Before the
Washington, D.C. 20555

In the Matter of

TRANSNUCLEAR, INC. Docket No. 11004997

(Export of 93.3% Enriched Uranium) License No. XSNM 03012

In the Matter of
Docket No. 11004998
License No. XSNM 03013
(Export of 93.3% Enriched Uranium)


Pursuant to Section 189a. of the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2239(a), and Section 304(b) of the Nuclear Non-Proliferation Act of 1978, 42 U.S.C. 2155a. (the "NNPA"), and the applicable rules and regulations of the United States Nuclear Regulatory Commission (the "Commission"), including 10 C.F.R. Part 110, Subparts H and I, the Nuclear Control Institute ("NCI" or "Petitioner") hereby respectfully petitions the Commission for leave to intervene as a party in opposition to the following export license applications:

(1) The Application of Transnuclear, Inc. ("Applicant"), dated October 27, 1997, for a license to export 26.738 kilograms of 93.3% enriched uranium to Canada for fabrication of target material, as published in the Federal Register on November 26, 1997 (62 Fed. Reg. 63205); and

(2) The Application of Transnuclear, Inc., dated October 27, 1997, for a license to export 3.005 kilograms of 93.3% enriched uranium to Canada for fabrication of target material.

In addition, Petitioner requests that the Commission order a full and open public hearing at which interested parties may present oral and written testimony and conduct any discovery and cross-examination necessary to resolve the factual and legal issues relevant to the Commission's determinations with respect to the pending license applications. Such a hearing would be in the public interest and assist the Commission in making its statutory determinations under the Atomic Energy Act, as provided for by Section 304(b) of the NNPA, 42 U.S.C. 2155a., and 10 C.F.R.  110.84.

I. Petitioner's Interests

Petitioner is a nonprofit, educational corporation, organized and existing under the laws of the District of Columbia, whose principal place of business is also in the District of Columbia. Its address and telephone number are: l000 Connecticut Avenue, N.W., Suite 804, Washington, D.C. 20036; (202) 822-8444. It is actively engaged in disseminating information to the public concerning the proliferation, safety and environmental risks attendant upon the use of weapons-useable nuclear materials, equipment, and technology. It develops strategies for halting the further spread of nuclear weapons and is deeply concerned with the inadequacies of present national and international systems for minimizing the use of such nuclear materials and safeguarding them against theft, diversion and other unauthorized uses.

NCI has undertaken special efforts to educate the public about the feasibility and desirability of eliminating bomb-grade (or "highly enriched") uranium ("HEU") from commerce in general and research reactors in particular and has strongly advocated the completion and full implementation of the Reduced Enrichment for Research and Test Reactors ("RERTR") program. Examples of its publications in the area include the January, 1991, Issue Paper, "Eliminating Bomb-Grade Uranium From Research Reactors"; its June 23, 1991, Washington Post "Outpost" article, "Politicians in the Lab . . . and Scuttling an Easy Way to Stop Nuclear Proliferation"; its September 1995 Issue Paper, "RERTR at the Crossroads: Success or Demise", circulated at the International Meeting on the RERTR Program in Paris, France; and its October 1997 Issue Paper, "RERTR End-Game: A Win-Win Framework", presented to the International Meeting on the RERTR Program in Jackson Hole, Wyoming, October 5-10, 1997. NCI has been a constant supporter of the RERTR program in testimony presented before the Advisory Committee on Reactor Safeguards and Congressional appropriations and authorization committees. It participated in the Department of Energy's proceedings to take back and dispose of U.S.-origin HEU spent fuel from foreign research reactors and in the Commission's own rulemaking to require conversion of licensed, domestic research reactors to non-weapons-useable fuel. It has been active in prior proceedings before the Commission relating to the export of HEU, specifically the proposed export of HEU to the HFR/Petten Reactor in the Netherlands (Dkt. No. 11004440, Lic. No. XSNM 02611) and the proposed export of HEU from the Fort St. Vrain reactor to France for reprocessing (Dkt No. 11004649, Lic. No. XSNM 02748).

Petitioner has important institutional interests which would be directly affected by the outcome of these proceedings. As noted above, it is actively involved in public information and education programs concerning arms control, the spread of nuclear weapons, and the risks of proliferation and nuclear terrorism in general and the use of HEU in particular. Its interest and ability to carry out these functions would be significantly and adversely impaired by the absence of a full, open and independent review by the Commission of the issues raised under the Atomic Energy Act and the NNPA by the pending license applications.

Petitioner has no other means to protect its interests in these proceedings, and those interests are not now represented by the existing parties. This Petition, moreover, is not interposed for delay or to broaden the proper scope of the proceedings. With respect to the first license application, it is timely filed, within 30 days of the publication of notice of the license application in the Federal Register, as required by 10 C.F.R.  110.82(c)(1). With respect to the second license application, Petitioner recognizes that this Petition comes more than fifteen (15) days after notice of receipt of the license application in the Public Document Room and thus outside the period within which intervention must ordinarily be sought in order to be considered "timely". See 10 C.F.R. 110.82(c)(2). However, there is "good cause" under 10 C.F.R. 110.84(c) for filing outside the fifteen day period. Because the application involves less than five kilograms of HEU, it was never publicly noticed in the Federal Register. See 10 C.F.R. 110.70(b)(2). Moreover, the Commission has discontinued its practice of mailing monthly reports of license applications to interested persons, upon which Petitioner has previously relied. Further, in this particular case, there can be no prejudice from the time of filing, since the first and second applications will presumably be considered by the Commission in tandem and identical issues are raised under each. Finally, Petitioner's contentions raise important questions concerning the appropriateness of continued commerce in and use of HEU, which is directly useable in nuclear bombs, and Petitioner submits that its participation will assist the Commission in developing a sound record.

II. Background

For many years, HEU has been used in the civil sector primarily to fuel research and test reactors around the world. It has also been used for the fabrication of target material for the production of medical isotopes, particularly Technetium-99m, which is a decay product of Molybdenum-99. However, its risks have likewise long been recognized. There have therefore been substantial efforts to curtail its use by substituting low-enriched uranium ("LEU"), which is not weapons-useable, capable of providing the same civilian benefits without significant economic penalty.

The risks associated with the circulation of HEU in commerce are self-evident. HEU was the material used in the Hiroshima bomb (Little Boy). According to the late J. Carson Mark, former head of weapons design at Los Alamos National Laboratory and a consultant to NCI, a "competent group" could build an implosion weapon with as little as about twelve kilograms of this material. [1]

Consequently, HEU is an attractive target for national diversion or seizure by terrorists. Indeed, the late Manhattan Project physicist Luis Alvarez once noted, "[W]ith modern weapons-grade uranium ... terrorists, if they had such materials, would have a good chance of setting off a high-yield explosion, simply by dropping one-half of the material on the other half." [2] Furthermore, the possession of this material in the hands of a Saddam Hussein or in a country such as Romania or the former Yugoslavia during a breakdown of civil order, or by terrorists who steal such material, would present a grave international threat. Unless quantities of HEU in commerce are substantially reduced, or eliminated, such risks are only likely to grow.

In recognition of the problems associated with continued reliance on HEU in research reactors, the United States instituted the RERTR program in 1978. Under the leadership of Argonne National Laboratory, this program has been developing high density, LEU fuels and targets -- material not suitable for fabrication into weapons but suitable for use in research reactors -- thereby allowing conversion to LEU and much reducing the amount of HEU in commerce. Its results have been impressive: the RERTR program has developed, tested, and qualified four types of LEU fuel "which make it technically possible to convert to LEU use some 95 percent of the 118 research reactors in 34 countries (36 in the United States and 82 in other countries)." [3] Of the 42 research reactors with power of at least one megawatt that were originally supplied with HEU fuel by the United States, 37 either have converted to LEU, are in the process of converting, or have no further need for fuel. [4]

Following the lead of the RERTR program, twelve large new research reactors constructed abroad since 1978 have been designed to use LEU fuel, including reactors in Japan, South Korea and Indonesia. China recently joined this international consensus by designing its next research reactor to use LEU fuel. [5]

U.S. policy has also been strongly in favor of reducing use of HEU. Thus, the Commission itself for more than fifteen years has sought to "reduc[e], to the maximum extent possible, the use of HEU in ... foreign research reactors." See 47 Fed. Reg. 37007 (August 24, 1982). The same Policy Statement affirms that "any reduction in the potential for access to these [HEU] inventories would constitute a reduction in the proliferation risk." Moreover, domestically, the Commission has since 1986 been requiring all licensed research reactors to convert to LEU. See 51 Fed. Reg. 6514 (February 25, 1986). In taking this action, the Commission asserted that the "domestic conversions are intended to be put on solid footing by setting a strong, resolute and sensible example, consistent with U.S. national policy, to encourage foreign operators of non-power reactors to convert to the use of LEU fuel." Id. at 6516. [6] In recognition of such policies, in 1995 the United States abandoned plans for a new HEU-fueled research reactor, the Advanced Neutron Source, at least partly because the bomb-grade fuel presented "a non-proliferation policy concern." [7]

In 1986, Congress first acted specifically to curb the risks associated with commerce in HEU. It passed the Omnibus Diplomatic Security and Anti-Terrorism Act, calling upon the President "to take, in concert with United States allies and other countries, such steps as necessary to keep to a minimum the amount of weapons-grade nuclear material in international transit." See Omnibus Diplomatic Security and Anti-Terrorism Act of 1986, Pub. L. No. 99-399, Sec. 601(a)(3)(A) (August 27, 1986). [8] Under this legislation, HEU exports were limited only to those countries "... which have cooperated closely with the U.S. in the Reduced Enrichment for Research and Test Reactors (RERTR) Program. Exports have further been limited to supply of only those research reactors which either cannot be converted at present to LEU fuel or which need additional HEU fuel while in process of conversion to LEU." 1991 Annual Report Under Section 601 of the NNPA, 22 U.S.C. 3281 (July 2, 1992), at 77. Finally, Section 603 of the 1986 law added a new Section 133 to the Atomic Energy Act, 42 U.S.C. 2160c., specifically requiring Commission consultation with the Secretary of Defense concerning the adequacy of physical security in connection with any proposed export or transfer of HEU.

Most pertinent to the pending license applications, Congress again dealt with commerce in HEU in Title IX, Section 903, of the Comprehensive National Energy Policy Act, Pub. L. No. 102-486, 106 Stat. 2944, enacted October 24, 1992 (the "Schumer Amendment"). The Schumer Amendment added a new Section 134 to the Atomic Energy Act, 42 U.S.C.  2160d., which limits the circumstances in which any HEU can be exported for use as a fuel or target in a research or test reactor. As its principal author stated, "[T]his bill codifies once and for all that bomb grade uranium is simply too dangerous to continue indefinitely shipping it overseas for non-military purposes". 138 Cong. Rec. H. 11440 (daily ed., Oct. 5, 1992). Under the Schumer Amendment, no HEU exports are permitted for use in a research or test reactor unless three conditions are met:

(1) there is no alternative nuclear reactor fuel or target enriched in the isotope 235 to a lesser percent than the proposed export, that can be used in that reactor;

(2) the proposed recipient of that uranium has provided assurances that, whenever an alternative nuclear reactor fuel or target can be used in that reactor, it will use that alternative in lieu of highly enriched uranium; and

(3) the United States Government is actively developing an alternative nuclear reactor fuel or target that can be used in that reactor.

42 U.S.C. 2160d.(a)(1)-(3). It was expected that, under the Schumer Amendment, all HEU exports could be phased out "within 5 years," assuming the RERTR fuel/target development program were restarted. In the absence of continued funding for the RERTR program, the only option would be to "cut off the bomb-grade exports immediately." See 138 Cong. Rec. at H. 11440 (Statement of Rep. Schumer).

The Commission's regulations fully incorporate the requirements of the Schumer Amendment. They provide that no HEU may be exported unless the Commission determines that:

(A) There is no alternative nuclear fuel or target enriched to less than 20 percent in the isotope U-235 that can be used in the reactor;

(B) The proposed recipient of the uranium has provided assurances that, whenever an alternative nuclear reactor fuel or target can be used in that reactor, it will use that alternative fuel or target in lieu of highly-enriched uranium; and

(C) The United States Government is actively developing an alternative nuclear reactor fuel or target that can be used in that reactor.

10 C.F.R. 110.42(a)(9)(i). In accordance with 42 U.S.C. 2160d.(b)(3), the Commission's regulations further define the phrase "can be used" to mean that (A) the fuel or target has been "qualified" by the RERTR program and (B) "Use of the fuel or target will permit the large majority of ongoing and planned experiments and isotope production to be conducted in the reactor without a large percentage increase in the total cost of operating the reactor." 10 C.F.R. 110.42(a)(9)(ii).

The HEU at issue in these proceedings is not intended to be used as reactor fuel but rather as target material for the production of medical isotopes, e.g., Molybdenum-99, the precursor of Technetium-99m. The material covered by the first application is intended for use in the NRU reactor operated by Atomic Energy of Canada Ltd. ("AECL") at its Chalk River Nuclear Laboratories in Chalk River, Ontario. The need for this material is uncertain. Applicant's transmittal letter states, "[T]his material may not be required. It will only be required if there is a slippage in the schedule for development of a new HEU UO2 target and on the construction of the new Maple LEU fueled reactors at AECL/CRL." [9] The material covered by the second application, likewise intended for use at Chalk River by AECL, is stated to be "part of a development program of a new HEU target to be used in the production of medical isotopes." Applicant's transmittal letter states that the target will be irradiated in the NRU reactor and that, "[w]hen the new HEU UO2 target is qualified, future irradiations will be in the new Maple Reactors to be built at AECL, Chalk River Labs."

Technetium-99m "is the most commonly used medical radioisotope ... relied upon for over nine million medical procedures each year in the U.S. alone, comprising over 70% of all nuclear medicine procedures." [10] Because it has typically been produced through the fissioning of HEU targets in research reactors, developing targets and chemical processes for producing this isotope using LEU has been an "important component" of the RERTR program. [11] Within the RERTR program, substantial progress has been made, and, "Experimental results continue to show the technical feasibility of converting current HEU processes to LEU." [12]

An array of alternative, target development activities is underway at Argonne National Laboratory. [13] However, NCI, based upon its participation in the recent Jackson Hole meeting and discussions with Argonne officials, understands that these do not include actively developing an LEU target which can be used in the NRU reactor at Chalk River or in the new Maple reactors, which are identified in the license applications as the eventual users of the newly-qualified HEU targets. A significant outstanding technical issue is whether the LEU foil targets being developed at Argonne are compatible with the chemical dissolution and separation process currently used by Canada for extracting Mo-99 from irradiated HEU targets. It is NCI's understanding that Canadian authorities take the position that their process is not compatible with the LEU targets under development at Argonne.

At the same time, NCI understands that a principal impediment to development of useable LEU targets is the absence of the requisite information and cooperation from Canadian authorities that are needed for an active development program to proceed. Upon information and belief, Canadian authorities have not provided Argonne with the information necessary to verify claims of incompatibility and to identify problems that require resolution to make it possible for Argonne actively to pursue an alternative LEU target development program for the Canadian reactors. Nor have Canadian authorities granted requests from Argonne staff to travel to Chalk River and observe the Canadian process. The failure of Canada to provide needed information and cooperation renders nugatory any assurances it may have made that it would convert the reactors to LEU use upon development of suitable LEU targets. [14]

Obviously, in the circumstances just described, the intended use of the HEU covered by the pending applications directly implicates the laws, regulations and policies discussed above. Indeed, the export of HEU for the development of new HEU targets cannot be squared with the RERTR program objective of developing alternative LEU targets. There are, in short, serious questions with respect to the consistency of the proposed exports with the Schumer Amendment, the need for the HEU targets within Canada and the acceptability of the proliferation and terrorism risks associated with the pending applications. These questions deserve in-depth consideration by the Commission before any licensing decision is made.

III. Petitioner's Contentions

As set forth in paragraph (a) below, approval of the proposed exports would be contrary to the requirements of the Schumer Amendment, Section 134 of the Atomic Energy Act of 1954, as amended, 42 U.S.C.  2160d., and the Commission's implementing regulations, 10 C.F.R. 110.42(a)(9). Further, in accordance with Section 53 of the Atomic Energy Act of 1954, as amended, 42 U.S.C.  2073, and 110 C.F.R.  110.42(a)(8) and 110.45(a), the Commission may not issue a license for the export of special nuclear material, such as the HEU at issue in these proceedings, unless it determines that "[t]he proposed export would not be inimical to the common defense and security." For the reasons set forth in paragraph (b) below, Petitioner submits that this requirement cannot be met by the pending license applications.

(a) The Proposed Exports Would Be Inconsistent with the Schumer Amendment and the Commission's Implementing Regulations.

The proposed exports would be inconsistent with the Schumer Amendment and the Commission's implementing regulations in at least two respects. First, Argonne National Laboratory is not "actively developing an alternative nuclear reactor ... target that can be used" in either the NRU or Maple reactor, within the meaning of Section 134a.(3) of the Atomic Energy Act, 42 U.S.C. 2160d.(a)(3), and 10 C.F.R. 110.42(a)(9)(i)(C). Second, because Argonne National Laboratory has not received the information and cooperation it needs from Canada in order to be able to undertake active development of LEU targets, the Commission cannot find that Canada has provided sufficient "assurances that ... it will use ... [an] alternative ... target in lieu of highly enriched uranium" in the NRU and Maple reactors, within the meaning of Section 134a.(2) of the Atomic Energy Act, 42 U.S.C. 2160d.(a)(2), and 10 C.F.R. 110.42(a)(9)(i)(B). Because neither of these mandatory requirements of the Schumer Amendment and the Commission's implementing regulations is satisfied, the Commission must deny the pending license applications.

(b) The Proposed Exports Would Be Inimical to the Common Defense and Security.

The proposed exports would be inimical to the U.S. common defense and security in several respects. First, to the extent positive Commission licensing action could imply U.S. government approval of either domestic or foreign use of almost 30 additional kilograms of HEU in research or test reactors, this would undercut the RERTR program, exacerbating the risk that operators who have not yet converted their reactors to use of alternative LEU targets would refuse to do so and that operators who have converted would revert to HEU use, contrary to the United States' non-proliferation interests. These risks are very real, with regard to fuel as well as target material. Among other consequences, shipment of HEU to Canada may hinder efforts (i) to discourage Russia from exporting 625 kilograms of HEU for use at France's ILL-Grenoble and Orphee reactors; (ii) to persuade Germany to drop plans for the FRM-II reactor, the first reactor in the West (with power of at least one megawatt) built to use bomb-grade fuel since the establishment of the RERTR program; (iii) to convince the operators of various reactors, including the JRC's HFR/Petten Reactor, South Africa's Safari I reactor, France's HFR and Orphee reactors, and Belgium's BR-2 reactors, to convert to LEU use; and (iv) to continue to engage Russia and China under recent agreements expanding the scope of the RERTR program. Second, approval of the pending application would lead to increased international transport of weapons-useable material, aggravating the risk of interception by rogue states, criminals or terrorists, Third, especially since Applicant states that 26-plus kilograms covered by the first application may not even be needed by AECL, the nuclear proliferation and terrorism risks associated with increasing amounts of HEU in international commerce necessarily outweigh any hypothetical benefits to Applicant or others from the proposed exports. In a world in which major efforts are underway to eliminate HEU surpluses, putting more into circulation makes little sense. [15] In light of such considerations, the grant of the pending license applications cannot be squared with U.S. common defense and security interests.

IV. The Need for a Full Oral Hearing

A full oral hearing to examine Petitioner's contentions is essential both to serve the public interest and to assist the Commission in making its statutory determinations. Such a hearing would fulfill the Commission's mandate to explore fully the facts and issues raised by export license applications, where appropriate through full and open public hearings in which (a) all pertinent information and data are made available for public inspection and analysis and (b) the public is afforded a reasonable opportunity to present oral and written testimony on these questions to the Commission. See 42 U.S.C. 2155a. and 10 C.F.R. 110.40(c), 110.80-110.91, 110.100. [16]

There is substantial controversy surrounding any continued use of bomb-grade uranium. Indeed, the questionable wisdom of permitting commerce in HEU has been sharply illustrated by disclosures that Iraq had begun to divert safeguarded HEU for the purpose of converting it to weapons-use prior to the Gulf War and by the actions of the United States, its allies and the International Atomic Energy Agency to remove the HEU in the possession of Iraq after the conclusion of the War. Similarly, after the fall of Romania's Communist government, the U.S. sought and won in 1991 permission to convert all unirradiated HEU fuel elements owned by the Romanian government to LEU. Only a public hearing in which issues related to the continued appropriateness of exporting HEU are fully aired and subjected to public scrutiny will serve to resolve legitimate public questions concerning both the need for granting these license applications and the risks associated with such action. Certainly, the unchallenged assertions of Applicant and/or the Executive Branch are not enough to satisfy the public interest in the case.

Petitioner includes among its directors, staff and supporters individuals with broad experience and expertise in technical and policy matters directly relevant to the risks and implications of the proposed exports. Additionally, it has expert consultants fully familiar with all aspects of the RERTR program. These individuals would bring to the instant proceeding perspectives which are presently lacking and are pivotal to an understanding and resolution of the factual and legal issues raised by the pending license applications.

IV. Relief Requested

For the reasons set forth above, Petitioner respectfully requests that the Commission:

1. Grant this Petition for Leave to Intervene;

2. Order that an oral hearing be held in connection with the pending license applications; and

3. Act to ensure that all pertinent data and information regarding the issues addressed by Petitioner be made available for public inspection at the earliest possible date.

Respectfully submitted,

Eldon V.C. Greenberg
1000 Potomac Street, N.W.
Suite 500
Washington, D.C. 20007
(202) 965-7880

Attorney for Petitioner

Dated: December 29, 1997
Washington, D.C.

End Notes

1. Mark, "Some Remarks on Iraq's Possible Nuclear Weapon Capability In Light of Some Known Facts Concerning Nuclear Weapons" (Nuclear Control Institute, May 16, 1991), at 2.

2. Alvarez, Adventures of a Physicist 125 (Basic Books 1987).

3. ERC Environmental and Energy Services Co., Review of the RERTR Program (Report submitted to the U.S. Department of Energy, May 15, 1990), at 3-3.

4. Three of the remaining reactors, two in France and one in Belgium, cannot yet convert. Operators of the other two, the European Union's HFR/Petten reactor in the Netherlands and the Safari I reactor in South Africa, so far have declined to convert to available, non-weapons-useable fuel.

5. Shi Yongkang, et al., "The China Advanced Research Reactor Project", and Yuan Luzheng, et al., "Preliminary Study of Core Characteristics for the Scheduled CARR", presented at the Fifth Meeting of the Asian Symposium on Research Reactors, Taejon, Korea, May 29-31, 1996.

6. Commission policy, it should be noted, has reflected the consistent views of the Executive Branch that it is important to U.S. non-proliferation policy to minimize the amount of HEU in international commerce. See Presidential Non-Proliferation Policy Statement of April 7, 1977, 13 Weekly Comp. Pres. Doc. 507 (April 11, 1977); U.S. Nuclear Non-Proliferation and Cooperation Policy (July 16, 1981), 17 Weekly Comp. Pres. Doc. 769 (July 20, 1981); 1991 Annual Report under Section 601 of the NNPA, 22 U.S.C.

7. 3281 (July 2, 1992), at 77.

8. U.S. Department of Energy, "DOE Facts: A New Neutron Source for the Nation" (February 1995).

9. Congress had previously passed resolutions supportive of Executive Branch efforts to reduce HEU use. See S.J. Res. 179, 97th Cong., 1st Sess. (July 27, 1981); S. Con. Res. 96, 97th Cong., 2d Sess. (May 27, 1982).

10. While the export of this material, as noted in the Applicant's transmittal letter, was previously approved by the Commission, that approval occurred in May 1992, prior to enactment of the Schumer Amendment; Executive Branch views, as far as appears from a search of the Commission's Public Document Room, seem never to have been submitted to the Commission; and the license issued (XSNM 02667) expired in May 1996. Such prior approval, therefore, has no bearing upon the issues raised by this Petition.

11. See Snelgrove, et al., "Development and Processing of LEU Targets for 99Mo Production", Proceedings of the Topical Meeting on Advances on Nuclear Fuel Management, Myrtle Beach, South Carolina, March 23-26, 1997.

12. Id.

13. Vandergrift, et al., "Progress in Chemical Processing of LEU Targets for 99Mo Production -- 1997", Paper presented at the International Meeting on the RERTR Program, Jackson Hole, Wyoming, October 5-10, 1997.

14. See Snelgrove, et al., supra; Vandergrift, et al., supra.

15. Although at the time of the previous license Canada stated that it intended to "[p]hase-out HEU use by 2000," nonetheless it now appears, given Canada's proposed development of a new HEU target, that this promise may not be fulfilled.

16. The United States has already committed, at an estimated cost of several billion dollars, to purchase 500 tons of Russian HEU, all of which is to be blended down to LEU to remove the bomb-grade material from international commerce and eliminate any risk of diversion to weapons. Approving the proposed export would be at cross purposes with this major U.S. post-Cold War initiative.

17. The Commission's regulations, it should be noted, include specific recognition that public participation and input are encouraged. 10 C.F.R. 110.81(a).

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