 Good afternoon, everyone. Thank you so much for joining us today. I'm Sharon Squassani. I direct the proliferation prevention program here at CSIS. And I was describing to my boss, this is my uranium plutonium week, because we're going to talk about uranium today with Cindy Vestergaard and plutonium later in the week as we explore Japan, what Japan is doing. But we are webcasting, so I would particularly ask you to turn your cell phone ringers off. And I'm going to give a short presentation on the US part of this project on governing uranium. And then Cindy will give her presentation. That's exactly what I was referring to, that cell phone ring. Unless you have a really cool cell phone ring, then that's, and then we'll open the floor to questions. And I ask that when you ask a question, just identify yourself so that everyone knows. This is totally on the record, correct? And so it's my great pleasure to bring back Pernon Kor. Cindy Vestergaard, she was here last year as a visiting fellow. And she brings a tremendous amount of expertise and enthusiasm, and she's just really plainly a lot of fun to work with. But Cindy is a senior researcher at the Danish Institute for International Affairs. She was formerly with the Canadian Department of Foreign Affairs and International Trade and has done a lot of work on chemical weapons, among other things, and nuclear stuff. Cindy was here in connection with a project funded, in part, by the MacArthur Foundation. I think there's some other funders involved. But it's a global project on governing uranium. And CSIS was privileged to be a part of that project. We published a report that is available on our website. So you choose, you can download the PDF for free, or you can pay for a version published by Rowan and Littlefield. That's also, you can look at the details on our website if you want, you know, a physical copy that looks really nice. I am going to brief, and I'm going to try and be as quick as I can, because I'm much more interested in the international implications of this. But I'm going to brief on the US portion of our project. And then Cindy will talk about the international research that's been ongoing and give a little more background about the project. So I'm going to get started. I have some slides. I'm going to stand up. I hope I can make all of this work at the same time. We're going to switch mics. Does that work? Yeah. OK. So this is actually a briefing that I gave in Copenhagen, some of these. But anyway, we'll give a little background. Why were we even involved in this project? There haven't been too much attention to the front end of the fuel cycle. And what we're looking at here is really uranium mining, milling, and conversion. In the non-proliferation world, for a lot of reasons. One, we have a lot of controls further down the product chain, where the material is more attractive. But the IAEA is actually in the process of defining what these prudent management practices would be for uranium security. And I'll say right off the bat, which is why I don't want to spend a whole lot of time today on this. The US is not the biggest risk here when you're looking globally. And why? Well, because we're a leader in non-proliferation and nuclear security. But also, if you were to look at the risks of different kinds of material in the US, you're not going to worry about the uranium in the mines. We have a lot of other material that is at higher risk. But having said that, we have a lot of experience across the board. We've produced uranium. We've consumed it. We export it. We import it. And so maybe there are some lessons learned in the way in which we've governed uranium for other countries, the newcomers, Malawi, eventually Greenland. So I'm going to highlight where the US experience may be unique, in which it's not applicable for other countries. Talk a little bit about some recommendations for improved governance. And then bring together in this group. And I see we have some people from industry, government, and other experts to sort of engage in a discussion on this area. OK, so this is just some history. This is the context part. We're going to really breeze through this. And this is my attempt to be flippant, I guess. When you go back to uranium, pre-war years, 20s, 30s, or even before, I would say we're relatively ignorant. What is this material? It was generally a byproduct of other things we were producing. And let me just stop here for a moment and recognize a couple of people in the room who did an enormous amount of work on this project. Number one is Stephanie Cook, who's sitting in the back. And then Bobby Kim, and I don't know, and Jake Greenberg also in the back. They did a lot of heavy lifting on the research and writing. So that phase lasted up until about 1939. And suddenly we discovered, well, uranium has a strategic value. And so we placed, we had positive controls on it. The Atomic Energy Commission had a lot of incentives, actually for production of uranium. And we had a uranium rush. But there was a lot of the controls in, never in the mines, but particularly in some phases right after the mine, in milling and enrichment, obviously. Then we moved through a kind of laissez-faire phase where we actually opened our market to foreign uranium. And then, of course, from the 80s, 82 to 92, a slump, and then probably about a steady state from 92, although I think, as you'll see when we go through the data, we've had a real drop in uranium production in the US. So just to give you a sense, this is where our uranium is in the West. Sorry if that's not totally clear on the slides. It is in the report. And this will show you the darker the color, the more dense the mines are. So you can see it's really kind of focused in the Western third of our country. Uranium prices, this particular graph goes just to 2,000. I'll show you. We have an update to that. But you can see you had a peak or a surge, and then it's gradually coming down. That's a combination of domestic and some imported uranium there. And then you can see price spike in the spot price more recently, and then the numbers are coming down. I think I know Melissa is in the audience, so she can probably, if you have specific questions about nodes in these graphs, I'm sure she can answer that. This is, you can see the blue line is purchased imports against domestic production. You can see they're at opposite ends. So in other words, we were trying to boost up our uranium production, and so we banned foreign imports. And then that switches. And you can see that in the early 90s, we had the megatons of megawatts program. And so we're importing a lot of HEU actually to blend down. This is actually domestic production imports of uranium concentrate. All right, and then this is just to give you a sense. This is our ore production. So production dropping off in the 80s. Now it's kind of at a steady state. And the difference, there is a difference in the technologies that have been using. So now we're getting a lot less uranium from the mines and more from the, what is it, the concentrates? Bobby held me out here, in situ leaching. This is our purchases. Just in case you thought that nuclear energy is a sort of path to energy independence, this very colorful graph shows where we're getting our uranium from. A whole lot of different countries. And you can see that includes Russia, Australia, Canada, obviously, Kazakhstan, some of those big producers. This orange part at the bottom is US production. All right, and then again, you can see operating mines. Some of these are, because the numbers are small, that some of these, you see a big drop off, but we've only had a few mines. And they're differentiated between underground open pit and these in situ leaching sites. And then again, operating conventional mills. Is it one or two mills that we have open now? One. So basically, the picture in the US is we had a lot of, we had a lot of incentives from the government to build up our production in the early years. It's fallen off. We are now no longer a big producer of uranium. We've got six conventional mines operating. Just one mill, just one conversion plant, Converdyne. Most of our exports are, you have six that we're exporting to get converted at Urenco and Euridif. And then we export some yellow cake to Canada and France for conversion, the 308. So what is industry? What motivations do they have to do their material accounting and control? Obviously, they want to comply with regulations, but mostly economics. So at the mine, you want good recovery rates. At the converter, you're going to do this for bookkeeping. You want to keep decent books. And then transportation, if you're transporting this material, one truck work can sometimes equal $2 million worth of material. So you're going to keep track of this. And basically, the history of uranium governance in the US has been mostly focused on, well, these guys have an economic reason to make sure that it's physically secure and to account for it. That has been, I'm not sure I would say compounded, but we have a particular system in the United States with the agreement states where states have a particular sovereignty that kind of compounds this. The NRC, if you didn't know this, the Nuclear Regulatory Commission does not regulate mines. That is kind of a historical, I mean, the reason is because of the mining law back in 1872, mining act, but also with this agreement states approach. So the NRC is regulating uranium processing, so it will regulate these institutes leaching and the mills and the conversion. So what you wind up with is that there are actually no physical protection requirements at mines. There are some requirements for transportation. But by and large, what we found is that the Department of Transportation regulations are mostly tied to safety rather than physical protection. And then from 1978, we had the landmark UMPTRAKA, the Uranium Mine Talings Recovery Something Act, which Control Act, whose basic focus was on environmental health and safety. So again, not on security, but there are some spillover effects for security. And then finally, there are some reporting requirements for imports and exports. But it's a little bit murky when you get back down to the details in terms of investigating violations. So here's just a chart that will show you the different elements of the front end that we looked at, conventional mining, ISL mining, milling, conversion, transportation, and then the material that's coming in and out of the country, what the legal requirements are, the different products that are associated with it. So or from conventional mines, uranium concentrate from the ISL and milling UF6 when it comes out of conversion. And then here are the lead agencies and the measures that are associated with them. And you can see it mining and milling primarily for safety and environmental reasons. Does any of this matter? Because often when you talk to industry, they're like, ah, well, this is not a big deal. And in nuclear non-pilliferation, it's certainly not the area in which we spend the most amount of attention, but it's gaining more attention. And so we said about thinking about risks. How do you think about the risks? And so the International Atomic Energy Agency, in nuclear non-pro, we all know what a significant quantity is when we're talking about highly enriched uranium or plutonium. But there's also a significant quantity in terms of natural uranium. And that is 10 tons of natural uranium. So what does that mean in terms of ore? You need a lot of ore to come up with 10 tons of natural uranium. The devil is in the details, though. So the question is, at what percentage, how good is your ore? How rich is it in uranium? At their best, US mines, at their best were 1% grade. So that equals into 1,000 tons of ore. So in order to get one significant quantity of natural uranium, which we'll see eventually through all the processing can yield, if you go up all the way up, could yield as much as 45 kilograms of HEU. But you've got to take 1,000 tons of uranium ore. Other places in the world have higher grade ore. So when you're looking at pitch blend or in Kazakhstan or Canada, then you're saying, well, you'd have to steal a lot less ore to get to that natural quantity. When you're looking at, for example, the second category, 0.086% grade, then you're looking at 11,000 tons that you're going to have to steal. And then, of course, as you move further up the chain into yellow cake and UX6, the quantities become smaller and smaller. So you're going to ask me next, why does that matter? I mean, the answer is, how much do you have to steal or would you need in the United States? Because uranium is not such a high grade. You'd have to steal a lot. So if you got that 10 tons of natural uranium, how much HEU or plutonium could you produce? Again, the devils are in the details. Everybody knows about enrichment, tails assay. This would have to have a 0.3 tails assay to get up to 45 kilograms of HEU. And if you're looking to go towards plutonium, then you could with 10 tons of natural uranium if you go through the entire process, yield 10 kilograms of plutonium. So not a terribly huge risk in the United States, but we started to think, OK, so where are the gaps in all of this? So these are the different points in the process that we looked at. So how secure are the ore stockpiles at the mining site, in transit to milling, at the milling sites, and route to conversion, all of these things? So we came up with this kind of rough table, which is divided into two categories. How attractive is the material, and what's the risk of detection if it were diverted or stolen? So one thing I want you to notice on the left hand, so under theft diversion or export control falsification, how attractive are ore stockpiles at the mines? We couldn't even really put, we just said lowest. In order to be motivated to steal ore at a mine, that material is really very unattractive for anybody seeking to divert it for nefarious purposes. At the same time, the risk of detection, here we are under the theft category, the risk of detection is low, relatively low. So when you come away with this, you're sort of like, well, the less attractive it is, do you care so much if the risk of detection is low? Probably not so much. But when you get to sort of the yellow cake at mills, for example, in a case of diversion, where the material is not so attractive, but there's only a medium chance of the risk of detection, I'm going to go into an actual case in the United States. But there are other cases overseas where some people kind of took advantage of the opportunities. So you shouldn't totally ignore this. I mean, there needs to be some attention to it. And I will say that this asterisk thing, where it says medium, it's medium now, but at the time that this case happened back in 1979, I would say that it was low. And that is that the risk of detection was low. So this is an excerpt from an article from the Rosswell Daily Record, from the Rosswell Daily Record from April 10th, 1979, where you can see that 5,000 pounds, not a terrific amount, of uranium was stolen from Sahayos Mill, and it was recovered in a kind of, I think it was sort of a sting operation. But this is what these guys testified that they simply loaded barrels of uranium into a company pickup truck on three occasions and drove it out of the plant. And they said, well, the easiest part was getting it out of the plant. And that's because the way they take inventory down there, it would never be missed, right? So what happened in this case is that if a barrel wasn't full, it wasn't a full barrel and it wasn't accounted for. And I think this was also the case of what happened in Kazakhstan when material was being diverted, not with official plant knowledge, but by some enterprising staff who were gonna make some extra money. And I can't remember where that material actually went to Iran or it was destined, or that was the intended destination. So since this incident, the accounting measures have been improved, I believe. So what does this tell us? You might think about a few governance objectives. You could have more transparency at the mines, at the mills, at the converters. You could have more follow-up on reporting, on thefts. You could have more monitoring of uranium movements. And the question is, if better security of uranium, if we agree that we need better security of uranium, could you kind of somehow wrap this up into a state level approach by the IAEA? And then the questions that I put on the table for us today, although I would like to, actually in the international context, focus on this. Does industry have incentives to do more, either in production or transportation? And if they don't, are there incentives that we can create for them? Can we better leverage safety regulations for security purposes? Are there additional cost-effective measures? I mean, that's really a critical, a critical adjective, cost-effective. Because if it's not cost-effective, then you're gonna have trouble implementing it, or even getting industry to consider it. And then overall, where does the US industry and government rank in terms of physical protection of uranium worldwide? And so now I'm hoping that Cindy will be able to put this in a broader context for us. So thanks for your attention, and we'll shift over to Cindy. That was good, thank you. I'll tell you, oh, no, I can come over here. I will give you more information about the project overall. It is, as Sharon said, an international project. In total, we are looking at 16, possibly 17, the 17th would maybe be Iran. We'll see how open they will be. But there are some indications that might be the case. So the 16 countries in total, we are looking at seven of the nine possessors of nuclear weapons, the only two we are not capturing are North Korea and Israel, and I think both for obvious reasons. And then we're also looking at, it's a mix of producing and consuming countries of uranium. We also have four states within Africa, Malawi, Tanzania, South Africa, and Namibia. We have Canada, Australia, Kazakhstan, and who else am I missing, Brazil. So I think that makes 16 all together. And we're looking at the safety security safeguards at the front end. How is it governed, and the reason why we're doing this is also because of after seven decades of mining uranium, we actually don't know how different states do and go about it. And as Sharon said, it's not because we're looking at it because we view it as a high risk as highly risked uranium or plutonium, but in the sense that because we have what are basically becoming shifting geographies of production and consumption. So what does this mean in this kind of shifting world? So for example, where the United States was the largest producer in 1979, today it's maybe the 10th, maybe even the 11th. Because in 2009, Malawi actually started producing. They are the most recent producer in 2009, and they actually became 10th by 2012. And so we're also seeing a lot more South to South trade. We also have a very thirsty consumer, India, which is now also engaging in trade. And this is creating a lot of shifts for export control regulations and policies that have been placed for three decades. So how are these states able to grapple with these changes? And also in terms of the NSG, the Nuclear Suppliers Group, about one third of yellow cake trade is actually done outside of the NSG. So how does this work in practice as well? And then the difference is also between nuclear weapon states, non-nuclear weapon states. So we're trying to get a mapping and scoping of these major new producers coming up, the current ones, the old, more traditional ones, and then how this is actually having an impact. In terms of policy relevance, if you are a newbie coming to the fuel cycle, in terms of my backyard, Denmark and Greenland are currently on the path to supplier status. Greenland is an island full of uranium, and it's all mixed in with its rare earth and gold and zinc and all the other things that they have. And so the question is, is that if you are a newbie, where do you go to get a sense of best practices? How do other states regulate? The IAEA can't really provide you these things. And I'll get into more in terms of the IAEA governance. Then the IAEA is also having an internal discussion at the moment about at what point do safeguards get triggered or where should they be triggered at the very front end of the fuel cycle? At the moment, it's only the product of conversion that basically has historically also been where the IAEA in full scope accountancy comes in. And then provide recommendations for governance gaps. Where do we see gaps? And some of them Sharon had just pointed out where are their industry gaps and so on and so forth. So in terms of the international picture, it's actually very limited. There's very limited governance for the very front end. So or and or residue is not under IAEA safeguards, meaning it's not under full material accountancy and control. So there's no IAEA inspectors to going around counting rocks, obviously. But what there is is a reporting requirement of exports and imports. So as soon as a drum leaves your borders or enters your borders of yellow cake, you need to report it to the IAEA. And when it comes to the additional protocol, however, and it says there, of course, if it's for nuclear purposes and not if it's to a nuclear weapon states. Now, nuclear weapon states such as the United States, however, do have a voluntary reporting. So they have since 1979, I want to say. Four, yeah, that would probably make sense. Yeah, but it's a very interesting aspect, actually. Of course, these rules and regulations were certainly heavily influenced by the nuclear weapon states. And at that time, anything coming in to their borders was not always necessarily what they wanted to report. Now, however, most of them do. The additional protocol came into play in 1997. And of course, this is a voluntary measure and it's the only measure where the IAEA actually has the ability to get a fuller picture from the very front end to the very back end as to what's happening in the state. And in this case, it is actually, it's a reporting requirement still. You have to report how many mines you have, where they are, production capacity, how much you produced last year, how much is expected this year. And again, that's it. The additional protocol, however, it does also have complimentary access or CAs. So they're not called inspections, they're called CAs. But the IAEA does go to mines under this protocol. So for example, Canada and Australia, they've each had about five visits over the past few years. It also helps with a lot of ground proofing for the IAEA. Then there's the Convention on the Physical Protection of Nuclear Material, the CPPNM. And that has, it requires that physical protection of Yellow Cake is done. And that it's done in a prudent management practice way. But it doesn't define what that means. So it's really up to interpretation and up to states to apply those protections, whatever they think they may be. And of course it doesn't apply to ore or residue, but it does apply to UOC, uranium ore, concentrate or commonly known as Yellow Cake. There is a 500 kilogram reporting requirement where you are supposed to, in advance of anything over 500 kilos or more, you're supposed to provide that information to the state where it's going. And then of course they will do the same. This also comes from the NSG, the Nuclear Suppliers Group has the same requirement. And the CPPNM just basically takes that same requirement. Sorry, let me just go back. So basically when you look at this picture, there's not much governance at the very front end. And when it comes to reporting, if you're a major producer like Canada, Australia, you do report monthly to the IAEA. If you're very small, you might only do it annually. On the regional side, we get also a mix. So URATOM is different than the IAEA in that ore is safeguarded. It is actually part of the entire full accountancy system. Again though, it is still much more a reporting requirement, but there is a material balance accountancy that has to go with it, physical inventory listings, advanced notifications. And that has been in place since 1957. URATOM safeguards are also applied at, for example, the UK civil facilities. And that includes Springfields, the conversion facility there. And the UK is an interesting case because we actually have a very clear separation of civil and military programs at the conversion facility. This is not the case, unfortunately, in all the different states that have converted. At ABAC, the Argentine-Brazilian nuclear, was it nuclear accountancy and control organization. This is the agreement between Argentina and Brazil so that they have a method to actually look at each other's programs. And their agreement, the QUAD agreement, basically has the same reporting requirements as the IAEA. They have to report their imports and exports. ABAC, though, tells you that we cannot verify this because they don't have the additional protocol. So it is a reporting requirement and for ABAC, safeguards and verification basically begin at uranium dioxide level. And this is actually a new thing. The first inspection under that would have happened in January last year in Argentine. So let's keep in mind that these are intermediate results. We are about, oh, we've got another year of the project to go. But I think most of these are sensical, also, in terms of you need to have clear legislation, clear rules and regulations, and you'd be surprised, and I will take you through some cases how that is not always the case. And inspection and enforcement, the need for actual people in place who are trained to be able to carry out the inspections and not just a matter of having the rules and regulations on paper, but of course, actually enacting them. Regular consultation with industry is highly critical and a very good best practice as are, of course, inventory and export control. So even though the IAEA requires reporting on imports and exports, it becomes incumbent on states to actually have a system of inventory control so they know what it is that they're supposed to be reporting, how much is coming in and out, and then how are they actually allowing that to leave their borders. A digitalized inventory database, this is something that is not common practice. In mining, it's based on ledgers. It's very old school. There is a movement, however, in different countries, particularly, if you can imagine Canada when it comes to its reporting to the IAEA, Canada's the second largest producer in the world. It actually gets an email these days before it used to be a fax from the different mining companies, more from Camaco, and they would tell them their inventory change documents every month and then they would take that information, put it into a different system. So two database, for example, full-time employees have to take that information today, put it into another system and then send it to the IAEA. Now there is an attempt to try to merge that system so it can be digitalized and more real-time reporting. So I'm gonna take you through three cases. I can answer questions. We've looked at about 10 so far in total, so depending on what questions you may have, but Australia is basically considered or has a reputation globally for being the gold uranium standard. It's a very transparent system. It's quite simplistic. There are some other actors, but ASNO is the Australian Safeguards Non-Proliferation Office. It's nestled within the Department of Foreign Affairs and they are responsible for safeguards, security, and also the bilateral nuclear cooperation agreements. And ASNO is, it's a fascinating organization or agency in that it is not just the one that reports to the IAEA and also works on issues to do with safeguards at the IAEA level, but it also has a security component that we don't always see in other countries. So they will approve security plans. The mine has to, by law, prepare a security plan that ASNO will approve. And those plans are good for five years. The mines do them. Usually they might subcontract someone out for them, but the mines do them and then ASNO goes through and looks at it. Mining licenses, mining policy nationally is done by resources, economic and tourism, I believe it is. And I think now it's actually been changed names to the Department of Industry. So they're the ones that actually look at the request for a mining license and also for exports, they will make sure that whatever is coming through is actually based on a sales contract. Whereas ASNO then looks at the export control side to make sure that there's a bilateral agreement and what are the terms of that bilateral agreement. So there's a double look at it from two different perspectives. And then there's AMSA, the Australian Maritime Safety Association. And it is the competent authority for shipping, but also for packaging. So they will go in and inspect seals, make sure everything's in place and look at the way that the drums are packed. They will actually visit mines once a year. ASNO goes usually once a year as well. They actually go and inspect and look every single time. And on transport security, one of the things that I found very interesting about Australia, they have about 11,000 containers shipped a year. Never in this time has there been a major incident. And that's major. And there's certainly a very high public sensitivity to yellow cake or uranium in general. You have to keep in mind that Australia exports all of its uranium. It does not use any of it. All of those abroad. And there was a case where, was it close to range of mine where a truck was what they call bog. It went into the ditch. It was moving around a wide load to let it go by. And it went in and it got ditched. And then the next day in the newspapers, it was uranium scare in Kakadu National Park. So I mean, there's a very high sensitivity, a lot of public, what would you call it? Oversight that keep things in check. And it's the same thing on the transport security side. The different states and territories do have full authority over their roads. But the mines do have to provide a transport plan. And the drivers are actually not allowed to deviate from that plan. Of course they have detours if there's a tree on the road. But they're not allowed to deviate. Malawi is an interesting case. They started mining before legislation was in place. Obviously not best practice. They know that. They will tell you that. And it's a very harsh lesson. If you start mining before, they do have a mining act. I can't remember when it was put in place. I want to say the 70s or 80s. And then they finally put in a nuclear energy act in 2011. But for two years they were producing before legislation in place. And it was a very perhaps naive attempt in the beginning where they actually believed that industry would teach them how it would work. And that's not the way to do it. Industry will not tell you that they love regulation, obviously, but it has to be a clear system that they're working in. So there is long term stability to be able to operate. And so there has to be something in place. The government is the one to provide oversight. And Malawi also didn't have the inspectors needed. There are some, obviously, cases where they were looking and doing the inspections before it would leave the borders. But it's not to the extent that we can see with others. Sorry, that's a misprint. I should say by 2012 it became the 10th largest producer. So when it started in 2009, it produced 100 tons. By 2012, it was producing 1,000 tons. And surpassing, no, not surpassing US. It's actually below that still. It currently has all of its rules and regulations under review. As you can imagine, if you start mining before you have legislation in place, then you put in legislation and then it kind of does not working. It's an extremely expensive process and laborious. And it will not create a very, this long term stability that we crave to be able to operate and do the mining. Palladin suspended operations actually, February of this year, they claim low spot price. And that's certainly probably a huge part of that equation for them. The mine has been losing money the whole four years that it's been up and running so far. One of the things that's also interesting about Malawi is that it does not have a bilateral agreement. So whereas Australia has a requirement that every shipment of UOC has to be part of a bilateral agreement. So they're not gonna ship off to a country unless there's a nuclear cooperation agreement in place. Some countries, however, just use contract. So in the case of Malawi, it's just a matter of Palladin with China. And all of the uranium from Malawi went to China. One of the other things about Malawi, which is in terms of the region that it's in. So when the yellow cake leaves Malawi, it goes through Zambia, which is a transit country, and it has no nuclear legislation. In Malawi, they call it kind of a light touch approach. They will have a convoy that will go with it. As soon as it gets into Zambia, it's 60 trucks that will accompany it. So they call that the heavy approach. Then it goes into Namibia, where there is a uranium mining certainly practice, to the bay there to get shipped out. So there is a need for a much more regional harmonization from a light touch to heavy touch, and really what are, what is the threat environment that they're working in? Do you need 60? Do you need five? What is the system, and then how are they going to be able to harmonize that better? And that's something that we've been hearing from Africa quite a bit, the need for regional harmonization and transport. There is also a African debate for talking about the latest consumer to enter the uranium trade, and that is India. And there's a big discussion right now about the Treaty Palindaba, which makes Africa a nuclear weapons free zone. The nuclear weapons free zone basically says that you cannot trade with the state outside of the NPT. Simple. And because now you have Canada and Australia, these very long time leaders in the field of uranium production, a lot of these African countries are saying, well, why can't we trade with India? If these other countries are having bilateral agreements with them, why can't we? So there's a current debate about this. There's a possible, there is a discussion about possibly amending the treaty. You all know how long amending treaties can take to, and they're not always that fun. So this is actually something to watch because there is rumblings. And a lot of the politicians are trying to figure out, again, why can't we not engage? How has this treaty, and why is it stopping us from doing so? But again, it also starts because it took, what, three, four decades for this treaty to actually come into force. This is China. This report was done by Tamara Patton, who did an absolutely brilliant job at sleuthing through the myriad of regulations and state-owned enterprises and everything that you see up there. It is quite fantastic. And China, from what she concluded was that it's kind of been in a perpetual sense of updating all of its regulations. And this perpetual sense, though, is created this web. And these aren't the regulations, these are just the agencies. But if you look in the report, I do have copies of it. And if you did not get one, just give me your business card, I'll make sure you get it. It's also online on our website, at ds, www.dis.dk. And so this web basically has kind of evolved over time and a lot of regulations are contradictory. Some of them overlap. Some of the different departments have their own rules and regulations that also might be contradictory. The legislation is unclear in terms of definitions. It does yellow cake apply. What is yellow cake? Even, and so it becomes very much a challenge if you are shipping to China. Who are you shipping to? But at least it's good to know these two, the China Nuclear Energy Industry Corporation and the Nuclear Fuel Company, are the only two entities in China that are allowed to purchase or import, export uranium. CNNNC, the China National Nuclear Corporation is the nuclear body and it has a dual role. And that's one of the important things about this. Again, China is a nuclear weapon state and its dual civil military structure has always been there and it's also perpetual. And CNNNC has kind of been not split. I mean, it's what, well over 100,000 employees. It's a massive organization. But in order for, where is the CAEA? There it is. The China Atomic Energy Authority is actually part of CNNNC, as you can see kind of up how they're connected. And it is the one that actually relates to the IAEA. They're the ones that talk to them. But you do have employees that are employed by CAEA and CNNNC, it's the same guy, they might have two different cards. So this is a system that is quite difficult, obviously to understand. And the end result is that it's actually very hard for us in the project to know really how implementation of the rules and regulations that China has laid out, how they work. And that's one of the challenges, particularly since it is quite opaque. And then just some gaps to highlight some gaps. There is obviously differences between nuclear weapon states and non-nuclear weapon states, just by the virtue of how much of the fuel cycle that they have. We do notice differences in public sensitivities. So there's a higher sensitivity in Australia to yellow cake than there is here. And even in Canada, Canada has almost the whole fuel cycle except for enrichment. And this also includes differences in inventory control, how they track everything and their export controls and inspection regimes. I think one of the interesting things is accounting for losses. This is a gap. The IAEA says that you have, it would be best practice if a drum was missing to find it within a year. That's a long time. Nuclear security premise, however, and the IAEA's current approach to looking at nuclear security for the Iranian industry, says one month would be prudent practice. And, but we have kind of an interesting dynamic when it comes to the legislation. So in this country, the NRC has a 15 pound figure. So if you lose 15 pounds, and it's more from a kind of a safety perspective where you lose it in process or whatever, that you have to report that or 150 pounds a year. They've never had, it's a self-reporting requirement. They've never had any such reporting ever come in. And in part, you can slightly understand why because 15 pounds, they lose that on a daily basis. 15 pounds is nothing. And you can imagine the paperwork to go through for 15 pounds. And the NRC also will tell you it's mostly from a safety perspective and it is from a security perspective, as Sharon also highlighted in her slides. Canada has a policy where you have to account for everything and Australia's every gram has to be accounted for. But again, these are self-reporting and it's almost impossible to be able to legislate that in the way, at least the way that they do. So this is one of the challenges in Canada. For example, doesn't even have a line item for theft. Granted, they've done threat assessments that say, okay, in the northern part of Saskatchewan, we feel that the yellow cake is secure. But should there not be that line item? What if it does happen? Bottle and Exit Conversion Facilities is another big issue. So for example, when Converdyne has been shut down, it just reopened what, January, February? It was shut down for over two years. And it was still business as usual in terms of all of its imports. So everything is coming in. It can be back to the skies. And then what does that mean for inventory control? Because it actually does not get registered in the system. I mean, obviously when it goes to the gate, there is an invoice back and forth. But then in terms of when it gets actually dumped into the facility, it can be years. So you can have a drum sitting out there for years. We do have cases of theft. We have cases of diversion. Sharon highlighted one from 1978. And we actually have cases of far more recent. We have, if you remember even last year, there was the guy from Africa who was caught with yellow cake in his heels at New York, at JFK. Then in November last year, when I was in Cape Town, there was a guy who had about one kilo in a plastic bag. And for both of these cases, there were thoughts that this was kind of samples of something bigger. This is what I've got. I can get you a whole lot more. We have a case in Namibia, which is similar to the Soheo experience where it was actually a sting. It was created by the Namibian police. Oh, sorry, Sharon. I think I might have stepped on something. And so they had tried to see actually how secure the mine was. And so they basically created a market. They wanted to know out there we want to buy 1,000 tons, let's say. And they found the same thing. There were employees, inside employees who actually used a gap in inventory control in the waste part. So drums that were damaged or drums that were half full or considered waste were not inventory the same way as everything else was. So it was moved out. The police caught it. So these are some cases. There was obviously a whole lot more. And that I think is an interesting part because when you do talk to many people, industry-government-wise, that is not really part of the discussion. And I think it should be in that we do have these cases. And depending on the threat environment or particularly if you're in a heightened security environment, what that means for you, particularly if you're a newbie to the fuel cycle. Obviously, kind of highlight again the need for harmonization, particularly on the transport side. There is the safety versus security. Some do the two-sided of one coin aspect. Some separate them. It is important to have both sets. Whether they're complementary or not, it is important in terms of best practice, but we don't see that all over the place. And then a need for a better military-civilian separation. After seven decades of mining uranium, I am actually surprised that the civilian side of nuclear weapon states is not more separate. And in fact, it should be demanded by the non-nuclear weapon states, particularly these days. Your conversion facilities are all dual use. China, all three, dual use. Russia, dual use. Here, dual use. Only ones that are not are Canada. And there are only six countries in the world where you can convert your commercial uranium. And that is the five NPT nuclear weapon states in Canada. So again, if you're a newbie, and you're like Denmark or Greenland, and you want to be able to somehow inspire confidence to your public that your uranium is actually going for civilian purposes, how do you do that when everything goes to dual use facilities? So that's one of the other main challenges. Thank you. Thanks, Cindy. I will open the floor for questions. And while you're gathering your thoughts, let me ask an easy question. Status update, what is the IEA doing? And I think you were part of an experts group on this. So if you can just update us on that. There was a consultancy on this uranium security, sorry, nuclear security for the uranium industry. And it has drafted a tech doc, which will be put forward to the Nuclear Security Guidance Committee, the IAEA NSGC as it's called in June. So it will go through the internal process. Once the NSGC, if they approve it, then it goes into I believe it's 140 days or something like that review period for states to comment. So if all things go well and smooth, then it should be published next year. And it bases everything on a graded approach. It doesn't say that look, yellow cake everywhere in the world should have five guards or anything like that. It's very much based on threat assessments, security environments, and also changes in those assessments and threat environments. And again, it's more for the newbies. If you are coming in, how much do you need to protect this stuff? And particularly if it's the only nuclear material in your country, how you go about it. It's not recommendations. It's just a sort of a dating step. No, it is recommendations. Uh-huh. I'll have a table of different scenarios and in a way highlighting at what point, for example, or how much you need to protect that, not really. The report basically says, up until the point of precipitation, there is a sense that and an understanding that basic common industrial practice will protect that part. It's when it becomes drummable, when it puts into a drum and movable, that that's where you have more of a security risk. And is the, this expert's group, is it mostly focused on just security? Or are they looking at a full just security? I believe there is a safety one as well now, but I don't know the status of that. So will they actually handle this as they handled other areas with a kind of, you know, whatever tech docs, you know, recommended, sort of, feel free to ignore. Well, hopefully not, but yeah. All right, I mean, I would be curious to see if I pass missions, then, which are the physical protection advisory services, whether they would take those recommendations into account and include that in their I passes. The idea also is for the IAEA, they did a pilot training last year in Africa, and this is also something that they can provide. So there is the training of the tech doc that is available to states, which is very useful. Questions from the audience? Yes, Mil. Yes, I'm Milton Honig. The IAEA is perhaps now visiting Iranian mine and Mil at Saqqand and Artakan. What is, what can they be expected to find? What is significance of that, if any? What, sorry, is the? What is significance of this visit, except just for the IAEA to exercise a visit is part of some kind of confidence-building measure. But I mean, can they really find anything? What are they looking for? Yep. Do I take a bunch of questions or should we do them each? Well, and a range of issues. You're talking about the in situ mines, I'm assuming. I don't know if there's any. Yeah, but they, because they don't go to count drums at the mills and like that, it's, and depending on the producer that you're talking to, of course, they kind of balk at the idea of counting thousands and thousands of drums. But they go and they, for various reasons, obviously there is a need for ground truthing. So again, understanding it is a learning exercise, of course, it's not just a matter of exercising that, right, but it's also a matter of learning more about particularly from the ground truthing side. And this is the same thing that happens when they're in Australia and Canada. They do learn a lot of information, particularly when they're looking at countries of proliferation concern. So they can use that information to understand production levels, how many people it takes, for example, what does it mean by so many people in a mine? And then understanding the, they do, they will go in and look at, not inspect per se, but they will go in and look at the various, the packaging area, for example, and how things are working. But it's not like they'll issue a violation, for example. I was just gonna add that given that right now the talks on Iran are really focused on trying to define an acceptable level of enrichment in some kind of final agreement if they're able to get to one, that it would be very important for the IAEA to understand what their plans, production plans are and how much they could actually produce in the next 10 years. And the IAEA went to the mine, went to one of the mines in January in Iran. And I think they're going to a couple more. Yes, we first learned. Dad, that most of their uranium comes from, I think from shipment from South Africa, when the Shoah was still there, the uranium mine, two uranium mines in Iran do not produce very much. No. And I don't think Iran should be counting on them. Okay. So thank you both for nice, very nice presentations. Very interesting, as always. I had a question which isn't maybe quite as relevant to the security aspects, but I wanna, given that you've started to look at uranium mining and the transportation and processing, one of the biggest concerns around uranium mining, of course, is how dirty it is. I mean, it's one of the, I don't know how many people have actually looked at extractive industries and all around the world, but we, meaning Green Cross, has done some work in that regard. And it really is astounding to me how dirty and environmentally dangerous uranium mining is all over the world, where it happens. And I wondered if you had any insight into environmental impact, public health impact, worker safety, which does to some extent post-overlap security issues, but not, I assume it's not a main goal of this report and study. No, I mean, none of us are environmental scientists on the project, we're all non-proliferation ones. So we are coming at it from that perspective. Now, of course, when we're going in and we're looking at the highway state, what all the rules and regulations are that govern, and particularly since there's usually an overlap on safety security, obviously we do get a sense of the environmental occupational health and safety issues, tailings issues, for example. And we do hear cases where, like for example, if we're talking about convertine, that was shut down because of safety issues. And so we have the same thing happening at different mines, obviously, as well, where there will be infractions and there are inspections. But I mean, let me give you, for example, some things or some trends that we do see. One of the things I found interesting with Australia is that now they are putting together a national dose, radiation dose system, or tracking system. So whereas before if you worked at one mine, and if you left and went to another mine, you would start fresh at the new mine. Whereas now any time if you're a miner and you're moving to different mines, your whole lifetime radiation dosage will be tracked. And I think that is a wonderful example of actually, well, one, studying it more and keeping better track from an occupational health and safety side. I can tell you also, I mean, when I was in Canada, it's the safety at these mines seems, again, I'm not an occupational health and safety person, but there are many layers that are in place. On the environmental side, you know, particularly when you look at the legacy sites, it's embarrassing, it's shameful. It's granted, you know, at the same time, a lot of these mines were initially established when the world did not think of the environment or pollution or what that meant. And some countries have done incredible jobs like this one actually on remediating a lot of the mines. And I think one of the things that for when I was starting out, I actually never would have imagined that I would be saying that the U.S. when it comes to its legacy sites has done a very good job. Industry in Australia is embarrassed by how it's going in Australia. And they'll tell you that. So it's a scar, the legacy mine. There is no doubt about that. And I think there has been a lot of lessons learned from them and how to carry that forward. But again, there's a lot of environmental scientists out there working on that. So we'll just try to focus on the nonproliferation side. I would just add that we give some specific examples in our report of the different regulations or restrictions that came from safety that have security benefits. But what your question sparks in me is this idea that some of these new producers, right, they may not have good governance systems across the board, right? So one of the ways, and maybe I'm really naive or idealistic, call it what you will. But if you get the environmental safety hook, you can get civil society more interested in that governance portion with your collateral security benefits. I think for, I would say overall for newcomers, the idea that you could approach this across the board holistically rather than piecemeal, right? You know, I mean, again, it's a question of don't do it the way we did it, you know, do it a lot smarter. Get that cell phone instead of your landmines first, right? Skip a generation, but you're absolutely right. I mean, the landmark legislation in the US, it was because of environmental health and safety. It was not because of anything else really. And we just happened to reap some benefits of, I would just comment that I do think you're absolutely right, chair, and that safety and security go sort of hand in hand. And if you, you can't really have one without the other in some ways. And I think if you're not worried about safety issues, which includes environment and public health and worker issues, occupational worker issues, really oftentimes can't convince companies or industry or governments to follow up with security improvements as well. So, and I do think this is an industry, but it's probably worse than most extractive industries in the world, but it's also in some ways similar. There's a lot of need in trying to figure out what to do with uranium tailings. And of course, all of this increases costs enormously as well. And so for new, less developed countries to get into these industries, there's some resistance because the cost of cost becomes much higher. But we have the same issue with cost nuclear power and spent fuel management and all that sort of the whole fuel cycle as well. So a lot of these questions come up on the same, the whole panoply I think of birth to death or birth to birth of the nuclear materials management. And the title of the report, governing uranium, in my mind points towards best business practices, which should put highest of all protection of public health and the environment. Hi, I'm Melissa Mann with URINCO, the Uranium Enrichment Company. And what's notable is what we're talking about is the stuff that eventually comes to our enrichment plants. So we're obviously very interested in what happens at the very beginning, the very early part of the nuclear fuel cycle. Cindy and Sharon, I just wanted to offer you some observations from that vantage point. First of all, I note that this week the spot uranium price fell below $30 for the first time in a very long time. And that continues a steady downward trend post Fukushima. And what that means that a lot of those aspirational mining projects are absolutely not viable, right? Per pound, right? Yeah, it's about a little over $29 a pound right now. So a lot of the entrance that we thought we were going to have into the nuclear fuel cycle are not coming. And even those big miners, perhaps with the exception of Kazakhstan, are cutting back their own programs. That partly speaks to the fact that there are phenomenal inventories of nuclear fuel in the market right now. And again, that's really a function of Fukushima. The 52 Japanese reactors are no longer taking uranium conversion or enrichment services. And the fact that we've had a number of reactors shut down over the past several years, including several in the US. What that means is that you have a not insignificant amount of uranium coming to utilities, not through the traditional mining source, but from secondary inventory supply. And so I just, I don't want you to lose sight of that because the numbers are significant. And what you may find is that shifts your analysis of where these controls come into play. As one example, I can tell you that we have an excess of enrichment in the market. And so what companies like mine are doing is turning over our capacity instead of producing low-enriched UF6, we're producing natural UF6. And are, in fact, displacing some, I don't think we have any miners here to throw things at me, but displacing some of that primary production. At Urenko, we have turned just shy of 15% of our total worldwide capacity to natural UF6 production. 15% of global. No, this is, correct. So instead of producing, we do it both through tail's re-enrichment or through the difference in our operational and contractual essays through underfeeding the operation, about a year and a half. But what that means is you, again, you get this vast, disparate difference where you might have all of the controls at enrichment site that you're used to seeing, you know, from that secondary production versus, you know, this variance at primary producing. Can I ask Melissa another question? Do you expect to increase that from 15% the amount of, I mean, did you see yourself increasing that? I don't, but speaking for Urenko only, no I don't because, you know, an enrichment plant is optimized to produce less than 5% enrichment, but certainly above 0.711% enrichment. So the farther we get off of that optimum, the less cost-effective it becomes. And unless the uranium price goes up dramatically and I don't see really any good reasons for that to happen, no, we're probably where we're going to be. Thank you, Haskell Institute for Energy and Environmental Research. Can we go back to the mines themselves for a moment and talk about safety and security there? And I'm particularly concerned about public safety in mines, especially those that are located where other people are around. And I'm sure there are lots of them, at least among those in the United States. What is being done to protect the tailings from being visited either inadvertently or ignorantly by local people who don't understand what's in those tailings piles? Well, I mean, again, we, you know, didn't really look, well, I shouldn't say that from a security perspective. Obviously we're looking at that. It depends on the location of the mine. So in Northern Saskatchewan, for example, there are no fences around these mines. There's also no people. The people fly in, fly out. And that's actually more and more a practice that happens, the flying in, flying out, because they are in usually extremely remote areas. And also some countries, for example, have rules or laws where you can't fence in wilderness areas. In Australia at Kakadu National Park, there is however a fence and there's a gate. And it is, you know, a mine that is within the national park. But it will say, it's very clearly stated that it is separate from, it's located in, but separate from Kakadu National Park. And when I went up to Northern Saskatchewan and looked at some of the old, older mines, they're extremely proud of their tailing ponds. And it's very interesting. And of course, a lot of the stuff that they're talking about on the environmental side, I can't grasp. But in terms of the security side, there wasn't any kind of threat assessments in those types of areas where, and nor have they had any cases where people would go in and or outsiders would actually infiltrate a tailing pond. There could be some issues with newbies. And that's where we could get into a safety security aspect. Most of these though are still in remote areas. If I'm thinking about Greenland, for example, any production there would take a long time, particularly with such a low spot price. But there it's rare earth. That is the primary target. And as I understand it, there is rules on not allowing fences, but because particularly in the area of Kalanafeld, I think we could suspect that there would be a fence at least around packing areas and at least around probably the tailings so that elk and caribou don't wander in and all these other kinds of aspects. But it really depends from state to state and where the mines are. Sydney, did you notice any differences in primary miners when it was intentionally a uranium mine versus uranium being a byproduct of some other mining activity? Yeah, big time. And this is actually where we see a lot of uneven reporting for the IAEA. So a lot of states will think, well, I'm shipping off gold or the mine is about gold. So whatever this uranium we're shipping off as well, we don't need to report it because it's a byproduct. And we do make the point again and again that if you are mining uranium, you are mining uranium, it doesn't matter whether it's a byproduct or not, it still triggers all these rules and regulations internationally at least and usually nationally as well. It's considered a strategic resource across so many states. So that's disconcerting. This sense that somehow because it's a byproduct it can't be diverted or it couldn't be misused. We also have the secondary, the phosphate issue where the technology to suck uranium from phosphates is very wide known. And I think we talk about with 20,000 tons of phosphates or uranium from phosphates since, I don't know, 50, 60 years ago. So this is also one that is not reported by a lot of different states. We have one case where I think it was 2006 where two Finnish companies, it's a small amount, reported receiving one ton of yellow cake from Congo and Congo did not report that one ton. So the IAEA though is also, and this is one of the challenges and which would be nice. We always talk about, of course, the IAEA is challenged by its lack of resources, financial particularly. But the transit matching on the 34AB, insert 134AB paragraphs of the imports and exports could probably be better. But again, they also need the resources to be able to do that. And without states doing the reporting and how do you go in and verify that? I have to ask a question. How are they doing? You said it could be better, but... I think it could be. Is it computerized? Is it? Oh, that's a good question I'll ask. I'm assuming that, well, they have to take all the information that comes in. But the IAEA could do a much better job in actually doing outreach about what 34AB mean. And that is not being done. And so they're, particularly to the newbies, anything, phosphates, we should go. And we should explain to them that there is this 34AB requirement. And also particularly for the newbies where they just don't know these requirements. They're very non-nuclear. And this is the other thing with most newbies, extremely non-nuclear. Most of them have no nuclear legislation at all. So even Denmark, Greenland, for example, Denmark is part of EuroTOM, but Greenland is not. Still, just by the fact that they could become this producer, they need a whole new export control system. They need inventory control systems they need and to be able to understand what the rules and regulations are. So they of course are asking the IAEA to come and explain all these things to them so they know what the requirements are and that they can fulfill them. And this is actually a really good point you raised too because politicians, unfortunately, really do not understand the term byproduct and that it really is just an economic term. So as long as it is the lower earning part of the deposit, then you can call it a byproduct. But as soon as that spot price jumps up like it did in 2007, it'll be the primary. Yeah, so I mean, this point means that a reliance, especially the low price of uranium, means that a reliance on the industry's economic reasons for doing accounting is misplaced or could be, wouldn't work as well. So if Greenland is gonna mine, they're gonna be looking at their gold and their rare earths and all the rest of it and could very well ignore uranium for... Well, they won't. They won't because you're gonna... Exactly, I won't let them. But there's also another good point that you raised, Melissa, which is one of the debates within Greenland and Denmark is because the uranium in Kvanafeld is mixed in with the rare earth in a very unique way, it requires a new milling or separation technology. And of course it's technology, but they still need to figure out what that is going to be. Then there is the kind of, well, maybe we'll just make some kind of mineral concentrate. So we'll have the rare earth, so we'll have the uranium, and it's not a high level, it's about 200 parts per million. Thorium is 800 parts per million. And then they have some zinc. But once it's put into this mineral concentrate, then the uranium goes up to 2,000 parts per million. But it's not considered source material into the IAEA, but it is captured under additional protocol. So it would still be reported. And that is something that states just don't know. Definitely had a question. I had a couple of questions for Cindy and maybe Sharon has some knowledge of this too. But there's an effort by, I guess, the NNSA and Ornall, the Oak Ridge, to, and I think it's been going on for a number of years, to do some kind of uniform bar coning on UF-6 cylinders. And apparently now they've got buy-in from industry, I don't know how long that's been either. And I wonder, A, if that has IAEA involvement or if you're involved, you know, if you, you know how that sort of might segue into what you're doing and also kind of what is your input with the IAEA on their own uranium governance project that you just described earlier? Is the consultant's opinion? Yeah, this thing that you say they're gonna come out with a report next year. The tech doc. The tech doc, yeah. And sorry, what is the question exactly about the tech doc? Well, I wondered how much input you're having. I mean, since you're doing this project, you think they'd want your input, so. Right, okay, thanks. Well, first I'll work backwards. I participated on the consultancy and to be honest, when I first got there, it was learning, learning, learning. This project has been an incredible learning experience. And the results, when we get them in, each of the reports, we share it all with the IAEA. Same thing as we do with Greenland and Denmark, for example. So as, and I ask questions. So whenever I'm stumped or I don't get something or what is the technical language or the legal language, whatever, I ask them and they're extremely responsive. So there's a very good working relationship there and they're certainly interested in everything that's coming out of here. And what it will mean for them, I don't know, that I think will remain to be seen, but also most of the states that we're doing these reports on are very interested in what comes out of them. Far coding. Melissa, you might have a little bit more to talk about actually. Maybe you could talk a little bit about this. Well, in fact, it was just last week that DOE hosted an international meeting here in town on that initiative. There was some industry participation, although it was actually fairly limited. There was definitely IAEA awareness of that meeting. I think one of the speakers, although XIAEA was Ollie, yeah. And I would say there's industry buy-in. It's not even. And I think the one common denominator was an agreement that the very first thing you need to have is a uniform serial numbering system. Because one of the things we found in UF6 cylinders that would be both for natural and enriched UF6 is that the serial numbering methodology just is all over the map. Some people say, you know, I named it for my grandfather. Some people call it one thing when it's at one plant. It has a different number when it goes to a different facility. So they're trying to come up with a uniform system so that what I call the cylinder on my side is the same thing that somebody else calls it. And then you can figure out when it comes and goes. The second part of that is whether you actually have a satellite tracking mechanism. And I'll say that remains unresolved. Partly because there's a regulatory component. There's a performance component. You know, what we do with UF6 cylinders is put them in a hot box and the tracking, I think they don't survive that environment. Two, what's the right tracking methodology and how is that used? Where we simply just heat the UF6, take it from it's solid to its gaseous form. And it doesn't survive, like it wouldn't survive satellite tracking. Well, it doesn't survive at all. The piece just disintegrates. Right. This is, yeah. So this is if you have an individual tracking device on a cylinder itself. Okay. Once it's been enriched, that dissolves. I mean, the problem is those devices don't necessarily survive either the transport environment or the operating plant environment. Nor are they a licensed part of the cylinder from a cylinder performance standard. But I am not aware that there was any conversation about extending that backwards to concentrate packaging. Right. There has been some discussion about it. It's not well received. But I think it's a good part of the, I mean, this discussion needs to happen where we do track soap better in many regards. My business cards were more trackable in that way. And of course, you can make the argument that look, but you can, you know, from a security perspective, you can make up a dummy lot, right? You can make your own scanners and all these other things. But of course, everything that you can do to further add these layers of not detecting. No, deterring, thank you. Deterring such cases, of course. I mean, it's one element and it would be exactly the same thing as Melissa. That would be one way to have this, if you can get the uniform methodology, then at least you know where that drum is and it's just a matter of hitting it. You can find it where it's gonna be. You know, if it's hanging out at a conversion facility for years or, I mean, at least there'll be a computerized, not just ledger system. One of the things I think I saw a picture of a USX drum and it had like seven, eight different. And then I saw, you know, there's been a couple of proposals as well. We'll just take on another. And so it must be confusing. And so again, I mean, we've been doing this trade for so long, there should be a much better system. Again, we have a much better system for soap. I was gonna say, wouldn't the system, at least forgetting for a minute the tracking devices that dissolve and the satellites, if you just had serial, serial number, a uniform serial number, wouldn't it also make it life a little easier just for record keeping for the converters and the enrichers? I mean, I can't speak for a convener. What we received is the natural UF6 and those packages do have distinct serial numbers. On the concentrate side, you gotta remember they're shipping them primarily in 55 gallon drums that are a one-off use before they might be scrapped, so. But they have uniform serial numbers. Not always. At a converter, yes. All right, with this tracking system that they're talking about be for enriched UF6 only or for the stuff that's coming into the enrichment plant as well as going out. Both, both natural and low-enriched UF6. And is there involvement of Tenex and like Arriva, for example, in this? I was not at the meeting last week. I know that Kamiko was in attendance. Certainly, Yurenko was. I'm not aware that the French or the Russians were present, but that may just be my ignorance. So is there any country that uses barcoding now on these drums? Not that we're aware of. So that could be an important. Along with a digitalized. It's not barcoding, but at least uniform serial numbering systems, an important recommendation in this. And then we help with inventory control, providing your reporting requirements for the IAEA. Are there other questions or comments from the audience? Yes. The risk of talking too much. What can I have you up here next time? Yeah. Just one of the other observations I was going to make. You talked about the differences, Cindy, in different countries. And when I think about the uranium that comes into our plants for processing, we do, in fact, treat certain origin uranium very differently. And that's because of the obligations that are imposed on it. So the tracking that we have on house, and we do track all origins and obligations, but the burden on us to do something extra is particularly significant for Canadian and Australian material, because they have obligations into perpetuity. And so anytime we move that material off our site, we do have another obligation to our national regulator, and there's a handshake between countries under the 123 agreements. Do you provide that into an electronic system? Does that go into NIMISPAN? Or is that just an email? Well, it goes into certainly an internal electronic system that we have, which is quite robust. And we do track that from a NIMIS standpoint for our US operation under our European operations that's done with your atom. Yeah. And that's a good point. And something that I didn't actually raise, I should remember that, put it into this, is that there are states, obviously, that do these obligations in Canada, Australia, do have the highest conditions of supply tacked on with their uranium. Your atom also usually has some kind of conditions of supply and then the US also has obligations when it sends its material away. So we do have kind of obligated material going around through the world and it's based on these 123 agreements. But if you're only going through contracts and of course, then that's not the case. In spite of those obligations though, I mean, my impression was that material at the converter is kind of infinitely fungible. Is that true or false? It's infinitely physically fungible from an accounting sense, not at all. And I'll speak more to the US experience because there is a little bit more of a robust system because we do have to report that to the NRC in many cases. One of the things to remember is the fuel cycle is incredibly international. And so something, you might have several shipments of ore coming into a conversion facility. They're often going from that conversion facility to some other location, often out of the country. They would need an NRC export license and the NRC requires you to report those origins primarily for the purpose of determining if you have Canadian or Australian but you also need to tell them what the balance is. And then in the US, something that seems unrelated is the Sarbanes-Oxley controls. So utilities that own these valuable commodities want to know exactly where they are and they often account for them, not just by volume and value, but also by origin. Yes, Paul? Last question. Okay, thanks. Once again, Paul Walker with Green Cross International. I keep thinking of the Oklahoma City bombing or many of the other improvised explosive bombings we, device bombings we have all over the world all the time these days. You said Sharon that 5,000 pounds, two and a half tons were diverted in 1979. And I'm wondering what if an Oklahoma City bombing took place with say half a ton or a ton of yellow cake? It was the same size bomb which is enormous, as we know. And yet distributed measurable radioactivity wouldn't be a nuclear explosive device obviously but would obviously spread measurable radioactivity all over Oklahoma City. It would be toxic, not necessarily radioactive. Yeah, well toxic then, yeah. How much of a difference would that make? And I'm thinking how would a terrorist group use a ton of yellow cake? Or would they necessarily... Well they'd have to be able to lift it for one. Yeah, but you know, the Oklahoma City bombing was a big truck and we know of test cases where big rental trucks have been left outside of for example, nuclear power plants, just to test whether anyone would raise a question about it being parked there for 24 hours. So say you brought in an 18-wheeler with a large explosive device, fertilizer and gasoline bomb or something and you put a ton of yellow cake into it. What difference would that make with or without the yellow cake from a sort of socioeconomic and destruction perspective? It's much more of a PR. It's a psychological terror aspect. It's kind of like the bogged truck, uranium scare and there was no scare. The truck just got its wheels stuck. So it is certainly public perception and sensitivities. When we talk about a spill in any country, actually when we talk about yellow cake spill, then it is treated as a toxic. It's not considered radioactive. Yeah, it's a chemical. So your emergency response would be based on that. I mean, remember that uranium-238 has a half-life of 700 million years. That is pretty long. So as you say, it's the toxic metal effects. It's a psychological impact and it's the contamination of the cost of the contamination of the area more than the radioactivity. Yeah. And I think the only place that I've actually seen a major, the actual hazmat suit is in Canada in the mines, but there they also have 20, 25% uranium grade. So it's a little bit different. I would say the bottom line is it would be worse. However, if I were that kind of person looking to make a dirty bomb, I would think you could find a much more highly radioactive, like a medical radioisotope, walk into a hospital, grab some cobalt 60 or something. And it's much, security is maybe about the same and with a higher impact. But you're right, it would, so the issue is what we tried to show, at least in the US, we've got to get lots of this material. And once you're getting lots of the material, the cost benefit, the difficulty of diversion or moving it or whatever increases. But I want to thank all of you for coming today. Thanks for your terrific questions and your comments and especially thanks to Cindy for coming from so far away. Thanks.