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Public Comment re Section 934 of the Energy Independence and Security Act of 2007

Public Comment by the Uranium Producers of America (UPA) re Section 934 of the Energy Independence and Security Act of 2007 (EISA). The UPA urges DOE to clarify the definition of nuclear supplier to not include uranium production or conversion services as a covered person under EISA. In the alternative, uranium producers and converters should be excluded under the regulations from any cost allocation formula because neither of these entities would contribute to the proximate causation of a covered nuclear incident.