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MINIMIZING CIVIL HIGHLY ENRICHED URANIUM STOCKS BY 2015: A FORWARD-LOOKING ASSESSMENT OF U.S.-RUSSIAN COOPERATION

Philipp C. Bleek, Center for a New American Security and

Laura S. H. Holgate, Nuclear Threat Initiative95

INTRODUCTION

At a June 2015 summit, the U.S. and Russian presidents announce that by the end of the year, almost all highly enriched uranium (HEU) will have been removed from civil sites, the culmination of an effort launched by the two countries almost a decade earlier. Proliferation risks remain, but one key danger has been effectively eliminated.

Is this scenario a pipe dream? If the task is feasible, does it merit the effort required to realize it? And what steps need to be taken now to make this goal a reality? This paper argues that the goal of having HEU removed from civil sites, is both plausible and desirable and lays out specific actions the United States and Russia should take to realize it.

Minimizing civil HEU by 2015 is desirable.96 As concern about nuclear proliferation to both states and terrorists has grown in recent years, policymakers and non-governmental analysts have increasingly seized on the importance of preventing access to nuclear-explosive material.97

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Philipp C. Bleek is a Nonresident Fellow at the Center for a New American Security and a doctoral candidate in international relations in the Department of Government at Georgetown University. This paper was written while he was a Visiting Fellow at the Center for Strategic and International Studies (CSIS). Laura S.H. Holgate is Vice President for Russia/New Independent States Programs at the Nuclear Threat Initiative. This paper draws substantially on Bleek’s “Global Cleanout of Civil Nuclear Material: Toward a Comprehensive, Threat-Driven Response,” CSIS Strengthening the Global Partnership Issue Brief #4 (September 2005). The authors thank CSIS for permission to reproduce portions of that paper here. Finally, the authors thank the participants at the November 2007, Vienna workshop at which this paper was presented as well as informal reviewers including Pablo Adelfang, Wilhelm Bleek, Jim Fuller, and Ira Goldman, and several U.S. government officials who shared information on a not-for-attribution basis, for helpful comments and critiques.

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The authors chose to focus this paper on the goal of HEU minimization, rather than elimination, on the assumption that a compelling case could potentially be made for keeping a small number of civil facilities fueled with HEU, perhaps shared through multinational research consortia, and held to the highest security standards.

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This paper uses the term nuclear-explosive to refer to material that could be used in a fission-based explosive device, rather than the conventionally but often incorrectly used terms fissile or fissionable. Fissionable, the broadest category, includes materials that are not nuclear-explosive. More narrowly, all fissile materials are nuclear-explosive, but not all nuclear-explosive materials are fissile; for example, the even-numbered isotopes of plutonium are not fissile but are, under the correct conditions, nuclear-explosive. HEU is both fissile and nuclear-explosive. Uranium is defined as “highly enriched” or “weapons-useable” when it contains 20 percent or more of the U235 or



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MINIMIZING CIVIL HIGHLY ENRICHED URANIUM STOCKS BY 2015: A FORWARD-LOOKING ASSESSMENT OF U.S.-RUSSIAN COOPERATION Philipp C. Bleek, Center for a New American Security and Laura S. H. Holgate, Nuclear Threat Initiative95 INTRODUCTION At a June 2015 summit, the U.S. and Russian presidents announce that by the end of the year, almost all highly enriched uranium (HEU) will have been removed from civil sites, the culmination of an effort launched by the two countries almost a decade earlier. Proliferation risks remain, but one key danger has been effectively eliminated. Is this scenario a pipe dream? If the task is feasible, does it merit the effort required to realize it? And what steps need to be taken now to make this goal a reality? This paper argues that the goal of having HEU removed from civil sites, is both plausible and desirable and lays out specific actions the United States and Russia should take to realize it. Minimizing civil HEU by 2015 is desirable.96 As concern about nuclear proliferation to both states and terrorists has grown in recent years, policymakers and non-governmental analysts have increasingly seized on the importance of preventing access to nuclear-explosive material.97 95 Philipp C. Bleek is a Nonresident Fellow at the Center for a New American Security and a doctoral candidate in international relations in the Department of Government at Georgetown University. This paper was written while he was a Visiting Fellow at the Center for Strategic and International Studies (CSIS). Laura S.H. Holgate is Vice President for Russia/New Independent States Programs at the Nuclear Threat Initiative. This paper draws substantially on Bleek’s “Global Cleanout of Civil Nuclear Material: Toward a Comprehensive, Threat-Driven Response,” CSIS Strengthening the Global Partnership Issue Brief #4 (September 2005). The authors thank CSIS for permission to reproduce portions of that paper here. Finally, the authors thank the participants at the November 2007, Vienna workshop at which this paper was presented as well as informal reviewers including Pablo Adelfang, Wilhelm Bleek, Jim Fuller, and Ira Goldman, and several U.S. government officials who shared information on a not-for-attribution basis, for helpful comments and critiques. 96 The authors chose to focus this paper on the goal of HEU minimization, rather than elimination, on the assumption that a compelling case could potentially be made for keeping a small number of civil facilities fueled with HEU, perhaps shared through multinational research consortia, and held to the highest security standards. 97 This paper uses the term nuclear-explosive to refer to material that could be used in a fission-based explosive device, rather than the conventionally but often incorrectly used terms fissile or fissionable. Fissionable, the broadest category, includes materials that are not nuclear-explosive. More narrowly, all fissile materials are nuclear- explosive, but not all nuclear-explosive materials are fissile; for example, the even-numbered isotopes of plutonium are not fissile but are, under the correct conditions, nuclear-explosive. HEU is both fissile and nuclear-explosive. Uranium is defined as “highly enriched” or “weapons-useable” when it contains 20 percent or more of the U235 or 89

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Acquiring nuclear-explosive material remains the most challenging step in the weapons acquisition process. Given such material, a sophisticated terrorist organization or a state could plausibly construct a rudimentary nuclear bomb. As the now-defunct U.S. Congressional Office of Technology Assessment concluded: “A small group of people, none of whom have ever had access to the classified literature, could possibly design and build a crude nuclear explosive device… Only modest machine-shop facilities that could be contracted for without arousing suspicion would be required… The group would have to include, at a minimum, a person capable of searching and understanding the technical literature in several fields and a jack-of-all-trades technician.”98 This assessment is particularly relevant for HEU, because its usefulness in the most rudimentary gun-type design makes it the material of choice for terrorists as well as states seeking a more rapid or less challenging route to a crude nuclear bomb. A few tens of kilograms are sufficient for such a primitive design, similar to that used in 1945 to destroy Hiroshima. As enrichment levels decline, more material is required, yielding both a larger and less powerful device, but the former might not be problematic for terrorists contemplating delivery via truck or ship and even a relatively weak device could have a yield equivalent to thousands of tons of conventional explosive. Luckily, HEU is extremely difficult to manufacture. Unfortunately, thousands of tons were manufactured over the past half-century for diverse uses, from nuclear weapons to targets used in civil production of medical isotopes. State weapons establishments are more likely to provide high degrees of security for their nuclear-explosive materials, although even here there is room for concern. Conversely, non-military or civil stockpiles of HEU are often less well secured, although their usefulness for constructing nuclear explosives is not necessarily commensurately lower. Although comprehensive, detailed data on civil sites possessing nuclear explosive materials has not been compiled, estimates suggest that there are approximately 100 metric tons of civil HEU worldwide.99 Located in civil research and test reactors, critical and subcritical assemblies, and medical isotope production facilities worldwide, some of this material is in facilities with high levels of security, some in facilities secured with little more than a padlock and a guard.100 Today there are more than 140 research reactors in more than 40 countries fueled U233 isotope. Constructing an explosive device with uranium at the lower end of the highly enriched spectrum poses additional technical challenges and also yields a larger and less powerful device. Material enriched to 90 percent is preferred by weapons designers and is often referred to as “weapons-grade.” 98 U.S. Congress, Office of Technology Assessment, Nuclear Proliferation and Safeguards (Washington, D.C.: OTA, 1977) p. 140. Available at http://www.princeton.edu/~ota/disk3/1977/7705/7705.PDF, accessed October 24, 2007. 99 The International Panel on Fissile Materials (IPFM) estimates that there are “very roughly, 100 tons of…HEU in the fuel cycles of civilian research reactors worldwide and in Russia’s nuclear powered civilian vessels.” According to IPFM, the United States has about 45 tons of civilian HEU, 10 tons of civilian HEU are in non-nuclear weapons states, and 8 tons in the UK and France combined. Good estimates for China and Russia do not exist, but Russia can be assumed to have at least as much as the United States. International Panel on Fissile Materials, Global Fissile Material Report 2007, Princeton University (2007), p. 11 and fn.23. Matthew Bunn estimates that “60 metric tons of HEU is in civilian use or storage throughout the world,” Securing the Bomb 2007, Harvard University (September 2007), p. 32. 100 In addition, HEU is also used, to a lesser extent, for naval and space propulsion and as fuel for commercial fast- neutron reactors. For further information on the various civil uses of HEU, see “Civilian Uses of HEU” in “Civilian HEU Reduction and Elimination,” Nuclear Threat Initiative Research Library, available at http://www.nti.org/db/heu/civilian.html; accessed October 21, 2007. 90

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with HEU, and more than 120 civil research reactors and associated facilities around the world with 20 kg or more of HEU.101 The threat of HEU leakage is not hypothetical, even if, to the best of our knowledge, acquisition by those with proliferation aspirations thankfully remains so for now. For example, as recently as 2006, 100 grams of stolen HEU of approximately 90 percent enrichment was recovered in the Republic of Georgia. The material was suspected to have originated in Russia, but efforts to identify its provenance were unsuccessful, and Georgian authorities were reportedly dissatisfied with the degree of cooperation they received from Russia.102 This seizure is not an isolated incident; an International Atomic Energy Agency (IAEA) database includes 17 separate incidents between 1993 and 2001 involving illicit trade in HEU or plutonium, with quantities as large as several kilograms, although the sum of the material intercepted during this period was inadequate for a nuclear bomb.103 To underscore the point further, in 2006 the U.S. National Intelligence Council assessed that “Undetected smuggling of weapons-usable nuclear material has likely occurred, and we are concerned about the total amount of material that could have been diverted or stolen in the last 15 years. We find it highly unlikely that Russian or other authorities would have been able to recover all the material likely stolen.”104 Eliminating civil HEU by 2015 is also feasible. Efforts to address elements of the civil HEU threat date back almost as far as the spread of this material beginning mid-century. For example, both the United States and Russia have long had in place programs to accept the return of HEU they supplied to other states. But until recently these efforts were ad hoc and addressed only a small fraction of potentially vulnerable materials. New opportunities following the end of the Cold War led to additional activity, including some high-profile U.S.-initiated efforts to remove material stockpiles of particular concern. In recent years this activity has coalesced into a more systematic effort, involving the United States, Russia, and the IAEA, to identify, secure, and remove potentially vulnerable HEU stockpiles. The United States has taken the initiative on this issue and plays a key ongoing role in carrying out operations. Russia has played an important cooperative role, providing logistical and technical capabilities and taking back Soviet-origin material for disposition. Finally, the IAEA has increasingly played an essential role as a coordinator, knowledge base, and contracting mechanism that also brings with it a degree of international legitimacy absent from purely bilateral or trilateral efforts. Although the goal is both desirable and feasible, it is also ambitious, and a variety of specific steps must be taken now and in the coming years if it is to be realized. Important progress has already been made, ensuring that at least some of these materials will never fall into the wrong hands. At the same time, much more remains to be done. There is substantial room to 101 The General Accounting Office (GAO) estimated in 2004 that there were 128 civil research reactors and associated facilities with at least 20 kg of HEU onsite; operations to clean out some of these have reduced that number slightly since then. GAO, “Department of Energy (DOE)Needs to Take Action to Further Reduce the Use of Weapons-Usable Uranium in Civilian Research Reactors,” GAO-04-807, July 2004. 102 Elena Sokova, William C. Potter, and Cristina Hansell, “Recent Weapons Grade Uranium Smuggling Case: Nuclear Materials are Still on the Loose,” Center for Nonproliferation Studies Research Story, January 26, 2007, available at http://cns.miis.edu/pubs/week/070126.htm; accessed October 21, 2007. 103 “List of confirmed incidents involving HEU or Pu” International Atomic Energy Agency, undated, available at http://www.iaea.org/NewsCenter/Features/RadSources/table1.html; accessed October 21, 2007. 104 U.S. National Intelligence Council, “Annual Report to Congress on the Safety and Security of Russian Nuclear Facilities and Military Forces” (April 2006). Available at http://www.fas.org/irp/nic/russia0406.html; accessed October 24, 2007. 91

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build on the successes that U.S.-Russian partnership has achieved to date. The United States could do much more to prioritize its efforts according to the threats particular stockpiles pose and to make those efforts more comprehensive. For its part, Russia should do more to make the efforts genuinely cooperative, stepping up as a partner rather than playing the subcontractor role as at present. Additionally, Russia could adopt a policy of HEU minimization for its domestic civilian research reactors, which make up half of HEU-fueled research reactors globally. The bottom line is that while much has already been accomplished and efforts to date deserve praise, much more remains to be done, especially if the goal of HEU minimization by 2015 is to be achieved. HOW DID WE GET HERE? Spurred by widespread enthusiasm for the peaceful potential of nuclear technologies, in the 1950s and 1960s the United States, the Soviet Union, and a few other states exported nuclear research reactors around the globe, many fueled with HEU, which was then thought to offer substantial scientific advantages. These efforts became part of the compact eventually formalized in the 1970 Treaty on the Non-Proliferation on Nuclear Weapons (NPT), under which states that agreed to forswear nuclear weapons were promised assistance in developing civil nuclear programs.105 Concern about the proliferation risks such practices entailed dates back almost as far. Early attempts to control nuclear weapons and related materials and technologies through multilateral fora achieved little headway. By the 1970s, enthusiasm for civil nuclear applications had been significantly tempered by proliferation concerns. Efforts to reduce the availability of weapons-usable civil nuclear material date back at least to 1978, when the United States initiated its Reduced Enrichment for Research and Test Reactors program to develop low-enriched uranium (LEU) fuels for HEU-fueled research and test reactors and targets for medical isotope production facilities.106 Since the 1970s, both the United States and Russia have made sporadic efforts to take back civil HEU they had previously provided to other countries, motivated at least in part by proliferation concerns. The Cold War’s end raised the specter of proliferation from the Soviet Union’s substantial and widely dispersed nuclear as well as biological and chemical weapons and weapons infrastructure, but also opened up new opportunities to ameliorate proliferation threats. Cooperative threat reduction programs spearheaded by Senators Richard Lugar and Sam Nunn, initially intended as a short-term effort to help Russia consolidate and dismantle its nuclear weapons and materials, expanded into a broad and durable agenda to address global threats posed by nuclear, biological, chemical, and radiological weapons, materials, and expertise. In the civil HEU area, the United States took advantage of several opportunities to conduct ad hoc operations addressing specific stockpiles of Soviet-origin material. Russia remained uninvolved in these early operations, tacitly or explicitly agreeing not to oppose them 105 To read the text of the Treaty on the Non-Proliferation of Nuclear Weapons, see http://www.iaea.org/Publications/Documents/Infcircs/Others/infcirc140.pdf; accessed April 6, 2008. 106 Office of Defense Nuclear Nonproliferation, National Nuclear Security Administration (NNSA), DOE, “Reduced Enrichment for Research and Test Reactors,” available at http://www.nnsa.doe.gov/na-20/rertr.shtml; accessed July 25, 2005. 92

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but also declining to accept Soviet-origin material. As a result, in 1994 and 1998 the United States transported Soviet-origin material to its soil and to Britain, finally securing Russian agreement to accept material for a 2002 operation. The first U.S.-initiated “cleanout” operation of Soviet-origin material was conducted in 1994, when Project Sapphire led to the removal of a remarkably large stockpile of 600 kg of unirradiated HEU, sufficient for tens of nuclear weapons, from Kazakhstan to the United States. Initiated through a backchannel communication from the Kazakhstani government, the high- profile effort required the efforts of officials representing multiple U.S. agencies and at all levels of the U.S. government, even involving then-Vice President Al Gore to overcome diplomatic hurdles. The operation was characterized by substantial and time-consuming interagency friction in Washington.107 The senior officials involved in Project Sapphire viewed that initiative as a one-time effort and despite some efforts to build on the precedent lower in the bureaucracy, the initiative did not lead to similar projects being pursued elsewhere. The next such operation did not take place until 1998, when Operation Auburn Endeavor removed from Georgia about 4 kg of unirradiated HEU along with additional LEU and spent fuel. Interagency friction again significantly impeded efforts. Given domestic political challenges to Project Sapphire, Energy Department officials were leery of once again bringing material to the United States, particularly since the Georgian material included spent fuel “radioactive waste.” After France was approached as a potential recipient and declined, Britain agreed. As was the case with the previous operation, once the secret transport was publicized, environmental and other public interest groups subjected the British government to public criticism, although much of it centered on the secrecy of the effort.108 Once again, little effort was made in the aftermath of Operation Auburn Endeavor to build on the successful effort by pursuing other vulnerable material stockpiles. And some U.S. officials subsequently concluded that in the future neither the United States nor Britain were viable locations to bring nuclear material, and particularly more controversial spent fuel, absent a critical proliferation emergency. Given political difficulties encountered in earlier operations that brought material to the United States and Britain, when U.S. officials sought to remove Soviet-origin HEU from Serbia in the 2002 Project Vinca, they made concerted efforts to secure Russian agreement to accept it, which was eventually forthcoming. The operation ultimately removed 48 kg of unirradiated HEU from a research reactor in Serbia to a Russian nuclear institute for disposition. A mid-level State Department official spearheaded the implementation, leveraging preexisting relationships with senior U.S. and Russian policymakers to overcome bureaucratic and diplomatic hurdles. In a unique twist, the non-governmental Nuclear Threat Initiative was asked to pledge financial assistance for spent fuel management as an additional inducement for securing Belgrade’s approval.109 Characteristic of its involvement in these issues even today, and reminiscent of the Richard Nixon-Henry Kissinger approach to U.S.-Soviet arms control during the Cold War, the State Department approached cleanout efforts more as a means to improve bilateral relations than as a non-proliferation end in itself.110 107 For further information on Project Sapphire, see Philipp C. Bleek, “Global Cleanout: An Emerging Approach to the Civil Nuclear Material Threat,” Harvard University, September 2004, pp. 5-9. 108 For further information on Operation Auburn Endeavor, see ibid, pp. 9-13. 109 For further information on Project Vinca, see Bleek, “Global Cleanout,” pp. 13-17 and Bleek, “Project Vinca: Lessons for Securing Civil Nuclear Material Stockpiles,” Nonproliferation Review 10 (Fall-Winter 2003), pp. 1-23. 110 This remains a strong side-benefit of U.S.-Russian cooperation: as several U.S. and Russian participants observed at the Vienna meeting at which this paper was presented, U.S.-Russian threat reduction cooperation, including on civil HEU minimization, is valuable not only for its risk reducing effects, but also because it maintains 93

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Project Vinca had been removed from a “slow-and-steady” Energy Department-led effort by State Department officials crafting a broader political package to engage a newly cooperative Serbia. The Energy Department effort subsequently cohered into a joint U.S.-Russia-IAEA initiative, then termed the “Tripartite Initiative,” to return Soviet-origin fresh and spent HEU to Russia. As part of that effort, 15 NPT signatory countries known to have received Soviet HEU were invited to participate.111 All but China and Libya responded positively; the latter subsequently cooperated. The IAEA subsequently dispatched technical teams to conduct on-site assessments to gauge fuel quantity, condition, and security at each site.112 The joint U.S.-Russian-IAEA efforts bore fruit in a 2003 operation to transport 14 kg of unirradiated HEU from Romania to Russia. Subsequent operations included the 2003 removal of 17 kg of HEU from Bulgaria; the 2004 removal of 13 kg from Libya, approximately 11 kg from Uzbekistan, and 6 kg from the Czech Republic; the 2005 removal of 3 kg from Latvia and 14 kg from the Czech Republic; the 2006 removal of almost 40 kg from Poland, and 286 kg from the former East Germany; and so far in 2007, the removal of almost 9 kg from Poland and 4.5 kg from Vietnam.113 As well, in 2006 the first shipment of spent HEU fuel was undertaken when 63 kg were removed from Uzbekistan, with another shipment of 80 kg of HEU contained in spent fuel shipped from the Czech Republic in December 2007.114 The pace of recent progress is due in no small part to understandings reached at the presidential level during a 2005 meeting in Bratislava. In their joint statement, U.S. President George W. Bush and Russian President Vladimir V. Putin committed both governments to securing nuclear weapons and material to preventing the possibility that they could fall into the hands of terrorists.115 This commitment included an acceleration of operations to remove HEU fuel from vulnerable reactors “in third countries” (i.e. not in Russia) and convert them to LEU fuel. The Libya operation is a special case, since it represented the culmination of years of on- again, off-again diplomatic engagement with the United States and several western European countries over Libya’s offer to surrender its weapons of mass destruction capabilities. The shipment of spent fuel from Uzbekistan also deserves special note, as it marked the first effort under Russia’s new law on spent fuel imports.116 The successful completion of the multiple phases of required document preparation, submission, and approval paves the way for future a channel for productive interaction even during times when increased friction characterizes the broader political relationship. 111 Interviews with IAEA official, July and August 2003. Invitation letters were sent in September 2000 to 15 countries: Belarus, Bulgaria, China, Czech Republic, Germany, Hungary, Kazakhstan, Latvia, Libya, Poland, Romania, Ukraine, Uzbekistan, Vietnam, and Yugoslavia. 112 Interviews with IAEA official, July 2003. 113 “Global Threat Reduction Initiative: More than three years of reducing nuclear threats,” National Nuclear Security Administration Fact Sheet, undated. Available at http://www.nnsa.doe.gov/docs/factsheets/2007/NA-07- FS-03.pdf; accessed October 23, 2007. For more information on the Romania and Bulgaria operations, see Bleek, “Global Cleanout,” pp. 18-20 and 20-21, respectively. 114 NNSA, “NNSA Removes Highly Enriched Uranium from Czech Republic,” Press Release, December 11, 2007. Available at http://www.nnsa.doe.gov/docs/newsreleases/2007/PR_2007-12-11_NA-07-57.pdf, accessed December 14, 2007. 115 For further information regarding the “Joint Statement by President Bush and President Putin on Nuclear Security Cooperation,” of February 24, 2005, see http://www.whitehouse.gov/news/releases/2005/02/20050224- 8.html; accessed February 23, 2008. See also Appendix D for full text of this Joint Statement. 116 Decree #418, “Government of the Russian Federation on the Procedure for Importation of Irradiated Nuclear Reactor Fuel Assemblies Into the Russian Federation,” July 11, 2003. 94

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spent fuel shipments. Since a pledge to remove a reactor’s spent fuel is typically a key element of obtaining agreement to remove fresh HEU fuel, this accomplishment is critical to fulfilling those promises and opens the door to more rapid approval processes in the future. Based on the Uzbek spent fuel experience, the IAEA has compiled a set of guidelines for spent fuel shipments to Russia and hosted a workshop for other sites that will be sending their spent fuel to Russia for disposition.117 The other recent operations were all broadly similar; the target countries expressed interest to the IAEA, which served as a facilitator in negotiations with the United States. In each case, packaging and transportation were conducted by several Russian firms who have established efficient working relationships with the program.118 Compensation varied only modestly across each operation, with the United States generally agreeing to provide either equivalent LEU fuel or funds for surrendered HEU to the target country and also compensating Russia for transportation and processing costs. At the same time, as operations were taking place with increasing frequency and in a permissive political environment following the September 11, 2001 terrorist attacks on U.S. soil, persistent advocacy from non-governmental organizations helped channel White House rhetoric on weapons of mass destruction threats into concrete programmatic developments. In May 2004, the Energy Department announced the Global Threat Reduction Initiative (GTRI), intended to consolidate a range of programs working to reduce the chance that terrorists could acquire either HEU or materials for a radiological “dirty bomb.” At present, GTRI, the institutional home of HEU cleanout efforts in the U.S. government, oversees six new or previously separate programs that deal with HEU. (In addition, GTRI manages both a domestic and an international radiological threat reduction effort; these programs are outside the purview of this paper.) This programmatic integration has already significantly resolved the bureaucratic friction that hampered earlier, more ad hoc efforts.119 Although the various U.S. programs that have recently been consolidated and strengthened currently form the core of the global response to civil nuclear materials, it bears highlighting that many are implemented in collaboration with the IAEA, Russia, and other partners on a more ad hoc basis. The IAEA in particular conducts a range of activities, such as assisting sites assess and upgrade security at civil nuclear installations, that help to make it less likely that civil nuclear materials will make their way into nuclear bombs. The agency cannot conduct cleanout operations in its own right; it has neither the mandate to do so nor the ability to take vulnerable nuclear material into its possession. But the agency can and does play a key role both as a facilitator in negotiations and as an implementer with needed technical expertise and capabilities. Finally, it is worth noting that the threat posed by civil nuclear material stockpiles, particularly as it relates to nuclear terrorism, continues to be contested. Officials implementing current U.S. programs, in contrast to more senior political leadership, tend to downplay the threat, highlighting the challenges posed by stealing sufficient material, evading capture, processing the material, and manufacturing an improvised nuclear device. Non-proliferation advocates outside government often respond by highlighting recent terrorist operations such as 117 Pablo Adelfang, Ira Goldman, Edward Bradley, et al., “IAEA Perspective and Lessons Learned in Shipping HEU Spent Fuel to Russia,” presented at the Institute for Nuclear Materials Management Annual Meeting, July 8- 12, 2007. 118 Interviews with U.S. administration officials, July 2005. 119 For discussion of bureaucratic friction in an early cleanout effort, see Bleek, “Project Vinca,” pp. 1-2, 17. 95

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the large-scale hostage takings repeatedly orchestrated by Chechen terrorists in Russia and arguing that neither processing material nor manufacturing a crude nuclear device poses insurmountable technical challenges. Although disagreements persist, those more and less skeptical about the threat appear to have found a measure of common ground in the argument that because terrorist acquisition of nuclear weapons would be so evidently catastrophic, any risk thereof merits a vigorous response.120 Important progress has already been made. Some material has been removed from vulnerable sites and processed into non-weapons-usable form, ensuring that it will never find its way into a nuclear weapon. Perhaps even more importantly, a broader policy and programmatic framework has now been put into place that has the potential to facilitate a genuinely comprehensive solution. But while much has been done, much more remains undone. Only time will tell whether the steps being taken now ultimately serve as the foundation for such an effort, but extrapolating current trends into the future yields a mixed verdict at best. The pace of operations remains slow, if steadily improving, and driven more by metrics than by threats.121 Given substantial difficulties in dealing with some of the more threatening sites, program officials appear to be concentrating their efforts on the more easily completed sites, which does not bode well for the pace once easier sites have been completed and only more challenging ones remain. While the completion of current programs would be a significant step toward securing civil nuclear materials, much material still remains outside their purview. What is needed to realize HEU minimization by 2015 is a more comprehensive program, targeting more sites in possession of more materials with the help of more partners. This requires a genuinely cooperative international effort. The United States and Russia can do much on a bilateral basis with select partners, but a true global cleanout would require commensurately global participation. The barriers to success are many and high. Facility operators pose some of the greatest hurdles, since policymakers tend to follow their lead in assessing cleanout proposals. Operators are likely to be skeptical about the feasibility and cost of maintaining functionality following facility conversion from HEU to LEU or of finding new work following the shutdown of a reactor. The higher security required to conduct research with weapons-usable material also often entails a higher level of prestige that facility operators may be loath to give up. And facility operators and targeted countries may feel singled out and hence resentful; the implication that some countries or facilities are less capable of adequately securing material or that their research does not merit the proliferation risk it poses is potentially offensive. Just because the challenges are significant does not imply that the goals are not worth pursuing. If nuclear proliferation to terrorists is indeed a threat of the magnitude that both Russian President Vladimir Putin and U.S. President George W. Bush have assessed it to be—in a recent joint statement they called nuclear terrorism “one of the most dangerous international security challenges we face”—then it would be irresponsible not to think outside the narrow 120 Both U.S. and Russian participants at the Vienna meeting at which this paper was presented suggested that joint discussions of the degree and character of the nuclear terrorism risk would be productive. Even if such discussion did not yield consensus, it would at least provide opportunities for better mutual understanding of threat perceptions, including areas of common ground and issues over which the two sides differ. That said, it is important not to overemphasize the degree to which threat perceptions differ between the two sides, in particular because there are also differences among policymakers and analysts on both sides. 121 For discussion of both progress of nuclear threat reduction toward meeting metrics and the validity of various metrics, see Bunn, Securing the Bomb 2007, passim. 96

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confines that characterize current efforts.122 What is needed now are actions commensurate with those words. MOVING TOWARD CIVIL HEU MINIMIZATION BY 2015 All Countries Should Take Concrete Steps to Minimize Civil HEU Possession and Use Efforts to clean out vulnerable stockpiles of nuclear weapons-usable material will both promote and be enhanced by a strengthened global norm against civil HEU. A recent positive development in this regard is the inclusion of a commitment to minimize HEU use in civilian facilities and activities in the June 2007 Joint Statement on the third meeting of the Global Initiative to Combat Nuclear Terrorism.123 Led by the United States and Russia in close and effective partnership, the Global Initiative has attracted the participation of over 60 states. Raising this principle to a global level through a formal IAEA policy, however, has proven difficult, as was demonstrated at a Norway-sponsored conference in June 2006. Despite the technical consensus that for most operating research reactors conversion to LEU would result in minimal loss of capacity, and that new reactors have been designed to run on LEU with performance equal to or better than existing HEU-fueled reactors, participants resisted any constraint on asserted rights to use any kind of nuclear material for peaceful purposes.124 Despite a plethora of IAEA-sponsored efforts to reduce global HEU risks, this rights- based perspective has prevented the IAEA from adopting a formal policy that would require that it reject any applications for technical assistance in establishing HEU-fueled research reactors or other HEU-based civilian facilities. An existing de facto understanding would cause any such applications to be frowned on and LEU-based (or non-nuclear) alternatives sought, but those member states who defend the broadest interpretation of their rights to peaceful nuclear technology have so far prevented the IAEA from a formal position opposing civilian HEU use. Given that little or no technical penalty is paid for staying within LEU boundaries for civilian applications, the member states to which the IAEA answers should seek a formal codification of this policy.125 122 “Announcing the Global Initiative to Combat Nuclear Terrorism,” Joint Statement by U.S. President George W. Bush and Russian Federation President Vladimir V. Putin, St. Petersburg, Russia, July 15, 2006, available at http://www.state.gov/p/eur/rls/or/69021.htm; accessed October 23, 2007. Note that U.S. policymakers tend to use stronger language, generally referring to nuclear terrorism as the greatest threat facing the United States, suggesting that Russian policymakers are more skeptical than their American counterparts and negotiated less strong compromise language for this statement. For the text of this Statement, see Appendix D. 123 U.S. Department of State Media Note “Global Initiative to Combat Nuclear Terrorism: Joint Statement,” June 12, 2007, available at http://www.state.gov/r/pa/prs/ps/2007/jun/86331.htm; accessed December 14, 2007. 124 “Minimization of Highly Enriched Uranium in the Civilian Nuclear Sector,” conference sponsored by the Government of Norway, June 17-20, 2006. The Conference Proceedings are available at http://www.nrpa.no/symposium; accessed October 19, 2007. 125 As noted above, HEU is at present used in a variety of non-weapons applications, including providing compact power plants for ships, submarines, and space vehicles. The technical feasibility of converting all such power plants to lower-enriched uranium fuel remains a subject of debate. Russia has committed to an LEU core for their floating power plants, which will be based on the KLT-40 reactor, the same reactor used in Russian ice breakers; this implies that existing ice breakers could be converted to LEU. While there are uncertainties about conversion of existing 97

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U.S. legitimacy in promoting global cleanout efforts would be strengthened by putting its own house in order. In this regard, a 2005 provision that lifts a legislative restriction on U.S. exports of HEU is shortsighted. A 1992 amendment to the Atomic Energy Act previously barred exports unless 1) no fuel or target of lesser enrichment were available, 2) the facility operator agreed to convert to LEU as soon as feasible, and 3) a U.S. program existed to develop an LEU alternative for the type of facility in question. According to the National Nuclear Security Administration (NNSA), “this law has been very helpful in persuading a number of research reactors to convert to LEU.”126 The new law, which was passed following intense lobbying on behalf of a Canadian medical isotope production company eager to avoid the expense of converting its facilities from HEU to LEU, allows exceptions for Canadian and European companies.127 It bears highlighting that the United States has no monopoly on such shortsighted policies: Germany recently completed construction on the first western HEU-fueled research reactor built since 1978. By contrast, Australia’s OPAL reactor, opened this year as a state-of-the-art regional center of excellence, demonstrates that cutting-edge research and isotope production can be carried out with LEU-based technology.128 In the near term, to the degree that LEU conversion fuel is not available or that a small number of HEU-fueled research reactors are needed to develop new technologies in service of the anticipated “nuclear renaissance,” adequate security systems designed to thwart demonstrated outsider and insider theft or diversion scenarios must be in place at such facilities. The United States and Russia Should Work with Others to Complete, Maintain, and Share a Comprehensive Database of Global Civil Nuclear Material Stockpiles A comprehensive database would enable threat-based prioritization and facilitate efforts to approach, negotiate with, and implement cleanout efforts at specific sites. The current lack of comprehensive data is striking; the IAEA, national governments, and the non-governmental expert community all appear unable to answer a basic set of questions regarding how much material is in what types of facilities and in how vulnerable a form and how well it is secured.129 This characterization of the current situation merits some caveats. First, in April 2006, NNSA submitted a classified study to Congress that sought to document every facility with nuclear weapons or nuclear or radiological material, although it did not include site-specific vulnerability assessments. Second, energy intelligence officials have recently been tasked to reactors in some cases, it is clear that new reactors could be designed to run off LEU; for example, French nuclear submarines employ LEU-fueled reactors. 126 NNSA Office of Defense Nuclear Nonproliferation Fact Sheet “Reduced Enrichment for Research and Test Reactors,” available at http://www.nnsa.doe.gov/na-20/rertr.shtml; accessed July 25, 2005. 127 See Alan J. Kuperman, “The Energy Bill’s Gift to Terrorists,” New York Times, August 11, 2005; Matthew L. Wald, “Medical Company Sought an Eased Limit on Uranium,” New York Times, August 9, 2005; and Michael Grunwald, “Uranium Provision to Alter U.S. Policy,” Washington Post, July 29, 2005, p. A4. 128 For further information on the reactor, see http://www.ansto.gov.au/opal.html; accessed October 24, 2007. 129 Matthew Bunn makes much the same point in his September 2007 report: “Remarkably, it appears that neither the U.S. government nor the International Atomic Energy Agency (IAEA) has a comprehensive, prioritized list assessing which facilities around the world pose the most serious risks of nuclear theft.” Bunn, Securing the Bomb, 2007, p. v. The IAEA Department of Safeguards maintains a comprehensive database whose information would be very useful for cleanout efforts. However, the information in that database is shared with the IAEA by countries under the explicit condition that it not be divulged, even to other departments within the IAEA. That database is also silent on the security status of nuclear sites and materials. 98

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establish a database with more specific information, including vulnerability assessments. Finally, GTRI officials are in the process of establishing a program management database for the universe of sites over which their programs currently or potentially have a mandate, including sites within Russia that have not yet been formally included in that effort. This database includes factors such as nuclear and radioactive material attractiveness, internal site vulnerability, country level threat environment, and—more relevant for radiological threats—proximity to strategic assets.130 These efforts deserve praise. But they also have shortcomings; data access issues are particularly important and potentially problematic. An effective global cleanout will require sharing information across countries. At the same time, program officials are understandably wary of disseminating information about vulnerable nuclear material stockpiles too broadly, and sharing restricted information such as that contained in the databases currently in existence or under construction, even with allied countries, poses considerable hurdles. Compromises will be necessary, perhaps even involving parallel databases containing information of greater and lesser sensitivity, but some form of access for IAEA officials and partner countries is a nonnegotiable requirement. In fact, given the need for multilateral access, the IAEA could be an effective host for at least one iteration of such a database. U.S.-Russian partnership can facilitate the database creation and refinement process; Washington and Moscow can work together on a basic set of questions that GTRI still cannot answer regarding how much material is in what types of facilities and in how vulnerable a form and how well secured. Some of this information may be difficult to obtain, but gaps themselves are likely to be instructive. This comprehensive database will almost certainly highlight materials or facilities outside the scope of current programs. Where these are found, the United States and Russia should work together on a prioritized approach to ensuring either the expeditious removal of vulnerable material or the adequacy of security at sites that will continue to use or hold this material. Russia Should Take on a Genuine Leadership Role Russian cooperation has been important to many of the global cleanout successes achieved to date. The increased intensity of engagement on the GTRI mission following its mention in the Bratislava Summit Joint Statement and in the U.S.-Russian-led Global Initiative shows that high-level direction and accountability can quickly improve cooperation and achieve results. On fresh fuel, cooperation has been sufficiently institutionalized with Russian firms that operations are relatively straightforward. On spent fuel, the recent Uzbek shipments have shown the path forward, accelerating promised shipments of spent fuel from other reactors in the process of converting. At the same time, there is a perception among many implementing officials that their Russian counterparts are more interested in profiting from operations than in genuine threat amelioration. Instead of funding repatriation activities itself, Russia insists on receiving complete compensation for packaging and transport expenses and takes possession of economically valuable fresh HEU. This suggests a lack of recognition that Russia is as much at risk from nuclear proliferation to states or terrorists as are the United States or other nations, and therefore that Russia has a powerful stake in the success of the global cleanout mission. Especially in the context of its recent economic achievements, Russia can and should 130 Written communication, NNSA official, October 25, 2007. 99

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demonstrate its international responsibility for the materials sent abroad in Soviet days by bearing at least some of the costs of repatriating fresh and spent HEU fuel. This critique also highlights the fact that there is now a constituency within Russia for HEU-cleanout. As one participant in this workshop pointed out, the existence of this domestic constituency bears substantial responsibility for the success of efforts to deal with third-party materials that are repatriated to Russia. This suggests the need to think through how such a constituency might be created for efforts to address sites within Russia. Perhaps owing to the lack of perceived threat, Russia has also done too little to get its own house in order.131 Fully half of the remaining HEU-fueled reactors in the world are located within Russia. While important progress has been made to improve security and speed elimination of weapons-related stockpiles, Russia has explicitly closed off its own civilian research reactor fleet from the scope of GTRI cooperation. In part, this is explained by the lack of any policy decision to minimize HEU in civil use, such as the United States took in 1978. As a result, not a single HEU-fueled reactor within Russia has been converted to LEU fuel,132 and HEU fuel continues to be transported around Russia and accumulate in spent fuel storage at dozens of reactors. A Russian policy decision to minimize HEU use domestically would be an important way to demonstrate leadership on this critical issue. Such a decision would open doors to the development of LEU fuels for those reactors with ongoing missions, to develop processes for treating HEU-bearing spent fuel, and to initiate decommissioning of reactors which have outlived their purposes. Current U.S.-Russian cooperation provides a valuable platform for these activities. While Russia’s domestic fleet overlaps little with the reactor types exported during Soviet times, LEU fuel design principles developed in current U.S.-Russian efforts to convert those exported reactors should contribute to accelerated development of LEU fuels for Russia’s domestic reactors. Furthermore, the United States has already developed two technologies for treating spent HEU fuel, which might be applicable to Russian needs. A “strategic master plan” for reducing risks of HEU use in Russian civilian research facilities, similar to those created for dismantling general purpose submarines and managing radiothermal generators, would be a useful starting point for defining the scope of effort required for Russia to take this challenge seriously.133 These recommendations mirror broader discussions at the Vienna workshop at which this paper was presented, in which multiple U.S. and Russian participants agreed that on nuclear threat reduction broadly, it is time for Washington and Moscow to move from a donor-assistance relationship to a full partnership, one with the two sides sharing responsibility for setting priorities, managing projects, and funding efforts. The United States and Russia Must Do More to Bring Targeted Sites on Board Sites currently being or already addressed are the low-hanging fruit, and negotiations with many other sites appear to have bogged down. Bringing more sites on board is likely to require an expanded menu of potential inducements, ranging from environmental remediation to research contracts for scientists at the targeted site. One lesson of past operations is that most 131 On differing U.S. and Russian nuclear fission terrorism threat perceptions, see pervious footnotes in this paper. 132 William Potter, Monterey Institute, written communication, August 2005. 133 For further information on the Strategic Master Plan, see Academician Ashot A. Sarkisov in this volume. 100

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cases have required genuinely unique sets of incentives. U.S. program officials consistently claim they have all the legislative authorities and senior official backing necessary, but current difficulties in bringing many sites on board suggest that more will be required. Additional flexibility and resources for designing incentive packages should be assigned to the global cleanout mission. More high-level political engagement may also be required to deal with the most difficult bureaucratic and political impediments. If there is a relevant lesson from Cold War arms control negotiations, it is that without engagement and pressure from the top, negotiations almost invariably languish. In this regard, the joint U.S.-Russian approach to Belarus in the context of removing the HEU located at the Sosny reactor is an excellent and overdue example; there may be other instances where a joint high-level approach would be fruitful. Balance is vital: implementing officials need to feel both support and pressure from senior policymakers, but micromanagement should be avoided. The United States and Russia and other partners can also make it harder for targeted sites to be intransigent. Interested nations exercise a range of potential levers ranging from trade access inducements to the ability to publicly name and shame. Creative ways to meet national needs for the training, isotope production, and irradiation services provided by research reactors should be considered in designing approaches to remove vulnerable HEU stocks. The IAEA is leading an effort to develop research reactor “coalitions” that would help raise the quality of products and services provided by reactors while ensuring steady streams of supply and rationalizing client relationships. These coalitions may lead to arrangements whereby HEU-using reactors are able to manage the temporary shutdowns required to convert to LEU while still supplying customers through production at an allied reactor. It may also allow for efficiencies that can permit the decommissioning of certain reactors. If reactor operators choose to shut down their reactor as part of HEU removal from the site, they should be eligible for assistance in doing so. There are likely to be several cases in which “repatriation” (literally, the return of HEU to the nation that exported it) is not politically or practically feasible. In these instances, the United States, Russia, and their partners should consider taking some vulnerable material of any origin to a venue where it can be safely and securely stored and disposed, perhaps in a third country. If such materials are to be brought to the United States, this would likely require expanding the coverage of the existing Environmental Impact Statement that defines the materials eligible for U.S. storage and disposition. Efforts to do so are underway, but are slow and politically charged. Certainly, post-September 11, 2001, post-Beslan security concerns call for a reexamination of the purely environmental basis for decades-old decisions to limit nuclear materials imports. The United States and Russia Should Do More to Spur Potential Partner Countries to Act and to Facilitate Cooperation When They Do The United States and Russia can do much more to spur others to join in global cleanout activities. Continued advocacy is important; Washington and Moscow can credibly claim that it is in other countries’ interest to engage. It is also important that efforts not be viewed as simply in the interests of or driven by the United States. When other countries are prepared to engage, the United States can do more to facilitate cooperation. U.S. officials have so far kept their efforts firmly anchored in the United States, choosing to emphasize control over broader cooperation. Although it entails additional 101

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complications, the integration of other countries will almost certainly be necessary to achieve a truly global cleanout, and if done effectively could speed the pace of implementation. If and when other countries do take action, coordination will become key to ensure that efforts are jointly prioritized and neither redundant nor conflicting. The IAEA’s extensive efforts in HEU minimization have created an excellent mechanism by which to coordinate contributions by multiple partners. The Agency’s competitive procurement requirements also facilitate integrating a wider range of nations into global cleanout activities. For example, Argentina’s INVAP company (Aplicadas Sociedad del Estado, “Applied Research, State Enterprise”) has bid successfully on supplying modern integrated control systems—often required by safety regulations in the context of reactor conversions—to participating facilities through the IAEA’s Technical Cooperation program. Another such opportunity can be found in Kazakhstan. As part of a project to blend down 2,900 kg of HEU in the form of fresh fuel for its closing BN-350 reactor, Kazakhstan installed a small HEU blend down line at its large uranium processing plant in Ust- Kamenogorsk. This facility has operated under IAEA safeguards, and has been upgraded to security levels consistent with HEU storage and processing.134 This blend-down line could be used to eliminate HEU stocks in nations for whom shipment either to Russia or to the United States is politically problematic, such as Ukraine. The resulting LEU is a commercial commodity, creating the chance to pursue this option as a mutually beneficial business proposition, which may be more acceptable to the HEU-holding state than the implication that it is not a responsible steward of such material. Similar potential exists in France at the CERCA facility and possibly elsewhere. These capabilities should be leveraged as part of creative solution sets to the challenges of global cleanout. In-kind contributions can also be important components of a successful cleanout project. In the case of planning for spent fuel removal from the Vinca Institute in Serbia, transit nations have pledged to absorb the costs of regulatory review of such shipments, which would normally be charged to the shipping country. Slovenia’s nuclear regulator has also supported, at no charge, the drafting and review of the multiple detailed plans and safety analyses associated with the spent fuel repackaging and shipping. These models can be replicated in future spent fuel shipments. The United States and Russia Should Engage the Private Sector More Fully to Assist in the Global Cleanout Mission The current design of the U.S. GTRI program makes extensive use of private businesses to accomplish HEU removals, through contracts for packaging and shipping fresh and spent HEU to the United States and Russia for storage and disposition. The private sector could do more to facilitate decisions to convert research reactors and remove HEU fuel. In many cases, these shipping companies have been involved in providing and removing fuel from these reactors for decades, and relationships have been established that can facilitate decisions to convert facilities and remove HEU. The United States should maximize the use of such private firms to design and lead HEU removal campaigns for agreed lists of facilities, freeing federal program staff to focus on the more challenging cases that require more political involvement. Private 134 A detailed account of this project is contained in Kazakhstan’s Nuclear Disarmament: A Global Model for a Safer World (Washington, D.C.: Embassy of the Republic of Kazakhstan to the United States of America and the Nuclear Threat Initiative, 2006). 102

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companies can also help design business plans for research reactors in the process of converting from HEU to LEU that would highlight the efficiencies and savings of operating with LEU fuel as well as ease the transition to the new fuel; such business plans should become a standard part of a reactor conversion package. Non-government organizations (NGOs) have also played valuable roles in global cleanout efforts to date and may be able to expand their engagement. One of their most valuable roles has been in the analysis and public advocacy for the global cleanout mission. Several U.S. NGOs were instrumental in highlighting the risks of vulnerable fissile materials in civilian facilities in the early 2000s, and Harvard’s Managing the Atom project along with the Monterey Institute for International Studies’ Center for Non-proliferation Studies have continued to advise the U.S. GTRI effort. More directly, the NTI has worked side-by-side with U.S. government efforts as well as directly with the IAEA to design and fund aspects of global cleanout missions. Other NGOs, in the United States and elsewhere, may be well-positioned to add information and influence to the task of minimizing civilian use of HEU. The United States, Russia, and Their Partners Must Follow Through In the rush to meet metrics and target high priority materials, the United States, Russia, and their partners must also follow through on sites where the highest priority materials have already been removed. Since the cleanout challenge is fundamentally political rather than technical—countries must voluntarily agree to cooperate—the “word on the street” regarding the treatment of cooperating sites has the potential to either facilitate or impede future efforts. The 2002 operation to remove HEU from Serbia is, at least to date, an example of particularly effective follow-through. As part of the negotiations to remove unirradiated HEU, the United States pledged to assist with removing spent fuel—with contributions tied to the proportion of HEU in the spent fuel—as well as with securing radioactive sources. These projects are under way, and the IAEA has successfully launched activities related to spent fuel repackaging and radioactive waste storage based on NTI’s $5 million contribution. At the same time, the IAEA has raised from European sources most of the additional funds required for shipping and reprocessing the spent fuel in Russia. The final cost of this contract is still under negotiation; willingness by Russia to absorb some of these costs would go far in demonstrating its leadership in global cleanout. The civil research reactor community is small and other countries considering cooperation will certainly be aware of the track record on prior operations. Those active on cleanout efforts already have sufficient difficulty obtaining cooperation from targeted sites without additional recalcitrance due to a perceived failure to follow through and honor implicit if not always overt commitments. CONCLUSIONS If civil HEU elimination by 2015 is to have even a chance of being realized, the United States and Russia will need to do a better job of matching deeds to words. Both sides have already taken important steps, laying the foundation for what could become a genuinely comprehensive effort. But that comprehensive effort has yet to be realized, and merely 103

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extrapolating the status quo will not achieve civil HEU elimination by 2015 or even on some lengthier timetable. By acting boldly, the two sides can take responsibility for nuclear dangers for which they bear primary, though not sole, accountability. Further, they can serve as role models, enhancing their ability to engage third parties. Finally, the cooperation the two sides have realized to date in dealing with material in third-party states can provide the basis for cooperation on sites within Russia, as yet off the joint agenda. The United States and Russia are the indispensable partners in ameliorating the civil HEU threat.135 The foundation is in place; now the two sides need to build on it to ensure that civil HEU never ends up in a state, or worse, a terrorist nuclear bomb. It is often asked, the day after a nuclear terrorist attack, what will we wish we had done? The United States and Russia have a clear opportunity, today and in the coming years, to ensure that securing civil HEU is not the answer to that question. 135 Additionally, as one participant at Vienna observed, U.S.-Russian threat reduction cooperation is important not only for its threat ameliorating effects, but also because successful cooperation helps the relationship weather political tensions that may undercut cooperation in other domains. 104