers with a commitment to take it back after irradiation. The third, a new law, would regulate expenditures from funds generated by importing foreign spent fuel, reportedly requiring a substantial fraction to be spent on environmental cleanup programs.

Although this legislation has now been approved, it has been the subject of very substantial controversy. With the legacy of decades of Soviet nuclear contamination, secrecy, and lies, large fractions of the Russian public simply do not trust anything that MINATOM does, and do not believe that imported spent fuel will be handled safely or the money used honestly. Polls indicate that 90% of the Russian public opposes the spent fuel import plan, and it has become target number one for the Russian environmental movement. Many international environmental organizations have also opposed the plan. Russian environmentalists raised 2.5 million signatures on a petition calling for a national referendum on the spent fuel import plan - an amazing grass-roots effort in a country where for signing anything critical of the government was a ticket to the gulag - but the Central Electoral Commission invalidated just enough of these signatures to bring the total below the 2 million mark that would have forced a vote. The Russian nuclear regulatory agency has also fiercely opposed the plan, arguing that Russia is not prepared to handle such an import scheme safely. What next steps the plan''s opponents will take now that President Putin has approved the legislation remains to be seen.DIFFERENT PROPOSALS FOR RUSSIAN SPENT FUEL IMPORTS

There are a variety of quite different proposals involving Russian spent fuel imports, with quite different implications. A few of the principal concepts will be discussed here.

MINATOM''s own concept for an international spent fuel service involves offering two different services: temporary storage with later return of the spent fuel for the minority of customers who would prefer that, or reprocessing without return of plutonium or wastes for most customers. MINATOM envisions importing 20,000 tons of spent fuel over 10 years, generating $21 billion in total revenue (at an estimated temporary storage price of $300-$600/kgHM, and an estimated price for reprocessing without return of wastes and plutonium of $1,200-$2,000/kgHM).[2] MINATOM projects actual costs of providing the services at roughly $10.5 billion. Another $3.3 billion would go to national and regional taxes and other payments to governments, leaving $7.2 billion available for addressing "social-economic and ecological problems." In approving the legislation, President Putin established a special commission overseen by a Nobel-prize winning physicist to oversee the funds.

While Evgeniy Adamov was Minister of Atomic Energy, he acknowledged that traditional reprocessing approaches pose a proliferation hazard and should be phased out, and entered into negotiations with the United States over the idea of a 20-year moratorium on such plutonium separation. But MINATOM hopes to develop new, proliferation-resistant reprocessing technologies and then build new reprocessing plants to implement them using revenues generated by importing spent fuel, beginning in 2020 or later. Retaining plutonium and wastes would make the service much more attractive than that offered by Britain and France, which require customers to take back these products.

While this approach is official MINATOM policy, it has virtually no supporters in the U.S. government, and is fervently opposed by Russian and international environmentalists. It would be impossible for MINATOM to meet its 20,000-ton target in the near term unless it could receive U.S.-obligated spent fuel, given which countries are most interested in off-shore spent fuel management services. The United States is certain to insist on retaining veto power over any reprocessing of the fuel, so MINATOM''s reprocessing plans will never come to fruition unless it develops a technology sufficiently proliferation-resistant to win U.S. support.

A radically different concept, the Nonproliferation Trust (NPT), calls for establishing a dry cask storage facility in Russia that would accept 10,000 tons of spent fuel from other countries on a commercial basis. At a projected price of $1,500/kgHM (based on proponents'' assessment of utilities'' willingness to pay), this would raise $15 billion in revenue. Project advocates estimate total costs for transportation, storage, and eventual disposal of the spent fuel in the range of $4 billion ($400/kgHM), leaving $11 billion in excess revenue, which they would allocate almost entirely to disarmament, nonproliferation, and cleanup initiatives in Russia [3].

Under its plan, the U.S.-based Trust would control construction and operations, and entities linked to the Trust would control the funds, with virtually none of the revenues going to the Russian government or Ministry of Atomic Energy (MINATOM) to spend on their own favored projects. In the Trust''s proposed contract, reprocessing of spent fuel would be banned, and Russia would be prohibited from entering into new contracts for foreign reprocessing (which would compete for the same spent fuel the Trust sought to store.)

In addition to promoting security goals such as disposition of excess plutonium, NPT advocates assert that the Trust would provide net environmental benefits, because the project would generate revenues for environmental cleanup that would far outweigh any hazards posed by 10,000 tons of spent fuel in dry casks. (Russian and international environmental groups remain fiercely opposed to the concept, however.) Project advocates have endeavored to convince Russian officials that NPT is the only approach likely to win U.S. government approval, since such approval would require a commitment not to reprocess the fuel, and would likely also require that the proposal have substantial disarmament and nonproliferation benefits. NPT''s officers and board include a number of senior Reagan-era U.S. government officials, including William Webster (former Director of both the CIA and the FBI), Admiral Daniel Murphy (former commander of the Pacific Fleet and chief of staff to then-Vice President George Bush), and William van Raab, former director of the U.S. Customs Service. Thomas B. Cochran of the Natural Resources Defense Council (NRDC), a U.S.-based environmental group, has also played a key role in shaping and promoting the project.

While NPT can point to a number of statements from senior Russian officials supporting additional work on their concept (including Deputy Prime Minister Ilya Klebanov), it appears unlikely that Russia would ultimately agree to an approach in which a U.S. entity controlled all of the money earned from such imports. The U.S. government has not yet taken a firm public position on NPT or other Russia-based international storage and disposal approaches. A number of U.S. officials have privately expressed support for approaches such as NPT''s that could provide new revenues to finance disarmament and nonproliferation projects, while expressing concern over relying too heavily on the success of such a private entity for projects that are critical to U.S. security objectives.

Table 1 compares expected revenues and allocations for the NPT proposal and MINATOM''s concept. It is interesting to note that the MINATOM plan assigns nothing at all from these revenues to development of a repository for eventually disposing of spent fuel or repository wastes, while the NPT plan assigns only $2.3 billion to these purposes - probably enough for the net additional cost of disposal of the spent fuel, but far less than the likely cost of actually developing and operating a Russian repository. If full repository costs were included, the profits from the import operation would shrink dramatically, or perhaps disappear.

Table 1: Proposed Revenue Allocations: MINATOM and NPT Approaches

In addition to these competing visions for Russian input of spent fuel generated entirely abroad, MINATOM is also pursuing a complementary fuel leasing concept, drawing on recent proposals by German and British firms to fabricate excess Russian weapons plutonium and uranium into reactor fuel in Russia; lease the fuel to reactor operators in Europe and Asia; and take back the spent fuel to Russia. These initiatives sought to put disposition of excess weapons material on a sustainable commercial footing while generating substantial profits for both MINATOM and Western partners. In the year 2000, MINATOM officials began to speak publicly in favor of such a leasing concept to finance plutonium disposition, and a senior official was appointed to attempt to negotiate such an arrangement.

CRITERIA FOR U.S. APPROVAL

A very large fraction of the spent fuel held by utilities most likely to be interested in Russia''s offer is subject to U.S. obligations: it was mined in the United States, enriched in the United States, fabricated in the United States, or irradiated in a U.S.-origin reactor, giving the United States consent rights over where it is shipped. U.S. approval is therefore crucial to the success of any large-scale Russian spent fuel import plan.

A number of requirements will have to be met for the United States to give its consent for shipment of spent fuel to Russia. First, under the Atomic Energy Act, the United States and Russia would have to negotiate an agreement for cooperation covering the transfer of the U.S.-obligated spent fuel. For years, the United States has refused to negotiate an agreement for cooperation with Russia because of its continued cooperation with Iran on sensitive nuclear technologies.[4] It would be difficult for the United States to shift on this point, as it forced both China and Ukraine to back away from their lucrative nuclear cooperation programs with Iran in order to get agreements for cooperation with the United States. While Russia has agreed not to carry out some particularly sensitive elements of its cooperation with Iran (such as the transfer of a laser isotope separation system) it has showed no willingness to end the larger components of the program, and indeed has announced that it is ready to sign a contract for construction of a second reactor at Bushehr whenever Iran is ready to sign. With neither Russia nor the United States inclined to change its position, Iran looms large as an obstacle to negotiating a U.S.-Russian agreement that would allow Russian import of U.S.-obligated spent fuel. U.S. officials hope, however, that the billions of dollars associated with spent fuel import will be enough to convince Russia to bargain away its less-lucrative nuclear trade with Iran.
Even if the United States and Russia reach agreement on the Iran issue, under the Atomic Energy Act, the United States will have to insist on a number of other points in any U.S.-Russian agreement on transferring U.S.-obligated spent fuel:

• No reprocessing without U.S. consent. The agreement will have to give the United States veto power in perpetuity over any reprocessing of U.S.-obligated spent fuel after it arrived in Russia - and the Bush State Department has already indicated that the United States will seek to block any reprocessing (though the Cheney energy policy statement suggests that new, more proliferation-resistant reprocessing technologies might gain U.S. support). Moreover, there will certainly be some who will advocate seeking to ensure that the arrangement did not contribute to reprocessing of other fuel not covered by U.S. obligations (for example, by providing financing for construction of reprocessing facilities, which is precisely what MINATOM plans to do with a substantial fraction of the revenue).
  
• No military use. U.S. law requires that agreements for cooperation include guarantees that the U.S.-obligated material will never be used for nuclear weapons or any other military purpose.
  
• Safety and security. The Atomic Energy Act requires that agreements for cooperation include guarantees that adequate physical protection will be maintained on any U.S.-obligated material that is transferred. Given long-standing concerns over security of nuclear materials in Russia, arranging measures to provide this assurance will take some negotiation - though spent fuel in dry casks is typically not a major security issue. At the same time, the United States will need to be assured that U.S.-obligated material will be handled safely. In principle, given the well-demonstrated safety of storage of spent fuel in appropriately designed and manufactured dry casks, it should be possible to reach arrangements that can guarantee the safety of the material for decades - though Russia''s past record of nuclear waste mismanagement, its decaying and accident-prone road and railroad infrastructure, and the weakness of independent regulation all raise significant issues. Tough negotiations will likely be required to ensure that the operation is managed and regulated in a way that meets Western safety standards. Safety of the material in the long term is also potentially a difficult issue, given the very modest progress toward establishing a geologic repository in Russia, and the lack of sufficient money to build such a repository in either the MINATOM or NPT proposals. Moreover, to give its approval for such a project, the United States will also want to have confidence in the government and industrial entities that will manage both the fuel itself and the revenues generated from it - a potentially troubling issue given U.S. concerns over widespread Russian corruption and MINATOM''s behavior in a variety of other areas, and the lack of large-scale industrial experience of some entities proposing to participate in such efforts.
  
• Transparency and safeguards. Since Russia is a nuclear weapon state, U.S. law does not require that Russia maintain IAEA safeguards on U.S.-obligated material transferred to Russia. As a matter of policy, however, the United States is very likely to want to ensure some level of international transparency over the material, and may seek Russian agreement to have IAEA safeguards over it. Customer states or other states with consent rights over some material may wish the facility storing the material to be under IAEA safeguards as well. It is at least possible that this would require Russia to negotiate a new safeguards agreement with the IAEA, as the existing voluntary offer agreement would not be adequate to maintain safeguards over material in perpetuity, as they would be in a non-nuclear-weapon state.
  
• No transfers of nuclear weapons-related technologies or reprocessing technology. The Atomic Energy Act forbids the United States to enter into agreements for cooperation with any state that has "assisted, encouraged or induced any non-nuclear weapon state to engage in activities involving source or special nuclear material and having direct significance for the manufacture or acquisition of nuclear explosive devices," unless the President judges that the state has taken adequate steps toward ending this assistance or encouragement. Similarly, cooperation with any state that has entered into an agreement "for the transfer of reprocessing equipment, materials or technology to the sovereign control of a non-nuclear weapon state" is prohibited unless the transfer was pursuant to an international fuel cycle evaluation or agreement to which the United States was a party. These provisions may be waived if the President determines that not carrying out the cooperation envisioned would be seriously prejudicial to U.S. nonproliferation objectives. The U.S. government would have to consider whether Russian transfers to Iran bring this section of U.S. law into play.
  
• No impacts "inimical to the common defense and security" - control of the funds. U.S. law requires that before allowing the transfer of U.S. obligated material, the government determine that the transfer would not be inimical to the common defense and security. This raises the issue of whether revenue from importing spent fuel would be used to support the Russian nuclear weapons program, including potential development of responses to planned U.S. national missile defenses - an outcome many U.S. critics would identify as being inimical to the defense interests of the United States. At the same time, if billions of dollars of revenue are to result from an activity that can only go forward with U.S. approval, U.S. policymakers may feel it is incumbent on them to put in place institutional mechanisms to ensure that sufficient revenue is provided for safe and secure management of the spent fuel in both the near term and the long term, rather than being lost to corruption and theft or spent on other governmental purposes. And the United States would like to see a substantial portion of whatever excess revenue there may be devoted to activities that serve U.S. interests, such as improving security for nuclear material and reducing excess weapons plutonium stockpiles. Thus, it appears inevitable that one important and difficult part of the U.S.-Russian negotiation over possible import of U.S.-obligated spent fuel will focus on U.S. efforts to control how the revenue is spent, and Russian efforts to avoid such U.S. control.
  
  There are also a number of daunting policy issues U.S. policymakers will have to face in considering whether to give approval to Russian imports of U.S.-obligated spent fuel that are not covered under the Atomic Energy Act. A key issue is what attitude to take toward a project that has been approved by the Russian people''s elected representatives, but is overwhelmingly opposed by the Russian people themselves. U.S. approval for the project in the face of such intense public opposition, with the Russian government refusing to submit the matter to the will of the people in a referendum, would raise deeply troubling questions about the genuineness of U.S. support for Russia''s transition to democracy. On the other hand, the United States may not be in a good position to withhold its approval until Russia agrees to allow the affected public to have its say in approving the project, given that the United States itself is moving forward with Yucca Mountain over the state of Nevada''s stringent objections.

Another basic issue is Russia''s credibility as a safe destination for thousands of tons of spent fuel and a reliable manager of billions of dollars needed for that fuel''s safe management. Russia currently is far from an ideal location to host a storage site or repository for spent fuel and nuclear waste. Russia has an ongoing legacy of severe mismanagement of nuclear waste that has led to the world''s worst nuclear contamination; a crumbling rail infrastructure prone to accidents; a weak nuclear regulatory agency under constant attack, which has fiercely opposed the spent fuel import plan; an investment climate ill-suited to long-term projects; rampant and deep-rooted corruption; and a continuing high level of political, social, and economic instability. (President Putin himself has warned that if his reforms are not successful, Russia may not survive as a unified state.) The only reasons to consider Russia are (a) Russia is the only major country which is currently willing to serve as a host for such a facility, and (b) Russian sites may offer the opportunity to raise a substantial non-government revenue stream for addressing nonproliferation, arms reduction, and cleanup needs problems in Russia. In principle, however, one could imagine arrangements - if they can be negotiated - that would provide sufficient Western involvement, independent oversight, and transparency to ensure that the operation is managed safely and funds spent appropriately. And it should be remembered, that if the concern is Russia''s long-term stability, 10,000 tons or even 20,000 tons of imported spent fuel in dry casks would be a modest issue compared to thousands of nuclear weapons, hundreds of tons of weapons material, and thousands of nuclear weapons experts.

Both the United States and Russia are likely to agree to enter into negotiations of an agreement for cooperation. Russia wants to start talks as it sees such a deal as the key to unlocking billions of dollars in profit, while the United States sees it as potentially the key to addressing Russia''s nuclear cooperation with Iran. But negotiating an agreement for cooperation that would allow Russia to import U.S.-obligated spent fuel will inevitably be controversial. Any such agreement will have to pass muster with the U.S. Congress, which under U.S. law has the authority to block all agreements for cooperation (though it has never done so). Many U.S. groups, including environmentalists and critics of bilateral cooperation with Russia, will seize on any weaknesses related to the above points that an eventual negotiated agreement may have to try to block it in Congress. While the United States will have substantial leverage in such a negotiation, neither Russia nor the United States can expect to get everything it wants. The Bush administration will have to carefully consider where to spend the U.S. leverage - whether, for example, to put more emphasis on seeking Russian acceptance of exactly the U.S.-desired approach on Iran, or on a greater degree of control or transparency over the revenues. Complex decisions on these points must be made soon.

To summarize, U.S.-obligated spent fuel is crucial to the success of an international site in Russia, and is unlikely to go to Russia unless: (a) there is a resolution of the Iran nuclear cooperation issue; (b) basic criteria such as ensuring safety, security, and the credibility of the key participants are met; (c) there is agreement that there would be no reprocessing of the fuel without U.S. consent; (d) there is agreement on safeguards or transparency arrangements acceptable to both sides; (e) there is a meeting of minds over control over the revenues from the project; and (f) the project provides sufficient benefits to U.S. security to convince the Bush Administration to go ahead and negotiate the agreement, and to allow it to sell the agreement to Congress. These criteria will not be easy to meet. Issues related to Russian democracy and stability will also have to be addressed.

CONCLUSIONS

There are many reasons to be concerned about Russia''s proposal to import foreign spent fuel, from safety to corruption to the opposition of the Russian people. In principle, however, if appropriate arrangements are put in place as a result of negotiations between Russia, the customer states, and the United States, it should be possible to ensure that the spent fuel is handled safely and money managed appropriately. Such arrangements, however, might still not address the deep-rooted Russian public opposition to the plan.

At the same time, there are strong reasons to support such an effort, if appropriate arrangements for safe management and financial accountability can be put in place. From a nonproliferation perspective, this spent fuel import negotiation may be the only leverage the United States has which is big enough to lead to a satisfactory deal on Russia''s nuclear cooperation with Iran. And it may be the only plausible source for the billions of dollars needed to address the proliferation, arms reduction, and cleanup issues posed by the Soviet Union''s nuclear legacy.

The Bush administration will need to make some tough decisions - and soon - on what approach to take in the inevitable U.S.-Russian negotiations over import of U.S.-obligated spent fuel. U.S. leverage in these talks will be substantial, but not infinite, and the administration will have to decide how much of it to spend on Iran, how much on control of the money, how much on reprocessing, and so on down the line.

NOTES
[1] For an extensive discussion of this history, and the various advantages and disadvantages of international sites for storage or disposal of spent fuel and nuclear wastes, see Matthew Bunn, John P. Holdren, Allison Macfarlane, Susan E. Pickett, Atsuyuki Suzuki, Tatsujiro Suzuki, and Jennifer Weeks. Interim Storage of Spent Nuclear Fuel: A Safe, Flexible, and Cost-Effective Approach to Spent Fuel Management (Cambridge, MA: Managing the Atom Project, Harvard University, and Project on Sociotechnics of Nuclear Energy, University of Tokyo, June 2001, available at http://ksgnotes1.harvard.edu/BCSIA/Library.nsf/pubs/spentfuel), Chapter 4. This paper is based on this report.

[2] First Deputy Minister of Atomic Energy Valentin B. Ivanov, Technical-Economic Basis for the Law of the Russian Federation: "On the Proposed Amendment to Article 50 of the Law of the RSFSR `On Environmental Protection''" (Moscow, Russia: Ministry of Atomic Energy, 1999, leaked and translated by Greenpeace International).

[3] The Nonproliferation Trust proposal is described in Joseph Egan, The Nonproliferation Trust Project: Frequently Asked Questions (Washington DC: Nonproliferation Trust, 2000), and on their website, http://www.nptinternational.com.

[4] At a minimum, the United States wants a clear commitment not to supply any reprocessing or enrichment technologies. The Clinton Administration sought, further, to cut off all nuclear cooperation with Iran; whether the Bush Administration will be willing to agree to a deal even if Russia and Iran proceed with the completion of the first light-water reactor unit at Bushehr remains to be seen. The Clinton Administration''s view was not so much that a light-water reactor is a proliferation hazard in itself, but that it may provide cover for other cooperation. As one official put it: "We were and still are opposed to this [Bushehr] reactor, not because we believe such a light-water power reactor under International Atomic Energy Agency Safeguards itself poses a serious proliferation threat, but because of our concern that the Bushehr project would be used by Iran as a cover for maintaining wide-ranging contacts with Russian nuclear entities and for engaging in more sensitive forms of cooperation with more direct applicability to a nuclear weapons program." John Barker, Deputy Assistant Secretary of State for Nonproliferation Controls, testimony to the Senate Foreign Relations Committee, October 25, 2000.