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1.2 (Buckley)
56^th Pugwash Conference
Cairo, Egypt, 11-15- November 2006

Immediate need for a universal  verifiable regulatory regime
to manage the nuclear energy renaissance

 Adele Buckley, Canadian Pugwash Group (Adele-buckley@rogers.com)

ABSTRACT 

Global demand for electricity virtually guarantees an increase in nuclear energy capacity.  While there are legitimate misgivings – increases the threat of proliferation, generates dangerous long-lived waste, no certainty about plant safety, and potential for nuclear terrorism -  it is essential to recognize  reality, and find the best way to minimize these multi-faceted risks. The sound regulatory regime developed by IAEA relies on the expertise and reliability of national regulators, and is voluntary.  Every nuclear reactor must be seen as having a global presence, but there is not a binding agreement that requires international oversight of all nuclear reactors.  The IAEa Additional Protocol for Application of Safeguards is directed solely at verifying that there are no activities leading to nuclear proliferation.  . The productive way forward is to promote universal adoption and enforcement of strict international regulations on safety, security and safeguards.   It is vital for the international community to work toward a binding international regime that addresses all factors.  To this end, civil society must take up its responsibility

Power utilities operate under a national regulatory system. Compliance with regulations, and demonstration of compliance by regular interaction with the regulatory agency is part of the cost of doing business.   A regulatory system, where nuclear power is concerned, must include every nation, binding all to the same regime.   The evident and legitimate regulatory agent is the IAEA.  A new universally inclusive international arrangement is vitally necessary, and the time to conclude this is now, taking advantage of the lead time before new nuclear power plants come on –line.  For credibility, the regulatory authority and inspection team interacting with specific plant must be a true third-party to it.  Such a protection system, whose goal must be to provide 100% safety plus 100% guarantee against malicious actions, is extensive and expensive.  Resources available to individual national regulators vary greatly.  The workable measure is for the entire regulatory cost to be borne by the individual nuclear power plants, as a cost of electricity production. 

In many countries, nuclear power would be welcomed, and/or public opposition would be ignored, so international treaty protection is particularly important.  Public acceptance is a critical factor in much of the U.S. and Europe. To mitigate opposition to the coming expansion of nuclear energy (as projected by the IAEA and others) governments would have to demonstrate their commitment to conservation and a balanced use of available energy generation technologies.  This means a maximum utilization of the most environmentally and security-friendly way of producing electricity, which would be visible and significant implementation of a full range of alternate energies, preferably in a distributed power configuration.  

1.0          Nuclear energy today

1.1          Nuclear power in place

About 16% of the world’s electricity supply comes from 442 nuclear reactors in 32 countries.  Many of these are at least 15 years old and will soon require massive refurbishment program.  Capital cost and maintenance of nuclear electricity plants is extremely expensive, and the complete cost, including waste storage in perpetuity, is rarely fully accounted.  Safety overall has been adequate, but, implementation and enforcement of national regulations is more advanced in some countries and less rigorous in others.  There have been near and actual accidents (specifically at Chernobyl and Three Mile Island) that have contributed to a general public mistrust of the technology.  Radiation releases from accidents, or regular airborne radiation releases from operating plants, circulate around the globe.

Illegitimate transfer of materials originating from nuclear electricity generation would provide terrorist organizations or state parties with the means of producing nuclear weapons.  Highly radioactive and long lived nuclear waste has accumulated and no means of long term disposal has yet been implemented.  Nuclear terrorism at power plants could be catastrophic to populations nearby because it is highly likely to release radioactivity from the on-site waste storage. 

In spite of all these problems, there is an apparently unstoppable nuclear renaissance.  

1.2            Nuclear energy renaissance

The renaissance of nuclear power was relatively quiet on the public stage five years ago.  India, at the 51^st Pugwash Conference, made it clear that it intended to supply its energy needs with a mix of technologies and that nuclear energy would have a prominent role.  In July 2005, India and United States signed a nuclear deal that would have India open most of its nuclear facilities for inspections and would, as part of the agreement, be able to buy nuclear power plants and fuel from the United States and other suppliers.  In May 2006,  President Bush[1] made a speech in Pennysylvania , presenting the view that the U.S. needs to build more nuclear power plants to expand the country’s energy supply without increasing global warming (there are many who see this as a flawed view).   The G8 major theme on Energy and Security concluded with a commitment[2] by Bush and Putin to promote and use nuclear energy in the U.S. and Russia.  President Putin attended the pre-G8 meeting of NGOs[3] in early July, 2006 and assured them that he would bring news of their strong opposition to nuclear energy to the G8 meeting; if he did so it was without effect. 

A new 1600 megawatt reactor, (advanced generation III+) is being built in Finland[4], the first in many years, and part of a new crop of nuclear power plants.  An underground waste disposal facility is being built at the same time and will begin accepting waste in 2020.     China has recently signed a deal with an Australian uranium supplier for an ongoing large supply of fuel for its to-be-built nuclear reactors.

The IAEA states[5] that “the civilian industry appears poised for worldwide expansion”, and has published its estimate that, over the next 20 years, world nuclear energy capacity will increase between 22 and 43 percent.  Like it or not, the reality is that the nuclear energy renaissance is underway, without a significant change in the problems of safety and security that have plagued it since the beginning. IAEA and its most active member states recognized this and staged a major international meeting, participants from 57 countries,  in Moscow in Feb 27-Mar 3, 2006 on  “Effective Nuclear Regulatory Systems: Facing Safety and Security Challenges”;  proceedings[6] were published in Sept., 2006.  The paper on behalf of the Chinese National Nuclear Safety Administration[7] says “According to the national nuclear development programme, nuclear electricity supply capacity will reach 40 GW(e) by 2020….,,, it will be necessary to build two or three 1000 MW(3) units every year.” 

This paper discusses the urgent need for continuous improvement and enforcement in the global nuclear regulatory system.  It also calls for the effort of the nuclear disarmament  movement to support rapid and credible implementation and enforcement.    

2.0          Conditions for productive movement forward

From the standpoint of safety and security, a nuclear power plant, ideally, provides:

1. Physical security – “100%” accident free
2. Security against terrorism – “100%” guarantee of prevention of significant harm in the event of a malicious attack
3. Security against proliferation – “0%” probability of access, physical or political, for any materials relating to the production of nuclear weapons

The approaches that could achieve these goals might be labeled “mitigation”, or “adaptation”.  In the mitigation scenario, we would oppose nuclear power and urge closure of existing nuclear power plants and pressure governments, worldwide, but the political will is absent.   Seeking these goals through an approach of adaptation would enable a productive move forward toward greater security.  While non-proliferation is very important, a safeguards regime must address all factors – physical plant safety, waste transport and waste storage, political/legal issues and prevention of terrorism.  There is much structural adjustment required to properly achieve the goals. 

It is necessary to actively seek ways to minimize harm, and existing international agreements do not suffice. 

IAEA has held international conferences on strategies critical to nuclear safety, beginning in 1991.  The Convention on Nuclear Safety has 56 contracting parties, and “Conference on Effective Nuclear Regulatory Systems…” in 2006 showed that the regulators know what is required, but they must “walk the walk”, not just “talk the talk”.  The next such conference will be in three years.  This pace is much too slow. 

Of particular note is the conference keynote address by Dr. El Baradei where he said “…every regulatory body has a unique design, based on national laws and the industry it must regulate….no two regulatory bodies have the same enforcement tools at their disposal.  …civil society and public at large are increasingly recognized as important stakeholders in the work of the regulatory body.”

Governments would be well advised to begin negotiations immediately on a new integrated agreement on nuclear energy regulations, before the world is faced with a full blown and completed nuclear renaissance.  Therefore, we, who wish to foster peace and security, have a role to play in urging governments to design, negotiate and conclude universally applicable, enforceable international standards. 

3.0          Multilateral Nuclear Approaches

Since it became evident that a number of states would be considering means to develop their own nuclear energy capability, and in particular their own fuel cycle facilities, the IAEA appointed an expert group to consider Multilateral Nuclear Approaches (MNAs).  These deliberations were reported in IAEA INFCIRC/640, February 2005.  The two dominant factors:

1. Assurance of non-proliferation, and
2. Assurance of supply and services

A multilateral approach to non-proliferation would reduce the risk by requiring the presence of a multinational team to prevent such actions as theft of fissile material, diffusion of sensitive technologies to unauthorized entities, or development of clandestine    parallel programmes.  However, the risk remains that the host country would expel multinational staff, and terminate its safeguards agreement under the NPT.  Assurance of supply could be acceptable, but there would need to be strong incentives for the host country to give up this degree of sovereignty.  A most critical step noted by the expert group is devising effective mechanisms for assurances of supply of material and services, commercially competitive, free of monopolies, of political constraints, and including backup sources of supply.   

IAEA’s Additional Protocol[8] …for the Application of Safeguards falls short of the goals (above) because it is directly solely at verifying that there are no activities leading to nuclear proliferation, and it involves only the NNWS (Non Nuclear Weapons States) 

A driving force for the MNA (Multilateral Nuclear Approach) in its various forms is Iran’s insistence on proceeding with its rights under the NPT to develop nuclear energy, at the same time as failing to satisfy its obligations to assure the IAEA that there are no undeclared nuclear activities in Iran.  As is well known, this situation engendered the UN Security Council Resolution 1696 (2006). 

Taking an optimistic view, it is possible that a new nuclear energy agreement, with even-handed inclusion of all states, could form a part of the system to ease the tension between Iran and the international community. 

4.0          IAEA (International Atomic Energy Agency)

The IAEA’s mandate[9], dating from 1956 and whose Statute was last changed in 1963, says that all states that are member states of the United Nations, can be members[10] of the Agency, providing that they fulfill their obligations in good faith .  IAEA has a strong internal structure and an expert professional staff.  Where nuclear energy is concerned, the IAEA appears in a role as provider of expert guidance, developer of safety and security standards (available for adoption by national regulatory agencies), sponsor of international conventions and supporter of new science and technology. 

IAEA has an operational role as an international inspection agency whose inspectors verify that safeguarded nuclear material and activities are not used for weapons purposes, and from time to time it reports non-compliance to the Security Council.  However,  IAEA has no operational role as far as nuclear energy is concerned and that is where the weakness of the international system lies. 

5.0          An Operational Role for IAEA – Agency for  Third Party Verification at Nuclear Energy Plants

5.1          Workable Practises in the Global Economy

It is time for the nuclear electricity generating plant to enter the mainstream of the regulatory system for electricity generators.  There are legal requirements (regulations) that the plant must fulfill and there are voluntary standards.  Both of these categories have their national and international levels   However, it is hard to ascertain whether or not there are true international standards for nuclear plants,  and national standards vary greatly, but ideally should be as good or better than those modeled by IAEA safety standards. 

It is common in industrial settings for individual plants to conform to ISO (International Standards Organization) standards such as the ISO 9001 systems for quality management, or the ISO 14001 for environmental management systems.  Holding these certifications is viewed as an advantage by all stakeholders and gives the corporate owner a competitive edge. An even better international model is the Forest Stewardship Council[11] (FSC), an a network to promote responsible management of the world’s forests. Forestry companies around the world are recognizing the value of FSC Certification for their products and are responding to industry and client pressure to undertake this certification.  

All of these regulatory and standard setting agencies have a mandate for regular inspection, and for frequent confirmation of conformance, and thus support an inspection group.  This is the working practice in the global economy and, for inspection of nuclear power plants; IAEA could take the role as the lead agency. It would be mandatory to recognize that a nuclear power plant has characteristics that differ from other electricity generators, and that is why the expertise of IAEA is vital.   The methodology that might work is outlined in the following sections.

5.2          Credibility and Safety through Third Party Verification

The only viable system of inspection is one which has the absolute confidence of all members of the international community.  This requires involvement of recognized certifiable experts in nuclear power plant technology.  The vital characteristic, in addition to expertise, is that the inspection team must be a third party[12] to

• the owner of the nuclear power plant
• the management of the nuclear plant
• subcontractors to the owners and managers
• the government of the country in which the nuclear plant is sited

It is particularly important that the core of the inspection team should have no link to the government of the country.  The government is the regulator, and often is also the owner, and therefore would be in a conflict of interest position as the inspecting agency.  This is a more onerous demand than the requirement for other types of electricity generators (e.g. coal-fired plants) but it is vital to the achievement of international credibility for the system.  Pragmatically, this aspect of third party verification would be a longer term goal.

A regular, periodic inspection of every plant and every nuclear reactor in a massive task, and could not be carried out by the IAEA staff alone with its own resources.  Therefore, the IAEA would be obliged to train and authorize others to carry out protocols of inspection that were authorized by IAEA.  These protocols would be highly technical and so would the level of expertise within the group of authorized subcontractors to IAEA 

Implementing such an inspection system would require expansion of IAEA, so that it could manage the inspection system, and the means of funding would be as discussed in the next section

5.3          The Only Viable Means of Meeting the Costs

IAEA is a UN agency, and is funded by member nations of the IAEA.  Considering the various political pressures that would apply, it could be difficult for the proposed inspection system to be funded through either the present system of  IAEA levies on individual nations, unless the funds were dedicated directly to the sites and numbers of individual inspections required. 

A viable means of meeting the costs of a truly credible inspection system would be to have a “user-pay” system, where the user is the individual nuclear power plant.  The cost of inspection would then become a part of the operating cost of every nuclear power plant.   In essence, the cost per kwH of electricity would include the cost of inspection.   The corporate entity that manages the inspection team would submit an invoice, for each service performed, to the corporate entity that runs the nuclear plant.  A portion of this fee would be submitted to IAEA, to support their portion of the services. The countries that have the largest nuclear generation of electricity would thus pay the largest proportion of the cost of the inspection system. This means that if North America and Europe chose not to build new capacity for nuclear power, they would not be paying for the substantial regulatory compliance cost of electricity production in Asia 

The key point is that the inspection system must be self-funding, and without subsidy. 

5.4          Short and Long Terms Goals for a Universal Regulatory Regime

The key to success is for ALL NATIONS, great and powerful, or relatively weak,  to acknowledge that  a universal regulatory regime is in their self-interest, and in the interest of global security, and affects all citizens of the world. 

Countries that have nuclear power plants today have national inspections systems and are not accustomed to the idea that a third party (recognized internationally) would be routinely involved in the inspection of nuclear power plants.  It would be a particularly big jump for nuclear weapons states (NWS) to accept such a regime because they are not subject to any international inspection at present, whereas the Non Nuclear Weapons States, that have ratified the Non-Proliferation Treaty, are already obliged to agree to international inspection.  Non-signatories to the NPT do not receive inspections. 

A comprehensive inspection and enforcement system would have to be designed so that it covered functional nuclear reactors, defunct nuclear reactors, research reactors, plants that manufacture the nuclear fuel supply, and the nuclear waste management system.  This is a major challenge, but could be managed over time, if the political will exists. 

Much of the benefit of the universal regime would be obtained by staying with the national inspection systems, even though the national inspectors are not true third parties to the nuclear power plants.  Thus, it would be best to set short term goals and longer term goals, as follows:

• SHORT TERM GOAL:  Universal inspections, under national regulations (that meet the highest standard enunciated by IAEA)  by national inspectors
• MID-TERM GOAL:  Universal inspections, under national regulations (identical in scope for all countries, adapted to the specific technology applied in the country), carried out by national AND third-party international inspectors. 
• LONG TERM GOAL:  Combine the two streams of inspection and enforcement that are the responsibility of IAEA and the international community:
  • Plant safety and plant security with respect to terrorism
  • Application of safeguards, per IAEA Additional Protocol, for verification of  the absence, or presence, of  material or activities that imply proliferation of the technology for weapons purposes. 

A credible and respected system would build confidence in the world’s citizens as they live and work in the vicinity of nuclear power plants. 

5.5          Sharing Expertise 

In countries where IAEA’s  recommended regulations have not been adopted, or national regulations need to be upgraded, bilateral or multilateral meetings would discuss the issues and hold training sessions.  Countries well versed in the technical aspects could transfer their technical knowledge to others.  For example, the Canadian Nuclear Safety Commission[13] (CNSC) states “Canada has a clear regulatory framework in place and is developing rigorous stands for physical protection of facilities and materials.  Assurance is obtained by verification of compliance and assessment of emergency preparedness and response “  and “ The CNSC, as the regulator of the nuclear industry in Canada, is committed to ensuring the licensees implement safety and security measures in accordance with Canadian and international standards.”  Within the Nuclear Suppliers Group, the United States is recognized as having the strongest and most protective safety regulations.  Enforcement is an integral part of a regulatory regime. Independent bodies in the US have recently made public their evidence that compliance is not always satisfactory.  Universal regulations regarding nuclear terrorism are to yet to be developed.

Considering the human resources required to do this right, building on the expertise of others would more quickly advance the technical tools for physical safety and terrorism prevention.   Technical information could be shared, presumably with limitations regarding the realities of commercial interests. 

6.0          Nuclear Waste Issues

6.1          Today’s situation

Nuclear waste is a stumbling block to those who would promote nuclear energy, because, in addition to low-level radioactive waste, the waste product of nuclear energy production is highly radioactive and long-lived.  Thus, strategies for disposal have created many years of controversy.  Nevertheless, the technical community has accepted the viability of secure centralized storage in a deep geological repository. No country has yet implemented such storage, but the country closest to achieving underground disposal is Finland.  That country is moving ahead with a project for underground disposal at Oikiluoto.  An article in Scientific American[14] reports that   “….spent fuel rods will be encapsulated in large canisters made of an inner shell of iron for mechanical strength and a thick outer shell of copper to resist corrosion.  The canisters will be placed in holes bored into the tunnel floors and surrounded by clay to prevent direct water flow to the canisters. The facility could begin accepting waste from Finland’s four nuclear reactors in 2020”.   The long awaited storage facility in Yucca Mountain in the United States, may never be approved as a result of unforeseen water problems. 

In Canada, the Nuclear Waste Management Organization[15] was given a mandate by the Government of Canada, reviewed every aspect of the situation with the input of world renowned experts and issued a report in November 2005[16].   The central recommendation is adaptive phased management of the waste, with use of a deep geological repository.  Adaptive management gives the flexibility to adapt to experience gained in earlier years of waste storage, and, most importantly, to also adapt to societal and technological changes.  During the Phase I program, there is provision for an optional step – relatively shallow storage with opportunity for retrievability, followed by later deep storage.   There would be continuous monitoring, sequential and collaborative decision making.  NWMO says that such storage could only be implemented, in Phase 1, at the earliest in 2035, and the final deep storage could be operational by 2065.  While this work seems thorough and rational, the delay in starting and the proposed time scale is beyond the comprehension of the ordinary informed citizen. 

At present, most nuclear waste is stored near to the site of its origin, which is, in many cases, near to large population centres.  As long as the nuclear reactors have a rugged fail-safe system, they are said to be well protected from a 9/11 type of terrorism, or from attacks on their central electrical control systems. (If this is not the case in every plant, then there is further reason for increased, enforced regulations to produce this degree of safety). There is an unacceptable exposure to potential terrorism through the presence of the waste.  Potentially, a terrorist attack could spread radioactive waste[17] over a large geographical area, thus endangering the lives of millions.  This situation, especially with the very long time lines projected for true storage of nuclear waste, is unacceptable.  There seems to be little public awareness of this dangerous situation.  Governments must be forced to move in a timely manner, but beyond citizen protests, a means of accomplishing this is unclear.  Also, it is not clear whether or not IAEA considers nuclear waste disposal a priority. 

Considering the nature of this very complex issue, nuclear waste processes also require standardization, third party verification and clearly need support from a well-honed international agreement. Considering the IAEA’s Multilateral Nuclear Approaches, MNA, one of the questions to be resolved is  - who owns the waste?  Again, the regime of certification and inspection of nuclear waste storage sites would be best managed by a user-pay type of system, so that there is an ongoing method financing the continuous monitoring required for such sites.

Where expertise exists, e.g. fuel container design, container retrieval technology, then it must be shared.  Mankind has insufficient resources to keep re-inventing technology.  Certified transport containers, also a potential subject for sharing of expertise, would be required for road, road/rail and water/road and so on.  Through an international rigorous regulatory system for nuclear power, the capability for any country to foster production or transport of material for nuclear weapons would be diminished or eliminated. 

6.2          The effect of scare-mongering

The public is rightly cautious about the safety of the nuclear power plant and the long term issues on handling of waste.   NGOs have made governments aware of their objections to satisfying increased requirements for electricity by using nuclear power.  This has, in the developed world, often resulted in an impasse for site approval.  Existing nuclear plants can add reactors[18], but fixing a site for new plants or permanent storage will be extremely difficult.  Due to the fear of release of radiation (founded in experience of past problems at nuclear plants, not with long term waste storage), now or in future times, the degree of risk is considered to be relatively greater than the array of other risks faced by society. This scaremongering prevents society from moving forward, and retains the risks at their present level, rather than taking steps to diminish them.

By way of comparison, consider neuro-toxic contamination with mercury from coal-fired power plants.  The present US approach is considered by state officials[19] to be highly flawed.  This is an environmental problem of extreme concern, to both present and future generations, because of the danger of permanent neurological damage, especially to infants.   A study of women in the United States[20] found that about five million women have mercury levels in their bodies above the level considered safe by the United States Environmental Protection Agency.   

Risks such as radiation (and mercury contamination) require vigilance by the public.  A strong, transparent and verified regulatory conformance would be an appropriate tool to demonstrate that strong protective safety measures are in place.  

7.0          Fuel Processing

7.1          Supply Guarantees

Agreement to implement a nuclear fuel cycle supply system has been confirmed at the G8 Summit, in Russia, July 2006.  This scheme, central to the Putin-Bush adoption of the Global Nuclear Energy Partnership, would create a central enrichment facility that would supply client countries with fuel for nuclear power plants.  Russia has proposed that it would produce fuel and collect spent fuel for Iran’s civilian nuclear program. 

A plant that provided nuclear fuel cycle supply would itself be a potential site for clandestine access to nuclear materials, and would require inspection by IAEA under the Additional Protocol.  Further, as proposed in this paper, there would be national and international regulations governing its safe and secure operation, and for conformance to these regulations, inspection would also be required. 

A rugged and transparent international nuclear inspection system with emphasis on inspection of fuel processing whether local or central, with participation by all countries, would be fair, and has potential to diminish the political problems associated with nuclear energy production.   

7.2          Political Problems with Iran

Iran has not complied with the Security Council’s deadline for relinquishing its enrichment program.  However, its response [21] indicates that it is open to negotiating and could be willing to adhere to the Additional Protocol. 

A recent  paper by Belfer Center[22],  points out that a viable solution needs to meet all sides’ bottom lines.  Iran does not want an agreement to be seen as diminishment of its national sovereignty, or its capability of application of state of the art technology.  It wants defense of its rights under the NPT and assurance against attack.  The United States, Europe and IAEA want no nuclear weapons development and full Iranian cooperation with verification, including resolution of questions about past nuclear activity.  A step forward may be possible. 

8.0          Future Times

8.1          New and alternate technology

As the nuclear reactors that exist and are to be built, reach the end of their useful life, better technologies should be available and economically competitive. Therefore, eventually, the onerous process of inspection to prevent nuclear proliferation would not  be part of the backdrop of electrical energy production. 

Nuclear generated electricity, when it exceeds demand, can readily be used to create hydrogen.  As use of alternative forms of energy increases, technology improvements and marked improvements in cost will both be present.  Maximizing alternate energy sources is very important, and all government policy should be so directed, so that use of nuclear energy is minimized.  Taking an optimistic view, a strict and enforced nuclear energy regulatory system could drive nations towards making a serious effort to use non-nuclear means to fill their energy needs.

8.2          Uranium supply issues

The known and projected supply of uranium ore will last only 60 years, unless more efficient new-technology reactors are used.  However, ominously for proliferation avoidance, reprocessed plutonium[23] can be used.   If reprocessing could be under a regulatory regime, safety and security would be greatly enhanced.   Fast nuclear reactor designs extract thirty times more energy from uranium, with less waste and less radiotoxicity.  Some parts of the technical community like the thorium fuel cycle, which is stated by IAEA[24] to have intrinsic proliferation resistance.     

9.0          Summary

Civil society activists have to come to terms with the reality that the need for energy security is driving the renaissance of nuclear reactors to supply electrical energy.  From this trend arises the necessity for universal international safeguards that address both physical safety and security from malicious intervention.  At present, IAEA inspection covers a limited number of countries, safeguarding only against proliferation.  All other safety and security regimes are voluntary within the international system, and regulated individually by each sovereign nation.  The service that peace activists can perform for global security is to advocate of immediate attention to defining, negotiating and adopting a universal agreement, covering all nations, and covering all aspects of the nuclear fuel cycle, including waste storage.  

Nuclear energy generation has the special characteristic that every nuclear reactor has a dangerous global presence.  Since nations will not choose to avoid nuclear energy, then it is in the self- interest of every nation that a universal inspection and verification system be adopted by all.  This goal, while difficult, is feasible over the long term if there is a true “level playing field”, and in the longer term there is true third party verification by experts external to the country in which the nuclear reactor is located.  This expensive regime is beyond the resources that would be available to the IAEA, unless a full “user-pay” system becomes a normal part of the business of nuclear energy generation.