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Comment to NOI re Retrospective Risk Pooling Program For Suppliers

Comment by Cameco Resources On Retrospective Risk Pooling Program For Suppliers, 75 Fed. Reg. 43945 (July 27, 2010), Section 934 Rule Making. As discussed below, Cameco believes that producers and providers of uranium concentrates and UF6 conversion services, whether directly or as an intermediary, should be excluded from the definition of nuclear supplier. In this regard, Cameco generally agrees with the comments submitted by the Nuclear Energy Institute ("NEI") on behalf of its members; however, Cameco disagrees with the implication of NEl's comments that producers of uranium concentrates and providers of conversion services should be included in the risk pooling program in the same manner and to the same degree as other suppliers of front-end and back-end nuclear fuel cycle goods and services.