August 30, 2002
Dear Chairman Meserve,
We are writing with regard to the request by Nordion, Inc. to amend its existing export license (XSNM 03171/03, Federal Register, July 31, 2002) to export an additional 15 kg of highly enriched uranium (HEU) for the production of medical isotopes at its NRU reactor and associated processing facility in Canada. This would be the third amendment to the license, and comes hard on the heels of the Commissions approval of both the original license and the first two amendments, each for the export of 10 kg of HEU for the same purpose. Nordion contends that its latest request is motivated by the need to continue producing isotopes at its old NRU facilities because of further unexpected delays in start-up of commercial isotope production at its new Maple reactors and associated New Processing Facility.
As with the original license and the first two amendments, the Nuclear Control Institute does not oppose this new request. However, we remain concerned with how its approval could affect implementation of Nordions other existing export license (XSNM 03060) for export of HEU targets for isotope production at the Maple facilities, including Nordions pledge to convert such production to LEU targets. As you know, implementation of that pledge is a continuing requirement for further exports of HEU Maple targets under the Schumer Amendment of the Energy Policy Act of 1992. NCI will detail these concerns in a forthcoming correspondence to the Commission, no later than September 15, 2002, in response to Nordions annual progress report on conversion (submitted to the NRC on May 31, 2002) and request to amend the Maple export license (XSNM 03060/02, Federal Register, August 16, 2002).
Regarding the matter at hand, the proposed third amendment to the NRU export license, we merely would urge the Commission to continue the precedent it has established in approving the original license and first two amendments: namely, initially approving the export of only 5 kg of HEU, and requiring the applicant to demonstrate need prior to exporting each successive 5 kg batch.
Alan J. Kuperman Edwin Lyman
Senior Policy Analyst President