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“For half a century, ACA has been providing the world … with advocacy, analysis, and awareness on some of the most critical topics of international peace and security, including on how to achieve our common, shared goal of a world free of nuclear weapons.”

– Izumi Nakamitsu
UN High Representative for Disarmament Affairs
June 2, 2022
Time for Leadership: South Korea and Nuclear Nonproliferation
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Chen Kane, Stephanie C. Lieggi, and Miles A. Pomper

South Korea recently has emerged as a significant nuclear exporter. In December 2009, a South Korean-led consortium won a $20 billion deal to export four nuclear reactors to the United Arab Emirates (UAE).[1] South Korea has been in the running for other nuclear reactor deals as well, including with Lithuania and Turkey, and may find itself with the opportunity to operate Jordan’s planned power reactors. Buoyed by these achievements,Seoul is aiming to capture 20 percent of the world market for nuclear reactors by 2030.[2]

All of a sudden, the countries that have long dominated nuclear sales—CanadaFranceJapanRussia, and theUnited States—have had to reckon with a serious new competitor.

Seoul’s growth as a nuclear exporter is not simply a tale for the business pages. How it carries out its new role matters because nuclear power is like no other industry; its chief materials and technologies can be used to make the world’s deadliest weapons. The United States and countries in the region—China, Japan, and North Korea in particular—follow events in South Korea carefully and try to shape its nuclear development. Moreover, nuclear technology is of specific concern when it is sold to volatile regions such as the Middle East—South Korea’s key export market.

Additional nonproliferation-related concerns, particularly in Washington, come from South Korea’s efforts to develop pyroprocessing, a spent fuel treatment process that Seoul believes it needs in order to manage the increasing amount of nuclear waste coming from its reactors. South Korean officials assure the international community that pyroprocessing is not the same as traditional reprocessing and entails few proliferation risks. Many outside experts and policymakers, however, are concerned that the process would be difficult to safeguard and could allow diversion of sensitive nuclear materials.

In the past, South Korea has been a sometimes-reluctant follower and occasional violator of international nuclear nonproliferation norms and rules. More recently, Seoul has taken steps to upgrade its nonproliferation credentials and comply with relevant nonproliferation obligations. Still, if South Korea is to meet its goals as a nuclear exporter and successfully conclude a new nuclear cooperation agreement with the United States, it will have to become a leader, rather than a follower, of the international nuclear nonproliferation regime.

Mixed Nonproliferation Record

In 1968, South Korea signed the nuclear Nonproliferation Treaty (NPT), but concerns about its security environment in the 1970s led Seoul to consider a military nuclear option. In the early 1970s, South Korean President Park Chung-hee made the acquisition of a reprocessing capability to separate plutonium for nuclear weapons a top priority. After the United States threatened to withdraw its security guarantees if Seoul did not halt its weapons development plans, South Korea ratified the NPT in 1975 and adopted an International Atomic Energy Agency (IAEA) safeguards agreement.[3]

The announcement by President Jimmy Carter in the late 1970s that the United States intended to withdraw all ground troops from the Korean peninsula revived Park’s interest in a nuclear weapons option. Seoul renewed its efforts to acquire a reprocessing capability from France, an effort thwarted by Carter’s personal intervention and his nearly simultaneous decision not to withdraw U.S. forces from the peninsula.[4]

Soon after the Cold War ended, Seoul and Pyongyang in 1992 signed the “Joint Declaration of South and North Korea on the Denuclearization of the KoreanPeninsula,” whereby both Koreas agreed not to “possess nuclear reprocessing and uranium enrichment facilities.”[5] The two sides also declared they “would not test, manufacture, produce, receive, possess, store, deploy or use nuclear weapons.” It is widely agreed that North Korea’s nuclear activities during the past decade, particularly its enrichment and reprocessing programs and nuclear tests, have been in clear violation of the 1992 agreement. Despite this, South Korea has never abandoned the joint declaration officially and has called on Pyongyang to abide by the pact, despite occasional suggestions in South Korean elite circles that Seoul should renounce the agreement.

South Korea’s additional protocol to its IAEA safeguards agreement entered into force in February 2004.[6] The additional protocol provides IAEA inspectors greater access to a country’s nuclear facilities, materials, and records, particularly undeclared facilities. When South Korea submitted its initial declaration, however, it disclosed to the IAEA a series of previously undeclared laboratory-scale experiments conducted by scientists at the Korea Atomic Energy Research Institute (KAERI).

The resulting IAEA investigations revealed that South Korean scientists had engaged in experiments related to uranium enrichment and conversion and plutonium separation.[7] Although the experiments produced very small quantities of nuclear material and did not appear to have been part of an organized nuclear weapons effort, the activities involved technical skills that would be applicable in a weapons program. IAEA Director-General Mohamed ElBaradei determined that the undeclared use of nuclear material in the experiments constituted a matter of serious concern.[8] According to the IAEA, South Korea informed the agency that the “experiments were performed without the knowledge or authorization of the government” and were “conducted solely to satisfy the scientific interest of the scientists involved.”[9] In May 2008, the IAEA concluded that it “considers all past undeclared activities involving uranium enrichment…conversion, and plutonium separation experiments as resolved.”[10]

Since then, Seoul has implemented several institutional reforms and educational programs aimed at strengthening its oversight of the activities taking place in its nuclear research facilities.[11] These past activities, however, have made it even more difficult for South Korea to gain support for acquiring dual-use technologies, such as those for uranium enrichment or spent fuel reprocessing, which could be used to produce nuclear weapons as well as nuclear energy.

Enrichment and Reprocessing

As South Korea has emerged as a nuclear exporter (see sidebar), its officials privately have voiced increasing interest in acquiring enrichment and reprocessing technology, in part to be able to provide potential customers with the full range of services for fueling their reactors and disposing of the spent fuel as many of its competitors already do.[12] South Korea’s civil nuclear objectives currently include attaining full self-sufficiency, which appears to include some increased capacity with regard to the nuclear fuel cycle.[13]

To be sure, South Korea’s interest in pyroprocessing primarily results from the country’s failure to solve its domestic spent-fuel management crisis. South Korea is far from alone in its failure to find a permanent site at which to dispose of its spent fuel, but the failure to win domestic political support for additional interim storage sites has led to an imminent crisis. Only a few years from now, South Korean scientists predict, the spent fuel pools at South Korea’s nuclear plants will begin to reach capacity.[14] South Korea has explored pyroprocessing as a potential long-term technical solution to this problem, although officials acknowledge that other measures such as interim storage would be needed for some time.[15]

Pyroprocessing treats spent fuel to remove its extremely radioactive but relatively short-lived beta-emitter constituents, such as strontium, cesium, and iodine, and leaves behind unused uranium and the extremely long-lived transuranic alpha-emitters plutonium, americium, and neptunium. South Korea plans to irradiate these latter materials in yet-to-be-designed fast-burner reactors, ultimately reducing the overall quantity of waste requiring permanent disposal. Some in South Korea, particularly those in the Ministry of Education, Science, and Technology and in KAERI, which is part of the ministry, see this as particularly advantageous because South Korea’s high population density makes it difficult to find sufficient space for a single, large, permanent underground repository for nuclear waste.

Although other elements within the South Korean government may not be convinced of the wisdom of this approach, Seoul has reached a consensus that the option of moving forward with this technology should be preserved in negotiations with the United States on a new bilateral nuclear cooperation agreement. The old agreement, set to expire in 2014, prevents South Korea from carrying out any “alteration in form and content,” such as traditional reprocessing, pyroprocessing, or enrichment, of U.S.-origin fuel without Washington’s permission. Seoul is hoping to relax some of Washington’s long-standing restrictions on the processing of spent fuel. The U.S. government has yet to give its blessing because it is worried that the process or its output could be too easily altered to produce a less benign product, that it will be too difficult to implement safeguards aimed to prevent such changes, and that any relaxation of U.S. rules would harm Washington’s broader global and regional nonproliferation efforts.

In particular, U.S. officials are concerned about how South Korean pyroprocessing would affect the 1992 denuclearization pact. Many in Washington fear that if South Korea were to break with the agreement openly by constructing its own reprocessing facilities, that action might provide a pretext for North Korea to claim its behavior was no more illegitimate than that of its southern neighbor. In addition, China and Japan see the denuclearization agreement as a cornerstone of the six-party talks, and U.S. officials will not want to provoke a rupture with Beijingor Tokyo.

South Korean officials seek to sidestep this problem by differentiating pyroprocessing from standard reprocessing, claiming, contrary to the opinion of many U.S. experts, including U.S government officials and those at U.S. national laboratories, that pyroprocessing is substantially more proliferation resistant.[16] Traditional reprocessing uses liquid solvents and ultimately separates pure plutonium, a weapons-usable material. Pyroprocessing leaves the plutonium mixed with other transuranic elements, such as americium and neptunium.

The United States and South Korea recently agreed to sign a memorandum of understanding to conduct a 10-year joint feasibility study on ways of handling spent nuclear fuel, including pyroprocessing. The study will be conducted in parallel with negotiations on the other issues related to the nuclear cooperation agreement. If the sides are not able to reach an understanding on pyroprocessing by 2014, when the current cooperation agreement expires, the two sides will have to agree whether and how to address the issue of pyroprocessing in the agreement.[17]

South Korean officials have talked privately and with increasing frequency of the need to build their own facilities to enrich uranium. To date, South Korea has relied on importing enriched uranium from Europe and the United Statesand then fabricating the fuel domestically. Yet, South Korea’s domestic market alone, which currently includes 21 nuclear power reactors (see sidebar), has approached the point at which it could make economic sense for South Korea to enrich the fuel itself. As that market grows and new overseas sales opportunities beckon, the lure of building enrichment facilities is likely to grow. This interest comes as the United States, in its bilateral nuclear cooperation agreements and in international venues such as the Nuclear Suppliers Group (NSG) and the IAEA, continues to try to limit the spread of enrichment facilities.

Seoul’s Nonproliferation Role

Given Seoul’s mixed nonproliferation record and the 1992 denuclearization agreement that disallows enrichment or reprocessing technology on the Korean peninsula, the United States and key regional states such as Japan and China are concerned about South Korea launching programs that involve such technologies. They fret that because of South Korea’s other capabilities, such as in missile technology, the possession of such technologies could bring the country within a few months of being able to build a nuclear weapon. They also worry that South Korea’s action might make it even more difficult to convince North Korea to return to the terms of the 1992 denuclearization agreement. South Korean officials counter that the United States and China long have had this concern aboutJapan’s extensive reprocessing program as well, but that the United States has granted Japan permission to reprocess U.S.-origin fuel. In contrast to South Korea, however, Japan developed its reprocessing program before U.S. views on reprocessing changed in the mid-1970s following India’s test of a “peaceful nuclear explosive,” which used plutonium from reprocessed spent fuel. Also, Tokyo did not agree to restrictions such as those included in the Korean denuclearization agreement and has no known violations of its IAEA safeguards agreement.

South Korea’s rise as a nuclear exporter has made its policies on these issues not only a regional but also a global concern. Nevertheless, Seoul has hesitated to take a leading role in global nonproliferation efforts. Notably, it has been quiet about efforts by some NSG members, particularly the United States, to increase restrictions on the trade of enrichment and reprocessing technology.[18] Moreover, unlike Japan (explicitly) and the United States (de facto), South Korea has not made adoption of an IAEA additional protocol a condition for supplying nuclear technology. JordanTurkey, and the UAE had agreed to abide by this protocol long before negotiating withSouth Korea, but other potential South Korean customers have not. South Korean officials have said they will support this requirement if the NSG endorses it, but not beforehand.[19]

Also, Seoul has been slow to cooperate with recent international efforts aimed against Iran’s nuclear program. This hesitation is based on economic interests: Tehran is an important trading partner for Seoul, and South Korea gets about 10 percent of its oil from Iran.[20] In September 2010, under U.S. pressure, South Korea announced new national sanctions on Iran. These measures included placing 102 Iranian firms and 24 people on a list “banning financial transactions without central bank approval,” more thoroughly inspecting cargo from Iran, and curbing South Korean investment in Iranian oil and gas enterprises.[21] South Korea also temporarily closed the Seoul branch of Bank Mellat, which is the Iranian bank’s only office in East Asia.[22] This bank is reported to have been involved with about 70 percent of all South Korean-Iranian transactions.[23] The Seoul branch also was suspected of being used to transfer payments for Iranian-North Korean weapons transactions.[24] Washington had been pressuring Seoul to close the Bank Mellat branch permanently, but the branch was reopened in December 2010, signifying that Seoul is still concerned about alienating a major trading partner. That same month, a South Korean company, DK Tech Corp., signed a $750 million agreement with Iran to develop two phases of the giant South Pars natural gas field. The deal was signed six months after another South Korean company withdrew from the project due to “mounting pressures of some [W]estern powers” related to the sanctions against Iran’s nuclear program.[25]

Despite its reluctance to impose sanctions on IranSeoul recently has taken some very public strides toward playing a greater leadership role in global nonproliferation efforts. After hesitating for many years, Seoul agreed in 2009 to join the Proliferation Security Initiative (PSI). The apprehension of earlier South Korean governments about the PSI was largely based on concerns that North Korea would see South Korean participation as a hostile move. The election of the more conservative Lee Myung-bak and the second North Korean nuclear test, in 2009, resulted in Seoul’s decision to become an active participant in the U.S.-led initiative. In fact, in November 2010,South Korea became the 21st member of the PSI Operational Experts Group, the guiding policymaking and operational body for the initiative.[26]

Additionally, at the April 2010 nuclear security summit in Washington—a gathering of global leaders intended to carry out President Barack Obama’s goal of securing all vulnerable materials, particularly highly enriched uranium and plutonium, from terrorists in four years—Seoul offered to host the next such summit in 2012.[27] In June 2010, South Korea agreed to host the next plenary meeting of the Global Initiative to Combat Nuclear Terrorism.[28] Since May 2007, Seoul has been an active member of that initiative, which focuses on law enforcement intelligence gathering to strengthen global capacity to prevent, detect, and respond to nuclear terrorism.[29]

Officials tout the value of South Korea’s experience as a country that developed a strong nuclear energy program without developing nuclear weapons as a model for nuclear novices in the developing world. Already the South Korean government has several programs aimed at exporting this model to other countries. KAERI provides training to new nuclear states in how to operate and manage nuclear technology, while other entities within the Korean nuclear establishment, such as the Korea Institute of Nuclear Safety and Korea Hydro and Nuclear Power Company, provide training for foreigners as well as Korean workers in safety, operation, and management aspects of nuclear facilities. At the nuclear security summit, South Korea pledged to build a nuclear security training facility that will serve as a simulation center.

Conclusion

South Korea should be congratulated for its recent nonproliferation initiatives, which show a welcome recognition that its new role as a global nuclear exporter comes with new global responsibilities for preventing nuclear weapons proliferation. However, if South Korea is serious about its goal of becoming one of the world’s top nuclear exporters, it also will have to become more serious about nonproliferation. In particular, it will have to change from being, at best, a follower of international nonproliferation norms to a leader in forging new ones. That will mean that Seoul will have to be willing at times to sacrifice potential business or take on strong domestic political constituencies, whether protesters or industry, in order to advance global nonproliferation goals by imposing sanctions on nonproliferation rogues, forgoing pyroprocessing, taking a more active role in supporting NSG efforts to restrict the spread of enrichment and reprocessing technologies, or requiring that potential customers have concluded an additional protocol to their IAEA safeguards agreements.

South Korea’s hosting of the 2012 nuclear security summit and its difficulties in dealing with spent fuel offer two particular opportunities to exercise leadership. If Seoul agrees to a cautious agenda for the 2012 meeting, it will be sacrificing a chance to make its own mark. South Korean officials should consider proposing a bold initiative of some type, such as seeking to conclude an agreement to phase out highly enriched uranium (HEU) in the civilian sector. At a time when U.S. funding for this effort faces cuts, South Korea should provide funding to help bring this about and urge other countries whose economies are faring reasonably well to follow suit.

Although South Korea’s research reactors now rely only on low-enriched uranium, which is not suitable for nuclear weapons, research reactors in other countries still use enough HEU every year to make as many as 30 nuclear weapons.[30] Because reprocessing raises nonproliferation concerns, Seoul should consider multilateral alternatives to its national effort to pyroprocess spent fuel. Such an effort would allow South Korea to address its spent fuel problems without undermining U.S. and global efforts to minimize the spread of enrichment and reprocessing technologies.[31]

Seoul could take the lead in establishing a new regional forum for more consistently and openly discussing possible options for dealing with regional spent-fuel stockpiles. Numerous emerging Asian economies, such asIndonesia and Vietnam, are contemplating nuclear power development, and many regional players are facing similar spent-fuel challenges. Although some of these states’ nuclear authorities are proposing similar solutions, there is little regional discussion or coordination of such issues. Sharing of best practices and lessons learned would be beneficial.

South Korea’s rise as a nuclear exporter is good news for the country’s nuclear industry and workers. Should Seoulembrace more nonproliferation responsibilities, it will be good news for South Korean and global security as well.

Seoul’s Nuclear Energy Outlook

Today, South Korea boasts the world’s fifth-largest nuclear reactor fleet. The country utilizes 21 nuclear power reactors providing 40 percent of the nation’s electricity supply. According to its 2008 National Energy Basic Plan, South Korea plans to increase the share of nuclear energy in its domestic electricity generation to 59 percent by 2030 by building roughly 14 more nuclear reactors.[1] The South Korean government set this goal in part to combat rising carbon emissions; South Korea posted the world’s largest increase in greenhouse gas emissions per capita during the last two decades.[2]

South Korea has been playing a growing role in the international nuclear market. Under a contract with the United Arab Emirates (UAE), the UAE will pay $20.4 billion for construction of four 1,400-megawatt reactors by 2020. Following the UAE deal, South Korea announced its objective to export 80 nuclear reactors by 2030.[3] It has been targeting contracts in India, Indonesia, Lithuania, Malaysia, the Netherlands, Saudi Arabia, South Africa, Thailand, Turkey, Vietnam, and others.[4] South Korea wants to expand in the long term into bigger markets such as China and United States, and Korean firms involved in export, such as Korea Hydro and Nuclear Power Company, are looking to export expertise to Europe, Southeast Asia, and the Middle East.[5]

Although South Korea’s plans are extensive, a number of factors may slow its export growth. For instance, South Korean nuclear consortia are at a disadvantage in comparison to established exporters from other countries in financing projects. Although it did loan the UAE $10 billion to construct its nuclear reactors,[6] South Korea has tended to avoid riskier deals that require the exporter to front the costs of constructing the reactor and to recover the investment from the long-term sale of electricity from the reactors. This limitation already had led South Korea to pull out of a reactor deal with Jordan, and it appears to be harming its current bid to construct reactors in Turkey.[7] —CHEN KANE, STEPHANIE C. LIEGGI, and MILES A. POMPER

ENDNOTES

1. Ministry of Knowledge Economy [South Korea], “National Energy Basic Plan, 2008,” August 28, 2008.

2. Kevin A. Baumert et al., Navigating the Numbers: Greenhouse Gas Data and International Climate Policy (WashingtonDC: World Resources Institute, 2005), http://pdf.wri.org/navigating_numbers.pdf; Moon Hee-chang, statement at KAERI, Daejeon, July 21, 2010.

3. Cho Chung-un, “Korea Aims to Be No. 3 in Nuclear Power Sector,” Korea Herald, January 14, 2010, www.koreaherald.com/national/Detail.jsp?newsMLId=20100114000059.

4. “South Korea Seeks to Boost Reactor Exports,” World Nuclear News, January 13, 2010, www.world-nuclear-news.org/NP-South_Korea_seeks_to_boost_reactor_exports-1301104.html; Lee Eun-joo, “For Nuke Plants, Korea Now Targets Lithuania,” Korea JoongAng Daily, November 18, 2010, http://joongangdaily.joins.com/article/view.asp?aid=2928547.

5. “Korea Needs Foreign Nuclear Partners,” Korea JoongAng Daily, June 24, 2010, http://joongangdaily.joins.com/article/view.asp?aid=2922226; “KHNP Foremost in Nuclear Plant Operation,” Korea Herald, March 25, 2010, www.koreaherald.com/specialreport/Detail.jsp?newsMLId=20100325000840.

6. Seoul’s loan has generated controversy in South Korea because of its belated revelation and what some saw as its overly generous terms. See Lee Soon-hyuk, “S. Korea Found to Loan $10B for UAE Power Plant,” The Hankyoreh, February 1, 2011, http://english.hani.co.kr/arti/english_edition/e_national/461703.html.

7. For more analysis on the issue of financing of South Korea’s nuclear exports, see “Keys to Winning Nuclear Bids,” Korea JoongAng Daily, December 28, 2010, http://joongangdaily.joins.com/article/view.asp?aid=2930167.

 


The authors are staff members of the JamesMartinCenter for Nonproliferation Studies at the Monterey Institute of International Studies. This article draws from their paper “Going Global: Issues Facing South Korea as an Emerging Nuclear Exporter” for the Korea Economic Institute.


ENDNOTES

1. In March 2010, South Korea signed a second reactor-supply agreement—a $130 million contract to construct a nuclear research reactor at the Jordan University of Science and Technology. The reactor is to be constructed by the Korea Atomic Energy Research Institute (KAERI) and the South Korean industrial conglomerate Daewoo. The five-megawatt reactor, upgradable to 10 megawatts, is a smaller version of KAERI’s HANARO research reactor.South Korea agreed to finance most of the project, with Seoul initially providing a $70 million soft loan. Some countries, such as Argentina, that export research reactors, however, do not export the far more lucrative power reactors.

2. “South Korea Seeks to Boost Reactor Exports,” World Nuclear News, January 13, 2010, www.world-nuclear-news.org/NP-South_Korea_seeks_to_boost_reactor_exports-1301104.html/.

3. Fred McGoldrick, “The Peaceful Nuclear Program of the Republic of Korea and Global Nonproliferation Considerations” (paper prepared for “CEIP-KAERI-IPC Joint Seminar on ROK-U.S. Nuclear Cooperation in the 21st Century,” WashingtonDC, July 14, 2008).

4. Ibid.; Kim Seung-young, “Security, Nationalism, and the Pursuit of Nuclear Weapons and Missiles: South Korean Case, 1970–82,” Diplomacy and Statecraft, Vol. 12, No. 4 (December 2001); “Official Hints South Korea Might Build Atom Bomb,” New York Times, June 30, 1977.

5. “Joint Declaration of South and North Korea on the Denuclearization of the KoreanPeninsula,” www.nti.org/e_research/official_docs/inventory/pdfs/aptkoreanuc.pdf.

6. International Atomic Energy Agency (IAEA), “Protocol Additional to the Agreement of 31 October 1975 Between the Government of the Republic of Korea and the International Atomic Energy Agency for the Application of Safeguards in Connection With the Treaty on the Non-proliferation of Nuclear Weapons,” INFCIRC/236/Add.1, June 18, 2004, www.iaea.org/Publications/Documents/Infcircs/2004/infcirc236a1.pdf.

7. Daniel A. Pinkston, “South Korea’s Nuclear Experiments,” CNS Research Story, November 9, 2004, http://cns.miis.edu/stories/041109.htm; IAEA, “Implementation of the NPT Safeguards Agreement in the Republic of Korea,” GOV/2004/84, November 11, 2004, www.iaea.org/Publications/Documents/Board/2004/gov2004-84.pdf; IAEA, “Safeguards Implementation Report for 2007,” GOV/2008/14, May 7, 2008.

8. IAEA, “Implementation of the NPT Safeguards Agreement in the Republic of Korea.”

9. Ibid.

10. IAEA, “Safeguards Implementation Report for 2007.”

11. Wan Ki Yoon, “Enhanced Transparency and Its Harmonization With Safeguards” (paper presented at the Japan Atomic Energy Agency International Forum, June 25, 2008), www.jaea.go.jp/04/np/activity/2008-06-24/2008-06-24-3-4.pdf.

12. One South Korean official said that South Korea’s inability to enrich and reprocess would likely be a barrier to export growth. See Kim Ji-hyun, “Seoul Considering Options to Improve Nuke Efficiency,” Korea Herald, March 30, 2010, http://biz.heraldm.com/common/Detail.jsp?newsMLId=20090708000058. In the case of such other exporters as France and Russia, the ability to offer these services has been seen as a benefit. France supplies enriched uranium and nuclear fuel for reactors and provides reprocessing services although it sends back high-level waste, shorn of plutonium, to its customers. In some cases, such as its deal for the Bushehr reactor in Iran,Russia provides nuclear fuel or enriched uranium, takes back the spent fuel, and does not return high-level waste to the customer.

13. Choi Kyung-hwan, “Korea’s Strategy to Become Nuclear Exporter,” Korea Herald, February 23, 2010, http://blog.daum.net/ihanpeace/2193.

14. Spent fuel from South Korea’s four CANDU reactors is now in interim dry cask storage at a reactor site in Wolsong, but this facility will be full by 2017. Additional construction of any interim spent-fuel storage facilities at Wolsong is effectively prohibited by the special law established on March 31, 2005 (law no. 7444), which prohibits any construction of spent fuel-related facilities in the same region as the low- and intermediate-level radioactive-waste disposal facility. Such a facility is now under construction near the Wolsong reactors in Gyeongju. For the text of the law in Korean, see http://likms.assembly.go.kr/law/jsp/Law.jsp?WORK_TYPE=LAW_BON&LAW_ID=A1885&PROM_NO=09885&PROM_DT=20091230&HanChk=Y.

15. South Korean officials believe that many of these interim storage facilities could be located at the pyroprocessing facility, thus obviating some of the need for more politically contentious separate facilities or transshipments to other reactor sites.

16. Several recent reports from the U.S. National Nuclear Security Administration (NNSA) and national laboratories indicate that U.S. government experts do not see a substantial difference in proliferation resistance between pyroprocessing and traditional reprocessing. Office of Nonproliferation and International Security, NNSA, “Nonproliferation Impact Assessment for the Global Nuclear Energy Partnership – Draft,” December 2008, http://brc.gov/library/docs/GNEP_NPIA.pdf ; Robert A. Bari et al., “Proliferation Risk Reduction Study of Alternative Spent Fuel Processing,” BNL-90264-2009-CP, July 2009, http://brc.gov/pdfFiles/January2011_Meetings/Jan6-7mtg/Tom%20Clements%20Brookhaven%20on%20reprocessing%20risks%202009.pdf; Charles G. Bathke et al., “An Assessment of the Attractiveness of Material Associated With a MOX Fuel Cycle From a Safeguards Perspective,” LA-UR-09-03637, July 2009, http://permalink.lanl.gov/object/tr?what=info:lanl-repo/lareport/LA-UR-09-03637. Some in the U.S. government assert that a recent Nuclear Regulatory Commission (NRC) analysis provides a response to South Korean attempts to assert a legal distinction between pyroprocessing and traditional reprocessing. NRC, “Update on Reprocessing Regulatory Framework - Summary of Gap Analysis,” SECY-09-0082, May 28, 2009, www.nrc.gov/reading-rm/doc-collections/commission/secys/2009/secy2009-0082/2009-0082scy.pdf. For comments by U.S. Department of Energy official Carter “Buzz” Savage on whether pyroprocessing is a form of reprocessing, see Kyle Fishman, “IAEA South Korean Concerns Resolved,” Arms Control Today, July/August 2008; Daniel Horner, “S. Korean Pyroprocessing Awaits U.S. Decision,” Arms Control Today, July/August 2009.

17. Hwang Doo-hyong, “S. Korea, U.S. Agree to Begin Joint Study of Pyroprocessing Spent Nuke Fuel,” Yonhap News Agency, October 26, 2010, http://english.yonhapnews.co.kr/national/2010/10/26/46/0301000000AEN20101026004200315F.HTML.

18. Daniel Horner, “Accord on New Rules Eludes Nuclear Suppliers,” Arms Control Today, July/August 2009.

19. Mark Hibbs, “Nuclear Suppliers Group and the IAEA Additional Protocol,” Nuclear Energy Brief, August 18, 2010, http://carnegieendowment.org/publications/index.cfm?fa=view&id=41393.

20. Chico Harlan, “Iran Sanctions Challenge South Korea to Balance Interests,” Washington Post, August 20, 2010.

21. Bomi Lim and Eunkyung Seo, “South Korea to Ban New Oil, Gas Investments in Iran on Nuclear Program,” Bloomberg, September 8, 2010, www.bloomberg.com/news/2010-09-08/south-korea-to-ban-new-oil-gas-investments-in-iran-on-nuclear-program.html; Donald Kirk, “South Korea Sanctions Iran – Under U.S. Pressure,” Christian Science Monitor, September 8, 2010.

22. Evan Ramstad, “South Korea to Close Iranian Bank Branch,” Wall Street Journal, September 8, 2010.

23. Kirk, “South Korea Sanctions Iran – Under U.S. Pressure.”

24. “N. Korean Arms Payments ‘Passed Through Seoul,’” Chosun Ilbo, January 18, 2011, http://english.chosun.com/site/data/html_dir/2011/01/18/2011011800520.html.

25. Benoit Faucon, “South Korea’s DK Tech Signs Deal for Iran Gas Field – Filing,” Wall Street Journal, December 17, 2010; “Iran, S Korea sign $750mn Gas Deal,” Press TV, December 9, 2010.

26. “Nation Joins Leadership of US-led PSI-OEG,” KBS World, November 1, 2010, http://world.kbs.co.kr/english/news/news_Po_detail.htm?No=76829.

27. Office of the Press Secretary, The White House, “Communiqué of the Washington Nuclear Security Summit,” April 13, 2010, www.whitehouse.gov/the-press-office/communiqu-washington-nuclear-security-summit.

28. Office of the Spokesman, U.S. Department of State, “Joint Co-Chair Statement Regarding the 2010 Global Initiative to Combat Nuclear Terrorism Plenary Meeting,” June 29, 2010, www.state.gov/r/pa/prs/ps/2010/06/143754.htm.

29. See “The Global Initiative to Combat Nuclear Terrorism,” www.state.gov/t/isn/c18406.htm; Choe Kwan-kyoo, “ROK’s Contribution to Global Nuclear Nonproliferation,” Nautilus Institute, January 28, 2010, http://www.nautilus.org/projects/civil-society-verification/korea.

30. Globally, research reactors require 750 kilograms of highly enriched uranium (HEU) per year. That quantity of HEU could be used to create approximately 30 nuclear weapons, using the IAEA definition of the minimum amount of HEU needed to produce a weapon (25 kilograms). See Ole Reistad and Styrkaar Hustveit, “HEU Fuel Cycle Inventories and Progress on Global Minimization,” The Nonproliferation Review, July 2008, p. 265; “IAEA Safeguards Glossary 2001 Edition,” International Nuclear Verification Series, No. 3, www-pub.iaea.org/MTCD/publications/PDF/nvs-3-cd/PDF/NVS3_scr.pdf.

31. For more details on these alternatives, see Miles Pomper et al., “Nuclear Power and Spent Fuel in East Asia: Balancing Energy, Politics and Nonproliferation,” Asia-Pacific Journal: Japan Focus, June 2010, www.japanfocus.org/-Ferenc-Dalnoki_Veress/3376. Among the alternatives this article proposes are a spent fuel repository or interim storage outside East Asia, traditional PUREX reprocessing in France or Russia, or a multinational pyroprocessing center outside or within the region.