ML20244C285

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Requests Commission Authorization to Issue GE Proposed License XSNM-2010 to Export Low Enriched U to Norway
ML20244C285
Person / Time
Issue date: 05/03/1983
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-PINV, TASK-SE SECY-83-164, NUDOCS 8305160168
Download: ML20244C285 (20)


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POLICY ISSUE Phy 3,1983 SECY-83-164 (Notation Vote) l

'For:

The Commission From:

William J. Dircks Executive Director for Operations

Subject:

APPROVAL OF A PROPOSED LICENSE TO EXPORT LOW ENRICHED URANIUM TO NORWAY (LICENSE NUMBER XSNM02010)

Purpose:

Comission review of proposed issuance of subject license to General Electric Company.

Discussion:

On January 6,1983, General Electric Company filed an application for a license to export a total of 34 irradiated fuel segments to Denmark and Norway for test purposes (application at Appendix A). The total amount of material involved is 26 kilograms of uranium enriched to 4.0% U-235 and 180 grams of proauced plutonium.

Twelve fuel segments containing 9 kilograms of uranium and 70 grams of plutonium will be shipped to the Riso National Laboratory in Denmark and 22 segments containing 17 kilo-grams of uranium and 110 grams of plutonium will be shipped to the Halden Institute of Energiteknikk in Norway for test irradiation and post-irradiatiorGxamination.

While this application involves small quantities of low enriched uranium and plutonium on which the staff would otherwise have the authority to act, this request is being forwarded to the Commission according to the July 28, 1980 men)orandum from the Secretary to the Executive Director for Operations which requires Comission review of any proposed export of source or special nuclear material to a country following passage of the NNPA in 1978.

No application i

has been received and considered by the Commission for the I'

export of SNM to Norway since passage of the NNPA.

(Exports to Denmark have been considered in connection with the previous cases for Euratom, i.e., XSNM01168, SECY-78-179 and others.)

CONTACT:

OW R. Neal Moore, IP

'N (49-27984)

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TA The Commission 2

Discussion:

Executive Branch Views:

(Continued)

In response to our March 11,1983 request for views the Executive Branch, on April 11 (Appendix B):

1.

concluded that the requirementsof the Atomic Energy Act, as amended by the Nuclear Non-Proliferation Act of 1978, have been met and that the proposed export would not be inimical to the common defense and security of the United States; 2.

confirmed that the proposed export is subject to all the terms and conditions of the Agreement for Coopera-tion between the Government of the United States and the Government of Norway concerning Peaceful Uses of Nuclear Energy, which entered into force on June 8,1967.

This was confirmed by a letter from the Embassy of Norway on February 3,1983,a copy:The staff notes that of which is attached to the Executive Branch views, i

the Norwegian letter of confirmation states that the Agreement entered into force March 26, 1970.

This is the date that an amendment to the Agreement of 1967, adding a new paragraph to Article VIII providing for limited transfer of U-233 to Norway, entered into force].

[The Executive Branch response also states that the proposed export to Denmark is subject to all the terms and conditions of the additional Agreement for Cooperation with Euratom and provides the assurances necessary for the approval of the shipment to EURATOM].

Staff Analysis:

l Norway is a party to the Treaty on the Non-Proliferation of j

Nuclear Weapons (NPT). Norway also signed a comprehensive safeguards agreement with the IAEA under Article III of the Treaty, which entered into force March 1,1972.

With regard to the criteria in Sections 127 and 128 of the Atomic Energy Act:

--With respect to the safeguards criterion the U.S.-44crway Agreenent provides:

For the assumption by the IAEA of responsibility for applying safeguards to materials and facilities subject to safeguards under the U.S.-Norway Agreement (Article VII.A);

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The Comission 3

Discussion:

.The U.S. has the right to require safeguards on (Continued) equipment or material or any material utilized in, recovered from,or produced through the use of supplied material or equipment [ Article X.B.2(c)(ii)];

--With respect to nuclear explosives use, as a party to the NPT, Norway is comitted not to acquire, develop or manufacture nuclear explosive devices for any purpose. This comitment will apply to the proposed export and to any special nuclear materiel produced through its use.

--hith respect to physical security in Norway the Government of Norway has assured the U.S. that physical protection measures providing as a minimum a level of protection comparable to that set forth in IAEA INFCIRC/225/Rev. I will be maintained with respect to all nuclear materials exported from the U.S. to Norway and to any special nuclear material produced in or through the use of such material. The Executive Branch advises that it has determined the physical security measures applied in Norway will be adequate for the material covered by the license application and for the facility intended to receive it.

--With respect to retransfers, the U.S.-Norway Agreement for Cooperation provides that no material, equipment or devices transferred to and under Norway's jurisdiction pursua 2 to the Agreement and any special nuclear material produced through the use of any such material or equipment shall be transferred to.: unauthorized persons or beyond Norway's territorial jurisdiction except as the parties may agree.

Thus, U.S. approval is required for retransfer of the material proposed to be exported or any special nuclear material produced through its use.

--With respect to reprocessing, Article VII.H. of the U.S.-Norway agreement stipulates that when any special nuclear material received from the U.S. requires reprocessing such reprocessing shall be performed at the discretion of the Commission in e,ither Commission facilities o'r facilities acceptable to the Comission, on terms and conditions to be later agreed. This same article further stipulates that the form and content of any irradiated fuel elements shall not be altered after I

their removal from the reactor prior to delivery to the Commission for reprocessing.

Thus, the U.S. has approval right over reprocessing or alteration in form or conteht of any U.S.-supplied material or material produced through its use.

The staff notes in this connection that U.S. approval for the irradiation and post-irradiation examination in Norway of the material proposed for export would be given upon approval of the export license.

--The proposed export does not involve the transfer of sensitive nucletr technology.

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The Comission 4

i Discussion:

--With regard to the full-scope safeguards requirement of (Continued)

Section 128 of the Atomic Energy Act, as a party to the NPT, Norway has accepted IAEA safeguards en all of its nuclear activities.

International' The International Safeauards and Foreion Physical Security Safeguards and Review section prepared by the Office of Nuclear Material Foreign Safety and Safeguards is attached as Appendix C.

Physical Security Review

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Conclusion:==

Based on the above, the staff concludes that the proposed export meets the requirements of the Atomic Energy Act of 1954, as amended by the NNPA of 1978, and that issuance of the proposed license will r.ot be inimical to the common defense and security of the United States.

Recommendation: That the Comission authorize the issuance of the proposed license to General Electric.

Scheduling:

The 60-day period for Comission review of this application expires on June 12,1983; the 120-day period expires on August 11, 1983.

The applicant has advised that shipment about May 17 should occur if current reactor loading schedules in Denmark and Norway are to be met.

Will

J. Dircks Executive Director for Operations q

Appendices:

A-Application fm.

General Electric dtd. 1/6/83 B-Executive Branch views dtd. 4/11/83 C-Int'l Safeguards and Foreign Physical Security Review L---___-____-______________

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Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Friday, May 13, 1983.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Tuesday, May 10, 1983,.with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires cdditional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of.when comments may be expected.

DISTRIBUTION:

Commissioners OGC OPE OCA OIA OPA EDO ELD SECY 1

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APPENDIX A

l FORM NR'C4 "

,.S. NUCLEAR REGUtAT*RY COMMISSION

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/.PPROVE D BY GAO

"-78f APPLICATION FOR LICENSE TO EXPORT NUCLkAR s.1s022 sires 2:

13 CF R 110 MATER lAL AND EOUlPMENT(SeeInstructions on Rtversel' D. APPUC ANT *S REFERENCE 2.NRC

[e L) CENSE NO.

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1. APPLICANT'S je. DATE oF APPLICATION 01-06-83 BDW-005-83 uSE q $ 4T M g S g / d

/M6 70 75 uSE

3. APPLICANT'S NAME AND ADDRESS l Ris ZGR L SUPPLIER'S NAME' ND ADDRES$

lRIS YEB (Comporte of applicant es not suppher of meteria!!

Gcneral Electric Co., Attn: B.D. Wilson MC 87 3 G33.f& If) n..

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'8 D STREET ADoRESS e.NAME 175 Curtner Avenue General Electric Company D.STREETpOORJ $

c. CLTY STATE ZIP CODE Sen Jose CA 95125 ValTeCit'd Nelear Center l' f
  • 9* m. - L a, 't 4 4.EPMoN E NUM eE R (Ares Coat - Aumcer - Emtensson>
c. CITT '"**8 L ht leg 3

$ TATE ZirCooE Pleasanton CA 94566 (408) 925-1380

5. FihST SHIPMENT
6. FINAL S-IPMENT 7. APPLICANTS CONTRACTUAL' B. FROPOSED LICENSE
9. US.DEP ARTMENT OF ENERGY SCHEDULED SCHEDULED DELIVERY DATE EXPlRATION DATE CONTRACT NO. (if Known/

Msy 2, 1983 December 1984 N/A Dec. 31, 1984 N/A

11. ULTIMATE END USE l
10. ULTIMATE CONSIGNEE l RtB

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U""#*"'*'d"'"*'"'#

e.NAME a) Riso National Laboratory b) Institutt for Energiteknikk Test irradiations and post-irradiation examination to obtain additional fuel D. STnEETpDgRg M m m,,

performance data. Reactors = A, DR-3;

""*~$d*}o~dSSN",* Denmark DR-3 May 1983 11a. EST. DATE OF FIRST USE M ts a,a -

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12. INTERME'DIATE CONS'idt t l RI$
13. INTERMEDI ATE END USE l

e.NAME

c. STREET ADORES $
c. CITY - ST ATE - count RY 13s. EST. D ATE OF FIRST USE
14. INTERMEDI ATE CON $tGNEE l Rs3

'l 15. INTERMEDIATE END USE l

s.NAuf m, STRE ET ADDRESS

c. CITY - ST ATE - CoVNTRY 1Sa. EST.DATE OF FIRST USE 15.
17. DESCRIPTION
18. MAX. ELEMENT 19. MAX. 20. MAX 21.

NRC linclude che_mical and phys > cal form of nueIrv snervant, g*ve costseeslut of wElGHT WT %

tSOTOFE WT.

UNST USE nuetror to *pment and componentsf Fully Clad, irradiated fuel as follows:

KG A.

RISO 12 test segments 9

4.0

.125 U-235

.070 Pu B.

HALDEN 22 test segments 17 4.0

.250 U-235

.110 Pu Total Export (see Item 25):

34 Segments 26

.375 U-235

.180 Pu

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22. COUNTRY OF ORIGIN.-

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)23. COUNTRY OF ORIGIN: SNM l

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SOURCE MATERIAL WHERE ENRICHED OR PRODUCED SA F EGU ARDS (tr Known/

USA USA

25. ADDITICNAL SNFORM ATION (Use sepsvare sheet if nectuaryl Export in GE 600 or 1600 series Cask to Riso (Denmark) where 12 segments will be removed, the remaining 22 segments proceeding to Halden.
26. The applicant comfies that this apphcation is prepared in conformity with Tctte 10. Code of F ctoral Regulations, and that oil information in this application is careect to the t>est cf his/her k nowledge.

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APPENDIX B 1

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XSNM02010 NORWAY & DENMARK BUREAU OF OCEANS AND INTERNATIONAL 53 Og g o )()

ENVIRONMENTAL AND SCIENTIFIC AFFAIRS April 11, 1983 MEMORANDUM FOR JAMES R. SHEA NUCLEAR REGULATORY COMMISSION Enclosed is an Executive Branch analysis covering a license application for the export to Norway and Denmark of low-enriched irradiated uranium fuel for further irradiation in the DR-3 and Halden research reactors and post-irradiation examination..

In accordance with the Atomic Energy Act, as amended, the analysis explicitly addresses how the requirements of Section 126 a.(1) of the Atomic Energy Act are met, including the specific criteria of Sections 127 and 128, as well as certain additional factors envisaged by Section 126 a.(1).

A detailed analysis for EURATOM including Denmark was submitted December 8,1978 for NRC applications XSNM01212,-1232 and -1241. In view of Executive Order 12409 extending the duration of the period specified in the first proviso to section 126 a(2) of the Atomic Energy Act, as amended, to March 10,1984, that detailed analysis remains valid. There hasbeen no other material change in circumstances since that submission.

The Executive Branch, on the basis of its review of this case, has concluded that the requirements of the Atomic Energy Act, as amended by the Nuclear Non-Proliferation Act of 1978, have been met and that the proposed export would not be inimical to the common defense and security of the United States.

Moreover, Norway and EURATOM have adhered to the provisions of their Agreement for Cooperation with the United States.

Therefore,,the Executive Branch recommends that the requested export

. license be issued.

James B. Devine

' Deputy Assistant Secretary s

Enclosure:

As stated.

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EXPORT LICENSE APPLICATION ANALYSIS XSNM02010 Countries:

Denmark and Norway Transaction:

Export of.125 kilogram and.'070 kilogram of produced plutonium -

contained in 9 kilograms of uranium enriched to 4 percent and.25 kilogram-U-235 and.11 kilogram of produced -

plutonium contained in 17 kilograms of.

uranium enriched to 4 percent in the form of irradiated fuel segments Applicant:

General Electric Company Date of Application:

January 6,1983 Purpose of Export Twelve irradiated fuel segments will be shipped to the Riso National Laboratory in Denmark and twenty-two test segments to the Halden Institutt for Energiteknikk in Norway for test irradiation in the Danish DR-3 and the Norwegian Halden research reactors followed by post-irradiation examination to obtain additional fuel performance data.

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NI Mr. 3, John A. Griffin i

Dire'etorf Division of Politico-Military 1

l Securi,ty Affairs U.S. Department of Energy Washington, D.C. 20585

Dear Mr. Griffin,

With reference to your letter of 27 January concerning an application for license to export nuclear material (License No XSNM 2010), I take pleasure in confirmin5 as follows:

The transfer of the material, as identified a.

on the license application, will be subject to all of the terms and conditions of the agreement for cooperation, which entered into force on March 26, 1970, concerning the civil umes of atomic energy between the Government of the United States and t'ne Government of Norway.

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The ultimate consignee, Institutt for Energi-teknikk, Halden, Norway, is authorized by the Government of Nor.;ay to receive and possess the material.

Sincerely,

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.ld Aasheim Secretary of Embassy Cc: Institutt for Energiteknikk Postbok: 40

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. DELEGATION OF THE COMMISSION OF THE EUROPEAN COMMUNITIES EURATOM SUPPLY AGENCY Washington D.C., February. 7 1983' JM/ck.

Mr.~ John A.' GRIFFIN Director, Div. of Politico Military security Affairs

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US DOE.

Forrestal Building, Room 4 B 044 1000 Independence Ave.,S.W.

WASHINGTON D.C. 20585

Subject:

General Electric Co., applic. BDW-005-83.

of January 6, 1983, for export of LEU and P u

Refer.:

XSNM- 0201Df

Dear Mr. Griffin,

We certify that the material mentioned in this application, namely 0.125 kg of U plus 0.70 kg of P 235 u

contained in 9 kg of total uranium and the transfer of L

this material will be subject to all terms and conditions of the Additional Agreement for Cooperation ~ dated July i

25, 1960, as amended.

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Further, we certify that Risd National Laboratory l

Roskilde, Denmark, as ultimate consignee is authorized by Euratom to receive and possess this material pursuant to the aforementioned Agreement for Cooperation.

The above mentioned material will be used in test irradiations and post-irradiation examination at the DR-3 reactor in Risd, Denmark, cerely cc.: Mr.

R. De LaBarre, Departmt. of State Ms. Betty Wright, j,. = -

N.R.C.

Mr. B.D. Wilson ktretay General Electric Co._ _, _ _ _ _

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Applicable Agreement for Cooperation The proposed export is subject to all of the terms and conditions of the

. Agreement for Cooperation between the Government of the United States of' America and the Government of Norway concerning Peaceful Uses of Nuclear Energy, which entered into force on June 8,1967. This was confirmed by a letter from the Embassy of Norway. A copy of that letter is attached.

Norway has adhered to all provisions of its Agreem'ent with the United States.

The proposed export to Denmark in the European Atomic Energy Community (EURATOM) is subject to all of the terms and conditions of the

-l Additional Agreement for Cooperation, dated July 25,1960, as amended. This was confirmed by a letter from the Delegation of the Commission of the European Communities. A copy of that letter is attached.

EURATOM has adhered to all provisions of its Agreement with the United States.

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2.

Extent to Which Export Criteria Are Met A.

Section 127 Criteria

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As provided in Section 127 of tile Atomic Energy Act, the following criteria govern exports for peaceful nuclear uses from the United States of source material, special nuclear material, production or utilization facilities, and any sensitive nuclear technology:

Criterion (1)

)

"IAEA safeguards as required by Article III(2) of the Treaty will be applied with respect to any such material or facilities proposed to be exported, to any such material or facilities previously exported and subject to the applicable Agreement for Cooperation, and to any special nuclear material 1-used in or produced through the use thereof."

Norway is a Party to the Treaty on the.Non-Proliferation of Nuclear Weapons and deposited its instrument of ratification on February 5,1969. The Government of Norway has also signed a comprehensive safeguards Agreement -

with the IAEA under Article Ill of the Treaty, which entered into force March 1,1972.

l Article XI of the U.S.-Norway Agreement provides that " safeguards provided in Article X shall be maintained."

l Article XII, A. also provides for the assumption by the IAEA of responsibility for applying safeguards to materials and facilities subject to safeguards under the U.S.-Norway Agreement.

Article X, B.2(c)(ii) grants the U.S. the right to require safeguards on equipment or material or any material utilized in, recovered from or produced through the use of supplied materials or equipment. Norway, in Article X, C.

undertakes to facilitate application of safeguards.

Therefore, it is the Executive Branch view that criterion (1)is met.

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Criterion (2)

"No such material, facilities, or sensitive nuclear technology proposed to be exported or previously exported and subject to the applicable Agreement for Cooperation, and no special nuclear material produced through the use of such materials, facilities, or sensitive nuclear technology, will be used for any nuclear explosive device or for research on or development of any nuclear explosive device."

As a non-nuclear weapon state Farty to the NPT, Norway has pledged not to acquire, develop or manufacture nuclear explosive devices for any purpose.

Since this commitment will apply to the proposed export and to any special nuclear material produced through its use, it is the view of the Executive Branch that criterion (2)is met.

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Criterion (3)

" Adequate physical security measures will be maintained with respect to such material or facilities proposed to be exported and to any special nuclear material used in or produced through the use thereof. Following the effective date of any regulations promulgated by the Commission pursuant to Section l

304(d) of the Nuclear Non-Proliferation Act of 1978, physical security measures shall be deemed adequate if such measures provide a level of protection equivalent to that required by the applicable regulations."

The Norwegian Embassy by letter dated November 13,1978 provided the following generic assurance:

"The Government of Norway confirms that physical protection measures providing as a minimum a level of protection comparable to that set forth in International Atomic Energy Agency publication INFCIRC/225/ Revision 1 will l

be maintained with respect to all nuclear materials exported to Norway from the United States and to any special nuclear material produced in or by the use thereof."

The Executive Branch has assessed the physical security measures applied by the Government of Norway with respect to nuclear material and facilities and determined that they will be adequate for the facility and nuclear fuel covered by the license application and consistent with the NRC regulations referred to in Criterion 3.

Therefore, it is the view of the Executive Branch that criterion (3) is met.

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Criterion (4) -

"No such materials, facilities, or sensitive nuclear technology proposed to be exported, and no special nuclear material produced through the use of such material, will be retransferred to the jurisdiction of any other nation or groups of nations unless the prior approval of the United States is obtained for such retransfer. In addition to other requirements of law, the United States may approve such retransfer only if the nation or group of nations designated to receive'such retransfer agrees,that it shall be subject to the conditions required by this section."

Article XI, B. of the U.S.-Norway Agreement for Cooperation stipulates that no material, equipment or devices transferred to and under its jurisdiction pursuant to this Agreement and any special nuclear material produced through the use of any such material or equipment shall be transferred to unauthorized persons or beyond its territorial jurisdiction, except as the " Commission"(i.e.

the NRC) may agree and then only if, in the opinion of the Commission, such transfer falls within the scope of an Agreement for Cooperation between the U.S. and the other nation or group of nations.

This article clearly gives the U.S. the required approval right over the retranfer from Norway of material, equipment or components supplied by the U.S. or produced through the use of such material or equipment and allows retransfers only if the Parties agree.

Therefore, it is the Executive Branch view that criterion (4)is met.

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"No such material proposed to be exported and no special nuclear j

material produced through the use of such material will be reprocessed, and no irradiated fuel elements containing such material removed from a reactor shall be altered in form or content, unless the prior approval of the United States is obtained for such reprocessing or alteration."

Article VII, H of the U.S.-Norway Agreement for Cooperation provides that: "It is agreed that when any special nuclear material received from the United States of America requires reprocessing, such reprocessing shall be performed at the discretion o' the Commission in either Commission facilities or facilities acceptable to the Commission on terms and conditions to be later agreed; and it is understood, except as may be otherwise agreed, that the form

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and content of any irradiated fuel elements shall not be altered after their removal from the reactor prior to delivery to the Commission or the facilities 1

acceptable to the Commission for reprocessing."

This article clearly gives the U.S. the required approval right over reprocessing or alteration in form or content of any U.S.-supplied material, material produced through the use of U.S. material or equipment, or material used in U.S. equipment.

In the proposed export, U.S. approval would be given for post-irradiation examination of the fuel segments supplied by GE.

Therefore, it is the view of the Executive Branch that criterion (5) is m et.

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Criterion (6)

"No 'such sensitive _ nuclear. technology shall be _ exported unless ' the

' foregoing conditions shall be applied to any. nuclear material or_ equipment i

which is produced or constructed under the jurisdiction of the recipient nation -

- 1 or group of nations by or through the use of any such exported sensitive j

nuclear technology."

The proposed export does not involve the transfer of sensitive nuclear I

technology. Criterion (6) is, therefore, not appilcable.

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B.

.,Section 128 Criterion i

Section 128 a.(1) of the Atomic Energy Act establishes the-following additional criterion: "As a' condition of continued United States export of source material, special nuclear material, production or utilization facilities, and any sensitive nuclear technology to non-nuclear-weapon states, no such export shall be made unless IAEA safeguards are maintained with respect to all peaceful nuclear activities in, under the jurisdiction of, or carried out under the' control of such state at the time of the export."

i As a Party to the NPT, Norway has accepted IAEA safeguards on all of its nuclear activities.

Therefore, it is the Executive Branch view that this criterion is met.

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Additional Factors A.

Safeguards Implementation The IAEA Secretariat noted in its Annual Report for 1981 that in carrying out the safeguards program of the Agency, it did not detect any anomaly which would indicate the diversion of a significant amount of safeguarded nuclear material, or the misuse of facilities or equipment for the manufacture of a nuclear weapon or other nuclear explosive device. The Secretariat concluded that nuclear material under Agency safeguards remained in peaceful nuclear activities or was otherwise adequately accounted for.

The Executive Branch has no reason to believe that the IAEA Secretariat's report is not valid.

In the light of this and other factors associated with the proposed transfers, the Executive Branch believes the framework of commitments, assurances, and safeguards is adequate for the purpose of those proposed exports.

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Inimicality Judgment Based on review of the application, it is the judgment of the Executive-l Branch that the proposed export will not be inimical to the common defense.

and security, and that the license should be issued.

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OES/NEC:RRDeLaBa[:bjb DRAFTED:

APPROVED: OES/NEC - C. R. Stoiber CLEARANCES:

DOE - N. Martin 8 ACDA - M. Lassiter[8 DOC - M. Thompson DOD - Col. Gallington '

PM/NPP - L. Warren EUR/RPE - J. Gads ng L/N - R. Bettauer

Appendix C

INTERNATIONAL SAFEGUARDS AND FOREIGN PHYSICAL SECURITY REVIEW Norway and Denmark are parties to the Treaty on Nonproliferation of Nuclear Weapons (NPT) and as such have agreed to accept IAEA safeguards on all i

peaceful nuclear activities.

A safcguards agreement between Norway and the IAEA pursuant to the NPT is in force.

Denmark is a party to the EURATOM-IAEA safeguards agreement currently in force and is subject to EURATOM as well as IAEA safeguards.

The latest available IAEA Annual Report (1981) indicates that subsidiary arrangements are in force for the Halden and Riso facilities as well as for all other Norwegian and Danish facilities listed in the report.

According to the 1981 OECD Halden Deactor Project Report, IAEA inspectors visit Halden frequently and have installed containment and surveillance measures.

Although the irradiated test segments are subject to IAEA safeguards in both countries, staff notes that they may be exempted or suspended from actual application of IAEA safeguards under applicable IAEA agreements because of the type and small quantities of material involved.

Although no definitive information is available to staff on whether or not IAEA safeguards will in fact be applied or on the effectiveness of safe-guards implementation at Halden or Riso, staff believes that accounting and control of the small quantities of material involved are within the capabilities of Norway, Denmark, EURATOM and the IAEA.

Staff has reviewed the physical security programs in both Norway and Denmark and found them adequate for the purpose of this export.

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