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	<title>ExportLawBlog &#187; NRC</title>
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		<title>How Not to Make a Dirty Bomb</title>
		<link>http://www.exportlawblog.com/archives/125</link>
		<comments>http://www.exportlawblog.com/archives/125#comments</comments>
		<pubDate>Fri, 09 Mar 2007 14:12:39 +0000</pubDate>
		<dc:creator>Clif Burns</dc:creator>
				<category><![CDATA[NRC]]></category>

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		<description><![CDATA[In an earlier post about Nuclear Regulatory Commission controls on the export of americium-241, the isotope used in smoke alarms, we discussed a group of competency-challenged terrorists who were planning on building a dirty bomb from smoke alarms. In an excellent article in this week&#8217;s New Yorker, Steve Coll provides more details on the not-so-alarming [...]]]></description>
			<content:encoded><![CDATA[<p><img align="left" hspace="20" vspace="5" src="http://www.exportlawblog.com/images/dirty_smoke_bomb.jpg" alt="Mock RDD in Seattle" title="Mock RDD in Seattle"/>In an earlier <a href="http://www.exportlawblog.com/archives/88">post</a> about Nuclear Regulatory Commission controls on the export of americium-241, the isotope used in smoke alarms, we discussed a group of competency-challenged terrorists who were planning on building a dirty bomb from smoke alarms.  In an <a href="http://www.newyorker.com/reporting/2007/03/12/070312fa_fact_coll">excellent article</a> in this week&#8217;s <em>New Yorker</em>, Steve Coll provides more details on the not-so-alarming plot:</p>
<blockquote><p>Charles Ferguson. . ., a former nuclear submarine officer trained in physics, . . . co-wrote an unclassified report titled “Commercial Radioactive Sources: Surveying the Security Risks.” About two years later, F.B.I. agents . . . asked to meet with him. They brought a document showing that some of his report had been downloaded onto the computer of a British citizen named Dhiren Barot, a Hindu who had converted to Islam. Barot, it turned out, had been communicating with Al Qaeda about a plan to detonate a dirty bomb in Britain, and he had used a highlighting pen on a printout of Ferguson’s study while conducting his research.</p>
<p>The report described how large amounts of certain commercial radioactive materials might pose a danger to a terrorist who tried to handle them. “This seems to have worried him,” Ferguson told me, referring to Barot, “so he decided to look at smoke detectors.” Some detectors contain slivers of americium-241; the isotope’s constant emission of radiation creates a chemical process that screens for smoke.<strong> Barot informed his Al Qaeda handlers that he was thinking about buying ten thousand smoke detectors to make his bomb. In fact, to make a device that would be even remotely effective, Ferguson said, he would have had to buy more than a million. “Either his reading comprehension was poor or he was evading the assignment,” Ferguson told me.</strong></p></blockquote>
<p>The rest of the article is an interesting account of the current efforts by the U.S. government to interdict nuclear-terrorism on U.S. soil.   Click <a href="http://www.newyorker.com/reporting/2007/03/12/070312fa_fact_coll?currentPage=2">here</a> to read it.</p>
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		<title>NRC Loosens Libya Controls</title>
		<link>http://www.exportlawblog.com/archives/88</link>
		<comments>http://www.exportlawblog.com/archives/88#comments</comments>
		<pubDate>Mon, 15 Jan 2007 17:39:58 +0000</pubDate>
		<dc:creator>Clif Burns</dc:creator>
				<category><![CDATA[NRC]]></category>

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		<description><![CDATA[Six months after the State Department removed Libya from the list of state sponsors of terrorism, the Nuclear Regulatory Commission got around to changing its regulations to reflect this removal. In a Federal Register notice issued Friday the NRC amended its rules and changed Libya&#8217;s status from an &#8220;embargoed country&#8221; under 10 C.F.R. § 110.28 [...]]]></description>
			<content:encoded><![CDATA[<p><img src="http://www.exportlawblog.com/images/qaddafi_smoke_detector.jpg" align="right" hspace="20" vspace="10" alt="General Qaddafi and his new American smoke detector" title="General Qaddafi and his new American Smoke Detector"/>Six months after the State Department removed Libya from the list of state sponsors of terrorism, the Nuclear Regulatory Commission got around to changing its regulations to reflect this removal.   In a <a href="http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-320.pdf">Federal Register notice</a> issued Friday the NRC amended its rules and changed Libya&#8217;s status from an &#8220;embargoed country&#8221; under <a href="http://www.nrc.gov/reading-rm/doc-collections/cfr/part110/part110-0028.html">10 C.F.R. § 110.28</a> to a &#8220;restricted country&#8221; under <a href="http://www.nrc.gov/reading-rm/doc-collections/cfr/part110/part110-0029.html">10 C.F.R. § 110.29</a>.</p>
<p>The effect of that designation is that certain nuclear materials for which general export licenses are available under NRC rules may now be used to export those materials to Libya.   For example, small quantities of americium-241 may now be exported to Libya under the general license provided in <a href="http://www.nrc.gov/reading-rm/doc-collections/cfr/part110/part110-0023.html">§ 110.23</a>.   </p>
<p>Although exporting americium-241 sounds rather sinister, you should realize that small amounts of americium-241 are used in certain industrial applications such as equipment used to measure the rate of production of oil wells.  Tiny amounts (less than 37 <a href="http://en.wikipedia.org/wiki/Becquerel">kBq</a>) of americium-241 are also <a href="http://www.atsdr.cdc.gov/toxprofiles/tp156-c5.pdf#page=3">used </a>in the ionization chambers of many residential and commercial smoke detectors.   Ionization smoke detectors are, in fact, the principal use of americium-241.  </p>
<p>People in Tripoli, however, shouldn&#8217;t expect to be getting American smoke detectors anytime soon.  Under § 110.23 americium-241 can be exported under the general license to restricted countries such as Libya only when &#8220;contained in industrial process control equipment or petroleum exploration equipment.&#8221; I suppose we are still concerned that Qaddafi might dismantle a hundred million or so smoke detectors, extract the americium-241 and make a dirty bomb or two.</p>
<p>I suppose I should acknowledge that a terrorist cell that couldn&#8217;t shoot straight did try to make a dirty bomb from smoke detectors.   A recently declassified intelligence <a href="http://www.globalsecurity.org/wmd/library/report/2006/wmd-acq_cia_2004.htm">report</a> to Congress contained this statement:</p>
<blockquote><p>British authorities announced the August 2004 arrest of members of an Islamic terrorist cell in the UK that may have attempted to produce an RDD [radiation dispersal device] using a radioactive isotope of americium taken from smoke detectors. <strong>The knowledge base and competence of this cell was low.</strong></p></blockquote>
<p>Uh, yeah.  Do the math on how many smoke detectors it would take, at 37 kBq of americium-241 per smoke detector, to make a useful dirty bomb and saying that the competence of this cell was low is an understatement.</p>
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		<title>NRC Agrees To Reveal Export Quantities in License Applications</title>
		<link>http://www.exportlawblog.com/archives/24</link>
		<comments>http://www.exportlawblog.com/archives/24#comments</comments>
		<pubDate>Tue, 26 Sep 2006 19:16:04 +0000</pubDate>
		<dc:creator>Clif Burns</dc:creator>
				<category><![CDATA[NRC]]></category>

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		<description><![CDATA[A license is required from the Nuclear Regulatory Commission to export certain nuclear materials. Those license applications are typically printed in the Federal Register for comment. After 9/11 the NRC deleted certain information from the Federal Register Notice, including the precise quantity to be exported, such as it did in this Federal Register notice of [...]]]></description>
			<content:encoded><![CDATA[<p><img align="left" hspace="15" vspace="5" src="http://www.exportlawblog.com/images/heu.jpg" alt="Highly Enriched Uranium" title="Highly Enriched Uranium"/>A license is required from the Nuclear Regulatory Commission to export certain nuclear materials.   Those license applications are typically printed in the Federal Register for comment.  After 9/11 the NRC deleted certain information from the Federal Register Notice, including the precise quantity to be exported, such as it did in <a href="http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/pdf/E5-3342.pdf#search=%22federal%20register%20nrc%20export%20uranium%22">this Federal Register notice</a> of an application for a license to export highly enriched uranium to France.</p>
<p>In response to these restrictions the <a href="http://www.nci.org">Nuclear Control Institute</a> wrote a <a href="http://www.nci.org/06nci/06/NRC-HEU-export-licenses-2006-Feb.htm">letter</a> to the NRC in February 2006 complaining that the omission from the public notice of the quantity of nuclear material to be exported deprived the public of meaningful comment on the license application.  The NCI letter cited an instance where public comment on an export of HEU to Belgium&#8217;s BR-2 reactor revealed that Belgium had no immediate need for the HEU and the license application was withdrawn.  According to NCI, limitation of export of excess quantities reduces the risk of diversion of the material to weapons use.</p>
<p>The NRC responded to the NCI letter on August 31 by agreeing to reveal the quantity in future proposed export applications.  In a <a href="http://www.fas.org/sgp/news/2006/09/nrc083106.pdf">letter</a> to NCI, NRC Chairman Dale Klein noted:</p>
<blockquote><p>[T]he NRC intends to disclose quantity information for enriched uranium above 6% U-235, mixed oxide materials, and certain other radionuclides absent an NRC determination of a compelling reason for nondisclosure. Federal Register  notices for proposed HEU exports will also include quantities requested. However, the NRC will continue to withhold information on projected or actual shipment schedules, delivery dates, date required, mode of transport, storage arrangements, or any other related logistical information provided by either the applicant, the licensee, other parties to the transaction or added by NRC, as this information could be useful to a potential adversary.</p></blockquote>
<p>&#8220;Hat tip&#8221; on this item to <a href="http://www.fas.org/blog/secrecy/2006/09/nrc_rescinds_secrecy_surroundi.html">Secrecy News</a>, a blog maintained by the Federation of American Scientists</p>
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